Bribery Act 2010 Case Studies

AuthorStuart H Deming; Truman K Butler; Vivian Robinson
Appendix B124
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Bribery Act 2010 Case Studies
These case studies (which do not form part of the guidance issued under
section 9 of the Act) look at how the application of the six principles might
relate to a number of hypothetical scenarios commercial organisations may
encounter. The Government believes that this illustrative context can assist
commercial organisations in deciding what procedures to prevent persons
associated with them from bribing on their behalf might be most suitable
to their needs.
These case studies are illustrative. They are intended to complement
the guidance. They do not replace or supersede any of the principles. The
considerations set out below merely show in some circumstances how the
principles can be applied, and should not be seen as standard setting, estab-
lishing any presumption, reecting a minimum baseline of action or being
appropriate for all organisations whatever their size. Accordingly, the con-
siderations set out below are not:
comprehensive of all considerations in all circumstances
conclusive of adequate procedures
conclusive of inadequate procedures if not all of the considerations
are considered and/or applied.
All but one of these case studies focus on bribery risks associated with for-
eign markets. This is because bribery risks associated with foreign markets
are generally higher than those associated with domestic markets. Accord-
ingly case studies focusing on foreign markets are better suited as vehicles
for the illustration of bribery prevention procedures.
FCPAUKBriberyAct_02-Appendix-BM.indd 124 7/18/19 10:17 AM

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