The Bribery Act

The Bribery Act, which has recently been enacted in the UK, introduces the following new criminal offences that can be created through James Coker Land Sales & Planning Ltd (The Business) :

  1. a general offence covering the offering, promising or giving of a bribe;
  2. a general offence covering requesting, agreeing to or receiving and accepting a bribe;
  3. a distinct offence of bribing a foreign public official to obtain or retain business;
  4. a new strict liability offence for commercial organisations where they fail to prevent bribery by those acting on their behalf, wherever in the world they may be.

The Bribery Act exposes The Business, its Directors and employees to liability that could result in:

  • individuals in the UK being jailed for up to 10 years and/or receiving an unlimited fine;
  • The Business receiving an unlimited fine.

Further, a Director if convicted of a bribery offence could be disqualified from holding a director position for up to 15 years.

This Business values its reputation for professionalism and trust.  We recognise that over and above any financial damage suffered, fraud may reflect adversely on our image and reputation.

The Business is therefore committed to preventing bribery and to promoting a culture where bribery is unacceptable.

The purpose of the following Policy Statement is to set out the Business’s aims with regard to limiting its exposure to bribery by:

  • Setting out a clear anti-bribery policy to prevent corruption and bribery;
  • Providing awareness training to employees, and Directors so that they can recognise and avoid the use of bribery by themselves and others;
  • Encouraging employees to be vigilant and to report any suspicions of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately;
  • Monitoring and rigorously investigating instances of alleged bribery and assisting police and other appropriate authorities in any resultant prosecution;
  • Taking firm and vigorous action against any individual(s) involved in bribery.


The following Policy Statement applies equally to all Directors and staff retained by the Business, consultants acting on the firm’s behalf, and any organisations, or other third parties, with which and through whom the firm conducts business.

Policy Statement

The Business prohibits the offering, the giving, the solicitation or the acceptance of any bribe in order to gain any commercial, contractual or regulatory advantage for the Business in a way which is unethical, or in order to gain any personal advantage for the individual or anyone connected with the individual.

The Business’s policies give details of the actions to be taken where it is perceived that fraudulent or corrupt acts are being perpetrated.  Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to a Director.

Responsibility  The prevention, detection and reporting of bribery is the responsibility of all employees and Directors throughout the firm. Suitable channels of communication by which employees and others can report confidentially any suspicion of bribery will be maintained by the Whistleblowing policy.

There may be situations faced by individuals in which the correct course of action is not always obvious or clear.  It is an individual’s responsibility to supplement this policy with their own common sense, following the spirit of the policy as well as its content.  Otherwise faced with uncertainty, an individual should ask themselves:

  • Do I have any doubts about the legality or the ethics of what I am doing or being asked to do?
  • Is it compliant with James Coker Land Sales & Planning’s policies and procedures?
  • Would I have any concerns about what I am doing being public knowledge?
  • Would I have any trouble explaining what I am doing to family or friends?

If anyone is asked to do something that they suspect is illegal, unethical or against James Coker Land Sales & Planning’s Anti-Bribery policy, Gifts and Hospitality policy or any other codes of conduct, then they must make a notification as described in the Whistleblowing policy.

Policy Implementation

This policy will be communicated to all employees and Directors.