The U.K. Bribery Act, however, does not allow for such facilitation payments. Does the U.K. Bribery…

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➤ How should D&R adapt commercial practices if facilitation payments are common in a market?
Begin with a country-specific risk assessment and strengthen third-party due diligence. Update procurement rules and contracts to ban facilitation payments and require written escalation for requests. Train staff on refusal and reporting protocols, use local legal advice to find lawful alternatives, and document every interaction to protect the company and preserve bid integrity.

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