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This paper sets out Transparency International UK's views on how to improve the regulation of post-public employment for former ministers and high-ranking civil servants in Westminster. arte longobarda riassunto SU,F's Musings from the Interweb. Staff raising genuine concerns about payments made to the firm, or associates on its behalf, should know that raising these concerns will not affect their career prospects or lead to disciplinary action. However, if you do not follow the suggested route, you should be able to justify to oversight bodies why your alternative approach is appropriate, either for your practice, or in the particular retainer. The offence does not have to take place in the UK but if it takes place outside the UK, the person committing the offence must have a close connection with the UK. Firms should be transparent about the expenses they pay, the business reason for their payment and any prior approval requirements, and maintain adequate records of the payments and prior approvals (if relevant). Anti-bribery policy - GOV.UK Using a third party also creates a risk, as the firm will have less control over the third party and visibility into their conduct. PDF The Bribery Act 2010 - Guidance - Justice It is now among the strictest legislation internationally on bribery. The Bribery Act covers transactions that take place in the UK or abroad, and both in the public or private sectors. In cases of conviction on indictment, individuals are liable to a term of up to 10 years imprisonment or to a fine not exceeding the statutory maximum, or both (see section 11 of the Bribery Act). Facilitation payments are small payments demanded by officials to provide a service that they are obligated to perform (such as processing a visa application). In larger firms, it may be that anti-bribery procedures and compliance become a standing item on the agenda of the audit committee or equivalent. The inclusion of "through a third party" is intended to prevent the use of go-betweens to avoid committing a crime, although if the written law of the country of the foreign public official allows or requires the official to accept the advantage offered, no crime will be committed.