The case was particularly sensitive because it appeared that a number of secret commissions had been paid. (essexcourt.com)
As Kelly implies, secret commission cases — which only require that money be taken «secretly» — do not require an absolute prohibition because it's not always wrong for agents to take money from third parties. (slaw.ca)
Michael Wilson & Partners Limited v Emmott: [2011] EWHC 1441 (Comm) Acted for the applicant in the Commercial Court challenging an arbitration award under ss 68 and 69 of the Arbitration Act 1996 involving allegations of diversion of corporate opportunities and secret commissions against a partner of a law firm. (erskinechambers.com)