Russian officials have been warned to stop touting for bribes. The euphemistic phrases used, as reported by the BBC, make curious reading.
Bribery may be easier and more common than we think. Some years ago I had the habit, on return from travel abroad, to put spare foreign currency in my passport wallet. That way I would know where to find it next time I was travelling. But on one trip I inadvertently handed my passport (in its wallet with the cash) to an immigration official and was immediately accused of bribery. Fortunately it was clear that I had nothing to gain from bribing him and my explanation was believed. But why, in the first place, would he think that I was attempting to bribe him?
In the UK, bribery has been outlawed since 2011 and serious infringements are subject to unlimited fines with up to ten years’ imprisonment for individuals and (significantly for employers) an unlimited fine for any company or partnership that negligently fails to prevent bribery.
Employers therefore need to make clear to employees what might be seen as bribery, to what extent gifts (giving and receiving), and hospitality are acceptable as well as how employees should raise any concerns they may have.
Where the risks are greatest employers need to be able to show that employees fully understand these matters and, to protect themselves as employers, have signed declarations from employees of that understanding. Covering the issues at every induction would be wise.
Employees may well also need to understand what is meant by a facilitation payment. Most of us use them at restaurants “to insure promptness” (i.e. by tips), but if it is promptness that we want from a public official (and surely we all crave that) then any payment would be unlawful. Our public officials, like the Russian officials, may need to eat dry bread.
You might want to consider whether you have an anti-bribery policy in place.