On 1 July 2011 Transparency International UK published a consultation on anti-bribery guidance for transactions.  This is intended to provide a tool for companies wishing to undertake anti-bribery due diligence in the course of mergers, acquisitions and investment.  Responses to the consultation must be received by 15 September 2011.  

The guidance sets out the good practice principles as follows:

  • Anti-bribery due diligence should be conducted for all but the smallest investments.
  • It should be conducted with sufficient depth and resources to ensure that it is undertaken effectively.
  • It should be conducted sufficiently early in the due diligence process.
  • The partners or board should oversee the due diligence reviews.
  • Bribery detected through due diligence should be reported to the authorities.
  • Information gained through due diligence should be passed on efficiently and effectively to the company’s management once the investment has been made.