The recent conviction of Sweett Group PLC sends a clear message out to businesses that the defence of having "adequate procedures" in place to defend prosecutions under the Bribery Act requires more than just a policy. Employees should be regularly reminded of their obligations, training and education needs to be provided to relevant individuals, disciplinary policies should address the issue as should whistleblowing procedures. There needs to be a clear culture throughout organisations from the top down. Only then is a court likely to be satisfied that adequate procedures have genuinely been put in place. Mere paper compliance will never be sufficient.