The importance of anti-bribery training: UK company is fined £2.25m for failing to prevent bribery

23 April 2019
Under UK law companies are responsible for bribes committed by “associated persons” where such bribes have been made for the benefit of that company.

The Sweett Group PLC has recently been fined £2.25m for an act of bribery which was committed by one of its subsidiaries in the Middle East. The subsidiary made a payment to a senior Emirati official in order to secure a consultancy contract relating to the development of a hotel in Dubai.

Despite the fact that Sweett itself had not committed any act of bribery companies are, under UK law, responsible for bribes committed by “associated persons”, where such bribes have been made for the benefit of that company. Associated persons include employees, subsidiaries (even if they are overseas) and agents. So how do you prevent similar problems occurring for your business

The defence

There is only one defence to prosecution for bribery committed by your associated persons. The defence is to ensure that you have adequate procedures in place to prevent bribery from being committed. Sweett had to plead guilty to the offence because it did not have adequate procedures in place.


A major component of ensuring that you have adequate procedures in place is ensuring that all of your associated persons receive anti-bribery training to educate them about the things they should and should not be doing.

How we can help

We can provide your business with a variety of either face-to-face or on-line anti-bribery training. As well as a standard “off the shelf,” on-line anti-bribery training product, we can provide you with bespoke training solutions that are customised to address the specific issues faced by your business. Ensure you don't get caught out because someone "didn't know the rules." 

For further additional information about how to get anti-bribery training for your business, please contact us.

Author: Helen Wright