Guidance on the New UK Bribery Act

The U.K. Ministry of Justice has recently issued its guidance (the “Guidance”) regarding the U.K. Bribery Act 2010 (the “Act”), which is to come into effect as of 1 July 2011. Given its extraterritorial jurisdictional implications, we believe that the Act is of relevance to Turkish and other non-U.K. companies doing or thinking about doing business in the United Kingdom or with U.K.-based companies.

The Act prohibits (a) the offering, promising or giving of a bribe (active bribery), (b) the requesting, agreeing to receive or accepting of a bribe (passive bribery) and (c) the bribing of a foreign public official in order to obtain or retain business or an advantage in the conduct of business.

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