Chapter ThreeBribery, corruption and adequate procedures




The team is assembled again for our second workshop, four weeks after the first. As agreed last time, the subject is to be an example of business ethics in action so that everyone has a template of what best practice looks like in this area that they can try to emulate in the Stronach Group.

My idea for this workshop is a little unusual. It is not based on any particular example of best practice that I have seen myself in one of my clients, neither is it derived from anything that I have read about in reports of a particularly admired company or business leader. Instead, I am going to talk about bribery and corruption and, specifically, about the procedures that organisations should adopt if they want to prevent it from happening in their business. When doing so I will be recommending that the team follows the approach set out in guidance from the UK Government that accompanies a recent piece of legislation, the Bribery Act 2010 (UKBA). This guidance represents, in my view, a classic example of the twin-track approach to a workplace situation.

I contacted the Chairman, Rachel Gordon, shortly after the conclusion of the first workshop because I wanted to sound her out about my choice of subject matter for today on two counts. First of all, the UKBA is regarded with scepticism in some quarters of the business world because it is thought to be burdensome and ...

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