If you were to ask all of your staff to describe the UK Bribery Act 2010 without researching, would they be able to? You may believe that not all your staff are in a role which exposes them to giving or receiving a bribe. As true as that may be, it doesn’t mean that they won’t ever witness a bribe within the organisation or have some suspicions about a member of staff.
Let’s go through a short scenario of what I’m trying to get across:
John, a project manager for a bank is trying to find a contractor to build a new branch. He’s had a few proposals from several contractors and is torn between two, Contractor A and Contractor B. Contractor A is cheaper, is more eco-friendly and has completed many similar builds. Contractor B’s salesman Mike is aware that their competitors have the edge, so offers John an all-inclusive holiday to Barbados as an ‘act of friendship’. John accepts this gift, and Contractor B happens to win the contract. Meanwhile, Mike’s assistant Laura has concerns about why, when they were the least obvious choice, they were picked and also why Mike offered a holiday to someone he hardly knows.
Laura considers raising the alarm to the appropriate person but doesn’t for four reasons:
- She’s not 100% sure if this would be considered a breach of the act
- She’s unaware of the process of raising the alarm
- Has no company anti-bribery policy to refer to
- She thinks that keeping quiet might be better for the company
Eventually, the bribe is uncovered by a third party and is made public. This leads to the Bank and the contractor being fined and John and Mike going to jail.
Had Laura had an anti-bribery policy to refer to, she would have been able to raise the alarm as soon as she had her suspicions. Maybe there was a policy available, but she never received information on where to access it. If the contractor had a BS10500 compliant Anti-Bribery Management System (ABMS) they may have avoided the fine, even though a bribe was carried out, as they would have been able to show they had adequate procedures in place to prevent bribery.
Making all staff aware of the UK Bribery Act 2010 will decrease the likelihood of a breach happening in your organisation, or at the least, help uncover a breach. And what’s the best way to do this? Implement an ABMS into your organisation, and purchasing our Anti-Bribery Management System Documentation Toolkit is the best place to start.