Memorandum to board accompanying anti-bribery policy

The following Practice Compliance precedent provides comprehensive and up to date legal information covering:

  • Memorandum to board accompanying anti-bribery policy

Memorandum to board accompanying anti-bribery policy

Summary

The Bribery Act 2010 (BA 2010) came into force on 1 July 2011. BA 2010 applies to any business incorporated or trading in the UK and covers bribery committed on its behalf anywhere in the world. It is substantially broader than previous anti-corruption legislation.

BA 2010 makes it explicit that individuals are prohibited from paying or accepting bribes. There is a specific offence of bribing a foreign public official. In addition, a business now commits an offence where bribery is committed on its behalf, unless it has in place adequate procedures to prevent bribery. What constitutes adequate procedures is not defined by BA 2010; it is for businesses to make their own assessment of adequacy. Guidance issued by the Ministry of Justice (MoJ) confirms we need to have in place a robust and enforced policy prohibiting bribery and corruption that everyone is aware of.

I therefore attach, for your approval and comment, a[n] [Group] anti-bribery and corruption policy. The policy, which applies to all our businesses, carries a short introduction from [insert name of relevant individual] stressing its importance and requesting the personal commitment of all our people to carry it into effect. It has been signed off by [insert name of relevant individual and/ or executive team].

Responsibility

The [CEO OR Managing Director] has overall responsibility for this policy. [[[Divisional] Managers OR Managing

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