SHINEBribery Risk: A growing problem for business or a problem overstated?

18 February 2016

Neill Blundell, Partner, Eversheds LLPHead of Fraud & Investigations

Neill BlundellPartner

Neill is a highly experienced fraud and regulatory lawyer who is able to advise clients on the interface between business and regulatory practice and the criminal law.  He has particular expertise in advising and representing individuals, corporate clients, professional firms and financial organisations in areas such as market abuse and insider dealing, corruption, money laundering, cartels and price fixing, extradition, bribery and criminal/regulatory compliance.

He has advised on high profile investigations and proceedings brought by the Financial Services Authority ("FSA"), Serious Fraud Office, Revenue & Customs Prosecution Office, the Crown Prosecution Service, Department for Business Enterprise & Regulatory Reform and the Office of Fair Trading.  He has advised individuals who have become the subject of a disciplinary investigation in their professional capacity.

Neill has been instructed on some of the largest UK fraud investigations. These include the SFO investigation into benchmark rigging, investigation into financial irregularities at a large supermarket chain and as well as various corruption investigations for major corporates. As well as being involved in a whole host of complex investigations by other bodies such as the CPS, HMRC, FCA and the CMA.

Neill also offers compliance advice and the development of bespoke compliance programmes in areas such as bribery and corruption and money laundering. 

In particular, he has advised clients on the US Foreign Corrupt Practices Act and its implications for their business, particularly where they perform public contracts in "red flag" countries like Nigeria and China.  He is also advising on the impact of the UK Bribery Act and is helping clients devise suitable anti-corruption programmes. He has also provided extensive training on the subject world-wide. He also sits on the CBI Anti-Bribery Working Committee.

Neill regularly lectures on fraud related issues and has published many articles in various publications including the Financial Times and Fraud Intelligence. He is author of the chapter on "Overseas Assets", in the Sentencing & Confiscation Section of "Fraud: Law, Practice & procedure".  He is also a contributor to Mitchell Taylor & Talbots "Confiscation & the Proceeds of Crime".   He is on the legal panel for the BBC News, Channel 4 News, BBC Radio 4, Sky News, CNN and Newsnight where he has appeared and been asked to comment on various issues including the investigation into MP's expenses. Neill is also a Solicitor Advocate in the criminal courts where he represents both individuals and companies facing criminal charges.

Neill Blundell is recommended in both Legal 500 2015 and Chambers 2015 Guide, quoting that Neill is “very deliberate, careful and linear in his approach to defending a case” and "his attention to detail is first-class, he has an amazing ability to recall and has a lovely humility in the way he talks and deals with people.”

− The UK: Bribery Act and Serious Fraud Office− The US: threat and enforcement− Worldwide considerations − Difficult issues− Q&A

IntroductionWhat we will cover

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1. A significant increase in enforcement action world-wide since 2012 and greater international cooperation

2. A need to be more vigilant in the monitoring of acts by employees or brokers

3. An increase in focus to target individuals who participate or ignore such acts. US Department of Justice announced focus on prosecution of executives

Three things you need to know in 2016

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The UK

Introduced to:− Consolidate patchwork of common law and statutory offences− Address the requirements of the 1997 OECD Anti-Bribery

Convention− Enhance UK law on bribery including bribery in foreign jurisdictions− Create the following four primary offences: Offences by individuals:

1. Active bribery (the offering, promising or giving of a bribe)2. Passive bribery (receiving or accepting a bribe)3. Bribing a foreign public official

Corporate offence: 4. Failing to prevent a bribe being paid (subject to the defence

of adequate procedures)

Purpose and philosophy – a reminder Bribery Act 2010

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Who does the UKBA apply to?

− Individuals if closely connected to the UK or British citizens

− Corporations which are incorporated in the UK or which carry on business in the UK

− Any sector and any business (public, private or charitable)

Where does it apply?

− Bribery taking place anywhere in the world

Changing attitudes and behaviorBribery Act 2010

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Enforcement and Prosecution − Serious Fraud Office (“SFO”)

• Often investigates cases which involve nationally, internationally and strategically important companies• Rolls-Royce, GlaxoSmithKline, Tesco, Barclays Bank, G4S and

Serco • More SFO prosecutions likely by re-introduction of blockbuster

funding (whereby SFO secures extra funds if its total costs on a case exceed 10% of its annual budget)• Deferred Prosecution Agreements

− Director of Public Prosecutions to remain in post for another 2 years− NCA now has remit for investigating overseas corruption. Former

Overseas Corruption Unit at City of London Police now housed in the NCA

Changing attitudes and behaviorBribery Act 2010

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Where a person offers, promises or gives a financial or other advantage to another person, and intends the advantage:

(i) to induce a person to perform improperly a relevant function or activity, or(ii) to reward a person for the improper performance of such a function or activity

OR

Where a person offers, promises or gives a financial or other advantage to another person, and knows or believes that the acceptance of the advantage would itself constitute the improper performance of a relevant function or activity

A reminder - what is a “bribe”?Bribery Act 2010

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Any function of a public nature

− Any activity connected with a business/trade or profession

− Any activity performed in the course of a person’s employment

− Any activity performed by or on behalf of a body of persons (whether corporate or unincorporated)

AND

− The person performing the function or activity is expected to perform it in good faith, impartially or is in a position of trust

Note: Can be a relevant function or activity even if it has no connection with the UK or is performed in a country or territory outside the UK.

What is a “relevant function or activity”?Bribery Act 2010

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− If the relevant function or activity is performed in breach of an expectation that the person will act in good faith, impartially or in accordance with a position of trust

What constitutes a “financial or other advantage”?− Cash− Transfers− Entertainment and Gifts− Travel and holidays− Charitable donations− Political contributions− Paying school fees− Goods and services− Hiring or employing

What is “improper performance”?Bribery Act 2010

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Personal liability

All employees: − Three individual offences of giving or receiving a bribe or bribing a foreign official − Max penalties of 10 years’ imprisonment and/or an unlimited fine− Termination of employment

Senior officers (directors, company secretaries, managers etc.)− If a company is guilty of bribery, senior officers may be jointly liable if they consented

or collaborated in the bribery − If bribery takes place overseas, senior officers can still be liable if they have a “close

connection” to the UK (i.e. British citizen or resident in the UK)− Disqualification as a director for up to 15 years

Why does it matter?Bribery Act 2010

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What must individuals in an organization be told?− Not to bribe− Not to be bribed− Report requests for bribes and concerns− Think through transactions and if in doubt, speak to someone!− Make sure due diligence is conducted on business partners and

recorded− Keep up to date with internal policies and training− Co-operate in any investigations

Personal liability Bribery Act 2010

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− A commercial organisation is guilty of an offence if a person associated with the organisation bribes another person intending to• obtain or retain business for that organisation, or• obtain or retain an advantage in the conduct of business for that

organisation− It does not matter whether the act or omission takes place in the

UK or elsewhere− Knowledge of the bribe is irrelevant (strict liability)− Organisation can be liable even if it does nothing improper

Penalties− Unlimited fine− Being disbarred from public procurement in the UK if the

organisation or its directors commit an individual offence under UKBA

Corporate liability Bribery Act 2010

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− A person is associated with an organisation if he performs services for or on behalf of the organization

− The capacity in which he performs services for the organisation is predominantly irrelevant

− Examples include employees, agents, subsidiaries and some joint venture companies – depends on all the relevant circumstances and not merely the nature of the relationship

− There is a presumption that employees perform services on behalf of the organisation unless the contrary can be shown

What is an “associated person”?Bribery Act 2010

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− The only defence available is that the organisation had adequate procedures in place to prevent the bribery from occurring

− The burden of proof is on the organisation to prove it had adequate procedures in place

“The objective of the Act is not to bring the full force of the criminal law to bear upon well run commercial organisations that experience an isolated incident of bribery on their behalf” (MoJ Guidance)

Bribery Act 2010The defence

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What are “adequate procedures”?− UK MoJ has formulated official procedures and principles on what

adequate procedures are− Generally, it is up to the organisation to decide what is appropriate− The key test is whether the procedures are proportionate to the

risks involved

The key six principles 1. Proportionate procedures (proportionate to nature, scale and

complexity of the organisation)2. Top level commitment (from the CEO to the post room)3. Risk assessments (periodic, informed and documented)4. Due diligence on third parties (on business relationships especially

if new)5. Communication (training and policies)6. Monitoring and review (identify issues as they arise and report on

such issues)

Corporate liability Bribery Act 2010

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− Available to prosecutors in the UK since 24 February 2014− A written agreement between the prosecutor and the defendant

company− Prosecution deferred and eventually dismissed, if the company

complies with set conditions; these are likely to include:• Financial penalty• Reparation to victims• Repayment of profits from unlawful conduct;• Appointment of an independent monitor (in more serious cases)• Measures to prevent future offending.

− Used in the US for many years but UK DPA is different to its US counterpart

Deferred Prosecution Agreements (DPAs)Bribery Act 2010

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− Sovereign note placement in 2013-2013 by Stanbic Bank Tanzania Ltd and Standard Bank Plc to raise $600m for Tanzanian government

− Initially quoted a fee of 1.4% of gross proceeds; matters did not progress until fee raised to 2.4%

− Evidence showed the additional 1% ($6m) paid to a “local partner”, EGMA• Chairman was head of Tanzanian Tax Authority; MD was ex-CEO

of Capital Markets and Securities Authority− Purpose of the $6m was to induce government officials to

favour Stanbic in appointing it to conduct the private placement

The first DPA: Standard BankBribery Act 2010

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− Offence of “failure to prevent bribery” (s.7) was made out

− Insufficient evidence to show “knowing participation”

− Accusation limited to having inadequate systems to prevent associated persons from committing an offence of bribery

− Prosecution deferred for three years under the following conditions:

1. Payment of $7m + to government of Tanzania;

2. payment of $25.2m in disgorged profits to HM Treasury;

3. payment of SFO’s costs of £330,000;

4. co-operation with ongoing and future investigations; and

5. review and upgrade its anti-bribery and corruption policies.

The first DPA: Standard BankBribery Act 2010

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− A defining moment in corporate criminal law and provides a cost effective manner of resolving criminality.

− Two key lessons:• Critical to launch an internal investigation early and consider self-

reporting early; and• Ensure that policies are truly adequate, practical and appropriate

to the business and actively promoted to all staff− “It is a high bar, for a DPA to be suitable” (Ben Morgan,

SFO)− The SFO have confirmed that DPAs will not be used on

every corporate case that they take on and had indicated three by Xmas 2015 – where are they?

The first DPA: Standard BankBribery Act 2010

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− Sweett Group, AIM-listed property surveyor• Self-reported bribery following an internal investigation, triggered by

allegations in the Wall Street Journal

• It appears that a former employee offered the design work on a $100m hospital construction contract in Morocco to a NY-based architecture firm if it agreed to pay a bribe to a UAE official who had control of the project

• This was in addition to evidence of deception seen in property deals

between 2012-2013

• SFO investigation of two suspicious contracts

• SG is pleading guilty to s.7 offence regarding conduct in the Middle East and was due in court on 12 February 2016 – what has happened?

The first prosecution under s.7 outside a DPABribery Act 2010

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The SFOEnforcement

− Currently around 22 ongoing investigations by the SFO against companies (under Bribery Act / pre-Bribery Act legislation)

− Co-operation with other regulators like the CMA and FCA − International co-operation with bodies like the US DOJ and SEC etc. − Director of SFO David Green QC: strict direction is evident and to remain in position for at

least two more years− Blockbuster funding:

• granted re Libor investigation• more recently SFO requested top-up of £21.1m to ensure funding through to the end of

the financial year• Obtaining payment of costs in DPA process• What will the future hold for the SFO? Will it be consumed by the NCA

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(under pre-existing UKBA laws)UK enforcement: the companies

Company Industry Date Penalty

Smith & Ouzman Secure Publishing Jan 2016 Criminal conviction - £1.3 million fine and £880,000 forfeiture

Abbott Group Oil and Gas Nov 2012 £5.6 million (civil settlement). First company to have met strict criteria of self reporting initiative.

Oxford University Press Publishing July 2012 £1.9 million (civil recovery order). Debarment from World Bank funded tenders for three years.

Mabey & Johnson Ltd Engineering January 2012 £130,000 (shareholder recovery)

Macmillan Publishers Ltd Publishing July 2011 £11 million (civil recovery order). Debarment from World Bank funded tenders for three years. Compliance monitor.

De Puy International Limited Healthcare April 2011 £4.8 million (civil recovery order)

MW Kellogg Limited Engineering February 2011 £7 million (confiscation of funds received from unlawful conduct)

BAE Systems Plc Defence/Aerospace December 2010 £500,000 (part of £30m global agreement)

Innospec Ltd Energy March 2010 £8 million (part of US$40m global settlement). 3 year US/UK compliance monitor

AMEC plc Engineering October 2009 £5 million (civil recovery order)

Mabey & Johnson Ltd Engineering September 2009 £6.6 million. Compliance monitor

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(under pre-existing UKBA laws and UKBA)UK enforcement: the companies

Company Individual Date Offence/Penalty

Aluminium Bahrain BSC (Alba)

Bruce Hall, former CEO July 2014 Sentenced to 16 months for conspiracy to corrupt

Sustainable AgroEnergy plc

Gary West, James Whale, Stuart Stone, Fung Wong

August 2013

Charged with conspiracy to commit fraud by false representation and conspiracy to furnish false information. West, Stone and Wong were also charged with offences of making and accepting a financial advantage contrary to s1(1) and 2(1) of the UKBA

Smith & Ouzman Limited

Chris Smith, Nick Smith, Tim Forrester, Abdirahman Omar

October 2013

Charged with offences of corruptly agreeing to make payments totalling nearly half a million pounds, contrary to section 1 Prevention of Corruption Act 1906

Innospec Ltd Paul Jennings, former CEO July 2012 Sentenced to two years in prison following pleading guilty to three charges of conspiracy to commit corruption

Innospec Ltd Mr Miltos Papachristos, Regional Sales Director for Asia-Pacific Region & Mr Dennis Kerrison, former CEO

June 2012 18 months and four years in prison respectively after being convicted of conspiracy to commit corruption

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(under pre-existing UKBA laws and UKBA)UK enforcement: the companies

Company Individual Date Offence/Penalty

Innospec Ltd Dr David Turner, former Sales and Marketing director

January 2012

16 month suspended sentence with 300 hours unpaid work following pleading guilty to three charges of conspiracy to commit corruption.

Mabey & Johnson Ltd

Richard Charles Edward Forsyth, former MD

February 2011

21 months imprisonment, disqualified from acting as a company director for five years and ordered to pay prosecution costs of £75,000.

Mabey & Johnson Ltd

David Mabey and Richard Gledhill February 2011

Mabey: Eight months imprisonment, disqualified from acting as a company director for two years and ordered to pay prosecution costs of £125,000.

Gledhill: eight months imprisonment, suspended for two years.

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The USAThe leader in fighting international bribery, or more interested in receiving huge settlement fees from corporate?

The US threat – why?

− Long arm reach of the US FCPA even for non US companies

− Working closely with foreign counterparts including SFO - a proactive approach

− More multi jurisdictional cases (Siemens)− Reorganisation of the SEC enforcement division with a

specialised FCPA unit− Increased focus on individual liability – often groups of

individuals from the same company and the same industry

− Dodd-Frank ActEversheds LLP |

− Anti-bribery provisions & Accounting provisions− Enforced by the SEC and DOJ− Impacts two categories of persons:(1) Those with formal ties to the US• Issuers – Those who own securities registered in the US or

must file periodic reports with the SEC.• Domestic concerns – Broad, any citizen, national or resident of

the US.(2) Those who take action in furtherance of a violation while in

the US• May be taken by an agent of the foreign person or entity. • May be directed at either US or non-US government officials.• Can implicate co-conspirators, even if the co-conspirators did

not take any actions in the US

Foreign Corrupt Practices Act (1977)The USA

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− A payment, offer, authorization or promise to pay money or anything of value (see Payment to a Foreign Official).

− Involvement of a foreign government official− A corrupt motive− Having the purpose to:

• influence any act or decision of the person receiving the promise or payment; • induce that person to do or omit any action in violation of his

lawful duty; • secure an improper advantage; or • induce that person to use his influence to affect an official act or

decision

What the FCPA prohibitsThe USA

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− Long arm reach of the FCPA even for non US companies.

− Working closely with foreign counterparts - a proactive approach

− More multi jurisdictional cases to become the norm (think FIFA, Siemens, Rolls Royce, GSK)

− Reorganisation of the US SEC enforcement division with a specialised FCPA unit

− Increased focus on individual liability – often groups of individuals from the same company and the same industry

− Dodd-Frank Act and its impact on whistle-blowers

The US extra-territorial effect

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− New “guidance” issued by the DOJ in September 2015

− Gives clear directives to federal prosecutors in pursuit of individuals, and provides powerful new weapons

− Steps that should be taken in any corporate investigation:

1. Provide all facts on individuals2. focus on individuals from the outset3. criminal and civil attorney communication4. absent “extraordinary circumstances”5. resolution of both corporate and individuals6. focus on factors other than individual’s ability to pay

DoJ – “Individual Accountability For Corporate Wrongdoing”Prosecuting individuals

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US enforcement: companies

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− Co-ordination between US and foreign counterparts has increased dramatically− FCPA investigations where local law enforcement have also investigated include:

Globalisation of US enforcement

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The US threat – recent examples

− Bristol-Myers Squibb: charged with violating the FCPA when employees of China-based joint venture allegedly made improper payments to obtain sales; agreement to pay more than $14 million to settle charges

− Hitachi: charged with violating the FCPA by inaccurately recording improper payments to South Africa's ruling political party in connection with contracts to build power plants; agreement to pay $19 million to settle charges

− 84 companies on the SEC corporate investigations list (as of 31 December 2015)

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Worldwide

Transparency International Corruption Perceptions Index 2015

Country RankScore (0 = highly

corrupt, 100 = very clean)

Denmark 1 91Finland 2 90Sweden 3 89

New Zealand 4 88Netherlands/

Norway 5 87

Switzerland 7 86Singapore 8 85Canada 9 83

Germany/UK/Luxembourg 10 81

USA 16 76Qatar 22 71Israel 32 61

Italy/Lesotho/Senegal/South

Africa61 44

India 76 38Russia 119 29Iran 130 27

Nigeria 136 26North

Korea/Somalia 167 8Eversheds LLP |

Country Enforcement of the OECD Anti-Bribery Convention, Progress Report 2015

Transparency International

Level of Enforcement Countries

Active Enforcement(adequate deterrent to foreign bribery)

Germany, Switzerland, UK, US

Moderate Enforcement(stages of progress in enforcement but inadequate deterrence)

Australia, Austria, Canada, Finland, Italy, Norway

Limited Enforcement(stages of progress in enforcement but inadequate deterrence)

France, Greece, Hungary, Netherlands, New Zealand, Portugal, South Africa, Sweden

Little or No Enforcement(no deterrent whatsoever or very little deterrence)

Argentina, Belgium, Brazil, Bulgaria, Chile, Colombia, Czech Republic, Denmark, Estonia, Ireland, Israel, Luxembourg, Japan, Mexico, Poland, Russia, Slovak Republic, Slovenia, Spain, Turkey

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Cases / Investigations concerning bribery of foreign officials Foreign bribery enforcement – a real picture

Country Cases Investigations

United States 184 111United Kingdom 27 22Netherlands 11 3Germany 6 16France 3 6Switzerland 3 6Austria 1 3China 1 2Greece - 1Italy 1 3Slovakia - 2Taiwan - 1Romania 1 1

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− Petrobras− FIFA Scandal

• US pressure on Swiss authorities

− Libor− GSK

• Paid $3 billion in US to settle allegations of illegal marketing (2012) • Found guilty of bribery and fined $483 million in China (2014)• Subsequently investigated by SEC (USA) for possible breaches of FCPA, and SFO (UK)• Internally investigating further allegations in Romania, Poland, UAE, Lebanon, Jordan,

Syria and Iraq.

− Alstom• French and Swiss investigators, US and UK prosecutors

− Other trends:• Sophisticated intelligence sharing• More emphasis on individual liability (you cannot send a corporation to prison)

Multi-jurisdictional casesIncreasing global cooperation

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Corporate hospitality and giftsDifficult issues

− Gifts, hospitality and donations (political or charitable) are potentially bribe

− Key test is whether it is reasonable and proportionate: avoid lavish hospitality!

“Bona fide hospitality and promotional, or other business expenditure which seeks to improve the image of a commercial organisation, better to present products and services, or establish cordial relations, is recognised as an established and important part of doing business and it is not the intention of the [UKBA] to criminalise such behaviour.”

“The Government does not intend for the [UKBA] to prohibit reasonable and proportionate hospitality and promotional or other similar business expenditure intended for these purposes.”

“It is, however, clear that hospitality and promotional or other similar business expenditure can be employed as bribes.”

David Green QC (Head of SFO): “We are not the Serious Champagne Office!”

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− Does it have a legitimate commercial purpose? − Is it appropriate to offer the particular hospitality to that person?

• Do not offer lavish hospitality to junior personnel• Do not offer hospitality to persons who can determine or influence the

outcome of a pending decision affecting your business.• Do not offer hospitality on multiple occasions to the same person over a short

period of time− Is it in line with industry standards and norms?− Does it pass the “sniff test”? Would you feel embarrassed if the hospitality

featured in the media?− Does it comply with applicable local law and regulations?− Think “GIFT”:

• Genuine: Not intended to procure improper performance • Independent: Does not affect the receiver’s judgment• Free: No obligation on the receiver or his/her relatives• Transparent: Can be declared publicly

What is “bona fide”, “reasonable” and “proportionate”?Difficult issues

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− Ensure employees comply with Anti-Bribery Policy/Code of Ethics/Gifts and Hospitality Policy …

− Follow due diligence protocol for agents

− Be live to suspicions and rumours concerning employees and third parties

Adequate proceduresDifficult issues

1. Risk Assessments

2. Implement Policies

3. Deliver Training and

Guidance

4. Senior Management Endorsement

5. Undertake Regular Reviews

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− Can be any person who performs services for or on behalf of the commercial organisation• formal contract and control not required• legal capacity not relevant

− Activities of subsidiaries, sister companies, joint ventures, consortia, consultants, agents, suppliers and third parties need to be monitored

− FCPA and UK enforcement history show that intermediaries and other third parties are a major area of exposure

− Red flags:• poor documentation• no clear business case• no proper due diligence• lack of approvals• poor transparency in use of funds• unusual payment channels and commercial structures• no proof of delivery of services

Difficult issuesThird parties / Associated persons

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Third parties / Associated personsDifficult issues

− Need for risk-based due diligence checks on third parties to be engaged

− Formal contracts should require third parties to behave in an ethical way and in compliance with anti-bribery legislation

− Need for formal approval and monitoring processes to check reasonableness of payments made to third parties

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− More like extortion

− FCPA allows them in theory (but record keeping requirements rarely met in practice)

− No requirement for a “corrupt” or “improper” intent

− Low level

− Requests are common in some high risk jurisdictions

Difficult issuesFacilitation Payments

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− The UK: Bribery Act and Serious Fraud Office• Legislation and enforcement mechanisms tightened• Prosecutors not well-funded but determined to get results using new processes such

as DPAs• NCA taking powers from SFO – uncertain what this will mean in the long run• Difficult to predict how many cases there will be in the UK

− The US: threat and enforcement• Still the pre-eminent enforcer of anti-bribery law• Assertive approach to jurisdictional issues • Now targeting individuals

− Worldwide considerations • Many “non-traditional” jurisdictions now prosecuting foreign bribery…• …but little consistency or clarity in how this will happen

− Difficult issues• There are warning signs that indicate corruption within an organisation and it is

therefore very important to have systems and controls that show it up• Corporate clients need to be willing to have detailed and sometimes uncomfortable

conversations about their values and approach to doing business

SummaryMain topics considered

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− To download Eversheds guide to bribery legislation around the world, please visit our website here

− Anti-bribery@work is our interactive online course designed for all organisations that carry on business in the UK and are concerned about the implications of the Bribery Act. For more information please click here

− Register here to hear about our events, publications and expert opinion

Useful Links

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Questions?

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