Last month on ‘International Anti-Corruption Day’ which took place on the 9^th December 2019, the British Institute of Interior Design (BIID) launched a new anti-bribery campaign aimed at unethical practices in the interior design industry.

The campaign is a national campaign and offers advice to Interior Designers on how to recognise bribery from suppliers, ensuring they have a process in place to identify a criminal offence under the 2010 Bribery Act. The campaign is being backed by John Penrose who is the Prime Minister’s Anti-Corruption Champion for Boris Johnson and Theresa May.

The BIID recommended that all interior design practices review their current internal process to make sure they have the relevant checks in place to avoid corruption and bribery. They listed out some questions that companies should include and here they are:

• ‘Does the practice use third party agents to introduce new business and/or negotiate on its behalf? If so, the bribery risk is likely to be greater.
• If the practice receives corporate hospitality does it need internal guidelines on the sort of entertainment or gifts that are acceptable and those that are not?
• What due diligence does the practice carry out on new business partners?
• Is the management of the practice taking a lead on anti-bribery? Is it communicating a clear zero-tolerance message? Has it assessed the business’ susceptibility to bribery? Has it put in place clear and proportionate policies and procedures to deal with this risk?
• Do employees need to be trained on bribery risks?
• Could the practice’s remuneration and incentive arrangements and practices potentially cause or lead to corrupt behaviour? Are your financial controls able to pick up any unusual or unexplained payments?’ (1)

Harriet Forde, President of the BIID says: “The purpose of the Kick Out The Kick-Backs campaign is to stamp out illegal business practices that damage the entire profession in order to foster a more honest and ethical design industry. The BIID is not aiming to impose a one-size-fits-all business model on the UK interior design profession, and we recognise that different clients, regions and sectors may have different fee structures. However, we believe that greater transparency between designers and clients will lead to better working relationships that benefit designers, suppliers and clients alike.”

National organisations supporting the campaign

• Anti-Copying In Design (ACID)
• Association for Project Management (APM)
• Chartered Institute of Building (CIOB)
• Association of Consultant Architects (ACA)
• British Institute of Kitchen Bedroom and Bathroom (BIKBBI)
• The Furniture Ombudsman
• National Association of Shopfitters and Contractors (NAS)

You may be thinking what should I do if I realise I may have accepted a bribery in the past? Could I face financial damages if a civil claim is made? Here’s what the BIID has to say:

“There is no statute of limitation for Bribery Act offences. This means that a Bribery prosecution can be made many years after the event.

If one was dealing with a corporate client concerning a past bribery situation which was material in terms of value or the number of times there had been a transgression then, the lawyer advising should give advice about self-reporting to the authorities.

For the reasons given below, if the bribe was for a relatively modest sum, then one would think in terms of drawing a line but ensuring that there is sufficient transparency going forwards concerning future commission payments.

When considering whether to prosecute for an offence under the Bribery Act, the public prosecutor would need to consider whether it is in the public interest to do so.  Prosecutors are more concerned with high profile companies (e.g. Rolls Royce which, under a plea bargain, agreed a £293m fine, a disgorge of profits of £258m and a payment to the Serious Fraud Office in respect of costs of £13m!); or, the bribing of public officials (e.g. in 2011, a clerk at Redbridge Magistrates Court became the first person to be prosecuted under the Act for accepting a bribe of £500 on about 50 occasions in return for not inputting details of traffic offences on a court database).” (2)

You can find further answers to questions you may have on the BIID website here.

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References

• Interior Design Magazine – BIID Launches new campaign to end bribery in interior design – 9^th December 2019
• BIID – Kick out the Kick backs questions answered – 2020