 Guidance was published by the Secretary of State three months before the Act came into force . The Guidance sets out 6 principles to be followed by business . They cover such topics as <unk> Procedures , Top @-@ level Commitment , Risk Assessment , Due Diligence , Communication ( including training ) and Monitoring & Review . The one firm conclusion to be drawn from the Guidance is that every commercial organisation that might be subject to the rigours of the Act needs to have a code of conduct in place that appropriately reflects the Guidance and to ensure its personnel are fully conversant with the risks and adequately trained . If it is then charged with the offence of failing to prevent bribery , it would be able to show evidence of the ‘ adequate procedures ’ which it will need in order to defend itself . 
