You have recently been employed as a Compliance Officer for E Ltd, a London-based company, that sells and maintains IT systems in both the private and public sectors. It has customers in the UK, Europe, South America and Africa. The Board of Directors has recently learned that a competitor, H Ltd, is being investigated by the Serious Fraud Office for bribery on the basis of its lavish corporate hospitality. For example, before the pandemic in 2020, H Ltd invited a number of actual and potential UK and international customers to a symposium in New York, paying for their flights, meals, five-star hotel accommodation and they provided generous expenses allowances. E Ltd had been considering the possibility of promoting and hosting similar events so as to avoid losing business to its competitors.

The Board of Directors have called you to a board meeting. You are expected to give a 5- minute presentation covering the following matters:

1. If E Ltd were to arrange a symposium similar to that organised before the pandemic by H Ltd, whether E Ltd might be criminally liable for bribery.

2. What steps E Ltd should consider taking as an organisation to avoid any possible future allegations of bribery.