Overview

Although the Act will only come into force next April, commercial organisations should be implementing adequate anti-bribery procedures now. This is not simply a question of box-ticking. Nor is it enough merely to ask employees to sign an anti-corruption policy. It is clearly in the interests of commercial organisations to develop and communicate a zero tolerance policy towards bribery that includes all employees and agents.

It is therefore important for affected businesses to make use of the lead time before the Act is brought into force to install adequate procedures. To this end, there will need to be suitable ethics and compliance programmes, structured oversight and scrutiny of all business arrangements including the processing of payments, as well as proper employee training programmes.

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