This note is designed to provide a brief overview of some of the key features of the laws against bribery in the home states of the contributing firms: France, Germany, Italy, Spain, the Netherlands and the United Kingdom (together, the “Six States”; individually, a “State”) and some practical guidance on the use of a single set of procedures which might be designed to prevent bribery so as to avoid or mitigate liability in each of them. It also considers some particular issues in M&A transactions. It is necessarily a high level summary and should not be regarded as legal advice.

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