Last month the Government announced a further delay in the implementation of the Bribery Act to allow for further consideration. This was generally seen as a response to concerns expressed by the CBI and others that the Act was unclear and the supporting guidance did little to help. The Act creates some entirely new offences, including an offence of “being bribed”, under which it is possible to commit the offence simply by accepting a gift in breach of your employer’s policy, irrespective of whether you or the giver intended the gift to be a bribe, inducement or reward for wrongdoing. Another new principle is that bodies and individual directors can now be liable for the actions of their employees if they have failed to take steps to prevent bribery or turned a blind eye to it. The offence of failing to take steps to prevent bribery applies to “relevant commercial organisations” and the definition of that term is wide enough to encompass public sector organisations that operate commercially. Some commentators have suggested that the Act might be withdrawn, but that is not likely as the Government is already overdue on an Organisation for Economic Co-operation and Development (OECD) commitment to introduce bribery legislation and has been criticised outside the UK and by promoters of transparency for the continuing delay. The Ministry of Justice is working on revised guidance to clarify the implications of the Act. It is proposed that three months’ notice will be given before the Act is implemented.