• The Bribery Act 2010: Implementing Adequate Procedures - What Employers Need To Know
  • July 8, 2011 | Authors: Robert F. Amaee; Helena Laughrin; John P. Rupp; Christopher Walter
  • Law Firm: Covington & Burling LLP - London Office
  • The Bribery Act 2010 (the “Act”), which came into force on 1 July 2011, makes companies that carry on all or part of their business in the United Kingdom liable for failing to prevent bribes from being paid by “associated persons” -- those performing services for or on behalf of the company -- unless they can demonstrate that they have developed and implemented “adequate procedures” to prevent bribery. Guidance published by the UK Ministry of Justice in March 2011 sets out six principles that are intended to help organizations develop and implement such procedures.