Anti bribery policy

2.1 The Bribery Act 2010 (‘the Bribery Act’) aims to promote anti-bribery practices amongst businesses. An organisation will commit a criminal offence under the Bribery Act if it fails to prevent bribery that is intended to obtain or retain business, or an advantage in the conduct of business for the organisation.

2.2 An individual can also be guilty of an offence under the Bribery Act.

2.3 There are four key offences under the Act

• Section 1 - Bribing another person
• Section 2 -Taking a bribe
• Section 6 - Bribing a foreign public official
• Section 7 - Failing to prevent bribery.

2.4 Before the Bribery Act came into force organisations were only likely to be guilty of a bribery offence if senior management were involved. The Bribery Act however applies to all staff in the organisation, and now an organisation may be guilty of bribery if only the individual offender knew of the bribery.

2.5 An organisation will have a defence to the corporate offence if it can demonstrate that it had adequate procedures in place to prevent bribery by, or of, persons associated with the organisation.

2.6 An individual guilty of an offence under sections 1, 2 or 6 is liable: • On conviction in a magistrate’s court - to imprisonment for a maximum term of 12 months, or to a fine not exceeding £5,000 or both • On conviction in a crown court - to imprisonment for a maximum term of 10 years or to an unlimited fine or both.

2.7 Organisations are also liable for these fines, and if guilty of an offence under section 7, are liable to an unlimited fine.