Section 7 only applies to relevant commercial organizations.  A relevant commercial organization is a body or partnership incorporated or formed in the UK irrespective of where it carries on business, or an incorporated body or partnership which carries on a business or part of a business in the UK irrespective of the place of incorporation or formation.¹  

The Bribery Act does not define “part of a business.”  According to the Ministry of Justice Guidance, this question is answered by “applying a common sense approach.”  The Guidance states that “organisations that do not have a demonstrable business presence in the United Kingdom would not be caught.”²  The government would not expect, for example, that the mere fact that a company’s securities have been admitted to the UK Listing Authority’s Official List, and therefore admitted to trading on the London Stock Exchange, in itself qualifies that company as carrying on a business or part of a business in the UK and therefore falling within the definition of a relevant commercial organization for the purposes of Section 7.