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[MUSIC]
>> WILL WINCH Employers need to take the Bribery Act seriously. Ah it’s got criminal liability
for a failure to comply with it. There’s unlimited fines and not only that but the
reputational damage that a business can suffer can be immense coupled with the fact that
if you’re trying to to do any public procurement that’s going to be ah out the window. Businesses,
the adequate procedures that businesses need to, the adequate procedures that businesses
need to put in place are going to depend very much on the resources of the business in question.
It’s going to a proportionate test. Ah if a business is operating in a high risk area
in a high risk jurisdiction with a lot of resources it will be expected to spend a lot
of time making sure its Bribery Act compliant. If the business is in the UK doing low risk
activities its unlikely that its going to have to do much more than a fairly basic minimum
but then that basic minimum light is going to be key. As a minimum we would anticipate
that a policy in place ah that spells out exactly what the what the firm thinks about
anti-corruption. Um what the firm is doing in terms of making sure that that policy is
properly implemented um and the penalties for getting it wrong, so that the employees
can be dismissed and they are dismissed if they if they do something wrong. Um that the
policy in a draw is worthless. The management has to get out and to tell the employees what
their obligations are. Without that there is no point in having the policy in the first
place. You need to tell people what your obligations are under the Bribery Act otherwise you wont
be protected.