UK Finance is concerned that the fight against corruption, especially bribery of public officials, is hindered by high-level international legal definitions and varied national legislation and interpretation. It sees that ambiguity between definitions and widely differing structures of government and public service delivery adds costs and delay to corporate ABC efforts.
It has now produced a practical and risk-based definition of “public officials” for this purpose, and has published a paper setting out how it suggests industry can work towards a solution.
The paper explains the Bribery Act definition is very wide-reaching and generic, which leads to ambiguity when firms try to define their risk appetite and controls. It seeks to build on this definition and proposes a three step approach to deciding what should be included and how firms can define their risk appetite. The paper includes a detailed list of bodies and functions that should be included or excluded, and an analysis of how key terms are within, or outside, key legislative and international guidance.