The Olympics are a fantastic opportunity for you and your employees to build relationships with your clients. Like many sporting events, there’s a wide range of corporate hospitality packages on offer.
But have you thought about how the Bribery Act will affect your employees’ ability to enjoy London 2012 with your business partners?
How does the Bribery Act affect your business?
Under the Bribery Act 2010, it is an offence to offer a bribe to an individual.
If found guilty, individuals could be liable to up to 10 years’ imprisonment, an unlimited fine, or both.
The offence refers to the provision of a financial or other advantage. Potentially, this could include an invitation to a sporting event.
How do you make sure your employees stay on the right side of the law?
What distinguishes legitimate corporate hospitality from an unlawful attempt to bribe someone is the accompanying intent. Using the Olympics as an opportunity for your staff to explain your business plans to potential clients or to build the relationship is likely to be legitimate. Providing an invitation in order to curry favour in a tender process is not.
The Ministry of Justice has tried to reassure businesses by commenting in its guidance that hospitality which is within the reasonable and proportionate norms of an industry sector is like to be acceptable.
The more lavish the hospitality, the greater the inference that it is intended to encourage or reward improper performance.
What should you do?
As an employer, you should have a Bribery Act policy in place. The policy should take account of all of the following questions:-
• Is the gift or hospitality reasonable and proportionate?
• Is there a legitimate business purpose?
• Does the provision of a gift or hospitality clash with any key business decisions?
• What are other companies in the same sector doing?
• Would the gift or hospitality conform with the recipients own internal rules? What is the general context?
And finally . . .
The Olympics are a great opportunity for you to showcase your business.
However, you must ensure that your employees are trained in the proper procedures under the Bribery Act 2010.
If you need any guidance on this, please feel free to contact me on 01604 601 575or complete the form below and we will call you.
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