Adequate Procedures, All you need to know about self reporting, Concerned about possible bribery? - Written by on Tuesday, June 21, 2011 23:47 - 0 Comments

The SFO – spiking the guns of a whistleblower

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We wrote recently about the SFO and their role as a potential solution to sleepless nights.

Howard Sklar has also written of what he would do if he were the GC of a UK company.

The thrust of these articles is that there is a window of opportunity to liaise with the SFO today to obtain guidance, and in appropriate cases, an acceptable resolution to historic bribery problems.

In a recent speech Richard Alderman, Director of the SFO underscored the SFO’s approach and highlighted another reason for engaging with the SFO in appropriate circumstances (say, to tell the SFO of challenges faced in connection with facilitation payments and the organisations approach to them) – spiking the guns of a whistleblower.

In his speech he emphasised that the role of the SFO was to help corporates that want to do the right thing implementing an anti-corruption stance.

Referring to “increasing confidence and trust between companies and the SFO”. Mr. Alderman reported that “companies now tell us what they are doing and they tell us the sorts of problems they are encountering. They tell us as well what they are doing about these problems.”

The SFO response?

Mr. Alderman said: “What we do is to give any advice that we might have to the company and we leave it to the company to get on and do what it thinks is right…It works to the company’s advantage because they have the assurance of working with the SFO on this. What this means, in particular, is that if we get a phone call from a whistleblower about the particular problem, we know that the company is trying to resolve it and therefore there is no need for us to take any action.” [our emphasis]

We are happy to liaise with the SFO and can do so on a no names basis if clients are concerned to maintain anonymity.

Image © Crown Copyright 2011

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