Following a case bought by the Serious Fraud Office, The Sweett Group plc has been convicted under section 7 of the Bribery Act 2010 and had pleaded guilty to failing to prevent an act of bribery. A substantial fine of £1.4 million was imposed in addition to costs and a confiscation order. The fraudulent act related to a payment by a subsidiary to a third party company to secure a building contract, a payment of which The Sweett Group plc was ignorant. The judge in the case noted that “the whole point of section 7 is to impose a duty on those running such companies throughout the world properly to supervise them. Rogue elements can only operate in this way – and operate for so long – because of a failure properly to supervise what they are doing and the way they are doing it.” While companies can defend themselves if they are able to show that adequate procedures were put in place to prevent bribery, there is still little guidance on what would constitute an “adequate procedure”.