Companies worried about facilitation payments in light of Britain’s new Bribery Act and other similar laws may want to review their policies on the subject—that is, assuming they even have one.
A review of the codes of conduct at 40 oil and gas companies—which are especially prone to encounter requests for facilitation payments, considering the parts of the world where they do business—found that more than half made no mention of the payments in their codes. What’s more, of the 15 companies that do have some policy about facilitation payments, only half give examples of what such payments actually are.
