2. One year on, is the
REAL IMPACT
COMING?

3. THE UK
BRIBERY ACT
- A REFRESHER

4. More effective legal
framework to combat
bribery and corruption in
public and legal sectors.

5. Replaces complex
offenses in Prevention
of Corruption Acts
1889-1916.

6. Creates a discrete
offence of bribery of a
foreign public official.

7. Creates a new corporate
offence of failure by an
organisation to prevent a
bribe being paid on
its behalf.

8. Requires the Secretary of
State to publish guidance
about procedures that are
relevant to commercial
organisations.

10. An individual guilty of bribing another
person, receiving a bribe or found to be
bribing a foreign official

11. An individual guilty of bribing another
person, receiving a bribe or found to be
bribing a foreign official
Maximum Prison Sentence: 10 Years.
Fine: Unlimited.

12. A company found guilty of failing to
prevent bribery

13. A company found guilty of failing to
prevent bribery
Maximum Prison Sentence: 15 Years for
those involved along with senior
executives and directors.
Fine: Unlimited.

14. Companies may also find
themselves debarred from EU,
US and other government
procurement lists.

16. Principle 1: Proportional Procedures
A commercial organisation’s procedures to prevent bribery by persons
associated with it are proportionate to the bribery risks it faces and to the
nature, scale and complexity of the commercial organisation’s activities. They
are also clear, practical, accessible, effectively implemented and enforced.

17. Principle 1: Proportional Procedures
A commercial organisation’s procedures to prevent bribery by persons
associated with it are proportionate to the bribery risks it faces and to the
nature, scale and complexity of the commercial organisation’s activities. They
are also clear, practical, accessible, effectively implemented and enforced.
Principle 2: Top-level Commitment
The top-level management of a commercial organisation (be it a board of
directors, the owners or any other equivalent body or person) are committed to
preventing bribery by persons associated with it. They foster a culture within
the organisation in which bribery is never acceptable.

18. Principle 1: Proportional Procedures
A commercial organisation’s procedures to prevent bribery by persons
associated with it are proportionate to the bribery risks it faces and to the
nature, scale and complexity of the commercial organisation’s activities. They
are also clear, practical, accessible, effectively implemented and enforced.
Principle 2: Top-level Commitment
The top-level management of a commercial organisation (be it a board of
directors, the owners or any other equivalent body or person) are committed to
preventing bribery by persons associated with it. They foster a culture within
the organisation in which bribery is never acceptable.
Principle 3: Risk Assessment
The commercial organisation assesses the nature and extent of its exposure to
potential external and internal risks of bribery on its behalf by persons
associated with it. The assessment is periodic, informed and documented.

19. Principle 4: Due Diligence
The commercial organisation applied due diligence procedures, taking a
proportionate and risk based approach, in respect of persons who perform or
will perform services for or on behalf of the organisation, in order to mitigate
identified bribery risks.

20. Principle 4: Due Diligence
The commercial organisation applied due diligence procedures, taking a
proportionate and risk based approach, in respect of persons who perform or
will perform services for or on behalf of the organisation, in order to mitigate
identified bribery risks.
Principle 5: Communication (including training)
The commercial organisation seeks to ensure that its bribery prevention policies
and procedures are embedded and understood throughout the organisation
through internal and external communication, including training, that is
proportionate to the risks it faces.

21. Principle 4: Due Diligence
The commercial organisation applied due diligence procedures, taking a
proportionate and risk based approach, in respect of persons who perform or
will perform services for or on behalf of the organisation, in order to mitigate
identified bribery risks.
Principle 5: Communication (including training)
The commercial organisation seeks to ensure that its bribery prevention policies
and procedures are embedded and understood throughout the organisation
through internal and external communication, including training, that is
proportionate to the risks it faces.
Principle 6: Monitoring and Review
The commercial organisation monitors and reviews procedures designed to
prevent bribery by persons associated with it and makes improvements
where necessary.

22. WILL THE
BRI BE RY
ACT
VER ACT?

23. 9 OF 10
LARGEST FOREIGN CORRUPT
PRACTICES ACT (FCPA) FINES
have been with non-US
based companies.

24. 90%
of FCPA prosecutions
have involved non-US
companies. Bribery is
not only likely to be
prosecuted in the
United States.

25. WATCH YOUR
THIRD-PARTY
BUSINESS PARTNERS

26. SENIOR
EXECUTIVES ARE
IN THE
FIRING LINE

27. 65%
of defendants in FCPA
prosecutions over the
past 6 years have been
at senior level. Senior
executives are the
individuals facing
prison and fines in
relation to fraud.

29. BRIBERY RISK
& HIGH GROWTH
OFTEN LINKED

33. • Abnormal cash payments

34. • Company procedures or guidelines
not being followed

35. • Unexplained preference for certain
contractors during tendering period

36. SOLUTIONS

37. Protect your organisation and its
corporate reputation with
Lexis® Diligence.

38. Protect your organisation and its
corporate reputation with
Lexis® Diligence.
Get in touch:
020 7400 2809
risk@lexisnexis.co.uk
www.lexisnexis.co.uk/risk