Aerospace and defence companies, foreign intermediaries and anti-corruption legislation are back in the spotlight. On December 6th, Rolls Royce Holdings plc, the world’s second-largest manufacturer of aircraft engines, announced that it had passed information to the UK Serious Fraud Office (SFO) relating to concerns about bribery and corruption. Rolls Royce stated that its disclosure may lead to the prosecution of individuals and the company itself.

The allegations relate to past conduct (therefore likely not covered by the Bribery Act 2010) involving intermediaries in China, Indonesia and elsewhere and were brought to the attention of the SFO by a whistleblower earlier this year. At the request of the SFO, Rolls Royce conducted an internal investigation with the assistance of an external law firm and has now passed on areas of concern, identified by the investigation, to the SFO.