The jury is out on compliance in the first test of the Bribery Act’s adequate procedures defence

This guidance note discusses a case relating to a refurbishment contractor firm where bribe payments were taking place, and illustrates the difficulties that small firms can face when seeking to implement controls for the prevention of bribery. The note provides guidance to small (and larger) firms, highlighting questions they should ask themselves when assessing whether their anti-bribery controls are sufficient.