Decision Point: How to Justify Facilitation Payments

You meet with Lorna and tell her your idea about using facilitation payments. She thinks this may be a good solution:

$$The facilitation payment approach may work since they're not considered to be bribes under the Foreign Corrupt Practices Act, but instead are considered payments made to expedite performance of duties of a non$-$discretionary nature. If we go in this direction, what would help us argue that these payments would be facilitation payments and not bribes?$$

Which of the following would be your best option?

Select an option from the choices below and click Submit.

The consequences of not making the payment would be severe for the company.

The officials receiving the payment are already obligated to do what the company is paying them to do$.$

Indicating that these payments are bribes would be a violation of Holden$-$Evan$$s code of ethics.