Bribery Act: Implementation Programme
The UK Bribery Act will not now come into force until April 2011. The Government will launch a short consultation process in September and it is important that those of you who have concerns about aspects of the Act that may seem unclear or to have implications for legitimate activities should make sure you submit your thoughts as part of this process. Government will consider submissions made during the consultation in compiling the guidance notes that are planned to be issued in January. These notes are intended to help companies understand what steps they should take to demonstrate that they have done all they reasonably can to prevent foreign partners becoming involved in bribery and so avoid liability for any activities that those partners might still engage in in spite of the UK company’s efforts however if other aspects of the Act appear to be causing confusion it is possible that the guidance might be extended to other areas too.