Syracuse University Application Essays Examples

Syracuse University Application Essays Examples Mrs. Stewart was an educator with Tyler ISD for 40 years. It was the Stewart’s desire to make a lasting contribution to their community by rewarding students who share their values of faith, education, and high moral character. Eligible students of all races are encouraged to apply. Recipients may attend any accredited 2 or 4-year college or university in the United States. The Gladys and Thomas “T.B.” Stewart Scholarship Fund was established in 2010 through the generosity of Gladys and T.B. The Hugh P. Brown Memorial Scholarship was established by Mr. Brown’s family to honor his adventurous spirit. He once drove a man to Galveston in a Model T. He also crashed a motorcycle in front of a beautiful young lady’s home. The Jordans were enthusiastic tennis and bridge players for many years. This scholarship supports students from Palestine High School in Anderson County, Texas. He displayed strength, perseverance, and courage which taught others to look at each day as a blessing. Jackson passed away at age 6 after a brave battle with a brain tumor. This scholarship will benefit students like Jackson’s sister, Meredith, who were greatly impacted by their sibling’s death. Recipient may attend any accredited junior college or non-profit technical school in Texas which offers a certification or associate’s degree program in automotive technology or a related field. Applicants must be female and under the age of 20 at the time of initial application. This scholarship supports students from Palestine High School or Westwood High School in Anderson County, Texas. The Stewarts, life-long residents of Tyler, valued their faith and the role of education in their lives and served as positive role models to young people. It was the Stewarts’ desire to make a lasting contribution to their community by rewarding students who share their values of faith, education, and high moral character. Recipients may attend any accredited college or university of their choice. Frances Cowan Gibson, a native of Tyler, was an accomplished artist who enjoyed drawing, painting, and printmaking. This scholarship will be awarded to students in any major who are pursuing fine arts studies, either as a visual art major or minor or simply taking art classes as an elective. In spite of a 3rd grade education, Hugh Brown read the Houston Chronicle every day and had a photographic memory. He had a long and successful career as an auto mechanic in Trinity County, Texas. This scholarship will support students studying automotive technology. Evelyn Davis Jordan graduated from Palestine High School at age 15 and went on to study music at SMU and the Cincinnati Conservatory of Music. On Christmas Day in 1938, she and Henry Jordan, a longtime Palestine attorney, were married. The Edna Faulk Haberle Visual Arts Scholarship was established to provide financial assistance to students planning to major in visual arts. While students from the namesake’s hometown of Jacksonville, Texas will be given preference, the scholarship is open to applicants from several East Texas counties. The Haberle family created this scholarship to honor Mrs. Haberle on her birthday in 2019. Recipient must attend a college or university located in the State of Texas that offers a geology degree program. The recipient must have achieved a minimum GPA of at least a 2.0 (on a 4.0 scale) in his/her high school or college studies. Jackson Huse loved everyone and never met a stranger. His gentle smile melted the hearts of those around him. Recipient may be a graduating senior from a public, private, home school or a current Texas College student. Preference is for residents of Smith County with a secondary preference for residents of East Texas. This scholarship supports students attending Texas College in Tyler, Texas and honors the legacy of Gladys and Thomas Stewart. The Stewarts valued their faith and the role of education in their lives and served as positive role models to young people.

Meteor and Asteroids Essay Topics - A Difficult Subject for Students to Understand

<h1>Meteor and Asteroids Essay Topics - A Difficult Subject for Students to Understand</h1><p>The subject of meteor and space rocks is the subject of various school articles that you should explore. They have entranced humanity since days of yore are still more famous than the various planets that we are aware of. It is justifiable that an individual with an enthusiasm for space science would need to take up a course that identifies with it. The principal thing you have to do is to make sense of what sort of science your theme would fall under.</p><p></p><p>Meteor and space rocks paper points are various and many. The classifications go from the conspicuous to the dark. Space science is one classification however there are likewise shooting stars, comets, and space rocks. There are a lot more classes that are not yet surely known or explored.</p><p></p><p>Meteorites are the primary thing that ring a bell. Nobody truly sees precisely what shooting stars are. Truth be told, there is no concurrence on what number of shooting stars there are. Most researchers accept that there are around a hundred thousand shooting stars that could be found on our planet alone.</p><p></p><p>Meteors tumble from the sky at some random time and they become objects that we call shooting stars. These shooting stars come in two distinct structures. Some are installed in the earth and others they drop out of the sky at mind blowing speeds. Meteors come in every single diverse size and hues. Some of them are splendid red and some are blue.</p><p></p><p>Meteor and space rocks exposition subjects are substantially more logical than shooting stars. Cosmologists are reading shooting stars for data that will be utilized in showing the understudies the manner in which our air works. These shooting stars furnish the understudies with a more noteworthy comprehension of the previous his tory of our planet. What we find about shooting stars will likewise be significant in encouraging people in the future about the a wide range of life frames that live on our planet.</p><p></p><p>Meteorites are entrancing and it is hard to examine them. So as to contemplate these shooting stars, you have to have an uncommon telescope. If you somehow managed to utilize a normal camera, you would make some hard memories getting a reasonable picture on account of the smoke that encompasses the meteor and the light dissipating chill out the rock.</p><p></p><p>Meteorites have caught the creative mind of a huge number of individuals and it isn't difficult to perceive any reason why. They are stunning and wonderment terrifying. At the point when you are contemplating shooting stars and space rocks exposition subjects you will be given numerous inquiries. It is each of the a matter of figuring out what your subjects will be in this regard.</ p>

Guidelines For Writing Public Management Research Paper Topics

<h1>Guidelines For Writing Public Management Research Paper Topics</h1><p>Public the executives inquire about paper points ought to be creative and animate the learning of your understudies. Since, the papers that are submitted will be perused and considered by the directors, you should consider the future patterns in the business with the goal that you can do your part to support this.</p><p></p><p>The pattern that you ought to know about is the ongoing exploration that has been led by these organizations. They have attempted broad research which shows that the flow age is more disposed to be impacted by innovation than different ages. Along these lines, it is hence prudent to examine the most recent patterns that may influence the manner in which an organization will operate.</p><p></p><p>The most significant part of open administration investigate paper points is the data that you give as your scholastic capability. It is along these lines basic that you incorporate the college where you concentrate with the goal that the perusers can get to your school certifications on the off chance that you choose to go into the field of the board. Remember to give data on your industry and field of study. Aside from your field of study, you ought to likewise show how your inclinations have helped you in getting where you are today.</p><p></p><p>The next thing that you ought to consider when composing open administration inquire about paper points is to give the perusers a lot of models. Despite the fact that, your examination paper would be utilized by those in the situation of CEO, this isn't the situation. Consequently, you have to give enough proof so the perusers can relate with your thoughts and opinion.</p><p></p><p>Your open administration inquire about paper themes ought to be novel. It ought to contain thoughts that have not been done previously. Yo u ought to consistently ensure that your thoughts are unique. Accordingly, in the event that you are wanting to compose an article on advertising, you ought to be set up to concoct an alternate thought from that of the others who have expounded on this topic.</p><p></p><p>Another factor that you ought to know about when anticipating the substance of your open administration explore paper themes is to guarantee that the models that you give are connected to your fundamental proposal. At the point when you are composing an article on correspondence the executives, you ought not utilize a straightforward case of what is regularly utilized in correspondence. Rather, you ought to have a model that reflects how correspondence functions. This will enable the perusers to see and welcome the rules that you are teaching.</p><p></p><p>It is additionally essential to offer credit to the individuals who preceded you when you are composing open admi nistration look into paper themes. This is particularly significant so as to demonstrate your regard to the individuals who have preceded you. Remember to thank the creator of the first research papers. You would then be able to include your own passage that communicates your thankfulness for the peruser and the examination paper that they presented.</p><p></p><p>These are a portion of the tips that can be utilized when composing open administration explore paper subjects. They incorporate the significance of including enough unique data, having assorted thoughts, and the need to follow a theme.</p>

How to Create a Perfect Thesis Proposal

<h1>How to Create a Perfect Thesis Proposal</h1><p>A theory proposition is a basic part of any understudy's scholastic program. A postulation proposition must be designed in a manner that passes on an exact message to the peruser. It ought to be a brief archive, clarifying the issues and giving supporting proof to help the understudy's position.</p><p></p><p>Proposals are intended for both exposition and Master's projects. Most of understudies get proposition recommendations from the counsel they have picked during their Master's program. Understudies regularly wrongly submit it to a teacher they have never met. The proposition is intended to impart data, not make friends.</p><p></p><p>The counselor and training staff at the college where the understudy is wanting to start their Master's program is a phenomenal wellspring of thoughts. Understudies have numerous inquiries regarding their counsel, so it's a smart thought to think about the issues that should be tended to over the span of the course, and afterward contact the teacher to check whether they can help the understudy in drafting the proposition. The person in question may have a few proposals for development and additionally recommendations on the best way to design the document.</p><p></p><p>Once the understudies have recognized their theme and extent of work, they should plan a gathering with the counsel to audit the last draft. The employee will talk about the entirety of the parts of the proposal and answer any inquiries. The idea of the school personnel and the workforce's calendar will impact the planning of the gathering. In the event that it is after a talk, at that point the time ought to be flexible.</p><p></p><p>Proposals ought to be kept to a base. The educator and counselor who handle most of uses are required to know the substance. At the point when it is an individual from th e school personnel who is taking a shot at the understudy's venture, it will be essential to ensure the person in question has the duty to go along all materials identified with the assignment.</p><p></p><p>Every credit hour of the student'seffort ought to be incorporated. The consultant and employees who are answerable for checking on the proposal ought to guarantee that there is no material missing. The educator will give duplicates of the work to the understudy upon completion.</p><p></p><p>Students who are composing a proposition are required to have a teacher associated with the procedure. The teacher is the individual who will give input on the proposition, yet it is likewise expected that the understudy picks the educator with whom the person in question is working. The connection between the understudy and teacher is critical.</p><p></p><p>In graduate school, the school personnel is generally contained t he alumni partner, the postulation counselor, and the alumni board of trustees. At times, the school personnel may comprise of a few people. The understudy and educator might be hesitant to communicate, however there is a sure cooperative energy that creates between the two.</p>

Review Essay Topics - 5 Tips to Finding the Right Essay Topic

<h1>Review Essay Topics - 5 Tips to Finding the Right Essay Topic</h1><p>If you have wrapped up your school English exposition, you realize that it is so basic to pick the correct paper subject. It's imperative to comprehend that the exposition subject that will represent the moment of truth your evaluation relies upon a few elements. Your major, GPA, exposition structure, scholarly foundation, and scholastic research are everything that go into your capacity to pick the correct article subject. In this article, we'll talk about how to pick the best paper subject for you.</p><p></p><p>The first activity is to think about whether you're taken a crack at school level courses or in the event that you are participating in online courses. It's very normal for understudies who do take online courses to compose their articles from home. For this situation, they would have the option to exploit inquire about help. Be that as it may, this isn't consta ntly conceivable, they despite everything need to comprehend the distinction among explore and different sorts of understudy inclusion. It's additionally a smart thought to look at the composing style of individuals who work at colleges with the individuals who do not.</p><p></p><p>Most understudies who choose to compose surveys consistently pick paper points that fit the material that they're checking on. In that capacity, it's imperative to peruse the different writing in regards to every point. You should understand surveys, news stories, and web journals that talk about these subjects in detail, as this will enable you to comprehend what kinds of points work best in your field.</p><p></p><p>Formulating a topic is a significant part of paper composing, and it can influence your prosperity with any theme. For instance, in case you're searching for better profession prospects, a subject like 'vision' is a decent method to move toward the inquiry. There are many subjects to browse, and in case you're searching for one, don't be hesitant to search for awhile.</p><p></p><p>Keep at the top of the priority list that your own encounters are significant while picking a school article theme. Subjects can assist you with making a wide speculation that can clarify numerous subtleties of your life. You can likewise pick a topic that you know a ton about and that is relevant to your specific subject matter.</p><p></p><p>When you start to consider survey exposition points, you'll understand that your first sense might be to follow the patterns of different authors. This is anything but a poorly conceived notion, yet it's essential to ensure that your work is unique. One tip is to peruse your preferred writers, and perceive how they picked subjects for their books.</p><p></p><p>Another extraordinary tip to remember when picking audit exposition points is to remember a couple of pictures for your paper. This should be possible by including diagrams, tables, and pictures inside your article. You can likewise utilize designs to clarify ideas. At the point when you consolidate these strategies, you will expand your odds of enduring the whole paper without agonizing over a solitary error.</p><p></p><p>Now that you have a smart thought of how to pick school article subjects, it's an ideal opportunity to get the opportunity to work. Follow these tips and you'll be well en route to benefiting as much as possible from your essay.</p>

All About Argumentative Essay Topics for Gun Control

<h1> All About Argumentative Essay Topics for Gun Control </h1> <h2> Things You Should Know About Argumentative Essay Topics for Gun Control </h2> <p>By method of model, in school, you may be mentioned to create a paper from the restricting point of view. Most regularly used as they start correctly a similar standard guide on paper. The understudies are offered with a conversation starter which doesn't have any real answer, and they're made to think basically as an approach to detail their own reaction to the dubious inquiry. </p> <p>Secondly, it's required to collect snappy realities and measurable information to help the content with the powerful contentions. To create an excellent contentious paper, you have to build up a prevalent proposition and clear, coherent contentions that will be trying to debate. The complete quality of an informative article is the way that it rules out individual sentiment. It's trailed by methods for a sentence of elaboration. </p> <h2> Understanding Argumentative Essay Topics for Gun Control </h2> <p>To put it distinctively as there are crooks, they will consistently find an approach to get a firearm or weapons. They can without much of a stretch acquire a weapon through the bootleg market. </p> <p>In reality, weapon wrongdoing insights show that uncontrolled firearm proprietorship will bring about more firearm wrongdoing and at last to insurgency. However, grant us to envision what number of intellectually sick are not recognized as intellectually sick and they're thoroughly allowed to visit the shop and buy whatever shotgun they like and execute whoever they don't care for! The criminal will simply turn to whatever other weapon they can discover and a considerable lot of them are openly advertised. Regardless of whether there's a law confining firearm utilization, criminal will consistently find a way to discover a weapon since lawbreakers are not as prone to obey laws. </p> <p>Guns are the most straightforward and speediest approach to carry out homicide and without them the wrongdoing would be diminished. Moreover, they are not the real issue that should be tended to. All things considered, they are one of the main sources of death. Weapons like the AR-15 attack rifle are created for the quick and successful slaughter of people. </p> <p>When you create an article, the absolute first draft is regularly loaded with linguistic blunders, which is a side road for most of perusers. After you're set up to start composing, investigate these example articles on weapon control for various recommendations on the best way to put your paper together.</p> <p>When you have settled on the absolute best way to deal with handling your exposition question, you can start the genuine creative cycle. In this manner you ought to present your exposition to a specialist article editor to reconsider your work and make vital modifications. Firearm exposition needs to discuss the issue by and large. Unquestionably, it typically expect a pugnacious and persuading article. </p> <p>Topics for a pugnacious article is a touchy issue which is sure to produce a lot of feeling on each side. Guarantee that necessities to expect your article endeavors to show a diagram. Contentious paper enables your musings on how best to make a straightforward example. A contentious article expects you to pick a point and have a situation on it. </p> <p>Even however the Constitutional privileges of people shouldn't be disregarded, the current nonappearance of guidelines for weapon possession inside the usa ought not proceed. For example, you can uncover the current firearm control guidelines in your state or the current situation with the conversation. Every year, many people kick the bucket from weapons. One of the primary clarifications for why firearm control is important is the lift in shooting circumstances, particularly in schools. </p> <p>On the brilliant side, you typically won't have to choose a fixed point and hold fast to it. Inside the bo dy, start with the side you're contending for. Significantly, you should be very much educated about each side of the discussion, so you may adequately reproach all the contentions your theoretical rival could have. These days you sound as though you know all the surfaces of the issue. </p>

An Essay Bribery Act 2010 - Free Essay Example

à ¢Ã¢â€š ¬Ã…“While it is entirely understandable that the government wishes Parliament to direct provisions to UK companies and show a strong hand to the international community, it is equally important that it does not suffocate activity in markets where those companies come up against international competitors.à ¢Ã¢â€š ¬Ã‚  Discuss the extent to which the Bribery Act 2010 has balanced the two objectives identified by Michaelson and Berkeley in this extract. As a member country of the Organisation for Economic Co-operation and Development, the UK ratified the OECD Anti-Bribery Convention[1] and in principle agreed to meet the standards set. Despite this, the UK was unsuccessful in fulfilling its obligations and this resulted in a à ¢Ã¢â€š ¬Ã‹Å"turning pointà ¢Ã¢â€š ¬Ã¢â€ž ¢[2] whereby the Bribery Act 2010 was implemented. The Actà ¢Ã¢â€š ¬Ã¢â€ž ¢s predecessors[3] were crucial factors owing to the implementation as they were considered à ¢Ã¢â€š ¬Ã‹Å"inconsistent, anachronistic and inadequateà ¢Ã¢â€š ¬Ã¢â€ž ¢[4]. This Act codifies the law and quietens the criticism of the UK for à ¢Ã¢â€š ¬Ã‹Å"lagging behind international competitorsà ¢Ã¢â€š ¬Ã¢â€ž ¢.[5] It is noteworthy that the phrase on the lips of so many commentators is à ¢Ã¢â€š ¬Ã‹Å"level playing fieldà ¢Ã¢â€š ¬Ã¢â€ž ¢[6] which à ¢Ã¢â€š ¬Ã‹Å"works both waysà ¢Ã¢â€š ¬Ã¢â€ž ¢[7]. Thus, this essayà ¢Ã¢â€š ¬Ã¢â€ž ¢s aim is to succinctly examine the extent to which the Act has brought the UK à ¢Ã¢â€š ¬Ã‹Å"into line with international norms on anti-corruption legislationà ¢Ã¢â€š ¬Ã¢â€ž ¢[8]. However, it is also argued that the Act may be disadvantageous for UK businesses[9] as stricter obligations are imposed compared to their foreign competitors[10]. It is intended to take the two latter objectives and analyse the degree to which the Act has balanced them. There have been arguments against the à ¢Ã¢â€š ¬Ã‹Å"delayà ¢Ã¢â€š ¬Ã¢â€ž ¢ in implementation of the Act and these provide strong bases for establishing a à ¢Ã¢â€š ¬Ã‹Å"strong hand to the international communityà ¢Ã¢â€š ¬Ã¢â€ž ¢[11]. The OECDà ¢Ã¢â€š ¬Ã¢â€ž ¢s Working Group on Bribery opined that it was à ¢Ã¢â€š ¬Ã‹Å"very disappointed . . . [in] the further delayà ¢Ã¢â€š ¬Ã¢â€ž ¢; proceeding to affirm that à ¢Ã¢â€š ¬Ã‹Å"establishing a level playing field for international business . . . will help strengthen the global economic recoveryà ¢Ã¢â€š ¬Ã¢â€ž ¢[12]. The OECDà ¢Ã¢â€š ¬Ã¢â€ž ¢s dismay at the delay was clear when they claimed that they would à ¢Ã¢â€š ¬Ã‹Å"threaten to blacklist British companiesà ¢Ã¢â€š ¬Ã¢â€ž ¢ should they remain à ¢Ã¢â€š ¬Ã‹Å"under-regulatedà ¢Ã¢â€š ¬Ã¢â€ž ¢[13]. The OECD urged the United Kingdom to implement the Act à ¢Ã¢â€š ¬Ã‹Å"as a matter of high priorityà ¢Ã¢â€š ¬Ã¢â€ž ¢ whilst Transparency International claimed that the delay à ¢Ã¢â€š ¬Ã‹Å"raised serious doubts about the credibility of the governmentà ¢Ã¢â€š ¬Ã¢â€ž ¢s commitment to the Bribery Actà ¢Ã¢â€š ¬Ã¢â€ž ¢[14]. Thus, it is widely accepted that the Act was critical in bringing the UK into line with OECD member states on anti-bribery. The USA has à ¢Ã¢â€š ¬Ã‹Å"been at the forefront of prosecuting international briberyà ¢Ã¢â€š ¬Ã¢â€ž ¢[15] and thus far à ¢Ã¢â€š ¬Ã‹Å"has been [the] predominant force in setting compliance standards for international businessesà ¢Ã¢â€š ¬Ã¢â€ž ¢.[16] The FCPA[17] was regarded, until the OECD Anti-Bribery Convention, as the only à ¢Ã¢â€š ¬Ã‹Å"explicit extraterritorial anti-bribery lawà ¢Ã¢â€š ¬Ã¢â€ž ¢[18]. However, it can be seen that the UK Bribery Act has à ¢Ã¢â€š ¬Ã‹Å"raised the barà ¢Ã¢â€š ¬Ã¢â€ž ¢[19]; and in doing so has shown à ¢Ã¢â€š ¬Ã‹Å"a strong hand to the international communityà ¢Ã¢â€š ¬Ã¢â€ž ¢[20]. The government define the Act as a à ¢Ã¢â€š ¬Ã‹Å"modern and consolidated bribery lawà ¢Ã¢â€š ¬Ã¢â€ž ¢[21] that superseded the à ¢Ã¢â€š ¬Ã‹Å"current law [that was] riddled with uncertainty and in need of rationalisationà ¢Ã¢â€š ¬Ã¢â€ž ¢[22]. Despite this, it remains to be seen whether the Act will à ¢Ã¢â€š ¬Ã‹Å"provide a better framework for the successful prosecution of bribery and corruption offences in the globalised industrial economyà ¢Ã¢â€š ¬Ã¢â€ž ¢[23]. It has been shown that the preceding laws did not comprise the common law offence of bribery and were à ¢Ã¢â€š ¬Ã‹Å"outdated, unclear and lacking in scopeà ¢Ã¢â€š ¬Ã¢â€ž ¢[24]. These laws would not be capable of allowing the UK to fulfil their international obligations under the 1997 Anti-Bribery Convention[25]. Bribery is described as being à ¢Ã¢â€š ¬Ã‹Å"in its very nature insidiousà ¢Ã¢â€š ¬Ã¢â€ž ¢ that has à ¢Ã¢â€š ¬Ã‹Å"potentially devastating consequencesà ¢Ã¢â€š ¬Ã¢â€ž ¢[26]. With this in mind, many commentators illustrate the importance of the Act à ¢Ã¢â€š ¬Ã‹Å"to deal with bribery much more effectivelyà ¢Ã¢â€š ¬Ã¢â€ž ¢[27]. It is argued that the old laws were lacking in scope because of their inability to apply to overseas subsidiaries; thus, they could not achieve the standards set by the OECD[28]. Looking at the FCPA in more depth, and comparatively analysing it, allows the extent to which the Act has à ¢Ã¢â€š ¬Ã‹Å"shown a strong hand to the international communityà ¢Ã¢â€š ¬Ã¢â€ž ¢[29] to be examined. The 1906 legislation[30] did not refer to foreign public officials and the Bribery Act sought to amend this[31]. In doing so, this fulfils the standards set out by the OECD[32] regarding anti-bribery[33]. Both the FCPA and the Act forbid the bribery of foreign public officials and provide evidence to suggest that the two Acts are similar in effect. The prohibited conduct in relation to the two Acts is similar: the FCPAà ¢Ã¢â€š ¬Ã¢â€ž ¢s wording suggests that it is irrelevant whether the bribe is à ¢Ã¢â€š ¬Ã‹Å"voluntarily offered or was suggested or demanded by a n officialà ¢Ã¢â€š ¬Ã¢â€ž ¢[34]. The Bribery Act parallels the FCPA[35] by including à ¢Ã¢â€š ¬Ã‹Å"an advantage [that] benefits the official at his request or with his à ¢Ã¢â€š ¬Ã‹Å"acquiescenceà ¢Ã¢â€š ¬Ã¢â€ž ¢[36]. Despite the fact that there are discrepancies in the language, there is evidence to suggest that the UK has succeeded in its attempt to move into line with à ¢Ã¢â€š ¬Ã‹Å"international norms on anti-corruption legislationà ¢Ã¢â€š ¬Ã¢â€ž ¢[37]. Further to this, it is argued that because the definition is so broad, in both Acts, it could cover those who do not appear to be foreign public officials. The à ¢Ã¢â€š ¬Ã‹Å"stand-alone offenceà ¢Ã¢â€š ¬Ã¢â€ž ¢ per section 6 puts the UK legal framework in general congruence with the OECD Anti-Bribery Convention as well as the US FCPAà ¢Ã¢â€š ¬Ã¢â€ž ¢[38]. Given that the UK has been under scrutiny to bring itself into line with anti-bribery norms, there has been strong criticism against the Act as it is extremely onerous on UK businesses; thus, stifling their opportunity in the international community.[39] It has been argued that the Act is à ¢Ã¢â€š ¬Ã‹Å"more restrictive than [the FCPA]à ¢Ã¢â€š ¬Ã¢â€ž ¢[40] and à ¢Ã¢â€š ¬Ã‹Å"provides the UK with some of the most draconian and far-reaching anti-corruption legislation in the worldà ¢Ã¢â€š ¬Ã¢â€ž ¢[41]. In a report by Parliament it was clarified that this would à ¢Ã¢â€š ¬Ã‹Å"prejudice the international competitiveness of UK businessesà ¢Ã¢â€š ¬Ã¢â€ž ¢[42]. The importance of this was exemplified by Frost when he commented: à ¢Ã¢â€š ¬Ã‹Å"in a cut and thrust world of exporting what we donà ¢Ã¢â€š ¬Ã¢â€ž ¢t want is the British playing with a straight bat and we find some that are notà ¢Ã¢â€š ¬Ã¢â€ž ¢[43]. With the above in mind, it is claimed that the à ¢Ã¢â€š ¬Ã‹Å"most significant sea-changeà ¢Ã¢â€š ¬Ã¢â€ž ¢[44] is that of a à ¢Ã¢â€š ¬Ã‹Å"corporationà ¢Ã¢â€š ¬Ã¢â€ž ¢s failure to prevent briberyà ¢Ã¢â€š ¬Ã¢â€ž ¢[45]. This section is notab le for its prohibition of a wider scope of conduct as opposed to its FCPA counterpart[46]. However, it must be noted that although the FCPA does not incorporate commercial bribery, it may à ¢Ã¢â€š ¬Ã‹Å"fill the gapà ¢Ã¢â€š ¬Ã¢â€ž ¢[47] by bringing these charges under the Travel Act[48] for example. Nevertheless, it is argued that à ¢Ã¢â€š ¬Ã‹Å"one would be forgiven for thinking that the legislation would permanently cripple the ability of UK companies to transact business overseasà ¢Ã¢â€š ¬Ã¢â€ž ¢[49]. Section 7 incorporates a strict liability offence whereby a corporation is held vicariously liable for the paying of a bribe by someone carrying out services on that corporationà ¢Ã¢â€š ¬Ã¢â€ž ¢s behalf. This à ¢Ã¢â€š ¬Ã‹Å"someoneà ¢Ã¢â€š ¬Ã¢â€ž ¢ is referred to as the à ¢Ã¢â€š ¬Ã‹Å"associated personà ¢Ã¢â€š ¬Ã¢â€ž ¢. Moreover, prosecutors would not be required to prove criminal intent by the corporation à ¢Ã¢â€š ¬Ã¢â‚¬Å" they would only need to show that the à ¢Ã¢â€š ¬Ã‹Å" associated personà ¢Ã¢â€š ¬Ã¢â€ž ¢ engaged in the bribe[50]. It could be argued, however, that this does not impose more onerous requirements compared to the UKà ¢Ã¢â€š ¬Ã¢â€ž ¢s foreign counterparts. The reason for this is because despite the fact that the FCPA does not incorporate a stand-alone corporate offence, legal liability would attach to a corporation (caused by an employee or agent) by other means. Responsibility on behalf of the corporation can be established through the common law principle of à ¢Ã¢â€š ¬Ã‹Å"respondeat superiorà ¢Ã¢â€š ¬Ã¢â€ž ¢.[51] Although the corporate offence may impose more severe requirements on businesses, and subsequently à ¢Ã¢â€š ¬Ã‹Å"suffocating activityà ¢Ã¢â€š ¬Ã¢â€ž ¢[52], there is a defence where a commercial organisation can put in place à ¢Ã¢â€š ¬Ã‹Å"adequate proceduresà ¢Ã¢â€š ¬Ã¢â€ž ¢[53]. This would reduce liability on the company if they can prove that they have à ¢Ã¢â€š ¬Ã‹Å"strong, up-to-date and effective anti-bribery po liciesà ¢Ã¢â€š ¬Ã¢â€ž ¢[54]. It is clear that the burden of proof is on the commercial organisation to show that relevant procedures are in place. Notably, the defence reduces liability of the commercial organisation because à ¢Ã¢â€š ¬Ã‹Å"the principal concern of the Act is to direct the criminal law [at them]à ¢Ã¢â€š ¬Ã‚ ¦ to ensure that active bribery is not committed on their behalfà ¢Ã¢â€š ¬Ã¢â€ž ¢[55]. The adequate procedures guidance[56] produced six principles with comments and explanations; thus, providing evidence that there has been an attempt to balance the two objectives. It is important to state that it remains with the courts to decide if the corporation has adequately put in place procedures to prevent the bribery of one of their employees or agents[57]. Thus, the company can discharge the burden if they implement the Ministry of Justiceà ¢Ã¢â€š ¬Ã¢â€ž ¢s guidance as well as implementing their own procedures re the six principles. It is argued, however, that à ¢ â‚ ¬Ã‹Å"where bribery has occurred, that self-evidently any procedures which were designed to prevent bribery must have been inadequateà ¢Ã¢â€š ¬Ã¢â€ž ¢[58]. It is clear that the Act may go too far in terms of penalties imposed on the individual or corporation. Although à ¢Ã¢â€š ¬Ã‹Å"strict penalties will make companies take notice and tighten controlsà ¢Ã¢â€š ¬Ã¢â€ž ¢[59] does it go too far? Does the Act put more onerous requirements on these UK businesses so that they are losing out compared to their foreign competitors? Under the Act, an individual may be given an unlimited fine or imprisoned for 10 years[60]. A corporation may receive an unlimited fine pursuant to section 7 of the Act. It is argued that these à ¢Ã¢â€š ¬Ã‹Å"stifferà ¢Ã¢â€š ¬Ã¢â€ž ¢[61] penalties are à ¢Ã¢â€š ¬Ã‹Å"draconianà ¢Ã¢â€š ¬Ã¢â€ž ¢[62]. The penalties under the Act à ¢Ã¢â€š ¬Ã‹Å"raised significantlyà ¢Ã¢â€š ¬Ã¢â€ž ¢[63] compared to the FCPA; thus, commercial organisations à ¢Ã¢â€š ¬Ã‹Å"may need to review compliance proceduresà ¢Ã¢â€š ¬Ã¢â€ž ¢ that allow them to conform with the scope of the FCPA[64]. It is widely commented that corporate hospitality could prove problematic for commercial organisations. The UKà ¢Ã¢â€š ¬Ã¢â€ž ¢s counterpart, the FCPA, incorporates a defence for a foreign official regarding à ¢Ã¢â€š ¬Ã‹Å"promotion, demonstration or explanation of productsà ¢Ã¢â€š ¬Ã¢â€ž ¢[65]. However, it is evident that the UK Act does not offer such a defence and could prove to be problematic for businesses. Furthermore, it could provide evidence of legislation which is far too onerous[66]. It is clear that the simplistic language of the Act, coupled with the fact that there is no need for the à ¢Ã¢â€š ¬Ã‹Å"offer, promise or paymentà ¢Ã¢â€š ¬Ã¢â€ž ¢ to be made corruptly, could render à ¢Ã¢â€š ¬Ã‹Å"all promotional gifts or hospitality expensesà ¢Ã¢â€š ¬Ã¢â€ž ¢[67] criminal. If corporate hospitality is to be criminal then it depends how à ¢Ã¢â€š ¬Ã‹Å"lavishà ¢Ã¢â€š ¬Ã¢â€ž ¢[68] it is. Lord Tunnicliffe stated that it would be legal to use corporate hospitality for à ¢Ã¢â€š ¬Ã‹Å"legitimate commercial purposesà ¢Ã¢â€š ¬Ã¢â€ž ¢[69]. Nevertheless, he stated that it could be illegal if it was à ¢Ã¢â€š ¬Ã‹Å"[too] lavish [a] hospitalityà ¢Ã¢â€š ¬Ã¢â€ž ¢[70]. It is continuously stated that it is à ¢Ã¢â€š ¬Ã‹Å"unclear as to what extent corporate hospitality falls within the Actà ¢Ã¢â€š ¬Ã¢â€ž ¢, and is subsequently à ¢Ã¢â€š ¬Ã‹Å"likely to trouble . . . businessesà ¢Ã¢â€š ¬Ã¢â€ž ¢[71]. Thus, arguably, the Act has unconvincingly balanced the two objectives in this sense. Distinguishing between what is à ¢Ã¢â€š ¬Ã‹Å"legitimate and illegitimate could prove problematicà ¢Ã¢â€š ¬Ã¢â€ž ¢[72]. This argument was strengthened when the English Law Commission à ¢Ã¢â€š ¬Ã‹Å"struggled valiantlyà ¢Ã¢â€š ¬Ã¢â€ž ¢[73] to determine what forms of corporate hospitality would be acceptable. The prosecution of the company for corporate hospitality remains in the hands of the courts and depends on the à ¢Ã¢â€š ¬Ã‹Å"slippery and subjective conceptà ¢Ã¢â€š ¬Ã¢â€ž ¢ of intention[74]. It would be inevitably beneficial for businesses if they reflected on their internal corporate hospitality policies and applied firm guidelines on the matter[75]. The criticism is extensive enough that some are alleging that à ¢Ã¢â€š ¬Ã‹Å"Christmas gifts are likely to be considered bribesà ¢Ã¢â€š ¬Ã¢â€ž ¢[76]. There has unquestionably been an attempt by Parliament to bring the UK into line with other OECD member states regarding anti-bribery. Nevertheless, there exists evidence to suggest that the Act has given rise to too onerous requirements on UK businesses. The anachronistic legislation was repealed by the Act and was undoubtedly needed. The delay in implementation was significant in emphasising the importance of this much needed law; however, it is clear that the Act has struggled to balance the two former objectives. There are sections in the A ct, namely section 6 for example, which brings the UK à ¢Ã¢â€š ¬Ã‹Å"into line with international norms on anti-corruption legislationà ¢Ã¢â€š ¬Ã¢â€ž ¢[77] and subsequently goes further than the FCPA golden standard. Nonetheless, the failure to prevent bribery on behalf of a commercial organisation is regarded as far too à ¢Ã¢â€š ¬Ã‹Å"draconianà ¢Ã¢â€š ¬Ã¢â€ž ¢, the penalties are excessive and companies could be convicted of bribery for sending à ¢Ã¢â€š ¬Ã‹Å"Christmas giftsà ¢Ã¢â€š ¬Ã¢â€ž ¢. Bibliography Legislation and Conventions Bribery Act 2010 Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. Foreign Corrupt Practices Act 1977 (United States) Prevention of Corruption Act 1906 Prevention of Corruption Act 1916 Public Bodies Corrupt Practices Act 1889 Travel Act 1952. Articles AaronBerg, D and Higgins, N, The Bribery Act 2010: All Bark and No Bite.? [2010] Arch. Rev. 2010, 5, 6-9. Addleshaw Goddard, à ¢Ã¢â€š ¬Ã‹Å"Corporate Hospitality and the Bribery Act 2010: Will Your Strawberries and Cream be Followed by Porridge?à ¢Ã¢â€š ¬Ã¢â€ž ¢ (August 2010) https://www.addleshawgoddard.com/asset_store/document/corporate_hospitality_and_the_bribery_act_2010_112048.pdf accessed 29 January 2013. Cannon, L, Rene, A, Corsi, A and Smith, R, à ¢Ã¢â€š ¬Ã‹Å"Bribery Act 2010: A New Era for UK Enforcement of Bribery and Corruption Offences?à ¢Ã¢â€š ¬Ã¢â€ž ¢ Fullbright Alert (9 April 2010)https://www.fulbright.com/index.cfm?DETAIL=yesFUSEACTION=publications.detailNEWPAGE=0PUB_ID=4422SITE_ID=461pf=y accessed 1 March 2013. Cogman, S, à ¢Ã¢â€š ¬Ã‹Å"Bye-bye backhandersà ¢Ã¢â€š ¬Ã¢â€ž ¢ Euro. Law. 2011, 106, 44-45. Cropp, N, à ¢Ã¢â€š ¬Ã‹Å"The Bribery Act 2010: Part 4: a comparison with the Foreign Corrupt Practices Act: nuance v nousà ¢Ã¢â€š ¬Ã¢â€ž ¢ [2011] Crim. L.R. 2011, 2, 122-141. Financial Markets Law Committee, à ¢Ã¢â€š ¬Ã‹Å"Analysis of uncertainty around the Bribery Act 2010 Ministry of Justice Consultation on guidance about commercial organisations preventing briberyà ¢Ã¢â€š ¬Ã¢â€ž ¢ (November 2010) Issue 160. Fine, M, à ¢Ã¢â€š ¬Ã‹Å"Coordinating UK Bribery Act FCPA Complianceà ¢Ã¢â€š ¬Ã¢â€ž ¢ Inspiring Principled Performance (April 2011). Kocoras J, The Bribery Act 2010: raising the bar above the US Foreign Corrupt Practices Act [2010] Comp. Law. 2010, 31(11), 362-369. Leigh, D, à ¢Ã¢â€š ¬Ã‹Å"British firms face bribery blacklist, warns corruption watchdogà ¢Ã¢â€š ¬Ã¢â€ž ¢ The Guardian (31 January 2011). Michaelson, J and Berkeley, A, à ¢Ã¢â€š ¬Ã‹Å"Positive Stepsà ¢Ã¢â€š ¬Ã¢â€ž ¢ [2009] 159 N.L.J 819. Ministry of Justice, à ¢Ã¢â€š ¬Ã‹Å"THE BRIBERY ACT 2010: Guidance about procedures which relevant commercial organisations can put into place to prevent persons associated with them from bribing (section 9 of the Bribery Act 2010)à ¢Ã¢â€š ¬Ã¢â€ž ¢ https://www.justice.gov.uk/downloads/legislation/bribery-act-2010-guidance .pdf accessed 25 February 2013. Peith, M, à ¢Ã¢â€š ¬Ã‹Å"UK: Chair Of OECD Working Group On Bribery Concerned Over Delay Of New Bribery Actà ¢Ã¢â€š ¬Ã¢â€ž ¢ (1 February 2011) https://www.oecd.org/newsroom/ukchairofoecdworkinggrouponbriberyconcernedoverdelayofnewbriberyact.htm accessed 4 March 2013. Russell, J, à ¢Ã¢â€š ¬Ã‹Å"What is the Bribery Act?à ¢Ã¢â€š ¬Ã¢â€ž ¢ The Daily Telegraph (London, 31 March 2011). Searcey, D, à ¢Ã¢â€š ¬Ã‹Å"On Second Thought . . . U.K. Bribery Act Delayedà ¢Ã¢â€š ¬Ã¢â€ž ¢ The Wall Street Journal (31 January 2011)à ¢Ã¢â€š ¬Ã¢â€ž ¢ https://blogs.wsj.com/law/2011/01/31/on-second-thought-uk-bribery-act-delayed/ accessed 21 February 2013. Sheikh, S, The Bribery Act 2010: commercial organisations beware! I.C.C.L.R. 2011, 22(1), 1-16. Shoosmiths, à ¢Ã¢â€š ¬Ã‹Å"A comparison between UK Bribery Act and the FCPAà ¢Ã¢â€š ¬Ã¢â€ž ¢ (9 May 2012) https://www.shoosmiths.co.uk/client-resources/legal-updates/A-comparison-between-UK-Bribery-Act-and-th e-FCPA-1543.aspx accessed 10 February 2013. Sullivan, G, à ¢Ã¢â€š ¬Ã‹Å"Proscribing Corruption à ¢Ã¢â€š ¬Ã¢â‚¬Å" Some Comments on the Law Commission Reportà ¢Ã¢â€š ¬Ã¢â€ž ¢ 1998 Crim. L.R. 547. , à ¢Ã¢â€š ¬Ã‹Å"The Bribery Act 2010: Part 1: an overviewà ¢Ã¢â€š ¬Ã¢â€ž ¢ Crim. L.R. 2011, 2, 87-100. Transparency International, à ¢Ã¢â€š ¬Ã‹Å"Bribery Act: Myth and Realityà ¢Ã¢â€š ¬Ã¢â€ž ¢ (1 February 2011) https://www.bond.org.uk/data/files/TI-UK_Briefing_UKBribery_Act.pdf accessed 2 March 2013. Tyler, R, à ¢Ã¢â€š ¬Ã‹Å"Bona Fide Corporate Freebies à ¢Ã¢â€š ¬Ã…“Must Survive Bribery Actà ¢Ã¢â€š ¬Ã‚ Ãƒ ¢Ã¢â€š ¬Ã¢â€ž ¢ The Daily Telegraph (8 Novemeber 2010). , à ¢Ã¢â€š ¬Ã‹Å"Christmas gifts could be illegal under Bribery Act, says PwCà ¢Ã¢â€š ¬Ã¢â€ž ¢ The Daily Telegraph (22 December 2010) https://www.telegraph.co.uk/finance/yourbusiness/8217356/Christmas-gifts-could-be-illegal-under-Bribery-Act-says-PwC.html accessed 14 March 2013. Weinstein, M, Meyer, R, Clark , J, The UK Bribery Act vs. the U.S. FCPA The Ethisphere (22 April 2011) https://anticorruption.ethisphere.com/the-uk-bribery-act-vs-the-u-s-fcpa/ accessed 10 March 2013. Working Group on Bribery, à ¢Ã¢â€š ¬Ã‹Å"UK: Chair Of OECD Working Group On Bribery Concerned Over Delay Of New Bribery Actà ¢Ã¢â€š ¬Ã‹Å", (1 February 2011) https://www.oecd.org/newsroom/ukchairofoecdworkinggrouponbriberyconcernedoverdelayofnewbriberyact.htm accessed 21 January 2013 Yeoh, P, à ¢Ã¢â€š ¬Ã‹Å"Bribery Act 2010: implications for regulated firmsà ¢Ã¢â€š ¬Ã¢â€ž ¢ J.F.R. C. 2012, 20(3), 264-277. , The UK Bribery Act 2010: Contents and Implications [2012] JFC 37, 37. Reports and Guidance Law Commission, à ¢Ã¢â€š ¬Ã‹Å"Reforming Bribery (The Stationary Office, 2008), Law Com No 313, HC Paper No 928. Law Commission, Law Com. No 248 (1998) [5.75 à ¢Ã¢â€š ¬Ã¢â‚¬Å" 5.82]. Ministry of Justice, Guidance about procedures which relevant commercial organisations can put into place to prevent persons associated with them from bribing (section 9 of the Bribery Act 2010) (Ministry of Justice, 2010), CP11/10. Transparency International, à ¢Ã¢â€š ¬Ã‹Å"Bribery Act Adequate Proceduresà ¢Ã¢â€š ¬Ã¢â€ž ¢ (July 2010). 1 [1] Officially known as: Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. [2] Yeoh, P, The UK Bribery Act 2010: Contents and Implications [2012] JFC 37, 37. [3] Public Bodies Corrupt Practices Act 1889; Prevention of Corruption Act 1906; Prevention of Corruption Act 1916. [4] AaronBerg, D and Higgins, N, The Bribery Act 2010: All Bark and No Bite.? [2010] Arch. Rev. 2010, 5, 6-9. [5] Michaelson, J and Berkeley, A, à ¢Ã¢â€š ¬Ã‹Å"Positive Stepsà ¢Ã¢â€š ¬Ã¢â€ž ¢ [2009] 159 N.L.J 819. [6] Ibid; See also, Working Group on Bribery, à ¢Ã¢â€š ¬Ã‹Å"UK: Chair Of OECD Working Group On Bribery Concerned Over Delay Of New Bribery Actà ¢Ã¢â€š ¬Ã‹Å", (1 February 2011) https://www.oecd.org/newsroom/ukchairofoecdworkinggrouponbriberyconcernedoverdelayofnewbriberyact.htm accessed 21 January 2013; finally see, Transparency International, à ¢Ã¢â€š ¬Ã‹Å"Bribery Act: Myth and Realityà ¢Ã¢â€š ¬Ã¢â€ž ¢ (1 February 2011) https://w ww.bond.org.uk/data/files/TI-UK_Briefing_UKBribery_Act.pdf accessed 2 March 2013. [7] Michaelson, J and Berkeley, A ,(n 3). [8] Russell, J, à ¢Ã¢â€š ¬Ã‹Å"What is the Bribery Act?à ¢Ã¢â€š ¬Ã¢â€ž ¢ The Daily Telegraph (London, 31 March 2011). [9] David Frost in à ¢Ã¢â€š ¬Ã‹Å"Tyler, R, à ¢Ã¢â€š ¬Ã‹Å"Bona Fide Corporate Freebies à ¢Ã¢â€š ¬Ã…“Must Survive Bribery Actà ¢Ã¢â€š ¬Ã‚ Ãƒ ¢Ã¢â€š ¬Ã¢â€ž ¢ The Daily Telegraph (8 Novemeber 2010)à ¢Ã¢â€š ¬Ã¢â€ž ¢. [10] Michaelson, J and Berkeley, (n 3). [11] Ibid. [12] Peith, M, à ¢Ã¢â€š ¬Ã‹Å"UK: Chair Of OECD Working Group On Bribery Concerned Over Delay Of New Bribery Actà ¢Ã¢â€š ¬Ã¢â€ž ¢ (1 February 2011) https://www.oecd.org/newsroom/ukchairofoecdworkinggrouponbriberyconcernedoverdelayofnewbriberyact.htm accessed 4 March 2013. [13] Peith, M in à ¢Ã¢â€š ¬Ã‹Å"Leigh, D, à ¢Ã¢â€š ¬Ã‹Å"British firms face bribery blacklist, warns corruption watchdogà ¢Ã¢â€š ¬Ã¢â€ž ¢ The Guardian (31 January 2011)à ¢Ã¢â€š ¬Ã¢â€ž ¢. [14] Chandrashekhar, K in à ¢Ã¢â€š ¬Ã‹Å"Searcey, D, à ¢Ã¢â€š ¬Ã‹Å"On Second Thought . . . U.K. Bribery Act Delayedà ¢Ã¢â€š ¬Ã¢â€ž ¢ The Wall Street Journal (31 January 2011)à ¢Ã¢â€š ¬Ã¢â€ž ¢ https://blogs.wsj.com/law/2011/01/31/on-second-thought-uk-bribery-act-delayed/ accessed 21 February 2013. [15] Cannon, L, Rene, A, Corsi, A and Smith, R, à ¢Ã¢â€š ¬Ã‹Å"Bribery Act 2010: A New Era for UK Enforcement of Bribery and Corruption Offences?à ¢Ã¢â€š ¬Ã¢â€ž ¢ Fullbright Alert (9 April 2010) https://www.fulbright.com/index.cfm?DETAIL=yesFUSEACTION=publications.detailNEWPAGE=0PUB_ID=4422SITE_ID=461pf=y accessed 1 March 2013. [16] Kocoras J, The Bribery Act 2010: raising the bar above the US Foreign Corrupt Practices Act [2010] Comp. Law. 2010, 31(11), 362-369. [17] Foreign Corrupt Practices Act 1977. [18] Cropp, N, à ¢Ã¢â€š ¬Ã‹Å"The Bribery Act 2010: Part 4: a comparison with the Foreign Corrupt Practices Act: nuance v nousà ¢Ã¢â€š ¬Ã¢â€ž ¢ [2011] Crim. L.R. 2011, 2 , 122-141. [19] Kocoras, J, (n 14). [20] Michaelson, J and Berkeley, (n 3). [21] Progress of the Bill, à ¢Ã¢â€š ¬Ã‹Å"Bribery Act 2009-10à ¢Ã¢â€š ¬Ã¢â€ž ¢, https://services.parliament.uk/bills/2009-10/briberyhl.html accessed 12 March 2013. [22] Law Commission, à ¢Ã¢â€š ¬Ã‹Å"Reforming Bribery (The Stationary Office, 2008), Law Com No 313, HC Paper No 928. [23] Cannon, L, Rene, A, Corsi, A and Smith, R, (n 15). [24] Yeoh, P, (n 2). [25] Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. [26] Jack Straw, The Ministry of Justice: Bribery Draft Legislation, 2009 Cm 7570, p3. [27] Ministry of Justice, à ¢Ã¢â€š ¬Ã‹Å"Government Welcomes New Bribery Law Recommendationsà ¢Ã¢â€š ¬Ã¢â€ž ¢ (20 November 2008). [28] Yeoh, P, (n 2). [29] Michaelson, J and Berkeley, (n 3). [30] Prevention of Corruption Act 1906. [31] The Bribery Act 2010, s6. [32] Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. [33] Sheikh, S, The Bribery Act 2010: commercial organisations beware! I.C.C.L.R. 2011, 22(1), 1-16. [34] Fine, M, à ¢Ã¢â€š ¬Ã‹Å"Coordinating UK Bribery Act FCPA Complianceà ¢Ã¢â€š ¬Ã¢â€ž ¢ Inspiring Principled Performance (April 2011). [35] Cropp, N, (n 18). [36] Fine, M, (n 33). [37] Russell, J, (n 8). [38] Yeoh, P, (n 2). [39] Michaelson, J and Berkeley, (n 3). [40] Weinstein, M, Meyer, R, Clark, J, The UK Bribery Act vs. the U.S. FCPA The Ethisphere (22 April 2011) https://anticorruption.ethisphere.com/the-uk-bribery-act-vs-the-u-s-fcpa/ accessed 10 March 2013. [41] AaronBerg, D and Higgins, N, (n 4). [42] Joint Parliamentary Debate in à ¢Ã¢â€š ¬Ã‹Å"Michaelson, J and Berkeley, A, à ¢Ã¢â€š ¬Ã‹Å"Positive Stepsà ¢Ã¢â€š ¬Ã¢â€ž ¢ [2009] 159 N.L.J 819à ¢Ã¢â€š ¬Ã¢â€ž ¢. [43] David Frost in à ¢Ã¢â€š ¬Ã‹Å"Tyler, R, à ¢Ã¢â€š ¬Ã‹Å"Bona Fide Corporate Freebies à ¢Ã¢â€š ¬Ã…“Must Survive Bribery Actà ¢Ã¢â€š ¬Ã‚ Ãƒ ¢Ã¢â€š ¬Ã¢â€ž ¢ The Daily Telegraph (8 Novemeber 2010)à ¢Ã¢â€š ¬Ã¢â€ž ¢. [44] Hoar, C, à ¢Ã¢â€š ¬Ã‹Å"Hard Graftà ¢Ã¢â€š ¬Ã¢â€ž ¢ C.N. 2010, May/Jun, 2-3. [45] Bribery Act 2010, s7. [46] Weinstein, M, Meyer, R, Clark, J, (n 40). [47] Ibid. [48] Travel Act, 18 U.S.C 1952. [49] Cogman, S, à ¢Ã¢â€š ¬Ã‹Å"Bye-bye backhandersà ¢Ã¢â€š ¬Ã¢â€ž ¢ Euro. Law. 2011, 106, 44-45. [50] Fine, M, (n 33). [51] Ibid. [52] Michaelson, J and Berkeley, (n 3). [53] Ministry of Justice, Guidance about procedures which relevant commercial organisations can put into place to prevent persons associated with them from bribing (section 9 of the Bribery Act 2010) (Ministry of Justice, 2010), CP11/10, https://www.justice.gov.uk/legislation/bribery accessed 12 March 2013. [54] Transparency International, à ¢Ã¢â€š ¬Ã‹Å"Bribery Act Adequate Proceduresà ¢Ã¢â€š ¬Ã¢â€ž ¢ (July 2010). [55] Sheikh, S, (n 32). [56] Ministry of Justice, à ¢Ã¢â€š ¬Ã‹Å"THE BRIBERY ACT 20 10: Guidance about procedures which relevant commercial organisations can put into place to prevent persons associated with them from bribing (section 9 of the Bribery Act 2010)à ¢Ã¢â€š ¬Ã¢â€ž ¢ https://www.justice.gov.uk/downloads/legislation/bribery-act-2010-guidance.pdf accessed 25 February 2013. [57] Sheikh, S, (n 32). [58] AaronBerg, D and Higgins, N, (n 4). [59] Michaelson, J and Berkeley, (n 3). [60] Bribery Act 2010, s 1, 2 and 6. [61] Yeoh, P, à ¢Ã¢â€š ¬Ã‹Å"Bribery Act 2010: implications for regulated firmsà ¢Ã¢â€š ¬Ã¢â€ž ¢ J.F.R. C. 2012, 20(3), 264-277. [62] Hoar, C, (n 45). [63] Transparency International, à ¢Ã¢â€š ¬Ã‹Å"Bribery Act Adequate Proceduresà ¢Ã¢â€š ¬Ã¢â€ž ¢ (July 2010). [64] Yeoh, P, (n 62). [65] Weinstein, M, Meyer, R, Clark, J, (n 41). [66] Ibid. [67] Sullivan, G, à ¢Ã¢â€š ¬Ã‹Å"The Bribery Act 2010: Part 1: an overviewà ¢Ã¢â€š ¬Ã¢â€ž ¢ Crim. L.R. 2011, 2, 87-100. [68] Shoosmiths, à ¢Ã¢â€š ¬Ã‹Å"A comparison betwee n UK Bribery Act and the FCPAà ¢Ã¢â€š ¬Ã¢â€ž ¢ (9 May 2012) https://www.shoosmiths.co.uk/client-resources/legal-updates/A-comparison-between-UK-Bribery-Act-and-the-FCPA-1543.aspx accessed 10 February 2013. [69] Lord Tunnicliffeà ¢Ã¢â€š ¬Ã¢â€ž ¢s letter to Lord Henley https://www.docstoc.com/docs/71131033/Lord-Tunnicliffes-letter-on-corporate-hospitalityDraft-letter- accessed 14 March 2013. [70] Ibid. [71] AaronBerg, D and Higgins, N (n 4). [72] Kocoras J, (n 16). [73] Law Commission, Law Com. No 248 (1998) [5.75 à ¢Ã¢â€š ¬Ã¢â‚¬Å" 5.82]; see also Sullivan, G, à ¢Ã¢â€š ¬Ã‹Å"Proscribing Corruption à ¢Ã¢â€š ¬Ã¢â‚¬Å" Some Comments on the Law Commission Reportà ¢Ã¢â€š ¬Ã¢â€ž ¢ 1998 Crim. L.R. 547. [74] Financial Markets Law Committee, à ¢Ã¢â€š ¬Ã‹Å"Analysis of uncertainty around the Bribery Act 2010 Ministry of Justice Consultation on guidance about commercial organisations preventing briberyà ¢Ã¢â€š ¬Ã¢â€ž ¢ (November 2010) Issue 160. [75] Addleshaw Goddard , à ¢Ã¢â€š ¬Ã‹Å"Corporate Hospitality and the Bribery Act 2010: Will Your Strawberries and Cream be Followed by Porridge?à ¢Ã¢â€š ¬Ã¢â€ž ¢ (August 2010) https://www.addleshawgoddard.com/asset_store/document/corporate_hospitality_and_the_bribery_act_2010_112048.pdf accessed 29 January 2013. [76] Tyler, R, à ¢Ã¢â€š ¬Ã‹Å"Christmas gifts could be illegal under Bribery Act, says PwCà ¢Ã¢â€š ¬Ã¢â€ž ¢ The Daily Telegraph (22 December 2010) https://www.telegraph.co.uk/finance/yourbusiness/8217356/Christmas-gifts-could-be-illegal-under-Bribery-Act-says-PwC.html accessed 14 March 2013. [77] Russell, J, à ¢Ã¢â€š ¬Ã‹Å"What is the Bribery Act?à ¢Ã¢â€š ¬Ã¢â€ž ¢ The Daily Telegraph (London, 31 March 2011).