Two executives of Smith & Ouzman Limited, a UK printing company, were sentenced for bribing foreign government officials, following a trial by the UK’s Serious Fraud Office (SFO) in a case brought under UK’s pre-Bribery Act of 2010. This decision sheds light on the importance of “adequate” compliance programs, including appropriate diligence into the appointment, renumberation, and retention of agents and consultants.
The decision further shows that UK companies need to have compliance procedures in place addressing the specific risks the company faces. The program must be tailored and specific to the industry and location, in addition to laying out general compliance principles. This decision indicates that UK courts will not hesitate to order significant jail time for directors who engage in corrupt activities. Sound compliance programs and anti-corruption controls are crucial, now more than ever.
[bctt tweet=”@SCCE Sound compliance programs and anti-corruption controls are crucial, now more than ever.”]
A more detailed account of this decision is available here.