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The Bribery Act 2010 became law on 1st July 2011 and has far reaching consequences for businesses, directors and senior officers that many may be unaware of.

It has always been an offence in the UK to offer, demand or pay a bribe and that includes facilitation payments. However , the new law tightens up the provisions, widens the net and imposes severe penalties for non compliance.

We can guide you through the the Bribery Act and help you assess the potential risk to your business. If there is a serious risk to your business then we can assist you in developing a corporate policy that fits your business and demonstrates you have taken all reasonable steps to ensure your business complies.

Due to the nature of the Bribery Act and the manner in which it is drafted, Lodestar cannot accept any liability for recommendations made or representations. Clients must satisfy themselves that the actions they are taking do not fall foul of the Act and are advised to and must seek specialist legal advice.


The only  defence is that the Company or individual has “Adequate Procedures“ in place to prevent acts of bribery , together with procedures for dealing with instances of bribery being reported or coming to light.

Due to the high level of publicity that bribery has received over the last few years the Government are keen for this legislation to be enforced. As a result it is expected that cases will start to be investigated well before the end of the year.

A comprehensive corporate policy and processes to match are vital to ensure compliance with the Act and should include the following elements:

  1. Identify management champion
  2. Risk Assessment
  3. Develop watertight policy and processes
  4. Enshrine policy into corporate culture
  5. Establish concise rules for employees
  6. Training
  7. Communicate policy and procedures
  8. Reporting procedure and register
  9. Continuous monitoring

Bribery Act

The Act  is drafted quite specifically and it is open to question how the authorities will police it and how the Courts will interpret its provisions.

Areas that business might find it difficult to interpret are:

Bribery Act