ADEQUATE PROCEDURES: 10 LESSONS IN 10 YEARS The Unwritten Do’s and Don’ts for Adequate Procedures under the UKBA: Concrete Examples of What Does (and Doesn’t) Measure Up.

June 24, 2020 2:15pm

Dame Alison Saunders
Partner
Linklaters

Dylan G. Moses
Partner
K&L Gates LLP

Gaon Hart
Global Anti-Bribery & Corruption Policy & Education Lead
HSBC

Tapan Debnath
Head of Investigations UK & EMEA
Nokia

Ten years since its inception, the UK Bribery Act has significantly raised the bar on corporate liability and reorganised existing rules on tackling corruption. Adequate procedures are an essential part of the overarching ethics policy of every company.

In this new session, leading practitioners will reflect on the evolution of the "failure to prevent" model and the “adequate procedures” under section 7 and share what it means for their organisation’s compliance policy. Benefit from a unique opportunity to benchmark and to ask questions while gaining worthwhile strategic insights for confronting new challenges coming across your desk.

  • How can companies ensure that their “adequate procedures” are adequate and not just a ‘box-ticking’ exercise?
  • How the threat of the corporate offence of “the failure to prevent bribery” is now viewed by most companies that carry business in the UK
  • Key lessons learned from the judicial interpretation in Sweett Group Inc case vs. the DPA with Standard Bank plc
  • What role the culture of compliance, training, messaging and the senior management’s commitment to demonstrate adequate procedures is playing today and how companies have taken them on board
  • How industry and the community are tackling pending confusing aspects of section 7 moving forward