INTRODUCTION Contributed by: Simon Bushell and Gareth Keillor, Seladore Legal
(depending upon the facts and relationships) if a large organisation has failed to comply with its own internal risk assessment processes. It is interesting to note that the government’s guidance includes eight hypothetical examples illustrating the scope of the FTP Fraud Offence,
with three of them focusing on ESG-related fraud. This suggests an increasing regulatory interest in how businesses’ ESG commitments intersect with corporate fraud risks. Companies should be mindful that misleading or fraudulent ESG claims could expose them to potential lia - bility under the new framework.
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