Where a bribe is made by an associated person, it is a defence for the commercial organisation to show it had adequate procedures in place to stop the associated person from carrying out the offence1.
The government has issued guidance2 to help commercial organisations put in place procedures to prevent bribery; such procedures should be based on the six principles set out in the guidance (which are not intended to be prescriptive). The procedures adopted should be tailored to the size of the commercial organisation. Sitting ‘behind’ the guidance and the procedures that a commercial organisation has to put
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