Bribery ACT
You have recently been employed as a Compliance Officer for G Ltd, a London-based company that produces
medical products and services for the healthcare sector. The company was established in 2018 before the
covid-19 pandemic crisis and initially specialised in producing Personal Protective Equipment (PPE) for
frontline healthcare workers. It has expanded rapidly in less than a year and now employs over 150 people.
The company supplies healthcare products and services to NHS Trusts and other healthcare providers in the
UK.
G Ltd occasionally promotes its goods and services using corporate entertainment. For example, it hired a
private box hospitality suite at the 2020 Cheltenham Festival (a national horse-racing event) in order to ‘meet
and greet’ key UK customers. A four-course meal was served as well as afternoon tea. Guests had access to a
free private bar and could place their own bets on the racing using a dedicated betting service. The
Cheltenham event was principally held to promote public relations, networking, and interest in G Ltd’s products
and services.
G Ltd has been considering the possibility of hosting much more extravagant events in line with its competitors
to avoid losing business to them.
The Board of Directors has recently learned that one such competitor is being investigated for bribery due to its
lavish corporate hospitality program. You have been called to a board meeting. You are expected to give a 5-
minute presentation covering the following matters:
1. Whether the hospitality provided by G Ltd for guests at the Cheltenham Festival event might make it
criminally liable for bribery
2. Whether G Ltd’s plans to expand its corporate entertainment program may give rise to allegations of bribery
3. What steps G Ltd should consider taking as an organisation to avoid any possible future allegations of
bribery
