To Pay or Not To Pay?
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10 Minutes
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For all staff
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UK
Small facilitation payments made to officials to speed up a permit or approval may appear harmless, but they are illegal and can result in imprisonment. This 10-minute express module explains how to spot a facilitation payment, how to resist a demand for one, and the narrow circumstances in which making a payment may be acceptable.
The UK Bribery Act provides no exemption for facilitation payments, unlike some other regimes, which catches staff who have worked in markets where the practice is routine. Refusing costs time and creates friction, so people pay and record it as an expense. Preparing staff in advance for that moment is what makes refusal realistic rather than theoretical.