Anti-Bribery

Anti-Bribery Awareness Training

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From 1 July 2011 the Bribery Act creates a new offence which can be committed by commercial organisations that fail to prevent persons associated with them from committing bribery on their behalf.  Failure to do so may lead to up to 10 years imprisonment, fines and immeasurable reputational damage.

The UK Bribery Act extends to all British citizens wherever in the world they live or work or transact business.   As a result of attaching the behaviour to the citizenship of the person, the UK has in effect achieved extra territorial reach with its provisions in this area.   For example, people who carry passports issued by the Crown Dependencies (Jersey, Guernsey or the Isle of Man) or British Overseas Territories, are British subjects for the purposes of this Act.

In rather the same way as anti-money laundering legislation requires businesses to have systems and controls in place to reduce the likelihood of money laundering, so the UK Bribery Act requires the introduction of anti-bribery procedures. The Ministry of Justice Guidance on the Bribery Act states that training should form an integral part of your organisation’s anti-bribery procedures.

The UK FSA and many national regulatory bodies (including the Jersey Financial Services Commission) have made public statements warning regulated entities that the regulator expects firms to consider their obligations under the Act seriously. 

Sator offers broadcast-quality web enabled learning to assist your firm meet the training requirement. Additionally, Sator will assist your business evaluate its risk of becoming involved in corrupt payments or practices and helps draft policies and procedures to mitigate these risks.

This web learning programme cost-effectively and conveniently enables you to meet the new requirements.

How does the Bribery Act affect your organisation?

The Bribery Act has far-reaching implications for all companies doing business in the UK, including foreign businesses and for overseas companies that employ British Citizens.  The Act creates a new offence which can be committed by companies and personally by senior officers, if they fail to prevent employees, associates and agents, based anywhere in the world from bribing another person on their behalf.

A company that can demonstrate it had “adequate procedures” in place to mitigate the risk of bribery and detect it if violations occur, would have a full defence to the charge of failure to prevent bribery.

What “adequate” anti-bribery procedures should your organisation have in place?

The Ministry of Justice Guidance on the Bribery Act sets out six principles which companies should embrace in order to establish an anti-bribery culture and develop adequate procedures:

  • Proportionate procedures
  • Top level commitment
  • Risk assessment
  • Due diligence
  • Communication and training
  • Monitoring and review

What anti-bribery training do your employees need to take?

Training is essential to ensure your company’s anti-bribery policies and procedures are embedded and understood, deterring bribery by both employees and associates.

Appropriate anti-bribery awareness training should:

  • Ensure all employees have a firm understanding of your organisation’s policies and procedures and what they mean in practice.
  • Enable employees to correctly respond to any bribery related issues.
  • Establish an anti-bribery culture across your organisation, whatever the level of risk.
  • Be continuous, regularly monitored and evaluated.

Anti-Bribery Awareness Web Training

Designed in conjunction with some the UK’s leading experts on bribery and corruption, the course provides all employees with the knowledge they require to comply with the Bribery Act.  The training portal can be branded with your company logo, include any statements you wish to communicate and be securely accessed from anywhere in the world.  This sets a very strong tone from your senior board and is sure to impress your staff with the importance they should place on these new developments.

The course is made up of:

  • Three broadcast-quality interviews - each lasting approximately 15 minutes.
  • Your company’s anti-bribery policies and procedures - which your employees must read and declare that they have understood.
  • Multiple choice assessment 
  • Supporting background reading material

Monitoring and evaluating your training

All information is securely stored automatically and can be managed centrally by your nominated anti-bribery point of contact.

Training reports appear in an Excel spreadsheet, enabling you to easily create reports for the Board and senior management. This data is essential as proof of your employees’ understanding and a demonstration of your company’s commitment to a robust anti-bribery culture.

Employees will also receive a certificate of completion for their training records.

Key benefits of the Anti-Bribery Awareness Training

  • Cost-effectively and conveniently ensures all your employees are aware of the risks of bribery and understand your policies and procedures.
  • Ease of study in the workplace.
  • Customised and branded for your organisation.
  • Incorporates your company’s anti-bribery policies and procedures into the course. Employees are required to confirm that they have read and understood them.
  • Assessed and certificated, evidencing your employees’ understanding.
  • Information is securely stored automatically, providing a full audit of your training across the organisation.
  • Easy and quick to set up, monitor and evaluate, saving you considerable time and money.

For further information or a free demonstration please contact Edmund Hatton at Sator on 01534 617 298.

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