AH Bribery Policy & Procedures

Question 1

Which of the below is not a general offence under the Bribery Act?

Answer 1

Bribing a civil service employee

Question 2

What is the four general offences?

Answer 2

Offering, promising and giving
Requesting, agreeing, accepting
Bribing a foreign public official employee
“Corporate Offence” / failing to precent a bribe involving an “associated” person.

Question 3

How many general offences are there under the Bribery Act?

Answer 3

Four

Question 4

What is the maximum penalty for a bribery offence?

Answer 4

10 years imprisonment and unlimited fine

Question 5

Why would something go against AHA anti-bribery policy?

Answer 5

Rewards for volume or value, and something obviously disproportionate.

Question 6

An example of something which goes against our anti-bribery policy is?

Answer 6

BDM offers cash incentive to any adviser that submits 3+ apps with them that week, and lender pays for all expense paid holiday as a thank you

Question 7

Examples of something which would be approve within our anti-bribery policy?

Answer 7

A token gift as a thank you and entering a prize draw by submitting an app

Question 8

What are the six key principles to help corporates apply appropriate procedures to comply with the Bribery Act of 2010?

Answer 8

Proportionate procedures
Top level commitment
Risk assessment
Due diligence
Communication (including training)
Monitoring and review

Question 9

What is not one of the six principles to help corporates apply appropriate procedures to comply with the Bribery Act of 2010?

Answer 9

Appropriate penalties in place

Question 10

What is the name of the peice of law that regulates bribery in the UK?

Answer 10

Bribery Act 2010

Question 11

Who is legally obliged to report suspected money laundering activities?

Answer 11

All staff

Question 12

Who should you refer to if you suspect an act of bribery?

Answer 12

The risk, compliance and technology director. DLS

Question 13

Who do you report suspicions of money laundering to internally?

Answer 13

Compliance support

Question 14

What is the maximum penalty for tipping off?

Answer 14

Up to 5 years in prison and/or a £5,000 fine.

Question 15

What is not considered a way of commiting fraud according to the Fraud Act 2006?

Answer 15

Failing to return a clients documents.

Question 16

Is a police officer a Politically Exposed Person?

Answer 16

No

Question 17

If you forget to make a copy of a clients passport but you did see it, which is correct?

Answer 17

Must make own copy of the ID or can accept a copy certified by an appropriate person.

Question 18

What is a companies only defence when considering bribery?

Answer 18

Its ability to demonstrate it had “adequate procedures” in place to prevent.

Question 19

Where should any form of gift be recorded?

Answer 19

Log of Partner entertainment

Question 20

Who manage entries to the Log of Partner Entertainment?

Answer 20

Team Leaders

Question 21

What are the five things the Statement of Policy contains?

Answer 21

Setting out a clear anti-bribery policy
Training all employees
Encouraging employees to report
Following appropriate disciplinary procedures
Investigating

Question 22

Which governmental department created the six principles to help corporates apply appropriate procedures to comply with the Bribery Act of 2010?

Answer 22

Ministry of Justice