The U.K. government has started consultation on how a key part of its new Bribery Act will work in practice, warning companies that they will need to “go beyond paper compliance” when the Act takes effect next April.

Companies will face prosecution under the Act if staff or third-party agents pay or offer bribes and the business did not have adequate measures in place to stop such behavior.

Draft guidance issued by the Ministry of Justice explains what kinds of procedures fit the description of “adequate.”

The guidance is built around six principles, one of which states that companies should go “beyond paper compliance to embed anti-bribery measures; in your organization’s internal controls, recruitment, and remuneration policies, operations, communications, and training on practical business issues.”

The other five principles state that companies should assess bribery risks in the markets and sectors where they operate; create a culture in which bribery is unacceptable, with board-level endorsement; exercise due diligence; have “clear, practical and accessible” policies and procedures; and review and monitor controls that are sensitive to bribery.

The guidance states: “The detail of how organizations will address these principles will vary, but the outcome should always be robust and effective anti-bribery systems and controls.”

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