Under current UK law, in order to find a company liable for offences requiring proof of a mental element (e.g., intention, knowledge or suspicion) it is necessary to prove that a "directing mind and will" of the organisation was involved in the misconduct. While this “identification principle” has been interpreted in different ways, it is generally held to require that a senior officer or director (the “directing mind and will" of the company) knew about or was involved in the offence. The principle has been repeatedly criticised as being unrepresentative of how corporate entities are structured and operate nowadays. Prosecutors and law enforcers argue that it hinders the effective enforcement of criminal law against large companies in particular, as it is often difficult to show that those at the top of the business had any knowledge or involvement in the wrongdoing at all.

https://www.linklaters.com/en/insights/blogs/businesscrimelinks/2023/july/the-proposed-reform-of-the-identification-principle-from-the-bill-that-keeps-on-giving