Facilitation Payments Seen as Problematic by Many...( For example 76% of respondents believ...),Health

For example, 76% of respondents believe it is possible to do business successfully without making facilitation payments if there is sufficient management support and careful planning. Buttressing this, 71% believe the employees of their company either never, or only rarely, make facilitation payments, regardless of whether facilitation payments are permitted under their corporate policies. When respondents were asked to gauge the level of risk facilitation payments pose to a company with respect to books and records violations or violations of other internal accounting controls, 58% assess such risk level as medium to high. Asked to assess how likely their company is to face a governmental investigation or prosecution related to facilitation payments, just over half believe they are moderately or highly likely to face such an investigation in the country where they are headquartered, and 40% believe they are likely to be investigated or prosecuted in the country where the payment is made.

Respondents expressed a desire for greater guidance from domestic and international enforcement agencies about what constitutes permissible facilitation payments:

• 81% seek a clear definition of facilitation payments with detailed examples;
• 58% want a clear definition of government officials to whom payments may be made;
• 57% want guidance about whether payments for non-discretionary tasks that incidentally have a business benefit are facilitation payments;
• 56% seek monetary thresholds;
• 54% want an expansive list of what constitutes a facilitation payment; and
• 46% seek guidance about the proper accounting for such payments.
  

Questions included on the survey about how corporate compliance policies currently address facilitation payments allowed respondents to select more than a single response. Some 80% of respondents' companies had a formal, written policy. In describing these
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