On 14 September 2010, the Ministry of Justice issued its promised Consultation Paper seeking comment on what might be “adequate procedures” to avoid criminal liability for a commercial organisation which has “failed to prevent bribery”. Responses are sought by 8 November…. Companies wishing to take advantage of the protection afforded against criminal exposure in the UK by establishing “adequate procedures” to prevent bribery now have a good indication of what UK authorities will expect, and can begin to consider steps to be taken in advance of the effective date of the Act next year.
‘Enforcement 40’ for 2020
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