Anti-Bribery & Trading
The UK Bribery Act 2010, which came into force on 1 July 2011, is possibly the most extensive piece of anti-bribery legislation in the world. It introduces changes under United Kingdom law that apply to the Club and its Managers in relation to all business transacted both in the United Kingdom and abroad.
Bribery is defined as the offering, promising, giving, accepting or soliciting a financial or other advantage as an inducement or reward for the improper performance of a relevant function or activity. There are four offences created under the Bribery Act, as follows:
Bribing Another Person
It is an offence for a person to offer, promise or give a financial advantage to another person intending the advantage to induce a person, or reward a person, for the improper performance of a relevant function or activity.
Receiving a Bribe
It is an offence for a person to receive, accept or solicit a bribe.
Bribing Foreign Public Officials
It is an offence to bribe a person who holds a legislative, administrative or judicial position of any kind in a country or territory outside the UK, or who exercises a public function for and on behalf of a territory outside the UK. This offence is committed if a person offers, promises or gives any advantage to such a foreign public official or to another person at the foreign public official’s request or with their consent
Failure of Commercial Organisations to Prevent Bribery
A commercial organisation is guilty of an offence if a person associated with it bribes another person with the intention of obtaining or retaining business or advantage in the conduct of business for that organisation. This is effectively a failure by the commercial organisation to prevent an offence under the Bribery Act.
Individuals found guilty of any offences under the Act can be imprisoned for up to 10 years and/or receive unlimited fines. If a company is found guilty, a senior corporate officer (such as a Director, Manager, Secretary or similar officer) can be imprisoned for up to 10 years and/or receive an unlimited fine if the court decides they have given their ‘consent’ or ‘connivance’ to the offence.
To comply with the requirements of the Bribery Act, North has drafted an anti-bribery policy and code of conduct. The Club and its Managers have also adopted a zero-tolerance policy in relation to bribery and corruption and are committed to acting professionally, fairly and with integrity in all of North’s business dealings and relationships.
The zero-tolerance policy extends to all of the Club’s business partners. Members, correspondents, brokers and any other third parties conducting business with North should contact the Club’s Managers if they have any questions or concerns regarding the effect of the Bribery Act or its application.
US Foreign Account Tax Compliance Act (FATCA)
FATCA is designed to increase transparency for the US tax authorities in relation to US persons earning income through non-US institutions. FATCA imposes withholding tax obligations where required reporting obligations are not met. To support FATCA compliance, our FATCA Form can be downloaded below:
The North of England Protecting and Indemnity Association Limited is a company registered in England.
Registered number: 505456
Registered office: The Quayside, Newcastle upon Tyne, NE1 3DU, United Kingdom.
VAT registration number: 828 5711 10.