The case of R v Corry serves as a reminder that businesses must have appropriate anti-bribery and corruption policies, procedures, risk assessments and training in place and be aware of the actions of people involved in the day-to-day running of the business.
In this case Corry, a Senior Manager at Coca-Cola Enterprises UK Ltd who had responsibility for sub-contracting works, influenced tender processes by supplying confidential data to individuals within three certain businesses (giving those businesses an unfair advantage) and in return accepted money, free tickets to sporting/ entertainment events and sponsorship of a football club where Corry was president.
As well as Corry, the two individuals he conspired with AND the three limited companies received sentences and substantial fines respectively.
The businesses were all found guilty of failing to prevent an associated person from bribing on their behalf as none of them could show that adequate actions, training, procedures and policies had been put in place to prevent it from happening.
Lesson to be learnt – businesses must take action, have the policies and procedures in place, carry out risk assessments, actively train those working in the organisation and review all the above regularly!
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