The Bribery Act 2010 came into force on the 1 July 2011. The Act introduced a corporate offence of failing to prevent bribery and holds an organisation liable where a person (ie an employee, agent, intermediary, joint venture or subsidiary) performs a relevant function on behalf of the organisation and commits an act of active bribery.
This is regardless of whether or not the organisation knew that these actions were taking place or that they were benefitting. The Serious Fraud Office (SFO) may impose an unlimited fine and up to 10 years imprisonment if the University is found to have committed a breach of the Act. The only defence is that the University has in place ‘adequate procedures’ to prevent bribery occurring.