Overview
When the Bribery Act 2010 came into force on 1 July 2011 it opened up a potential liability for individual trustees, corporate trustees and sponsoring companies alike. Despite this, a recent survey found that 51% of pension schemes have no formal policies or guidelines in place to deal with the acceptance of hospitality and the receiving of gifts by trustees.
In the last few weeks, the FSA imposed a fine of £6.895m on Willis Limited for failing to organise an adequate risk management system and the High Court ordered MacMillan Publishers to pay
more than £11m for unlawful conduct in this area.
Given these recent decisions, there has never been a more important time to consider the issues presented by the Bribery Act and to take preventative action, as Shoosmiths reports.
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