John Smart, partner in the FIDS team at Ernst & Young provides five tips to help businesses prepare for the Bribery Act:

1.    Get your process right.  Businesses should appoint an ethics officer and undertake a risk assessment to give that officer a clear picture to work from.  It is very important to record incidents where ethical standards may have been breached, keep records and log any concerns;

2.    Know exactly what is going on in your company, especially if you operate in countries where corruption is common.  It could be a shrewd move to employ a risk assessment adviser to examine  your overseas operations;

3.    Working out what you can and can’t offer to clients can be difficult - you are required to judge whether or not a gift or corporate entertainment counts as “appropriate”.  What is lavish to one may be seen as stingy by another.  For instance, it might be acceptable to take a top broker out for lunch, but not to fly him out to New York in First Class;

4.    Train your employees - make sure they understand the Act by giving adequate support and guidance.  Keep hold of any materials used, to show that you’ve taken every suitable precautions;

5.    Demonstrate the message of zero tolerance.  As a first step, discuss the issues at a  board meeting and ensure the minutes reflect that you have added anti-bribery measures to your code of conduct.