Bribery Act Training

Understanding and Meeting the Demands of the UK Bribery Act

Our Bribery Act training explains the legislation and explores what organisations can do to reduce the risk of bribery and corruption within their organisations and supply chains. 

All businesses and organisations are now accountable for ensuring the actions of their employees do not breach the latest Bribery legislation and as we have seen even some of the largest businesses are coming under scrutiny. Where an offence is proved to have been committed with the consent or connivance of a “senior officer” of the institution both that person and the institution can be prosecuted.

do your staff know the dividing line between a gift to a customer and a bribe?

We are aware of a case where an individual at an academic institution was offered a payment by a student in return for arranging the award of a PhD needed for the student’s career advancement. This is easily identifiable as a bribe. But what of the apparently generous donor who demands a controlling place on the board of the new research institute they are funding, together with the right to insist on the courses offered and even admission of students? There are particular risks in relation to international activities. For example, what due diligence is undertaken on overseas agents or intermediaries?

The Bribery Act covers four distinct but related offences

  1. offering, promising or giving a bribe
  2. requesting, agreeing to receive or accepting a bribe
  3. bribing a foreign public official to obtain or retain business
  4. failing to prevent bribery but not having “Adequate Procedures” in place.

As is often the case with legislation, it is not always clear what actions are with the law and what are not, for example customer hospitality, if it quite feasible that a customer offered a free seat at Ascot by one company could be seen as a breach of the legislation whilst the same customer being offered an identical seat by an alternative company would not be breaching the legislation.

As a minimum all institutions need to review the adequacy of their existing systems, policies and training. Updating of Policies, Procedures and Manuals together with the effective training and monitoring of staff is likely to be essential, but especially so when schools, colleges and businesses have employees who deal with government contracts, are offering funded training responsible for attracting work, are negotiating contracts or ensuring contract achievement.

Areas when breaches could occur, include:

  • Setting up or working with Foreign Business, Offices or Agents
  • Working with Suppliers and Contractors
  • Potential for common practice abroad to constitute bribery under the act
  • Implications of employees or agents becoming involved in local practices, which may constitute offences under the Bribery Act.
  • Incentives, rewards and perks for the issue, renewal or maintenance of a contract
  • Catering, cleaning, maintenance
  • Accessing Government Funding
  • Accepting contributions to school, college, organisational funding
  • Equipment, good, services, gifts in kind
  • Pupils promotion to sports captain, head boy/girl etc
  • Amendments to entry requirements
  • Access to preferential services
  • Access to Board or Governors
  • Corporate Hospitality

What is acceptable? and what is not?

This workshop explores the legislation in some detail explaining what is permissible and what is not. In doing so it aims to provide clear and concise guidance to HR and Operational Managers from all sectors and businesses.

For Whom?

This workshop is designed for Senior Leaders, HR and Operational Managers from all business and Organisations including Commercial, Private, Public, Education and not for profit

Bribery Act Training – Outcomes, Aims and Objectives

Delegates attending will have a clearer and practical understanding of:-

  • Bribery and its consequences
  • The rationale for and detail of the Bribery Act 2010
  • Critical compliance issues for any organisation or company
  • Critical issues for particular types of organisation or company
  • How to develop and manage Bribery Act policies and procedures in house
  • How to carry out a Bribery risk assessment
  • How to consider external stakeholders and/or providers of goods, facilities and services
  • Law enforcement frameworks
  • How to obtain further information and advice or help

Bribery Act Training Course Content

1.Understanding Bribery

Understanding the Context – a look at how bribery is defined and how it presents itself using real case studies.

  • What constitutes bribery?
  • Could corporate hospitality constitute bribery?
  • What about donations?

2.The Bribery Act

  • What is the purpose of the Bribery Act?
  • What offences are created under the Act?
  • How bribery is regulated
  • Understanding the internal and external risks for to your organisation or company

3. Meeting The Act – Minimising Risk and Avoiding Prosecution

  • The six key principles for best practice for compliance with the Bribery Act
  • Third party due diligence and ‘elephant traps’
  • A focus on how bribery can occur and the policies you needed to manage the risk of bribery
  • How to carry out and implement a bribery risk assessment toolkit with 12 top practical tips for a compliance checker
  • How else might a company or organisation avoid prosecution?
  • Issues for specific types of organisation and companies
  • Issues for organisations involved in public procurement
  • Engaging staff with the importance of managing bribery
  • Enforcement Framework – The Ministry of Justice and Serious Fraud Office
  • Sources of help and further information

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FAQ – Frequently Asked Questions about the UK Bribery Act 2010

1. Does the UK Bribery Act 2010 apply to companies operating outside the UK?

Yes, the UK Bribery Act 2010 has broad extra-territorial reach. It applies to any company that “carries on a business, or part of a business” in the UK, regardless of where the company is incorporated. If a foreign entity conducts business in the UK, it can be held liable for bribery committed anywhere in the world to win business for that company.
 

2. Can my company be liable if a third-party agent pays a bribe?

 
Yes. Section 7 of the Bribery Act makes commercial organisations liable for failing to prevent bribery by “associated persons”. This includes employees, agents, subsidiaries, and joint venture partners. If an agent pays a bribe to win a contract for your company, your company can be prosecuted, even if top management was unaware of the payment.
 

3. Are facilitation payments (grease payments) allowed under the UK Bribery Act?

 
No. Unlike some other international anti-corruption laws, the UK Bribery Act makes no exception for “facilitation payments” (small payments made to speed up routine government actions). Such payments are regarded as bribes and are illegal, regardless of local custom or small amounts.
 

4. What are “Adequate Procedures” to prevent bribery?

 
Under Section 7 of the Act, a company has a full defence if it can prove it had “adequate procedures” in place to prevent bribery. According to UK Ministry of Justice guidance, these procedures should be based on six principles:
  • Proportionate Procedures: Tailored to the size and risk of the business.
  • Top-Level Commitment: A culture of integrity from senior management.
  • Risk Assessment: Periodic, documented assessment of internal/external risks.
  • Due Diligence: Risk-based checks on third parties.
  • Communication & Training: Training employees to understand the policy.
  • Monitoring & Review: Regular updates to the procedures.
 

5. Is reasonable corporate hospitality illegal under the Bribery Act?

 
No, reasonable and proportionate hospitality is not forbidden. The Act does not criminalize bona fide hospitality designed to improve a company’s image or establish cordial relations. However, if the hospitality is lavished in a way that suggests an intention to induce improper performance, it can be considered a bribe.
 

6. What is the difference between the UK Bribery Act and the US FCPA?

 
While both are stringent, the UK Bribery Act is generally broader. Key differences include:
  • Scope: The UK Act covers both private-to-private and private-to-public bribery, whereas the FCPA primarily focuses on foreign public officials.
  • Facilitation Payments: The UK Act prohibits them, while the FCPA has a limited exemption.
  • Corporate Liability: The UK Act introduced the “failure to prevent” offence (strict liability), making it easier for prosecutors to charge companies.
 

7. What are the penalties for violating the UK Bribery Act?

 
Individuals found guilty can face up to 10 years in prison and unlimited fines. For companies, the penalty is an unlimited fine, plus potential debarment from public sector tenders and reputational damage.
 

8. What is a Deferred Prosecution Agreement (DPA) for bribery?

 
A DPA is a mechanism where a company agrees to a range of conditions (such as paying a fine and implementing compliance programs) in exchange for the Serious Fraud Office (SFO) suspending prosecution. DPAs are not available to individuals, only to companies and partnerships.
 

9. Who enforces the UK Bribery Act?

 
The Serious Fraud Office (SFO) is the primary enforcement agency, particularly for large or complex bribery cases. The Crown Prosecution Service (CPS) and the National Crime Agency (NCA) also handle cases.
 

10. Does the Act cover charitable or political donations?

 
Charitable or political donations can constitute a bribe if they are used to influence a foreign public official and obtain business advantage. Companies should ensure donations are transparent, compliant with local law, and not tied to business procurement.

FAQ Courses - Frequently Asked Questions about our training courses

Answers to common questions about our training courses can be found below.  Our website details our overall base course offer and prices.  Answers to  questions about our courses can be found below.  Answers to questions about Concrew Training as a company can be found on our “about-us” page or our “FAQ” page
 

Our training courses can be aligned to the specific needs of:

  • Human Resources, HR and L&D teams
  • Governors and Trustees
  • Directors and Senior Leaders
  • Managers and team leaders
  • Department Specialists
  • Internal trainers and subject experts
  • The general workforce, specific departments and individuals
  • Businesses and organisations across the UK

Whether you’re upskilling a small team, undergoing change, rolling out training organisation-wide, we can support you.

Our courses are highly participative and interactive. To ensure we involve everyone and cater for each attendees’ individual needs we limit attendance as follows. We can run multiple sessions where attendee numbers need to be higher.

  • Up to 15 people can attend online training courses.
  • Up to 20 people can attend face-to-face “training room” based training courses

Most of our training courses are attributed with 6 face-to-face learning hours. Including breaks, they usually run for about 7 hours.

We can condense most topics into 3 hour sessions.

We can combine and/or extend our courses to create bespoke multi-day programmes for you.

We deliver online courses via our clients’ video conferencing platform, throughout the UK.  Attendees can be based abroad but payment needs to be made by a UK based organisation.

We can deliver face-to-face training on your premises in England, Scotland and Wales.

Yes, we can deliver all our courses online in real time on your video conferencing platform, on a date and at a time that works for you.

We do not offer pre-recorded training.

Yes. We can deliver at your premises, in a training room, office, boardroom, classroom or at a venue organised by you

Yes, we can deliver at weekends, evenings and during night shifts.  This makes our training more accessible for Governors, Trustees and shift workers.

We publish detailed course overviews for all courses. These course overviews are based on the individual course learning plans.

Each course overview outlines indicative content as final content is always based on each individual customer’s own requirements.

Factual content is updated to reflect the very latest developments before each course runs.

Yes. We align final course content to each individual customers’ needs. This includes dovetailing content with your own policies and procedures, when required.

Why should you use Concrew Training?

  • Specialist HR, Employment Law & Compliance training provider
  • We reference to official Government bodies such as ACAS, ICO, EHRC
  • Content tailored to your policies and procedures
  • CPD certificates included
  • 12 months of post-course support
  • UK-wide delivery
  • Online and face-to-face options
  • Open and transparent pricing

Yes. We prefer to do this. Including your  policies and procedures in the training helps us contextualises the learning and improve quality

It makes it easier to demonstrate how, where and why good practice applies.

We do not charge extra for aligning content to your prevailing situation, internal policies and procedures

Yes, of course. We treat all the information you provide as strictly confidential. We only use the information you provide for the specific training assignment/s you book with us

We use a team of subject specialists to deliver the training. They all have in-depth subject knowledge and experience. They are able to answer most questions posed to them, on rare occasions complex or obscure questions may require post course answers. Our subject specialists are also highly experienced trainers, trainers who can make even dull and boring subjects come alive.

Our trainers bring years of industry experience and deliver engaging, interactive sessions that keep participants engaged, involved and learning. Our trainers are subject specialists and able to answer virtually any subject related question.

Yes, we can provide CPD certificates for all our courses. They detail the number of learning hours and headline course content.

Certification is included in all half-day and one-day courses, it is an optional extra for 60/90 minute lectures.

Our customers and clients say things like:

We recommend our training is booked 2 to 3 months in advance. We only reserve dates against form bookings. Availability decreases with time.

During quieter periods we may have a very limited amount of short term, 2-week or less, lead time availability.

You are required to:

  • Provide the video conferencing platform (Teams/Zoom etc) or training room
  • Provide all the equipment, including a laptop for the trainer, when the training is delivered face-to-face on your premises or similar
  • Issue invites to all parties
  • To print/distribute materials and CPD certificates from PDF files we supply*

*Most materials can be distributed electronically

  • We are a specialist HR, Employment Law & Compliance training provider
  • We reference to official Government bodies such as ACAS, ICO, EHRC
  • Content can be tailored to your prevailing needs, inhouse policies and procedures
  • CPD certificates are included
  • 12 months of post-course support is provided
  • We offer UK-wide delivery
  • we have online and face-to-face options available
  • Our pricing is open and transparent 

Our training is high quality and budget friendly. We charge the same price for all topics.

Our prices include reasonable alignment to your specific needs, your inhouse polices and procedures.

Our prices vary according to training location, the number of attendees, and payment terms. Our prices page gives full information.

Please complete our quote form.  This form captures the key information we need to provide a quote and answer any related questions you may have. 

Our prices page and Company FAQ Page may also be of help