Archive for June, 2011

Is a corporate pension scheme trustee a commercial organisation for the purpose of the Bribery Act 2010?

Wednesday, 22 June 2011

Last week Stephen looked at whether he could still take his pension trustee clients to Wimbledon as a result of the Bribery Act 2010 ( The Bribery Act 2010: can I still take my pension trustee clients to Wimbledon?!).  However, there’s another aspect of the new Act that interests me and that’s the “section 7 offence” that catches commercial organisations who fail to prevent bribery by those associated with them.  If a corporate pension scheme trustee is deemed to be a commercial organisation then it would also need to be concerned about the activities of those performing services for or on its behalf (such as investment managers, custodians, administrators etc).  (more…)

The Bribery Act 2010: can I still take my pension trustee clients to Wimbledon?!

Friday, 17 June 2011

The Bribery Act 2010 bites from 1 July 2011.  Wimbledon’s 20 June to 3 July – so as long as it’s not the semis or finals I’ll definitely be fine – phew.  But would I actually be in trouble for the semis/finals? – “You cannot be serious?!” (à la Mr McEnroe) I hear you say.  Well you’re right, because fortunately Ken Clarke explicitly stated “Rest assured – no one wants to stop firms getting to know their clients by taking them to events like Wimbledon” in the Ministry of Justice’s Bribery Act guidance – Ken’s clearly a tennis fan as well – good lad.  So what’s the deal with the Bribery Act then for pension scheme trustees?  In short – it’s all about internal controls and keeping registers…

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