Recent reports in the media suggest that communications provider O2 is under investigation by the SFO for potential breaches of the Bribery Act. Unsurprisingly, neither the SFO nor O2 have made any comments in relation to these media reports.

While little detail is available during the early stages of an investigation of this nature, this has not prevented media speculation about what it concerns. It is believed to relate to alleged abuse of O2’s UK incentive scheme, which rewarded employees with a bonus based on customer growth. The Telegraph, which first reported the story, revealed that their sources informed them that the investigation concerned former O2 executives involved with the payment of kickbacks with custome...

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