This post was also written by Neil Donovan.

The UK Ministry of Justice (“MoJ”) official with responsibility for managing the implementation of the Bribery Act 2010 (“Act”) provided an update on the status and content of the revised adequate procedures guidance during a speech last Thursday.

The speech covered the following:

  • Timeframe- according to the official, the delayed adequate procedures guidance will be published “as soon as possible” but set no specific date. There is still no information about when the Act will come into force but the MoJ has promised a three month gap between publication of the guidance and the coming into force of the Act.
  • Principles in the Guidance- the six guiding principles contained in the draft of the guidance released last year will remain but the revised guidance will differ “quite substantially” from the previous version.

The timing of the adequate procedures guidance and the Act remain unclear. The content of the guidance is also apparently in a state of flux. Nevertheless, companies who are waiting for the guidance to implement changes to their policies and procedures may wish to reconsider. It will almost certainly take most companies more than three months to plan and make changes and they may run out of time.