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Anti-Bribery Policy (draft)

http://www.transparency.org.uk/our-work/business-integrity/bribery-act/guidance-for-ngos

Countries that allow facilitation payments

Section titled “Countries that allow facilitation payments”

The following countries do allow their citizens to make facilitation payments when abroad1:

Australia, Austria, Canada, Greece, South Korea, New Zealand, Slovak Republic, South Africa, Spain, Switzerland and the U.S.A.

This information is only included for completeness because some volunteers may mention it; Whisper doesn’t encourage anybody to make facilitation payments. It would only apply to payments made for the volunteer’s own benefit, not for Whisper’s benefit, and even then “facilitation payment” only covers routine activities, so for example it may be allowable to pay when they apply for a permit, but it would not be allowable to pay for the official to issue the permit even though their paperwork is not in order.

The following countries do not allow their citizens to make facilitation payments:

Argentina, Belgium, Brazil, Bulgaria, Chile, Czech Republic, Denmark, Estonia, Finland, France, Germany, Hungary, Iceland, Ireland, Israel, Italy, Japan, Luxembourg, Mexico, Netherlands, Norway, Poland, Portugal, Russia, Slovenia, Sweden, Turkey and the U.K.

In the UK, The Director of Public Prosecutions or the Director of the Serious Fraud Office must personally decide that a prosecution under the Bribery Act is in the public interest2.

  1. http://www.fcpablog.com/blog/2015/8/5/notes-from-iaca-part-three-concl-a-facilitation-payments-que.html ↩

  2. http://www.justice.gov.uk/downloads/legislation/bribery-act-2010-quick-start-guide.pdf ↩