Your Questions: Answered - Written by on Saturday, March 31, 2012 2:29 - 2 Comments

Your Questions Answered: Jo Morgan CCO IMI PLC – Debunks Olympic corporate hospitality myths.

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Question:

I’d like to entertain some clients at the Olympics in the summer. I’ve read lots in the press about lavish hospitality being outlawed by the Bribery Act. My concern is that some of the tickets for popular events run into thousands of pounds and so I’m concerned that the amount is too much. On the other hand, the Olympics is a once in a lifetime chance for us to entertain our best clients. Surely, I can’t be prevented from inviting clients along as a result of the Bribery Act? Help.

Answer:

Here at IMI plc we have very clear guidelines on entertaining. We have monetary limits above which one needs Executive Director approval for the event. In reviewing such requests the Directors look at:

a) who the entertainment is being offered to (i.e. customer, supplier, public, private, what level in the organisation the person receiving the entertainment is);
b) what circumstances exist at the time the offer of the entertainment, and at the time the entertainment will take place, (i.e. is there a live bid or other circumstance which would mean that the entertainment could improperly influence a decision or provide an improper advantage);
c) whether there are any other circumstances which might make the entertainment look inappropriate – essentially this is the “newspaper test” – how would we feel if the entertainment was reported in the newspaper? Would it look OK to the ordinary man? That will generally tell you how the law enforcers would view it too.

I do not believe that it was the intention behind the Bribery Act to prevent attendance at events such as the Olympics and therefore if you consider the points above and you are comfortable with answers then you should be OK.

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London Calling: The Olympics and Corporate Hospitality under the UK Bribery Act « FCPA Compliance and Ethics Blog
Apr 19, 2012 0:09

[...] another post, entitled “Jo Morgan CCO IMI PLC – Debunks Olympic corporate hospitality myths”, the guys questioned a compliance practitioner Jo Morgan, the Chief Compliance Officer (CCO) of [...]

London Calling: The Olympics and Corporate Hospitality under the UK Bribery Act
Apr 20, 2012 5:18

[...] another post, entitled "Jo Morgan CCO IMI PLC – Debunks Olympic corporate hospitality myths", the guys questioned a compliance practitioner Jo Morgan, the Chief Compliance Officer (CCO) of [...]

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