Bribery Act 2010 Update

The Serious Fraud Office (SFO) has announced that three people have been convicted and sentenced as part of its investigation into the Sustainable Growth Group (SGG), including its subsidiaries, Sustainable AgroEnergy plc (SAE) and Sustainable Wealth (UK) Investments Ltd. The convictions related to various offences including conspiracy to commit fraud, conspiracy to furnish false information, fraudulent trading, and bribery contrary to sections 1 and 2 of the Bribery Act 2010. They were sentenced as follows:

• Gary Lloyd West, former Director and Chief Commercial Officer of SAE, was sentenced to a total of 13 years' imprisonment and was disqualified from being a director for 15 years.
• James Brunel Whale, Chief Executive Officer and Chairman of SGG, was sentenced to a total of 9 years' imprisonment and was disqualified from being a director for 15 years.
• Stuart John Stone, Director of SJ Stone Ltd, a sales agent of unregulated pension and investment products, was sentenced to a total of 6 years' imprisonment and was disqualified from being a director for 10 years.

Our checklist outlines the offences introduced by the Bribery Act 2010 and the penalties for committing them. It also highlights practical steps that businesses can take to help avoid breaching the legislation.

It is critically important that you take the Bribery Act and its implications for your business seriously.  Our team has carried out in-house Bribery Act training for a number of clients as well as help them to draft their Bribery Act Policies.  If you undertook training when the Act came in, you may want to consider refresher training for new starters and/or current employees, or your salesforce. Please contact Peter Bennett or a member of our employment team to see how we can help.