8/19/2019 Scenario 8 Mona
1/2
SCENARIO 8
I am starting a biscuit manufacturing company in Mangalore. A
local government agency has toinspect and approve equipment &
plants and biscuit factory infrastructure. With their
permissiononly I can run the factory. I spend all my earnings to
start this business. But when the officials cameto inspect the
factory & equipment, they directly as ed me to bribe them.
Demand prevention: How to reduce the probability o the demand
bein! made"
• Inform your management in advance that logistical and other
company support for obtaining theapproval will be necessary
• Include in contracts the ma!imum amount of lead time to allow
permits to be issued• Implement a company policy and
guidelines•
prohibiting bribery, including how to re"ect demands for
facilitation payments whenever possible, and communicate these to
employees
• #stablish and implement systems allowing employees to report
demands for bribes and$or facilitation payments
• %rovide anti corruption training, which includes definition of
e!tortion and facilitation paymentsand what to do when they are
demanded
• 'stablish good relations with relevant government bodies,
licensing agencies and local andtraditional authorities where you
operate
• (iscuss with authorities the problems that employees face with
payment demands from localofficials and ways to prevent such
situations from occurring
• Wor with local commercial associations to document and publish
the offiial procedures,time and lees involved for technical
approval of the equipment
• %rohibit payment of non documented e!penses not compliant with
laws or contractual
provisions and establish guidelines requiring that all e!penses
are documented to include at leastthe amount, date and identities
of persons ma ing and receiving payment
Re#pon#e to bribery demand: How to react i the demand i#
made"
• )efuse to pay• Immediately report the incident to management
and obtain authority to ta e appropriate
action• Inform the official that ma ing the payment as requested
is prohibited by your company and
e!plain that the demand is illegal and could also lead to the
termination of the employeema ing the payment
• *a e the name of the person and state that all fees must be
paid directly to the governmentoffice in return for an official
receipt that includes all payment details, including the identityof
officials receiving payment
• If it is logistically impossible to ma e direct payment to a
government office, request that theofficial provide a receipt on
government letterhead
• Ma e use of e!isting relationships to identify a more senior
person in the licensing bodywhom you can approach instead, in order
to e!plain the dilemma
