The UK Bribery Act is now in force and the government has published guidance for commercial organisations on what is expected of their anti-bribery policies and procedures.
Commercial organisations, wherever based, doing part of their business in the UK are subject to the Act and should be reviewing their polices and procedures to ensure compliance and provide themselves with a defence if a bribe is paid in connection with their business. Senior officers should be involved both to ensure compliance with government expectations and to reduce the risk of committing the personal offence created for them of consenting to or conniving in bribery.
Companies must be prepared to carry out proper internal investigations where grounds for suspecting wrongdoing exist. Incomplete investigations or ones that are not independent will be inadequate and risk serious consequences reputationally and with the authorities.
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