Bribery Bill will enhance role of in-house lawyers
The traditional role of the lawyer is changing. Unprecedented levels of new, complex legislation and an increasing gap between innovation and developments in the law are creating sources of additional legal risk. Lawyers, and particularly in-house lawyers, have an opportunity to enhance their role, taking on broader and more dynamic responsibilities as regulation becomes increasingly principles-based, focused on outcomes. This is particularly apparent in the developing area of anti-corruption law.
February 03, 2010 at 03:26 AM
3 minute read
The traditional role of the lawyer is changing. Unprecedented levels of new, complex legislation and an increasing gap between innovation and developments in the law are creating sources of additional legal risk. Lawyers, and particularly in-house lawyers, have an opportunity to enhance their role, taking on broader and more dynamic responsibilities as regulation becomes increasingly principles-based, focused on outcomes. This is particularly apparent in the developing area of anti-corruption law.
Company executives are waking up to the increasing strategic importance of the in-house legal team. In the UK, as the new Bribery Bill progresses through Parliament, in-house lawyers will have to become more closely involved with business decision-making processes in order to protect their organisations from potential civil and criminal exposure and consequent damage to their reputation.
The scope for active in-house lawyer engagement in this area is broad, extending from the important field of mergers and acquisition due diligence (and successor liability exposure) to a range of matters such as intermediaries, incentives, employee selection as well as a broader focus on corporate culture and governance.
In short, the Bribery Bill seeks to hold to account organisations and individuals in the UK and overseas for involvement with offering, promising or giving a bribe, or accepting, soliciting or agreeing to receive an illicit payment, increasing the maximum prison term for bribery from seven to 10 years. Bribing a foreign public official to obtain or retain business will become a specific criminal offence. Organisations could be prosecuted on a strict liability basis for failing to prevent bribery if they cannot prove that they have 'adequate procedures' in place to prevent such illegal payments. Directors will have a corresponding civil liability.
The Bribery Bill will, if enacted, provide a principles-based regulatory approach focused on outcomes for in-house lawyers to interpret and implement at their organisations. While we anticipate some formal guidance, the Government will not provide a precise list of prescribed rules for organisations. It will, however, leave the procedures that will be needed to achieve those outcomes to the lawyers and senior managers of organisations to work out for themselves.
The Government will provide non-prescriptive guidance on 'adequate procedures', setting out relevant principles backed by illustrative good practice examples to help organisations develop procedures that are appropriate to their own circumstances and business sectors. In-house lawyers will need to assist in the development and implementation of these procedures, co-ordinating the various control functions within their organisation and facilitating change in their organisation's behaviour when this is required.
Good anti-corruption procedures tend to involve tailored risk analysis, policies, systems, sanctions, helplines and monitoring. In-house lawyers will need to consider these elements when working with senior management to develop and implement their own procedures.
In-house lawyers will also need to understand and engage directly with regulators and enforcement authorities regarding the prescribed outcomes. They will need to work with such bodies in a constructive way and exercise good judgment about how their organisation can best deliver outcomes. Managing regulatory risk will become more akin to managing commercial business risks. Sound judgment and effective implementation will be key to delivering the desired results.
Sam Eastwood is a litigation partner and head of the business ethics and anti-corruption group at Norton Rose. Chris Campbell-Holt is a researcher at the firm and was a member of the secretariat of the Woolf Committee.
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