Overview

Companies attempting to comply with the UK Bribery Act 2010 face a dilemma when it comes to facilitation payments - small, unofficial payments paid to facilitate routine government actions, mostly to foreign officials. Sometimes referred to as ‘grease’ payments, they are usually made to obtain something to which the commercial organisation is already legally entitled.

However, the dilemma facing commercial organisations is as follows: if such payments were made they would be illegal and, if documented, technically they would provide a prosecutor with clear evidence of an illegal act. However, by not recording them, the organisation would be going against the primary principle of being open and transparent in respect of all transactions - the cornerstone of any Bribery Act compliance programme.

This briefing offers details of a six-step solution proposed by the Serious Fraud Office which helps companies and employees to comply with this aspect of the Bribery Act. Click 'View Briefing' for full details.