The Ministry of Justice today released the final guidance on the UK Bribery Act, describing how companies will soon be liable for prosecution if employees are found to have engaged in bribery anywhere in the world.
While the Government has stressed that the legislation will not penalise those businesses that take a common sense approach to spending, the need to demonstrate reasonable and proportionate behaviour leads to several new challenges, making expense management mission critical for business.
The line between ‘appropriate’ and ‘excessive’ expenditure on a prospect or client is blurred at the best of times, but the final guidance on the Bribery Act has turned the spotlight on the need for even greater transparency into how businesses spend money, especially in the traditional minefield of corporate hospitality.
With the onus now on CFOs to ensure that expenses are both reasonable and validated, the boundaries of what is acceptable must be clearly defined – particularly when it comes to travel and entertainment spend. The key is to put processes in place to enforce policies and make it easy for employees to demonstrate that an expense incurred is not a bribe.
However, it can be very difficult for organisations to keep track of and validate the payments made by employees while they’re out entertaining clients. To overcome this problem, employees must be able to easily demonstrate compliance by logging their expenses as they accrue. This would significantly reduce the risk of error and enable CFOs to quickly identify expenses as and when legislators get heavy-handed.
The Bribery Act will undoubtedly spur businesses to consider the challenges surrounding compliance, and to put solutions in place to better manage even the most disparate expenses incurred by employees.