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"The UK Serious Fraud Office (SFO) has issued its long-awaited guidance on corporate co-operation. For the first time in one place, the SFO has set out what in its view are ‘indicators of good practice’ for companies under investigation. This is a helpful clarification. In its own words the SFO defines co-operation as going ‘above and beyond’. The list of indicators of good co-operation practice is extensive and not, as the SFO itself points out, exhaustive. That said, the SFO acknowledges that each case turns on its own facts, and some indicators on the list may not apply in some cases, perhaps hinting at a little flexibility depending on specific circumstances. Companies dealing with the SFO and/or identifying suspected wrongdoing in their organisation must therefore carefully consider the guidance and determine whether and/or to what extent they can meet the SFO’s co-operation requirements. Companies should also review existing policies and procedures dealing with internal investigations in ..."

"In a case that demonstrates the perils of selling a business with an illicit contract on 30 May 2019 the SFO issued a press release announcing that Carol Ann Hodson, the former director and owner of a company named ALCA Fasteners Ltd (ALCA), pleaded guilty to paying bribes amounting to £300,000 in order to secure contracts worth £12m. The bribes were paid to purchasing manager1 of a German company over the course of five years and, according to a Serious Fraud Office (SFO) press release, the bribes were paid monthly in cash instalments and on one occasion, Ms Hodson sent jewelry in a brown envelope to the purchasing manager. While the bribery scheme itself may not be noteworthy what is is first, the fact it was revealed following the sale of the business when the buyers picked it up and more importantly second, the pragmatic approach taken by the SFO in respect of the ..."

"Without much fanfare the government recently launched a subsidised Business Integrity Consultancy Service. Despite the lack of publicity, and the somewhat opaque government website marketing the scheme, the initiative appears, at first blush, to be a potentially valuable resource for SMEs that want to expand their businesses into certain high-risk areas of the globe, i.e., emerging markets that carry risks of bribery, corruption, and human rights issues, according to the UK government.  This is especially so since the government has recently rejected the House of Lords suggestion that additional guidance on Adequate Procedures would be useful stating that: "…the guidance was only ever intended to provide general procedural guidance. It was deliberately not prescriptive but is certainly not a one-size-fits-all document. It is rather an outline guide as to how businesses should go about the task of determining what is required for them in a way of bribery prevention procedures." "...the Government does not ..."

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