AIC has published some informal general guidance on compliance with the Bribery Act. The note focuses on the "failure to prevent bribery" offence. It says it is unlikely an investment company would be liable for the actions of an investee company or subsidiary under this offence, as it is unlikely that the investee company or subsidiary would be providing services to the investment company and bribing to get or keep a business advantage for it. The note says the risk of committing the offence through an external investment manager is higher. The note continues by assessing what investment companies should do to comply with the Ministry of Justice’s principles for adequate procedures. (Source: AIC Paper on Bribery Act 2010)