AH Bribery Policy & Procedures Flashcards
Which of the below is not a general offence under the Bribery Act?
Bribing a civil service employee
What is the four general offences?
Offering, promising and giving
Requesting, agreeing, accepting
Bribing a foreign public official employee
“Corporate Offence” / failing to precent a bribe involving an “associated” person.
How many general offences are there under the Bribery Act?
Four
What is the maximum penalty for a bribery offence?
10 years imprisonment and unlimited fine
Why would something go against AHA anti-bribery policy?
Rewards for volume or value, and something obviously disproportionate.
An example of something which goes against our anti-bribery policy is?
BDM offers cash incentive to any adviser that submits 3+ apps with them that week, and lender pays for all expense paid holiday as a thank you
Examples of something which would be approve within our anti-bribery policy?
A token gift as a thank you and entering a prize draw by submitting an app
What are the six key principles to help corporates apply appropriate procedures to comply with the Bribery Act of 2010?
Proportionate procedures Top level commitment Risk assessment Due diligence Communication (including training) Monitoring and review
What is not one of the six principles to help corporates apply appropriate procedures to comply with the Bribery Act of 2010?
Appropriate penalties in place
What is the name of the peice of law that regulates bribery in the UK?
Bribery Act 2010
Who is legally obliged to report suspected money laundering activities?
All staff
Who should you refer to if you suspect an act of bribery?
The risk, compliance and technology director. DLS
Who do you report suspicions of money laundering to internally?
Compliance support
What is the maximum penalty for tipping off?
Up to 5 years in prison and/or a £5,000 fine.
What is not considered a way of commiting fraud according to the Fraud Act 2006?
Failing to return a clients documents.
Is a police officer a Politically Exposed Person?
No
If you forget to make a copy of a clients passport but you did see it, which is correct?
Must make own copy of the ID or can accept a copy certified by an appropriate person.
What is a companies only defence when considering bribery?
Its ability to demonstrate it had “adequate procedures” in place to prevent.
Where should any form of gift be recorded?
Log of Partner entertainment
Who manage entries to the Log of Partner Entertainment?
Team Leaders
What are the five things the Statement of Policy contains?
Setting out a clear anti-bribery policy Training all employees Encouraging employees to report Following appropriate disciplinary procedures Investigating
Which governmental department created the six principles to help corporates apply appropriate procedures to comply with the Bribery Act of 2010?
Ministry of Justice
