Welcome back to the podcast. I'm Alexandra Ragi, and I'm in London today talking about the UK

Bribery Act and the compliance landscape here with Michelle de Cluver. Michelle is a partner with

Adelshaw Goddard's corporate crime and investigations team.

She has extensive experience in complex cross-border crime investigations, including bribery,

money laundering, and fraud. Michelle has been a great supporter of Trace, traveling for our events

to locations as far-flung as Dubai and Manila, for which we're very grateful.

Michelle, thank you for joining me.

Thank you very much, Alexandra.

Most people listening will be generally familiar with the UK Bribary Act,

but perhaps you can summarize some of the highlights and especially the features that distinguish this law from similar laws in other countries.

I think there are probably three differences to highlight.

And certainly we saw this when the Bribery Act came into force,

that these were the three areas that international companies were really focusing on changing in their compliance programs.

Very importantly, in terms of what amounts to bribery, the UK Bribery Act does cover commercial bribery. So there are many jurisdictions

where bribery is really focused on bribery of public officials. The UK Bribery Act does include

bribery of foreign officials, but commercial bribery is also illegal. Can you just give

us an example of purely commercial bribery? Because this does distinguish the UK

Bribery Act from older laws like the USFCPA. Right.

So an example might be where a company is bidding for a contract and it in some way influences

the procurement process and obtains a valuable contract from a purely commercial counterparty.

There may be no public officials involved in the procurement side at all.

If we can just stay with that for a minute, what do you think is the public policy behind that?

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