"Take Five: Preparing Boards for the UK Bribery Act"
Corporate Board Member, September 30, 2010
John Kocoras was interviewed about the UK's new Bribery Act. Under the Act, he said, "companies operating in the UK may be held liable in the UK for bribes paid by employees or agents outside the UK unless the company had in place 'adequate' procedures to prevent bribery." Mr. Kocoras advised chief compliance officers to communicate with their boards about whether company anti-corruption practices conform to the Act. "Conformance will likely involve moderate adjustments to existing anti-corruption policies and procedures designed to comply with the U.S.'s Foreign Corrupt Practices Act," he stated, adding that boards will be challenged to ask, "[I]s the message getting across not only to senior leadership but to the sales staff out in the field in all corners of the world, and is middle management reinforcing the anti-corruption message?"