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Defining “adequate procedures” in response to the UK Bribery Bill 2009
How much is enough? - adequate anti-bribery procedures
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The UK Ministry of Justice published the draft Bribery Bill on 25 March 2009. As well as proposing general and specific bribery offences relating to the bribery of foreign public officials, it also introduces a specific corporate offence of failing to prevent bribery.
The draft Bill introduces the concept of “adequate procedures” as a potential defence to the accusation of failure to prevent bribery. The term “adequate procedures” is not defined in the draft Bill, but it is clear that they must have been in place at the time of the alleged offence.
In our experience, the implementation of effective anti-bribery policies and procedures can take a considerable amount of time. This means that for the defence to be available by the time the Bill becomes law, organisations need to act now.
This is an emerging area and practices will evolve, but from our practical experience we believe that approaching “adequate procedures” requires three key elements:
Read ‘How much is enough?’ to find out more.
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