Monday 26th August 2019
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Comsure operates in:the UK, Jersey, Guernsey

A common sense approach to bribery policy and procedures

ABC law demand that companies take adequate steps to prevent corruption. To realise this, they must take a proactive approach to establish that corruption, in all its various guises, will not be tolerated.

Regular anti-bribery and corruption training and a clear, well-publicised policy against which corporate entertainment can be assessed on a case-by-case basis are essential.  While industry, geography, and the size of any given benefit may affect whether hospitality is corrupt, the underlying principle must remain unchanged: the intention is key.

The following basic questions, which can be incorporated into any such policy, also act as helpful guidelines:

1. Will the offeree feel any pressure to contract?

2. Are we completely comfortable disclosing what we have offered or accepted?

3. What might a reasonable member of the public think?

4. Could a prosecutor establish a link between the benefit offered and an intention to influence?

5. Is the benefit being offered as a quid pro quo for the award of business?

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