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Qualifications of partners
Unusual or unexplained payments (esp cash)
High commission rates
Lack of transparency
Public Bodies Corrupt Practices Act 1889: bribery of a public official created a criminal offence
Specifically, the Act prohibits a person covered by the Act, whether by himself, or in conjunction with any other person, from corruptly soliciting or receiving, or agreeing to receive, for himself, or any other person, any gift, loan, fee, reward or advantage whatever as an inducement to, or reward for, doing or forbearing to do anything in respect of any matter or transaction whatsoever, actual or proposed, in which the public body is concerned. A person may also not corruptly promise, or offer, any gift, loan, fee, reward, or advantage whatsoever, to any person, whether for the benefit of that person, or of another , as an inducement to or reward for doing or forbearing to do anything in respect of any matter or transaction whatsoever, actual or proposed; in which the public body is concerned.person
Prevention of Corruption Act 1906:
This Act deals with the corrupt transactions of agents. Agents are prohibited from corruptly accepting or obtaining, or agreeing to accept or attempting to obtain, from any person, for themselves, or for any other person, any gift or consideration as an inducement or reward for doing or forbearing to do any act, or for showing or forbearing to show favour or disfavour to any person, in relation to his principal's affairs or business.
2.7 It is an offence for any person corruptly to give or agree to give, or offer, any gift or consideration to any agent as an inducement or reward for doing or forbearing to do, or for having done or forborne to do, any act, or for showing or forbearing to show favour, or disfavour, to any person in relation to his principal's affairs or business.
2.8 It is also an offence for any person knowingly to give to any agent, or for any agent knowingly to use, with intent to deceive his principal, any receipt, account or other document, in respect of which his principal is interested, and which contains any statement which is false or erroneous or defective in any material particular, and which to his knowledge is intended to mislead the principal.
Prevention of Corruption Act 1916
This Act creates a presumption of corruption in certain cases prosecuted under the 1889 and 1906 Acts. If it is proved that any money, gift or other consideration has been paid, or given to or received by a person in the employment of Her Majesty, or any Government Department or public body, by or from a person, or agent of a person, holding or seeking to obtain a contract from Her Majesty, or any Government Department or public body, the money, gift, or consideration shall be deemed to have been paid or given and received corruptly as such inducement or reward as is mentioned in the Act in question, unless the contrary is proved.