Your firm should be vigilant about bribery and corruption, which are both criminal offences under the Bribery Act 2010, whether committed in the UK or abroad.
While we do not enforce that Act, we do expect authorised firms to have considered and taken steps to address the risk of bribery and corruption within their business, including where these risks come from third parties.
Reasonable steps are likely to include:
- senior management that stays up to date with, and fully abreast of, bribery and corruption issues
- adequate bribery and corruption risk assessment
- policies and procedures (including staff recruitment, vetting and remuneration) that cover bribery and corruption risks
- training and awareness programmes that ensure staff have adequate understanding of the risks associated with bribery and corruption
- adequate and risk-sensitive measures that address the risk that a third party acting on behalf of the firm may engage in corruption
For further detail and examples of good and poor practice in anti-bribery and corruption, see Financial Crime: A Guide for Firms.