The Ministry of Justice, on 30 March 2011, announced its intention to delay the implementation of the Bribery Act 2010 until 1 July 2011. It also however issued its guidance on the procedures that can be put in place by employers to prepare for its implementation.

This, like the guidance published in September 2010, sets out six principles that are intended to give all commercial organisations a starting point for planning, implementing, monitoring and reviewing their bribery free business. Principle 1 is the implementation of proportionate procedures. Like developments in Health and Safety law before it, employers are going to be held accountable for the actions of their employees. Caution will therefore be necessary in any business where employees are responsible for attracting work, negotiating contracts or dealing with foreign import and export agencies. The presence of a clear and concise procedure in a staff handbook will go some way to protect the diligent employer from prosecution should an employee be found to be in breach of the Bribery Act 2010.

If you wish to enquire about having a staff handbook suited to the needs of your business, or indeed wish for an existing handbook to be updated, then please do not hesitate to contact Stephen Nixon, Andrew Pointon or David Evans at Enoch Evans LLP. Please call (01922) 720333 or email ee@enoch-evans.co.uk.

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