as easy as abc anti-bribery & corruption programme bribery & the …€¦ · a bribe then...

As Easy as ABC... Anti-Bribery & Corruption Programme

Bribery & the Damage Caused

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Welcome.

Welcome to the University’s Anti-Bribery & Corruption Programme. This module is ‘Bribery and the Damage Caused’. In order to proceed please click on the button below.

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This module is ‘Bribery and the Damage Caused’. It aims to provide you with a definition of bribery, examples of how it can occur, and reasons why it should be prevented. It is one of a series of modules designed to enable you to identify and understand: - what is bribery and the damage it causes; - the University’s response to bribery, the rules and your obligations; - specific bribery risks and how to respond to them. You do not have to complete the programme all in one sitting. Using the menu and navigation buttons you can select those areas you wish to cover and work through each as often as you wish. You may return at any time to work through new areas or to review those you have already covered. The first two modules also contain interactive questions designed to test your understanding of the material provided.

Introduction – aims and approach.


From the Registrar: “The University of Oxford operates on a global basis in pursuit of its mission to achieve and sustain excellence in every area of its teaching and research. Integrity and fairness, both actual and perceived, are vital to the University’s success in achieving this mission. The University has an excellent track record of operating with high levels of probity in all we do, and has never tolerated bribery or fraud. Council has adopted a Policy and a set of Standards on bribery and fraud. These are a clear statement of our zero-tolerance approach to these activities. I expect every University employee, wherever they work in the world, to uphold our Policy and Standards and attach considerable importance to training sessions of this type which are designed to ensure that you are informed of the content of our Policy and Standards and are equipped to implement them in your daily work. Thank you for your support in ensuring that the University of Oxford continues to operate with the highest levels of integrity around the world.”

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Please select one of the sections below by clicking on the adjacent button: What is bribery... When is a bribe not a bribe? How bribes are paid... The damage caused... Test my knowledge...

Module menu.

This is a summary of how bribery is interpreted by the UK Bribery Act, 2010 – it is a broad definition that covers a number of key points, each of which are outlined on the following pages. The first point to note is that bribery is not a new crime – the 2010 Act is simply the latest piece of applicable UK law (many other countries also have similar legislation). It applies to any person or organization based in the UK, and extends to include their activities wherever they take place in the world. It also applies to any foreign person or organization who operates within the UK. Its reach, therefore, is global.


What is Bribery? “Bribery is the offering, promising, giving, requesting, or accepting of a financial or other advantage with the intention to induce or reward improper performance.”

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What is Bribery? “It wasn’t me, officer...”

You cannot side-step the law by getting someone else to do the dirty work for you since the Act also makes it an offence for an agent or associate, acting on your behalf, to pay or offer a bribe. This has very wide implications and requires organizations to consider just who might be ‘acting on their behalf’ because, in addition to staff, this could also cover agents, consultants, partners, some suppliers, etc. – this issue is considered further in the section ‘How Bribes are Paid’.

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What is Bribery? Bribery is the offering, promising or giving...

If you give or pay a bribe then this is an offence under section 1 of the Act, and applies irrespective of who the intended recipient is. This section also covers any offer or promise of a bribe as well – so a person who offers a bribe that is refused and not actually paid over may still be prosecuted for offering, promising or giving the bribe. Example: When applying for a job at the University, Alice offers a bribe to members of the selection panel. They decline, but Alice has still committed an offence under section 1 even though no bribe was actually paid over. You must not offer, promise or give bribes.

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What is Bribery? Individual and organizational liability

An organization may also be liable to the corporate offence of failing to prevent bribery (under section 7 of the Act) if bribery occurs and it is found not to have had ‘adequate procedures’. Example: The Brent Institute of Research frequently sends staff and students on field trips to those parts of the world where bribery is commonplace. Staff are provided with no guidance, however, on what they are permitted and not permitted to do. In the event of a bribe being paid, not only is the individual potentially liable (under section 1), but the Institute may also be liable under section 7. Additionally, under section 14 of the Act, senior officers of an organization can also be held personally liable if they have consented to or connived at an offence that the organization has committed.



What is Bribery? Bribery is the requesting, or accepting...

If you accept a bribe then this is clearly an offence under section 2 of the Act. Similarly, this also extends to cover any request of a bribe as well – so a person who asks for a bribe that is refused and not actually paid over may still be prosecuted for requesting or accepting the bribe. Example: Chris is responsible for reviewing tenders in a procurement exercise. He suggests to one of the bidders that their submission will be more favourably regarded if they pay for his next holiday – whether or not the bidder takes up this suggestion, Chris has still committed the offence under section 2 of requesting a bribe. You must not allow yourself to be bribed.



What is Bribery? ...of a financial or other advantage...

You may think of bribes solely in monetary terms, but cash is only one form a bribe may take – a bribe can take any form, size or value that provides the intended recipient with some form of benefit or advantage. This means bribes can be money, discounts, vouchers, loans, gifts, hospitality, preferential treatment, business advantage, etc. and there is no minimum or maximum value – these aspects are considered further in the section ‘How Bribes are Paid’. Example: Drawbridge Construction offers a senior manager in Estates Services an all expenses paid trip to see a golf tournament in the US, in return for ensuring that they remain on the preferred suppliers list.



What is Bribery? ...with the intention to induce or reward...

Bribery requires there to be intent behind the action or promise to influence the performance or actions of the recipient. A further feature is that often the intent or the bribes themselves are concealed and presented as something quite innocent to hide their true nature – this is considered further in the section ‘How Bribes are Paid.’ Example: If Lord Elsinore provides a freely given donation that truly has no strings attached then it is not a bribe; but if he provides a ‘donation’ to a Medical Sciences department on the understanding that their labware will all be purchased from the company on whose board he happens to sit, then this is not a true donation but a bribe.



What is Bribery? ...improper performance.

This means failing to do the job properly, i.e. - not doing the job at all, not doing it completely; or - not acting impartially, but favouring a particular person, organization or outcome; or - abusing a position of trust or good faith. ‘Facilitation payments’ are an example of this: additional payments made, usually to an official or person in position of authority, in order that they do their job properly – e.g. money to a border officer to ensure they stamp your passport; gifts to a government officer to ensure they don’t delay issuing a licence, etc. If you bribe a public official within the UK then you commit a section 1 offence of offering a bribe, but there is also a specific offence, under section 6 of the Act, that covers bribes to foreign public officials. Examples of who is defined as a public official follow...



What is Bribery? Public officials – examples.

‘Public officials’ is a broad term that relates to anyone in a position of official authority. This can include: - government ministers and civil servants; - local government members and officials; - the police and other security agencies, such as immigration and border control; - the armed forces; etc. Extra caution must always be exercised, therefore, when dealing with public officials, either within the UK or overseas. In some countries – China for example – where industry is owned by the state, a public official could also be someone managing or running a company.



What is Bribery? Summary of the UK 2010 Bribery Act.

Under the UK Act, the following offences can be committed by an individual or an organization: Section 1 – Offering, promising or giving a bribe Section 2 – Requesting, agreeing to or accepting a bribe Section 6 – Bribery of a foreign public official The following offence can only be committed by an organization: Section 7 – Failure to prevent bribery In addition, any offence committed by an organization can be extended to include: Section 14 – Senior officers consenting to or conniving at bribery



What is Bribery? Summary of obligations in respect of the Act.

You must not offer, promise or give bribes. You must not allow yourself to be bribed. You must not bribe foreign public officials. The University must not fail to prevent bribery. Senior officers must not consent to or connive at bribery within the University. Consider also that, in addition to the legal position, there are moral, ethical and reputational dimensions to bribery. These are explored further in the section ‘The Damage Caused’.

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When is a Bribe not a Bribe? The ‘reasonableness’ or ‘newspaper’ test.

The legal test of whether an action constitutes a bribe is, under the Bribery Act 2010, based upon whether a ‘reasonable person in the UK’ would deem that it relates to the improper performance of a function or activity. When faced with an uncertain situation, therefore, ask yourself what it would look like to someone else not involved – if it appeared in the news concerning someone else, what would you think? The rule of thumb should be that if it appears or feels in any way doubtful or ‘fishy’ then you should avoid it, or at the very least seek further advice.



When is a Bribe not a Bribe? Donations and items given freely.

A freely given donation that truly has no strings attached is not a bribe; but a ‘donation’ that is in fact intended to influence the recipient is a bribe dressed up as something else. You should always be careful, therefore, when considering donations, gifts, entertainment or hospitality that purport not to have any strings attached – the University has particular rules that must be followed to ensure that there is nothing untoward in this area. These are detailed in the Policy and in the separate module ‘Anti-Bribery Measures’.



When is a Bribe not a Bribe? Justifying the unjustifiable.

Bribery often involves concealment or a clouding of transparency – in the act itself or in seeking to explain or justify the act. Common excuses include: - “We didn’t think that would be regarded as a bribe” - “But we’ve always done it that way” - “You have to in this country otherwise nothing can get done” - “We can’t compete if we don’t do it” - “I had no idea our agent was doing this” etc. NB Ignorance of the law is not the same as having no intent to influence someone.



When is a Bribe not a Bribe? Duress – the one exception to the rule.

The law allows one exception under which a bribe or facilitation payment can be paid: where not to do so would place an individual in imminent or immediate personal danger. Example: Frances is travelling to an overseas conference. At night, in the taxi from the airport, the driver requests an additional payment in order to take her safely to the hotel. When she declines he stops the car in the middle of a notorious and dangerous neighbourhood and orders her out. In these circumstances the law would allow Frances to make the additional payment to protect herself. You must still report such incidents as soon after the event as possible and be able to explain the threat to your safety, but you should not normally be held liable for paying the bribe.


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How Bribes are Paid Common forms of bribery.

The means of bribery are many and varied – this diagram outlines some of the common forms in addition to cash payments. The following pages examine some of these in more detail and provide examples.

Source: Transparency International (adapted)



How Bribes are Paid Facilitation payments.

Facilitation payments are, in short, additional payments to facilitate the proper performance of a job, i.e. they give you access to or speed up something to which you are entitled to anyway. Examples include any small extra payment to: - speed up a decision on a licence, visa, application, etc. - obtain swift passage through an airport or border; - get goods released from customs; - ensure connection of utilities or essential services; - ensure security from police officers or law agencies. Facilitation payments usually take the form of cash and often involve public officials.



How Bribes are Paid Gifts and hospitality.

Gifts and hospitality can be used as a means of inducing improper performance, as well as for reasonable and legitimate business purposes. Examples include: - lavish entertainment by a supplier or applicant of someone involved in considering tenders or applications; - frequent and regular hospitality provided by an HR agency to personnel staff; - gifts of an excessive nature that you provide to a prospective client, sponsor or donor in the hope that this will impress. The common factor is the intent to influence improper performance and the excessive nature of the gifts and hospitality.



How Bribes are Paid Political and charitable donations.

The University does not permit the making of political donations – you may need to be aware of this if engaging the services of a politician (as a speaker, advisor, etc.). On a broader basis, donations (whether provided to or by the University) can also be used as a means of disguising bribery if there is some hidden advantage to be gained in return by the donor. Examples might include: - a donation to a charitable body in which an individual has a decision-making interest or from which they benefit personally; - sponsorship of a research institute or programme by a commercial body from whom the supplies for that research must be bought exclusively.



How Bribes are Paid Agents and associates.

Agents, associates or partners acting on behalf of the University are a significant potential channel for bribery: out of sight, however, should not mean out of mind (or indeed out of control). Situations that might give cause for concern include: - agents in overseas territories who act as ‘fixers’ to arrange travel, access to individuals, accommodation, etc – do they pay bribes in order to secure the necessary arrangements? - partners or associates working with the University on teaching, research, or associated activities, themselves sub-contracting work to unregulated agents – can you be certain the sub-contractors do not pay bribes? - a shipping agent who transports goods on behalf of the University to overseas territories where bribery is endemic – exactly how do they ensure your items clear customs in time?



How Bribes are Paid Commission and payment in kind.

Consider carefully any arrangement that involves payment of commission to a third party: is the size of that commission appropriate or could it be used by that party to bribe on your behalf? Example: ‘Go For It’ is a company that helps place undergraduate language students with suitable hosts overseas during their study. It receives a commission for every student successfully placed. This payment is large enough, however, to enable Go For It to offer bribes to attract potential hosts and yet still make a profit. Payment in kind, i.e. non-monetary arrangements can also be used as a means of covering up bribery so, as a general rule should be avoided. Examples might include: - gifts, goods or free use of assets or facilities; - services provided in return at a free or preferential rate.



How Bribes are Paid Relatives and friends.

Paying or favouring a relative or close friend is another common means of disguising bribery. Bribes can, of course, also be paid in order to obtain a benefit or position for a relative or friend. Examples might include: - side-stepping admissions rules to make a place available to the relative of a donor or sponsor; - employing the relative of someone to whom ‘a favour is owed’; - employing relatives or friends who will turn a blind eye to untoward activity; - providing gifts or hospitality to a relative or friend of an individual it is intended to influence, rather than directly to that individual.



How Bribes are Paid Offsets.

Another means of hiding bribery – similar to commission – is an arrangement involving offsets, i.e. where fees owed in one direction can be offset by charges made in return. Such arrangements are frequently used legitimately where sub-contractors are employed (including caterers, cleaners, etc.) but because it is easy to ‘lose’ individual transactions or values when offsets are applied, care should always be taken in checking that all such charges are correct, legitimate and justified.


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The Damage Caused Scale and significance.

Source: Transparency International

This is the Corruption Perceptions Index Map, produced annually by Transparency Internat-ional, a not-for-profit global coalition against corruption. The map measures the perceived levels of public sector corruption in countries worldwide – the darker the shade of red, the higher the degree of perceived corruption in that territory.



The Damage Caused Scale and significance.

Source: Transparency International

You may wish to consider this in respect of any countries in which you have dealings or research interests. Further information may be obtained directly from Transparency Internat- ional at: www.transparency.org


http://www.transparency.org/


The Damage Caused Global and personal impact.

Bribery and other forms of corruption destroy trust, damage social and economic development and undermine fair competition. In 2004 the World Bank Institute estimated that globally more than $1 trillion ($1,000,000,000,000) is paid annually in bribes. This includes both developed and developing economies. Putting this into context, Transparency International estimated in 2011 that bribery in Kenya amounted to adding 15% to the average family’s annual cost of living. There is also evidence from other parts of the world that construction projects which suffer from catastrophic failures and often fatalities have bribery at their core in the sourcing or passing off of shoddy materials.



The Damage Caused Personal cost.

Individuals who are involved in bribery and are convicted under the UK Bribery Act can expect custodial sentences of up to ten years; unlimited fines can also be applied to both individuals and organizations. Example: In 2011 a clerk at Redbridge Magistrate’s Court was the first person convicted under the new Act for receiving a bribe of £500 on the understanding that he could influence criminal proceedings relating to a motoring offence. He was imprisoned for 3 years.



The Damage Caused Reputational damage.

The damage to reputation that bribery – or even the hint of bribery – can cause is potentially enormous. This not only means in terms of newspaper headlines. Within a University context, it could translate to: - research sponsors withdrawing support; - donations for capital buildings projects being withdrawn; - HEFCE and other funding being restricted, or subject to strenuous review and conditions; - the ability to attract top-quality staff being damaged; - imposition of a tighter control framework with less flexibility to operate as freely as previously.



The Damage Caused Summary.

Bribery is not a victimless crime. The damage caused is widespread, with both a global and personal impact. Morally and ethically it is difficult to justify. For individuals involved it can result in fines and imprisonment; for organizations it can result in fines. In both cases there is likely to be reputational damage which may have consequences for future funding, attractiveness of the organization, tighter controls, etc.


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Test My Knowledge

The following pages contain scenarios and questions with multiple choice answers that are designed to illustrate further the key points covered in this module. Consider the question and select your answer by clicking on the adjacent button. Some scenarios may have more than one correct, or partially correct, answer.



Test My Knowledge

You are approached by the Head of a Medical Sciences Department. They have received an anonymous tip-off that an agency they use to recruit subjects to a clinical trial in Africa is bribing individuals to sign up and take part. How would you advise the Head of Department?


1. Application of the Bribery Act.

Not to worry – it’s happening outside the UK and in a country where this is normal practice.

A.

Not to worry – even if it is bribery, it’s being carried out by a third party, not the department, so we cannot be blamed.

B.

The University may be liable for the actions of an agent, acting on its behalf, even though this is overseas.

C.

The department should encourage the agent to stop doing this on moral and ethical grounds.

D.


Test My Knowledge



Not to worry – it’s happening outside the UK and in a country where this is normal practice.

A.

Incorrect – the UK Bribery Act extends globally and applies even where custom and practice may be at odds with that legislation. The only exception would be if such payments were allowed under written law in the place that they were made.

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Test My Knowledge



Not to worry – even if it is bribery, it’s being carried out by a third party, not the department, so we cannot be blamed.

B.

Incorrect – the UK Bribery Act applies to agents and third parties where they are acting on behalf of UK-based organizations. The department may be liable for a section 7 offence of failure to prevent bribery if it is aware of an agent performing in such a way but takes no action to prevent it.

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Test My Knowledge



The University may be liable for the actions of an agent, acting on its behalf, even though this is overseas.

C.

Correct – the department may be liable for a section 7 offence of failure to prevent bribery if it is aware of an agent performing in such a way but takes no action to prevent it.

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Test My Knowledge



The department should encourage the agent to stop doing this on moral and ethical grounds.

D.

Only partly correct – the department may also be liable for a section 7 offence of failure to prevent bribery if it is aware of an agent performing in such a way but takes no action to prevent it.

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Test My Knowledge

You are involved in a staff interview panel for a vacancy in the department when you are approached by a ‘friend’ of one of the applicants who promises to ‘make it worth your while’ if that candidate is selected. If you decline the offer has any offence been committed?


2. Giving and receiving.

Yes – potentially by both the candidate and the ‘friend’ under section 1 of the Act.

A.

Yes – but only by the ‘friend’ since the offer was not made directly by the candidate.

B.

Yes – but only by the candidate, since the ‘friend’ was acting on their behalf, not for their own benefit.

C.

Yes – by the candidate and the friend, but also by yourself, since a bribe was offered to you.

D.


Test My Knowledge



Yes – potentially by both the candidate and the ‘friend’ under section 1 of the Act.

A.

Correct – although it would depend upon circumstances, it is likely that both the candidate (as primary beneficiary of the improper performance of the task) and the ‘friend’ (as their agent) would be liable under section 1 for offering a bribe, even though it was declined.

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Test My Knowledge



Yes – but only by the ‘friend’ since the offer was not made directly by the candidate.

B.

Only partly correct – although it would depend upon circumstances, it is likely that both the candidate (as primary beneficiary of the improper performance of the task) and the ‘friend’ (as their agent) would be liable under section 1 for offering a bribe, even though it was declined.

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Test My Knowledge



Yes – but only by the candidate, since the agent was acting on their behalf, not for their own benefit.

C.

Only partly correct – although it would depend upon circumstances, it is likely that both the candidate (as primary beneficiary of the improper performance of the task) and the ‘friend’ (as their agent) would be liable under section 1 for offering a bribe, even though it was declined.

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Test My Knowledge



Yes – by the candidate and the friend, but also by yourself, since a bribe was offered to you.

D.

Incorrect – only if you accept a bribe is there a potential liability on you under section 2. If you are offered a bribe but decline then there is no personal liability.

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Test My Knowledge

The department has an outsourced cleaning contract, due for renewal and subject to a tendering exercise. The existing supplier has offered to undercut any rival’s prices if they are told what they are – has any bribery offence been committed?


3. The nature of bribes.

No – there may be issues of not following proper internal procedure, but no bribe has been offered or paid.

A.

Yes – the supplier would gain a competitive advantage and commits a section 1 offence of offering or giving a bribe.

B.

No – this is common business practice; the supplier benefits from winning the contract and we benefit from a reduced price.

C.

Yes – the supplier commits a section 1 offence, and the department a section 7 offence of failing to prevent bribery.

D.


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No – there may be issues of not following proper internal procedure, but no bribe has been offered or paid.

A.

Incorrect – although the supplier has not physically handed over money or gifts, they would obtain a competitive advantage unfairly over their rivals through giving a reduced price in return.

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Test My Knowledge



Yes – the supplier would gain a competitive advantage and commits a section 1 offence of offering or giving a bribe.

B.

Probably correct – the supplier does indeed commit a section 1 offence and the department would commit a section 2 offence (receiving a bribe) if it accepted the arrangement. There is a grey area, however, around how far the department’s section 7 liability (failing to prevent bribery) extends: if its staff or agents offer a bribe then clearly it is caught, but what about a supplier of this type? Could they be said to be acting in the department’s interests as well as their own? Case law at present is unclear, so play safe and get suppliers to sign up to abiding by the University’s policy. Continue...


Test My Knowledge



No – this is common business practice; the supplier benefits from winning the contract and we benefit from a reduced price.

C.

Incorrect – irrespective of whether the practice is common or not, and the fact that an advantage would be obtained by both the supplier and the department, an offence has been committed.

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Yes – the supplier commits a section 1 offence, and the department a section 7 offence of failing to prevent bribery.

D.

Possibly correct – the supplier does indeed commit a section 1 offence. The department would commit a section 2 offence (receiving a bribe) if it accepted the arrangement, although there is no indication at this stage that it has. There is a bit of a grey area, however, around how far the department’s section 7 liability (failing to prevent bribery) extends: if its staff or agents offer a bribe then it is clearly caught, but what about a supplier of this type? Are they completely independent, or could they be said to be acting in the department’s interests as well as their own? Case law at present is unclear on this point. Continue...


Test My Knowledge

You have arranged for a shipping agent to transport some vital research equipment overseas. They have called to say that the local customs official won’t release the items until he receives an extra ‘entry fee’. What do you tell the shipping agent?


4. Dealings with overseas bodies.

Pay the fee – the equipment is vital for the research project and any delay could jeopardize its success.

A.

It is down to the shipping agent to decide whether or not to pay the fee – but the University will not pay the agent any more.

B.

Do not pay the fee unless written confirmation can be obtained that it is required under local law.

C.

Do not pay the fee unless the official concerned can provide a receipt on headed notepaper.

D.


Test My Knowledge



Pay the fee – the equipment is vital for the research project and any delay could jeopardize its success.

A.

Incorrect – urgency is not a valid justification under the Bribery Act, so if a fee is paid then an offence is committed under section 6 of bribing a foreign public official. It would only be allowable to pay the fee if someone were placed in personal danger by not doing so.

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Test My Knowledge



It is down to the shipping agent to decide whether or not to pay the fee – but the University will not pay the agent any more.

B.

Incorrect – even if the department pays no more for the agent’s services, the agent is still acting on their behalf so the section 6 offence of bribing a foreign public official would still apply.

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Test My Knowledge



Do not pay the fee unless written confirmation can be obtained that it is required under local law.

C.

Correct – the fee should not be paid unless it can be shown to be an official requirement under the written legal code of the territory in question.

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Test My Knowledge



Do not pay the fee unless the official concerned can provide a receipt on headed notepaper.

D.

Incorrect – the official concerned may be quite prepared to put his request in writing, but unless it is a formal, legal requirement of the territory concerned then any payment may still be considered a bribe.

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Test My Knowledge

An existing sponsor is visiting and the Head of Department wishes to hold an evening meal in their honour as recognition of their generosity at a prestigious hotel. What would you advise?


5. Gifts and hospitality.

Do not hold any kind of meal as it may be construed as a bribe in return for the sponsorship funding.

A.

That the meal go ahead, but that the venue be changed to the staff canteen as it is less ostentatious.

B.

That the meal go ahead at the prestigious hotel as proposed, but only if it is not a regular occurrence.

C.

That the meal go ahead, but that a more lavish venue be chosen to recognize the contribution the sponsor is making.

D.


Test My Knowledge



Do not hold any kind of meal as it may be construed as a bribe in return for the sponsorship funding.

A.

Incorrect – bribery does not rule out all legitimate business entertaining. The visitor is an existing sponsor, so an appropriate level of entertaining should be acceptable; extra care may need to be taken in respect of potential sponsors, but if the event is not overly lavish or a frequent occurrence then it is unlikely that it would influence a decision whether or not to give funding.

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Test My Knowledge



That the meal go ahead, but that the venue be changed to staff canteen as it is less ostentatious.

B.

Incorrect – bribery does not rule out all legitimate business entertaining. The visitor is an existing sponsor, so an appropriate level of entertaining should be acceptable; extra care may need to be taken in respect of potential sponsors, but if the event is not overly lavish or a frequent occurrence then it is unlikely that it would influence a decision whether or not to give funding.

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Test My Knowledge



That the meal go ahead at the prestigious hotel as proposed, but only if it is not a regular occurrence.

C.

Correct – bribery does not rule out legitimate business entertaining. The visitor is an existing sponsor, so an appropriate level of entertaining should be acceptable, as long as it is proportionate and not overly lavish or frequent. Extra care may need to be taken in respect of potential sponsors, but it is unlikely that a modest one-off event of this nature would influence a decision whether or not to give funding.

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Test My Knowledge



That the meal go ahead, but that a more lavish venue be chosen to recognize the contribution the sponsor is making.

D.

Probably incorrect – although bribery does not rule out all legitimate business entertaining, care should be taken on whether the entertaining is appropriate in scale and frequency.

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