The Civil Recovery Unit recovered £212,800 on 25 September 2015 under an agreed civil settlement with a Glenrothes based company which accepted that it had benefited from unlawful conduct by a third party.
In June 2015, solicitors acting on behalf of Brand-Rex Ltd, a developer of cabling solutions for network infrastructure and industrial applications, contacted the Crown Office to disclose an instance of failing to prevent bribery by a third party associated with the company.
Between 2008 and 2012 Brand- Rex operated an incentive scheme known as “Brand Breaks” for UK distributors and installers. An independent installer of Brand-Rex products offered his company’s tickets for holidays abroad to an employee of one of his customers.
The individual who ultimately received the tickets was in a position to influence decisions as to which company they purchased cabling from. Personnel from this company and individuals connected to them used these tickets for foreign holidays in 2012 and 2013.
Brand-Rex became aware of this issue through an internal review and launched an extensive investigation conducted by external solicitors and forensic accountants. As a consequences of the investigation, Brand Rex made a self-report to Crown Office and accepted that they failed to prevent this when they should have done, accepting responsibility for a contravention of Section 7 of the Bribery Act 2010.
The value of the settlement reflected the benefit that the company derived from the unlawful conduct.