The Bribery Act 2010 covers a multitude of sins, not all related to hospitality, events and incentives. There are assuredly risks for companies, directors and individuals, but the good news is that its introduction did not outlaw corporate hospitality, as had been initially feared.
The Serious Fraud Office (SFO) look at five factors when considering corporate hospitality in the context of the Bribery Act.
Does the company have a clear issued policy regarding gifts and hospitality?
Does the scale of the expenditure in question fall within the confines of such policy and if not, has special permission for it been sought at a high level within the organisation?
Is the expenditure reasonable and proportionate with regard to the recipient?
Is there evidence that such expenditure has been recorded by the company?
Is the recipient entitled to receive the hospitality under the law of the recipient's country?
Rest assured that although we never advise clients on legal or tax issues, Inconnection are fully conversant with the terms of the act and we ensure that everything we do is compliant with it.
As Justice Secretary at the time Ken Clarke stated, “no one is going to try to stop businesses getting to know their clients by taking them to events like Wimbledon, Twickenham or the Grand Prix"