With implementation of the Bribery Act 2010 on 1 July 2011 imminent, Jonathan Cotton and Richard de Carle give a brief recap of the basic features of the Act and consider some of the remaining areas of uncertainty for businesses:

  • the scope of the Section 7 "failing to prevent corporate offence"
  • who is your "associated person"
  • when a non-UK organisation is "carrying on a business in the UK"
  • the scope of the Section 7 foreign public official offence
  • corporate hospitality and promotional expenditure
  • facilitation payments
  • when anti-bribery procedures will be adequate
 
 

Contacts

 

Jonathan Cotton (partner), Richard de Carle (partner)

 
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