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Bribery Policy

BACKGROUND

The UK Bribery Act 2010 (“the Act”) makes it an offence for a person to pay or receive a bribe either directly or indirectly. The Act covers transactions that take place in the UK and abroad.

The four main offences are:

  • bribing a person to induce or reward them for performing a relevant function improperly
  • requesting, accepting, or receiving a bribe as a reward for performing a relevant function improperly
  • using a bribe to influence a foreign official to gain a business advantage
  • failure of a commercial organisation to prevent bribery

The Act also covers the situation where a person associated with an organisation bribes a person with the intention of gaining or retaining a business advantage for a commercial organisation. Therefore, “persons associated” will include local attorneys, agents, intermediaries, joint venture partners, distributors, suppliers and so forth all of whom could render an organisation guilty of an offence under the Act.

WHAT IS BRIBERY?

Bribery is the offering or giving of a financial or other advantage with the intention of inducing a person to perform improperly a relevant function or activity or to reward a person for the improper performance of such a function or activity. Functions and activities include any function of a public nature, any activity connected with a business and any activity performed in the course of employment.

In short this means giving money or some other benefit to induce someone not to do something they should do or to do something which would be improper, for example the giving of work or a contract without following the proper process.

GILL JENNINGS & EVERY LLP

Gill Jennings & Every LLP (GJE) does not tolerate any form of bribery or corruption. It is a requirement of GJE’s policy that everyone within the firm and with whom the firm deals complies with it and that they do not commit any action which breaches any of the offences under the Act.

It is normal practice within the firm’s area of business to receive and provide hospitality and gifts. It is still the case that gifts and hospitality are not prohibited under the Act, however gifts and hospitality are not permitted if they could be perceived to influence a business decision or to be excessive and inappropriate. GJE therefore keep a record of any noteworthy gifts and hospitality received or given.

The firm works with a number of overseas companies and agents. If there is any suspicion that there may be a breach of the Act, including where a local attorney or agent may be involved in or linked with bribery or corruption, our staff will refer the matter immediately to GJE’s Managing Committee. This may result in the immediate termination of the contract with the local attorney or agent.

WHO TO CONTACT

If you have any questions or concerns in relation to GJE and The Bribery Act, please contact the firm’s Practice Director, Jenna Massey via jenna.massey@gje.com.