CORRUPTION IN THE PRIVATE SECTOR: THE CONVERGENCE OF LEGAL SYSTEMS. Salomeja Zaksaite*

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1 CORRUPTION IN THE PRIVATE SECTOR: THE CONVERGENCE OF LEGAL SYSTEMS Salomeja Zaksaite* Vilnius University, Lithuania Abstract. Corruption in the private sector is an interdisciplinary issue covering international law, criminal law, civil law and disciplinary law. One of the key difficulties is the broadness of the concept of corruption in the private sector. The broad definition actually fits all branches of the aforesaid laws. Therefore, one must draw some guiding (yet, simplified and relative) criteria according to which the convergence of legal systems could be possible. One of the criteria is harm, damage or dangerousness. Another criteria come from ECHR case-law: the nature of offence and the nature of sanction entrenched in a certain legal system. Considering such criteria, it can be decided what legal system(s) should be applied to tackle corruption in the private sector. Key words: Corruption, private sector, damage, ultima ratio INTRODUCTION As it is stated in the explanatory report on the Criminal Law Convention on Corruption, countries of Western, Central and Eastern Europe have been literally shaken by huge corruption scandals and some consider that corruption now represents one of the most serious threats to the stability of democratic institutions and the functioning of the market economy. 1 The aforementioned words emphasize the threat of corruption and (further) need to criminalize it. However, such need should be grounded on some clear principles. In other way the principles of legal certainty and ultima ratio might be violated. In order to cover the topic, the following aim has been set up: to identify the possible guidelines for convergence between legal systems in the context of corruption in the private sector. To implement the aim, the structure of the paper is divided into three parts: 1) the concept of corruption in the private sector; 2) the problems of criminalization of corruption in the private sector; 3) convergence of legal systems in case of corruption in private sector. * Salomeja Zaksaite earned a master s degree and a PhD in law (thesis Cheating in Sports: Prevalence and Prevention Problems, defended in 2012) from the Vilnius University. From 2006, she has been working at the Law Institute of Lithuania as a research fellow at the Criminal Justice Department. From 2013, she works at Mykolas Romeris University on the project Postdoctoral Fellowship Implementation in Lithuania (The manager of the postdoctoral project is the Research Council of Lithuania). Salomeja Zaksaite has written a large number of scientific and practical publications, and carried out both qualitative and quantitative interdisciplinary researches. Scientific interests: criminology, sports law, criminal law, crime prevention. 1 Council of Europe Explanatory Report on the Criminal Law Convention on Corruption [1999] Access through the internet: POLITIKA KAIP TUŠČIA VIETA 397

2 1. THE CONCEPT OF CORRUPTION IN THE PRIVATE SECTOR Certain international documents devoted to criminal and civil law provide definitions of corruption in the private sector. 2 For example, The Criminal Law Convention on Corruption provides quite a broad definition of active and passive bribery. Article 7 stipulates that each party shall adopt such legislative and other measures as may be necessary to establish as criminal offences under its domestic law, when committed intentionally in the course of business activity, the promising, offering or giving, directly or indirectly, of any undue advantage to any persons who direct or work for, in any capacity, private sector entities, for themselves or for anyone else, for them to act, or refrain from acting, in breach of their duties. 3 A very similar definition is presented in the Council Framework decision combating corruption in the private sector: the Member States are to take all the necessary measures (inter alia criminal measures) to ensure the punishment of the following intentional conduct when it is committed in the course of business activities: promising, offering or giving an undue advantage to any person directing or who directs or works for a private sector entity in order that the person should perform or refrain from performing any act in breach of that person s duties (active corruption). 4 Article 2 of Civil Law Convention on Corruption stipulates that corruption means requesting, offering, giving or accepting, directly or indirectly, a bribe or any other undue advantage or prospect thereof, which distorts the proper performance of any duty or behaviour required of the recipient of the bribe, the undue advantage or the prospect thereof. Article 3 stipulates that each Party shall provide in its internal law for persons who have suffered damage as a result of corruption to have the right to initiate an action in order to obtain full compensation for such damage. 5 Last, but not the least, corruption in the private sector is also regulated by disciplinary law. For instance, Article 62 of the FIFA disciplinary code stipulates that anyone who offers, promises or grants an unjustified advantage to a body of FIFA, a match official, a player or an official on behalf of himself or a third party in an attempt to incite it or him to violate the regulations of FIFA will be sanctioned: a) with a fine of at least CHF 10,000, b) with a ban on taking part in any footballrelated activity, and c) with a ban on entering any stadium. 6 The same definition is entrenched in the disciplinary code of the Lithuanian football federation. The problems of the aforementioned definition are quite explicit: the definitions of corruption in the private sector in different law systems are rather similar, but the consequences of almost identical acts are very different: from a ban on taking part in a specific activity up to relatively long imprisonment. The current policy of the EU is urging to criminalize corruption in both the 2 In this paper, critical (yet realistic) insights about the lack of unified definition of corruption are not analyzed. 3 Council of Europe Criminal Law Convention on Corruption [1999] (ETS No. 173). 4 Council Framework Decision 2003/568/JHA of 22 July 2003 on combating corruption in the private sector [2003] OJ L 192/54. 5 Council of Europe Civil Law Convention on Corruption [1999] (ETS No. 174). 6 FIFA disciplinary code [2011]. Access through the internet: 398 POLITIKA KAIP TUŠČIA VIETA

3 private and public sector. 7 Such policy calls for systematic analysis what are the main problems of criminalizing corruption. 2. THE PROBLEMS OF CRIMINALIZATION OF CORRUPTION IN THE PRIVATE SECTOR IN THE REPUBLIC OF LITHUANIA In the Republic of Lithuania, corrupt practices in the private sector theoretically are to be covered by the existing criminal regulation 8 in the chapter Crimes and Misdemeanours to the Public Service and Public Interests (namely, Articles and 230 of the Lithuanian Criminal Code). These articles stand for: Taking bribes (Art. 225); Trading of Influence (Art. 226); Giving Bribes (Art. 227); Abuse of Authority (Art 228); Definitions (Art. 230). The third paragraph of Article 230 stipulates that persons employed at any state or private office, enterprise or organisation, a political or public institution, or engaged in professional activities, discharging public functions and having appropriate authority and a position in public administration shall be held to have the status equivalent to that of a public official. It is important to note that corruption in the private sector in Lithuania is not narrowed to profit-seeking activities as it is recommended in the Criminal Law Convention on Corruption: First of all, Article 7 restricts the scope of private bribery to the domain of business activity, thus deliberately excluding any non-profit oriented activities carried out by persons or organisations, e.g. by associations or other NGO s. This choice was made to focus on the most vulnerable sector, i.e. the business sector. 9 Lithuania chose to broaden the private sector by not indicating that the necessary feature of the private sector s bribery should be profit-seeking. Such an alternative is possible also according to the aforementioned Explanatory Report: nothing would prevent a signatory State from implementing this provision without the restriction to in the course of business activities. However, theoretical covering has not much in common with the practical incrimination of bribery. For instance, there was not a single case in which anyone would have been sentenced for sports bribery in Lithuania. In my view, there are two main problems in criminalizing these phenomena: 1) the lack of clarity concerning the concepts of status equaled to a public official, public administration authorities and public functions ; 2) the lack of clarity concerning the concept of great damage. These problems raise serious doubts whether the Lithuanian criminal regulation is in conformity with the principle of legal certainty. 1. The attributes of person equaled to public official, public administration authorities and public functions are necessary in order to incriminate corpus delicti of corruption-related 7 According to point 48 of the conclusions of the European Council meeting in Tampere on 15 and 16 October 1999, corruption is an area of particular relevance in establishing minimum rules on what constitutes a criminal offence in Member States and the penalties applicable. Council Framework Decision 2003/568/JHA of 22 July 2003 on combating corruption in the private sector. Preamble, point 7. 8 Criminal Code of the Republic of Lithuania, Official Gazette No [2000]. 9 Council of Europe Explanatory Report on the Criminal Law Convention on Corruption [1999] Access through the internet: POLITIKA KAIP TUŠČIA VIETA 399

4 crimes that are in Chapter Crimes and Misdemeanours to the Public Service and Public Interests. Although it is correct to recognize that people in the private sector do have public administration authorities, it does not necessarily mean that Lithuania has properly criminalized corruption in the private sector. Corpus delicti of bribery and other corruption-related crimes requires a specific subject. The subject shall be a public official or a person who is equaled to the public official. The subject could also be a private person (also, working in non-profit sector), however, this person must have the power of public administration or the right to provide public services. Not all people working in the private sector have such rights and powers; therefore, stricto sensu, a large part of private employees cannot be the subject of criminal liability for the aforementioned offences. 2. Another serious problem is related to the concept of great damage. This attribute is necessary to incriminate corpus delicti of the Abuse of Authority which is, in principle, the most general corruption-related crime. 10 However, there is no explicit interpretation what is to be regarded as great damage. It is complicated to imply this quality mostly because damage might occur after relatively long period of time and sometimes it might not be clearly seen at all. It should be also pointed out that great damage is a requisite quality in order to separate these crimes from disciplinary or administrative offences. Also the issues of assessing immaterial damage arise, and so the ultimate difficulty is that if damage is understood too broadly and applied too vaguely, then the criminalization of corruption in the private sector can become a selective measure for overly discretionary punishment. In turn, the principle of ultima ratio is potentially violated, and if so, we must raise a question under what circumstances only disciplinary responsibility should be applied. 3. CONVERGENCE OF LEGAL SYSTEMS The aforementioned insights on the ambiguity of the definition of corruption as well as problems of criminalization of corruption imply that the criminalization of corruption might not be in conformity with the principle of ultima ratio. In my view, a thorough estimation of harm (or damage) might help avoid to broad extension of criminal liability. As it is noted in the European Criminal Policy Initiative, extended criminal liability abandons the requirement of even an abstract danger for a legally protected interest and hence is not compatible with the principle of proportionality (and derived from that the principle of ultima ratio) which is an essential guideline for criminal policy. 11 Harm (or related concepts dangerousness and damage) is one of the main criterion, according to which it should be decided what type of liability should be applied. Assessing this criterion, it is possible to show one of the possible convergent schemes in the light of corruption in the private sector. Without any criterion, one can speak about divergence and vagueness when national sys- 10 The first paragraph of Article 228 stipulates that a public official or a person of equivalent status who exceeds his authority or who wilfully fails to perform his duties or performs them improperly, where this causes great damage to the State, a legal or natural person, shall be punished by a fine, or detention, or imprisonment for a term of up to 5 years. 11 European Criminal Policy Initiative: A Manifesto on European Criminal Policy [2011], Access through the internet: 400 POLITIKA KAIP TUŠČIA VIETA

5 tems do not cooperate, but rather interfere with and confuse one another. On the top of the scheme there lies EU law which draws the guidelines for the national regulation. Criminal law lies in the centre, as currently corruption in the private sector is primarily associated (and is recommended to be associated) with criminal law. Actually, the scheme (pyramid) can be seen also from a civil law perspective, for example, in the light of competition law; and also from the perspective of disciplinary law (for example, sports law). Thus, the pyramid might be Scheme No 1. The (Inter)relation of Legal Systems in turned over. The type of liability depends on Case of Corruption in the Private Sector the degree of harm. If there is no harm, there is no liability. If the harm is little (for instance, abuse of position in the private sector in order to get small immaterial advantage), then disciplinary liability is to be applied. If the harm is relatively big, then criminal liability should apply. Civil liability goes in parallel with criminal or disciplinary liability with the aim (consequences) to compensate the concrete damages and to void the corrupt contracts. For the sake of objectivity, it must be noted that the criterion of harm is not necessary very clear. It is related to weighing principles that sometimes can be competing. For instance, in case of corruption in sports, sometimes certain acts (as sport betting itself 12 ) might cause harm to fair play, but such damage might be compensated by the aim to attract certain funding to sports and to ensure the sustainability of sporting activity (which often receives sponsorship from the betting business). It should also be noted that, theoretically, all kinds of liability can be applied in one single case: disciplinary (eg. ban to engage in certain activity), criminal (eg. fine) and civil (eg. annulment of contract). Then a complicate question of double jeopardy arises. As it was noted by the ECHR, each case must be treated separately and three main criteria must be taken into account: the legal classification of the offence in question in national law, the very nature of the offence and the nature and degree of severity of the penalty. 13 Thus, the national systems cannot duplicate one another: if civil or disciplinary sanction is huge, then it should be considered that one legal system is deterrent enough and the other system (criminal law) is not to be applied. In such case the principle of ultima ratio is also properly taken into account. 12 In reality, such acts lie on the margin between no liability (lawfulness) and disciplinary liability. 13 Malige v. France, application no /95 [1998] ECHR 1998-VII, no. 93, 35. POLITIKA KAIP TUŠČIA VIETA 401

6 CONCLUSIONS 1. International documents provide quite a broad definition of corruption in the private sector. Moreover, corruption in the private sector is regulated at least by the four systems: international law, criminal law, disciplinary law and civil law. Such pluralism calls for identification of circumstances under which each system is to be applied. 2. The current policy of EU recommends criminalizing corruption in the private sector. Lithuania has partly implemented this recommendation by entrenching that persons working in the private sector are to some extent equalled to persons working in the public sector. However, some vagueness incriminating corruption in the private sector is still present, and the aforementioned regulation is applied relatively rarely in practice. 3. The convergence of the four legal systems is possible when the functions of each system and the nature of offence as well as the sanction for the offence are taken into account. Criminal law as ultima ratio can be applied only when the harm of the offence is relatively big, while disciplinary law is applied when the harm is little. Civil law should have another (compensatory) function, and it can be applied in conjunction to disciplinary and criminal law. Bibliography 1. Criminal Code of the Republic of Lithuania, Official Gazette No [2000]. 2. Council of Europe Criminal Law Convention on Corruption (ETS No. 173) [1999]. 3. Council of Europe Civil Law Convention on Corruption (ETS No. 174) [1999]. 4. Council Framework Decision 2003/568/JHA of 22 July 2003 on combating corruption in the private sector [2003] OJ L 192/ Council of Europe Explanatory Report on the Criminal Law Convention on Corruption [1999] Access through the internet: 6. European Criminal Policy Initiative: A Manifesto on European Criminal Policy [2011], Access through the internet: EN.pdf 7. FIFA disciplinary code [2011] Access through the internet: administration/50/02/75/discoinhalte.pdf 8. Malige v. France, application no /95 [1998] ECHR 1998-VII, no POLITIKA KAIP TUŠČIA VIETA

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