Bribery Act 2010 Case Studies

• Author: Stuart H Deming; Truman K Butler; Vivian Robinson
• Pages: 124-135

Appendix B124

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Bribery Act 2010 Case Studies

Introduction

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.

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