The Bribery Act 2010

The Bribery Act 2010 came into force in the UK today, 1 July 2011.

The Bribery Act 2010 regulates how companies conduct their operations and business activities in the UK and overseas and defines a bribe as a financial advantage or other reward that is offered to, promised to, given to, or received by an individual or company to induce or influence that individual or company to perform its public or corporate functions or duties in an improper manner (ie not in good faith, not impartially, or not in accordance with a position of trust).

The Bribery Act 2010 creates the criminal offiences of:

• a company, employee or associated person (including consultants, agents, contractors or temporary staff) acting for, or on behalf of, the company offering, promising or giving a bribe;
• a company, employee or associated person acting for, or on behalf of, the company requesting, receiving, or agreeing to receive a bribe;
• an employee or associated person acting for, or on behalf of, the company offering, promising or giving a bribe to a foregin public official with the intention of influencing that offical in the peformance of his/her duties to gain an advantage; and
• failure by a company to prevent birbery by its employees or associated persons acting for, or on behalf of, the company.

Church International is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas and prohibits employees or associated persons from offering, promising, giving, soliciting or accepting any bribe.  The bribe might be cash, a gift or other inducement to, or from, any person or company.  This prohibition also applies to indirect contributions, payments or gift made in any manner as an inducement or reward for improper performance, for example through consultants, contractors or sub-contractors, agents or sub-agents, sponsors or sub-sponsors, joine-venture partners, advisors, customers, suppliers or other third parties.

Church International permits corporate entertainment, gifts, hospitality and promotional expenditure that is undertaken:

• for the purpose of establishing or maintaining good business relationships;
• to improve the image and reputation of our company; or
• to present our services effectively;

provided that it is

• arranged in good faith, and
• not offered, promised or accepted to secure an advantage for the Company or any of its employees or associated persons or to influence the impartiality of the recipient.

We depend on our employees and associated persons to ensure that the higest standards of ethical conduct are maintained in all our business dealings.  Employees and associated persons are encouraged to report any concerns that they may have to our Head of Compliance, Legal & Support, Lesley Hayes as soon as possible.