What does an effective anti-bribery and corruption programme require?

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By Monique Carroll, Liu Xiangwen and Zhu Yuanyuan

An in-depth understanding of the unique legal environment in China is essential to fully understand compliance requirements.

In some industries, particular conduct or business models permitted elsewhere may be very sensitive and considered bribery or corruption in China. It is therefore recommended that companies operating in China adapt their compliance programmes to account for industry-specific regulations and sensitivities and undertake regular internal compliance audits as a check on the effectiveness of the compliance programme and to ensure that it remains up to date.

In addition to China’s general anti-bribery and corruption laws (i.e. the Anti-unfair Competition Law, the Trial Regulations of the State Administration for Industry and Commerce on Prohibition of Commercial Bribery and the Criminal Law), there are a number of industries that have unique regulations aimed at preventing bribery and corruption…

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