The Ministry of Justice published its highly anticipated Consultation Paper on the UK Bribery Act 2010 on 14 September 2010. The Consultation Period is now open and the Ministry of Justice invites responses on proposed non-statutory guidance from the wider business community (including non-UK-based entities). The draft guidance provides some colour to a grey area of the Act, the definition of “adequate procedures.” This definition is of crucial importance to both UK-domiciled and non UK domiciled companies because under section 7 of the Act, there is an absolute defence for commercial organisations if they have “adequate procedures” in place to prevent bribery. As the consultation process is open to all interested persons, non-UK companies may wish to provide feedback on the relevance and appropriateness of the draft non-statutory guidance provided thus far.