Food for thought on the Bribery Act


Organisers of corporate jollies need to be more open about who they are wining and dining.

A conference and events industry expert said transparency is needed to stay on the right side of the UK Bribery Act. The law was introduced to make it easier to prosecute organisations that made corrupt payments.

But analysts say it was not intended to stamp out corporate hospitality.

Last year Brighton and Hove council chiefs entertained eight conference and event organisers to slap up meals in the city.

The dinners took place at English’s restaurant in East Street and Chilli Pickle in Jubilee Square in the wake of the UK Meetings Show in London. They were charged to the credit card of Brighton and Hove’s convention bureau manager as official council business.

John Fisher, managing director at the FMI Group an international hospitality agency based in Shoreditch, said that event promoters and clients have agreed a few ground rules in the wake of the Bribery Act.

1 You don’t offer hospitality shortly before or shortly after the granting of a contract for services. Most people now offer a dead period of, say, three months when no supplier is offered hospitality if a big contract is coming up or just been awarded.

2 Any hospitality offered under the banner of marketing or promotion should be openly discussed and agreed and there should be no do this get that deals or secret arrangements.

3 There is generally more leeway with private firms but as the act is aimed mainly at public sector employees in positions of discretional influence, public sector workers need to be open and above board if any hospitality or promotion is offered.

4 A public record of expenditure should be kept in a register of offers and acceptances that is open to scrutiny. There should be an internal process of approval which again is open to scrutiny. Decisions to offer or accept hospitality should be openly recorded and reviewed from time to time to see if the hospitality has been proportionate and reasonable.

Mr Fisher said: “When the act was passed Ken Clark issued some guidelines from the Ministry of Justice stating very clearly that it was perfectly ok to offer hospitality to promote good relations with potential clients provided it was ‘appropriate and reasonable’. One man’s reasonable is another man’s outrage .

“It’s all about context. If a client is going to bring say £10,000 worth of spend to Brighton then £75 quid for a meal to encourage them to do so is probably reasonable. There are no monetary guidelines in the act so you have to take a view.”

A spokeswoman for Brighton and Hove City Council said: “We have had a note from Visit Brighton that reports a successful familiarisation visit following the UK Meeting Show. Lead times for meeting and conference bookings can be in excess of 12 months and Visit Brighton is in dialogue with several of the attendees who may confirm business in the future. To date, one of the attendees has booked two meetings and used two seafront hotels. Another attendee has booked an event with a sailing organisation based at Brighton Marina. A yacht based at the marina has also been chartered by an attendee of the visit.”