In late 2011, the Royal Mail issued an instructive to its employees that laid down terms for accepting Christmas tips from customers. It suggested that its workers should consult with their superiors if they were offered cash tips of £30 or more, or hospitality related gifts worth £25 or more, for a decision to be reached regarding whether tips should be accepted or not. The employer did authorise the acceptance of lower value tips on the basis that employees did not receive them from customers in exchange for preferred treatment, which could be interpreted as bribery. The Royal Mail suffered considerable ridicule in the popular press for taking these precautionary measures against a seemingly innocent and traditional practice. Yet they were not alone during the 2011 festive period, when many business owners and their human resources people remained befuddled about what they should or should not give to and receive from customers further to recent amendments to corporate bribery laws.
Like many aspects of employment law and health and safety regulations, changes can be accompanied by rafts of confusion, sending shock waves through businesses. They understandably become concerned that what they have always considered to be licit and right might become illegal and wrong overnight. In the case of amendments to anti-bribery laws, Christmas 2011 saw many business people scratching their heads about whether or not they should present their loyal customers with the usual gifts and treats, or whether they might be open to accusations of bribery and corruption.
We, at NorthgateArinso, are market leading providers of employment law, health and safety and human resources expertise. It is our of care to our clients that they understand what the changes to anti-bribery laws means in real terms, and to help them establish best practices to ensure that the changes are abided by.