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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