Ernst & Young provides five tips to prepare for Bribery Act

28 Apr, 2011

John Smart, partner in the Fraud Investigation & Dispute Services (FIDS) team at Ernst & Young provides five tips to help businesses prepare for the Bribery Act:

1.    Get your process right.  Businesses should appoint an ethics officer and undertake a risk assessment to give that officer a clear picture to work from.  It is very important to record incidents where ethical standards may have been breached, keep records and log any concerns;

2.    Know exactly what is going on in your company, especially if you operate in countries where corruption is common.  It could be a shrewd move to employ a risk assessment adviser to examine your overseas operations;

3.    Working out what you can and can’t offer to clients can be difficult – you are required to judge whether or not a gift or corporate entertainment counts as “appropriate”.  What is lavish to one may be seen as stingy by another.  For instance, it might be acceptable to take a top broker out for lunch, but not to fly him out to New York in First Class;

4.    Train your employees – make sure they understand the Act by giving adequate support and guidance.  Keep hold of any materials used, to show that you’ve taken every suitable precaution;

5.    Demonstrate the message of zero tolerance.  As a first step, discuss the issues at a board meeting and ensure the minutes reflect that you have added anti-bribery measures to your code of conduct.

John Smart specialises in sensitive investigations particularly compliance, fraud and asset recovery, and advising clients – including in-house counsel – on fraud risk management.  

John has developed Ernst & Young’s services with global pharmaceutical, retail and media clients, investigating fraud, patent/copyright infringement, counterfeiting and parallel trade, and advising on compliance and fraud risk management issues.  He also has extensive experience of carrying out high profile, public investigations into compliance, bribery and corruption, suspected frauds and other sensitive matters in many international locations.  


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