Bribery Act in force on 1 July 2011
Guidance issued April 2011
The Act creates new criminal offences, including bribing or being bribed, with maximum penalties of 10 years imprisonment or an unlimited fine.
There is also a new corporate offence for commercial organisations (likely to include corporate pension trustees) which fail to prevent anyone performing services on its behalf (including a trustee director) from committing bribery, unless the organisation had "adequate procedures" in place to prevent bribery. The guidance makes clear that the Act is not intended to prohibit genuine corporate hospitality.
The Act potentially impacts individual and corporate trustees plus sponsoring employers.