A corporate body may have a statutory defense where it can demonstrate that it took all reasonable steps and exercised all due diligence to avoid the commission of the offense, under section 18 of the 2018 Act. There is no guidance as to what may constitute “reasonable steps” or “due diligence” – however, it is likely that the court may have regard to the UK equivalent guidance that adequacy of a commercial organization’s procedures will be assessed by reference to six key compliance principles, including risk assessment, proportionate procedures, top level commitment, due diligence, communication and training, and monitoring and review. It is important to note however that the UK equivalent legislation refers to “adequate procedures” rather than the higher Irish standard of “all reasonable steps.”