This client memo addresses the draft guidance the UK Government published last week on "adequate procedures" that companies can put in place to prevent bribery by their "associated persons." Establishing an effective anti-bribery programme is critical for any commercial organisation affected by the Bribery Act, due to come into force in April 2011, because it is the only defence to the new sweeping corporate offence. That offence potentially holds commercial organisations strictly liable for bribes paid for their benefit anywhere in the world by persons performing services for them or on their behalf.