… a typical anti-bribery procedure will assess the risk of bribery in the business from the point of view of geography, the nature of customers, and the practices of a particular industry. The business will make clear that bribery is never acceptable. It will require checks on agents and representatives, limit and monitor expenditure on gifts or hospitality, monitor books and records, provide staff with appropriate training, and protect whistle-blowers who report concerns to management. The procedures should be properly resourced, robust and responsive to the assessed risk of bribery. They should be fully and visibly supported by senior management.
— Attorney Eoin O’Shea of Reed Smith on what the government officials might consider “adequate procedures” to prevent bribery when enforcing the UK Bribery Act.