BBA has responded to the Ministry of Justice's consultation on "adequate procedures" under the Bribery Act. It supports the principles-based approach the guidance suggests, but says it is essential the guidance recognises that a risk-based approach is acceptable. It also wants clarification on whether organisations are required to follow any other relevant guidance and, if so, whether the MoJ considers some of that "other" guidance more important. BBA is also concerned the timetable for implementation is too challenging. Among its other comments are that more clarity on some definitions, including that of "associated person" would be helpful. It also says some of the more helpful text in the draft guidance is not likely to appear in the final guidance, while the illustrative scenarios in the draft are not drafted helpfully for businesses trying to assess their risks.