This entered into force on 1st July 2011 and catches all forms of business-from sole traders to large corporations. The Act catches the obvious offences of bribery, but the key new offence is the one that can be committed by commercial organizations failing to prevent bribery (section 7). A business will only have a defense, if it can show that it had in place “adequate procedures” designed to prevent bribery. This is where your next piece of ‘housekeeping’ comes in. Put those procedures in place! Set up a top level team who will scrutinize all aspects of the business and, its’ now neatly organised(!) contracts to assess possibilities of bribery. Make sure your staff anti- bribery policy has been updated. Check out the Ministry of Justice Guidance Note which sets out the steps you must take and make sure you document them all.