6 Principles For Compliance With UK's Bribery Act

Law360, New York (April 21, 2011, 12:48 PM EDT) -- On March 30, the U.K. Ministry of Justice released its much-anticipated guidance on “adequate procedures” for corporate compliance with the U.K. Bribery Act of 2010 (the guidance). The Bribery Act, scheduled to take effect July 1, makes it an offense for a company to fail to prevent bribery by “associated persons,” defined as those persons who provide services for or on behalf of the company.

The term presumptively includes the company’s employees, but it is not limited to employees and may also include agents, joint venture...
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