With the Bribery Act 2010 due to come into force on 1 July, bringing with it possible criminal sanctions for non-compliance, companies are increasingly turning their attention to improving their risk management framework. Many companies will already have drafted anti-bribery policies and set out in detail the rules surrounding gifts and hospitality. Stage two of preparation for the Bribery Act’s implementation is likely to involve rolling out training to employees to ensure that they are aware of any new policies and of the behaviour expected of them.
But putting in place new policies and providing training will be insufficient to protect companies from risk. The key for any company wishing to minimise its risk exposure is to ensure that its policies are actually complied with, and this is likely to require a further step – a change in the culture and attitude of the organisation as a whole to risk.
