One of the easiest requirements of the act is for the business to make a clear statement that the business culture is one where bribery is never acceptable.

This should be a clear statement that the organisation has a zero tolerance to bribery and a commitment to carry out business fairly, openly and honestly.

Businesses must undertaken risk assessments and put policies and plans in place.

Ministry of Justice guidance follows six principles:

• proportionality -€“ the actions the business undertakes should be proportionate to its risks and to its size;
• top-level commitment -€“ top level management must foster a culture where bribery is never acceptable;
• risk assessment -€“ the business assesses the nature and extent of its external and internal risks;
• due diligence -€“ the business knows who it is conducting business with and assesses the bribery risk;
• communication -€“ the business communicates its policies, its procedures and trains its staff;
• monitoring and review -€“ procedures are established that ensure regular reviews are undertaken to assess business risks to prevent bribery.
  

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