Following on from our two e-updates in April of this year (available by clicking here and here) in relation to the new Bribery Act 2010, the Ministry of Justice have commenced their consultation into the guidance to be issued to commercial organisations in implementing anti-bribery procedures.
Section 9 of the Bribery Act requires the Secretary of State for Justice to publish guidance on procedures that commercial organisations should put in place to prevent bribery. This guidance will be of great importance to commercial organisations in shaping their anti-bribery procedures and policies. It is this guidance which is the subject of the current consultation.
The consultation opened on 14 September 2010 and is seeking comments on draft guidance published as part of the consultation.
The draft guidance itself (available by clicking here) is broken down into six principles that commercial organisations should look to implement in their anti-bribery procedures: (1) Risk Assessment; (2) Top Level Commitment; (3) Due Diligence; (4) Clear, Practical and Accessible Policies; (5) Effective Implementation; (6) Monitoring and Review. The consultation is seeking comments on whether these principles are sufficient, and whether there are other principles/procedures that should be considered as part of anti-bribery strategies.
To aid the consultation, the Ministry of Justice is holding a number of discussion seminars around the country in September and October. Details of these seminars are available by clicking here.
Any organisations wishing to contribute to the consultation can do so by submitting responses online or in hard copy. The consultation is open until 8 November 2010.