In light of the guidance issued by the Government, top tips for principals to reduce the risk of prosecution of agents engage in bribery include:

  1. Putting in place policies and procedures to counter bribery, and communicate these to agents. This will enhance awareness and help to deter bribery by making clear the basis on which the business does business. Such policies must be monitored regularly. 
  2. Ensure compulsory training on your anti-bribery procedures. If you feel that only a few agents operate in a high risk area, ensure the training is targeted accordingly. 
  3. Reporting lines of communication and whistle blowing procedures should be communicated so that agents can report corruption safely and in confidence. Reporting structures should be ready and implemented prior to 1 July 2011
  4. Consider introducing reviews of agents to take into account their knowledge of anti-corruption policies, and introduce incentives for exemplary behaviour and knowledge. 
  5. Review agency agreements so that breach of the anti-bribery provisions is a ground for immediate termination without payment of compensation under the Commercial Agents Regulations. 


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