William Fry - Publication - New UK Bribery Legislation has implications for businesses with a UK presence

William Fry - Publication - New UK Bribery Legislation has implications for businesses with a UK presence: "The corporate offence represents the most significant aspect of the Act. It applies where a “person associated with the organisation (defined broadly as persons providing services and specifically includes employees, agents or subsidiaries) bribes another to gain business or a business advantage for the organisation. It is a strict liability offence and the only defence available is to show that the organisation had adequate procedures in place to prevent bribery. The Act therefore encourages businesses to have an anti-corruption policy in place. Finalised guidance on what constitutes “adequate procedures” was initially intended to be published by the Ministry of Justice in early 2011 but may now be delayed. The Ministry of Justice has stated that the Act will not come into force until three months after any guidance is published"?