Dilemma 7:  Payment of agent – Answer

If you are a senior manager in a company, you need to be aware of potential corruption risks, must ask appropriate questions, and must take reasonable steps to prevent the corrupt situation.  You must not turn a blind eye to any suspicious situation.  If you are involved in a corrupt transaction (e.g. in the payment of money to a corrupt agent) you could be liable for participating in the transaction if you were put on notice of a potentially corrupt situation but failed to take reasonable action to prevent it.  The payment of a large sum to an agent in a tax haven has put you on notice of a potentially corrupt situation.  You must now make appropriate enquiries to satisfy yourself that the payment is legitimate.  Do not accept unsatisfactory assurances from other managers.  Raise your concerns to a higher level of management.  If you are still not satisfied, refuse to authorise the transaction.