How to spot bribery red flags (with a scored example)

“Everyone pays the clerk a little to get the stamp today” is the sentence people use to make a bribe feel like postage. Under UK law, a facilitation payment to a public official to speed a routine action is still a problem your firm has to prevent. You may be overseas, tired, and told it is cultural. The practised move is not a lecture on the Bribery Act. It is: we cannot pay that, we need the official route, I will log this. If you argue on the spot about whether £40 counts, you have already started negotiating. Small and routine is how these things hide. Name it as a payment to get a process skipped, then stop.

A customer, a partner, or a colleague will often grant that the rule exists, then ask you to step around it for this deal, this port, this inspector. That is the test. If you say yes to the exception, you have taught them you are available. If you go quiet, they will fill the silence with a story about how helpful you were. Say the no in the room: I cannot do that, I will not hide the gift, I need to take this to compliance. Then do it. A private moral discomfort that never becomes a report is how organisations fail the Ministry of Justice’s adequate-procedures test. The SFO’s corporate guidance is dull on purpose: record, escalate, do not freelance an investigation.

A modest lunch on a working visit can be fine under policy. Tickets plus “we need this awarded by Friday” is not a grey area you have to decode alone. Ask what they want in return, even if they have not said it. If the answer is a decision, a specification, or silence about a problem, you are in a flag. Register the hospitality or refuse it. Do not split the bill in cash to keep it off the register. Do not take the family tickets “because it would be rude.” Rudeness is cheaper than a dawn raid. If you are unsure, that is already a reason to log it. Uncertainty is the point of a speak-up line.

Memory is generous to the person who wanted the shortcut. Before you leave the desk, note who said what, the amount if they named one, the process they wanted skipped, and who else was in the room. Put it on the register or the speak-up channel — not in a private notebook that dies when you leave. Ministry of Justice guidance on adequate procedures is boring on records for a reason. The SFO will not be impressed that you felt uncomfortable. They will ask what you did. A clean note is what you did. Do not tidy their language into something milder. “To speed the stamp” should stay “to speed the stamp.” Softening it in the write-up is how flags disappear.

You are not there to redesign their workaround until it feels almost compliant. The no is the intervention. If they switch to hospitality, gifts, or a “success fee” that only pays if a decision goes their way, that is the same conversation, not a new friendly one. Repeat that it has to go through process. Then leave the room or the call. Staying to be liked is how “just this once” becomes a series. If they joke that you are being difficult, you can live with that. You cannot live with being the person who knew and helped. Harassment readiness research is at /blog/harassment-policy-benchmark — different harm, same freeze. Speak-up is the skill in both.

Tipping them off so they can “keep it informal” is how you join the arrangement. Your duty is the route, not a courtesy to the person who asked. If you are afraid of retaliation, say that on the speak-up channel too. It is a reason to use the confidential path, not a reason to stay silent. If the asker is a customer who will now be angry, let sales leadership and compliance hold that. Do not take the commercial heat as a bribe to forget. Deals that only exist because someone paid a clerk are deals you should be willing to lose. That sentence is easier in a practice room than in a port. Practise it anyway.

Laughing it off. Paying and claiming it back as taxis. Investigating the other person on WhatsApp. Warning them you might report so they can tidy the trail. Keeping a side note in a private notebook instead of the register. Practise the sentence: I cannot do it that way, I need to take this through our process. Harassment is a different harm, but the same organisations fail both when people freeze — the harassment readiness research is at /blog/harassment-policy-benchmark. This page is practice for the conversation, not legal advice on a live suspicion. Use your speak-up route and the official guidance.