Guidance about procedures which relevant commercial organisations can put into place to prevent persons associated with them from bribing (section 9 of the Bribery Act 2010), Ministry of Justice (2011).
UK Ministry of Justice guidance on The Bribery Act 2010, published as the Act came into force to help organisations understand the legislation and deal with the risks of bribery. The aim was to offer clarity on how the law would operate given that wholly new offences were being introduced including offering or receiving bribes, bribery of foreign public officials and of failure to prevent a bribe being paid on an organisation’s behalf. The Act also includes a full defence if an organisation proves that despite a particular case of bribery it nevertheless had adequate procedures in place to prevent persons associated with it from bribing. The guidance provides high level procedural guidance, confirms the need for ‘speak up’ or whistleblowing procedures for the reporting of bribery, and emphasises the need for bespoke training to those involved in administering such mechanisms.