THIS subject has been considered in Novoship (UK) Ltd. v Mikhayluk [2015] 2 W.L.R. 526; [2014] Q.B. 499. The first plaintiff (“Novoship”) and the 14 other plaintiff companies (“the Novoship Group”) were indirect subsidiaries of the JSC Novorossiyak Shipping Co., incorporated in Russia. The first defendant, Mr. Mikhayluk, was an officer of Novoship and in charge of negotiating the charter of vessels owned by members of the Novoship Group. In litigation in the Commercial Court, he was held to have been in breach of his fiduciary duty to members of the Novoship Group by his corrupt conduct between 2002 and 2004 in dealings with various charterers. These included the sixth defendant, Mr. Nikitin, and the eighth defendant, Henriot Finance Ltd. (“Henriot”), a Virgin Islands company owned and controlled by him. There were connections with a number of jurisdictions but the litigation was conducted on the footing that the governing law was that of the English forum.