Bribery Act 2010 Update: Guidance for Commercial Organizations


The Ministry of Justice has published the long awaited finalized guidance on “adequate procedures” under the Bribery Act 2010. The Act will come into force on 1 July 2011.

The Bribery Act 2010 creates a new offence under section 7 which can be committed by commercial organizations which fail to prevent persons associated with them from “bribing” another person on their behalf. An organization that can prove it has adequate procedures in place to prevent persons associated with it from bribing will have a defence to the section 7 offence. The new guidance published under section 9 of the Act, will help commercial organizations of all sizes and sectors understand what sorts of procedures they can put in place to prevent bribery.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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