The Practical Implications of the UK Bribery Act for Russian Business
On March 15 a breakfast briefing “The Practical Implications of the UK Bribery Act for Russian Business” took place in Moscow. The UK Bribery Act is being introduced in the next few weeks and will have some major implications for business in Russia. Stronger than existing anti-corruption legislation, the new legislation imposes strict liability for failure to prevent bribery, includes facilitation payments as an offence, and renders companies liable for the actions of subsidiaries and third parties. It applies not only to British companies, but to any company doing business in the UK including Russian companies.
For any company operating in the challenging Russian environment, the legislation raises a number of questions for corporate management. How can companies minimise the risks of exposure to the new legislation? How can they establish in-house codes of conduct and compliance systems which go beyond a purely formalistic approach? How can they identify and enforce “adequate procedures”? How can they create a zero-tolerance culture which employees can truly understand and buy into?
Our special guest was Richard Alderman, Director, Serious Fraud Office (UK). At the briefing Alistair Graham, Partner, Dispute Resolution practice (White & Case, London) and Charlie Monteith, Counsel, Dispute Resolution practice (White & Case, London) presented the impact of The UK Bribery Act on companies. Then Will Kenyon, Partner, Forensic services leader (PwC UK) and Irina Novikova, Director, Forensic services (PwC Russia) presented the mechanics of adequate procedures and their practical implications for companies in Russia.
The meeting was organized jointly by IBLF, PwC and White & Case. In attendance were about 70 representatives of major Russian and international companies working in Russia including AvtoVaz, Basel, NOVATEK, Severstal, Siemens, Sistema, Suek, TNK-BP, CTC Media and Wimm Bill Dann.