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Bribery Act: Who needs a Bribery Act policy?

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The Bribery Act is coming into place in June, and Justice Secretary Ken Clarke has released Bribery Act guidance today.

Does everyone have to have a Bribery Act policy in place? What companies should worry about the Bribery Act?

The short answer is that no, not everyone needs a Bribery Act policy in place. The guidance clearly states: “If there is very little risk of bribery being committed on behalf of your organisation, then you may not feel the need for any procedures to prevent bribery.”

Of course, if you’ve assessed your company’s position and there is a risk of bribery – and if you wish to rely on the defence – then the procedures that you adopt should match the risk.

“There is no need for extensive written documentation or policies,” the Bribery Act guidance states. “You may already have proportionate procedures through existing controls over company expenditure, accounting and commercial or agent contracts for example.”

In micro-businesses, it may be enough for simple oral reminders to key staff about the organisation’s anti-bribery policies.

But in larger businesses, management must be “fully aware and committed” to the objective of preventing bribery.

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