In Ireland, a key issue for consideration and active management is businesses' anti-corruption policies ("ABC"). As we grow used to the staff working from home, companies should ensure that they review their ABC policies to ensure that they are fit for purpose and reflect their employees current working environment. The Criminal Justice (Corruption) Act 2019 places a positive obligation on companies to have an ABC policy in place and to (i) ensure it is fit for purpose and (ii) that staff receive training on it. Now is in an important time for companies to ensure that their ABC policy is a living document which reflects the current environment. Key consideration should be given to checks and balances such as the ability to sign off on agreed payments, issuing purchase orders, procurement and accepting gifts. Should you require any assistance in (i) drafting your ABC policy or (ii) updating it to reflect your current working environment please contact a member of our team.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.