Case Study

Investigation in to real estate company’s UK Bribery Act compliance

Stroz Friedberg is a specialized risk management firm built to help clients solve the complex challenges prevalent in today’s digital, connected, and regulated business world

An international real estate company was alerted by one of its contractors that a decision making employee of the real estate company had received bribes from said contractor in order to secure development contracts. The contractor had also self-reported the matter to the police resulting in the arrest of individuals allegedly complicit in the corrupt scheme.

The client required confirmation as to whether the allegations could be substantiated, whether other development projects were at risk and the potential implication for the organisation from a UK Bribery Act perspective.

Stroz Friedberg forensically imaged the employee’s company laptop, network files, email files and the electronic contractor files. This data was then hosted on a review platform and made available to the Stroz Friedberg Financial Investigators for examination. In addition to this, a number of boxes of hard-copy documents were also identified as being relevant for review.

The Financial Investigation team constructed a timeline of events, transactions and communications based on the electronic media and hard-copy documents to understand what transpired prior to the awarding of the contract, the performance of the contract and any subsequent actions carried out. Two suspect contracts were examined in great detail to identify areas of weakness through which the process may have been manipulated to allow the appointment of a pre-determined contractor.

Stroz Friedberg also conducted interviews with client staff including junior staff, peers and management level staff of the subject to understand the subject’s expected behaviours, the way in which the subjects area of the business operated, the company protocols and anti-bribery controls in place.

The client and their legal advisers were provided with a factual report outlining the chain of events that led to the situation, whether the client could or should have had corporate knowledge of the actions of its staff, and whether there was more the client could reasonably have done in the situation.

Stroz Friedberg also provided the client with suggested controls and procedures to reduce the likelihood of similar allegations arising in the future. The client was able to address its concerns over the commercial validity of these payments, their level of exposure and the UK Bribery Act implications.

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