The Bribery Act and Entertainment
Posted: 27th July 2011
The Serious Fraud Office has advised that when considering whether expenditure on corporate hospitality can be considered to be a bribe, it will look at five factors:
- Whether or not the organisation has issued a clear policy regarding gifts and hospitality;
- Whether the expenditure in question was compliant with the policy and, if not, whether or not it had been sanctioned at the appropriate level within the organisation;
- Whether or not the expenditure was proportionate with regard to the status of the recipient;.
- Whether or not the expenditure had been entered in the organisation’s books of account; and
- The lawfulness of the receipt by the recipient under the laws of his or her own country.
We can assist you in setting up a clear anti-bribery policy.