The UK’s Bribery Act 2010 came into force in 2011. The legislation has wide territorial reach and applies to companies and individuals with little connection to the UK. Completing a deal in the UK or employing a UK resident can be enough for the Act to bite. It covers bribery committed by the organisation, or on its behalf, anywhere in the world. We have substantial experience representing companies investigating (or being investigated for) alleged corruption and bribery.
Bribery and corruption investigations are a key part of our work. Members of our team have worked with specialist counsel in other countries including the US, Canada, Russia, China, Brazil and Germany to conduct cross-border investigations often with the involvement of multiple regulators. You can find our more details of our investigations practice here https://www.corderycompliance.com/internal-investigations/
We have helped clients with bribery due diligence particularly when they are conducting corporate transactions.
We provide face-to-face training to our clients on this key subject or via live or recorded broadcasts in multiple languages from our in-house studios. This is also including dedicated training sessions for our client’s business contacts including their sales channel to reinforce compliance. Intermediaries have been a key feature of recent UK bribery enforcement including in the Rolls-Royce and Airbus cases. Training is a key part of reducing risk.
Our clients value our discretion and we don’t make public comment on the cases where we have been involved. As well as conventional investigations which we lead we have experience of helping shareholders look at the probity of investigations into alleged wrongdoing at their investee companies. We also have experience of working with other counsel as joint investigatory counsel.
We help our clients with a consistent approach to stamping out corruption. For example in one project we advised a US corporation on strategies and programs to comply with the UK Bribery Act 2010. The corporation had board representation on around 50 entities. We worked on a program for the appointed directors of those entities to train them on their responsibilities and to give them materials to prompt discussions with other board members. The project was complex since in some investments our client had small stakes (in some less than 10%) but in some it owned all or the majority of the issued shares. We devised a uniform approach to bring simplicity since some directors were common to different boards
We add specialist resources to our team when required including data gathered through a special arrangement with LexisNexis, specialist technology resources and experienced prosecution lawyers to test the evidence we gather.
You can read our thoughts or listen to podcasts on recent bribery cases here https://www.corderycompliance.com/category/bribery-corruption/