Menu4/3/18: The first contested case of a “failure to prevent” bribery under the UK Bribery Act has resulted in a conviction of a small refurbishment company. In an article by Victoria Fitzpatrick and Kelly Hagedorn of law firm Jenner & Block, the authors caution, “The case highlights how important it is for organisations to have adequate procedures in place to prevent bribery in order to defend against such an allegation.” A point worth noting: the UK government has published guidance on those adequate procedures and, according to the authors, “… the case suggests that companies which have not reviewed and updated their compliance programs in light of this guidance could be found guilty of the failure to prevent offence if bribery does occur. The article provides a good overview of the specific case and adequate procedures.
