Facilitating Payments. For the avoidance of doubt, facilitating payments (otherwise known as “greasing payments” and defined as payments to an individual to secure or expedite the performance of a routine government action by government officials) are no exception to the general rule and therefore prohibited. GLOSSARY The terms defined herein should be construed broadly to give effect to the letter and spirit of the GSK Policy 007. GSK is committed to the highest ethical standards of business dealings and any acts that create the appearance of promising, offering, giving or authorising payments prohibited by this policy will not be tolerated. Anything of Value: this term includes cash or cash equivalents, gifts, services, employment offers, loans, travel expenses, entertainment, political contributions, charitable donations, subsidies, per diem payments, sponsorships, honoraria or provision of any other asset, even if nominal in value. Payments: this term refers to and includes any direct or indirect offers to pay, promises to pay, authorisations of or payments of anything of value. Government Official shall mean: Any officer or employee of a government or any department, agency or instrument of a government; Any person acting in an official capacity for or on behalf of a government or any department, agency, or instrument of a government; Any officer or employee of a company or business owned in whole or part by a government; Any officer or employee of a public international organization such as the World Bank or United Nations; Any officer or employee of a political party or any person acting in an official capacity on behalf of a political party; and/or Any candidate for political office
Facilitating Payments. For the avoidance of doubt, facilitating payments (otherwise known as “greasing payments” and defined as payments to an individual to secure or expedite the performance of a routine government action by government officials) are no exception to the general rule and therefore prohibited. GLOSSARY The terms defined herein should be construed broadly to give effect to the letter and spirit of the ABAC Policy. GSK is committed to the highest ethical standards of business dealings and any acts that create the appearance of promising, offering, giving or authorising payments prohibited by this policy will not be tolerated.
Facilitating Payments otherwise known as “greasing payments” shall mean a payment to an individual to secure or expedite the performance of a routine government action by government officials.
Facilitating Payments. For your Engagements with World Class Education, World Class Education may remit payments for commissions or other payment obligations owed to you through World Class Education Platform. World Class Education, as a service to Instructors, has agreed to remit such monies to you or, in the case of any adjustments for errors or otherwise under the Engagement with the World Class, return all or a portion of the monies to the Instructors. You acknowledge and agree that such payments are made to and for the benefit of you only, and not to, or for the benefit of, or for the account of World Class Education, and not for or on account of any debt of the World Class Education. You also acknowledge and agree that with respect to your Engagements with World Class Education, World Class Education is merely facilitating payments between the Instructors and its students and that World Class Education is merely a conduit for such Instructors payments to you. World Class Education agrees that it will not use any monies for such payments to you for World Class Education’s own use or purposes except for the charges and/or offsets that you have agreed to in this Agreement. You agree that World Class Education shall have no liability to you for performing the function of processing payments from Instructors and you under Engagement.
Facilitating Payments. What Are These and Are They Allowed? In some countries, it may be the local practice for businesses to make payments of small amounts to low-level government officials in order to expedite or “facilitate” routine government actions over which such officials have no discretion. Examples of routine, non-discretionary actions include providing police protection, granting visas or utility services, or clearing customs. Such payments are called “facilitating payments”. Facilitating payments, whether legal or not in a country, are prohibited under this policy. In extremely limited circumstances, however, LS&CO. may permit facilitating payments. You must consult the Regional Compliance Officer or Chief Compliance Officer BEFORE making or authorizing such a payment. Specific approval for each payment is required. If any such payments are approved, they must be accurately documented in the company’s books and records. LS&CO. recognizes that its personnel operating outside of the U.S. may confront situations where payment is demanded to avoid physical harm. In these very limited circumstances, “Personal Safety Payments” may be made. Examples of such circumstances include: • Being stopped by persons claiming to be police, military, or paramilitary personnel, who demand payment as a condition of passage of persons; • Being threatened with imprisonment for a routine traffic or visa violation unless a payment is made; and • Being asked by persons claiming to be security personnel, immigration control, or health inspectors to pay for (or to avoid) an allegedly required inoculation or similar procedure. Only under these or similar circumstances, and only where there is an imminent threat to the health or safety of LS&CO. personnel, may a Personal Safety Payment be made without prior approval. If the need for a Personal Safety Payment can be anticipated, or if circumstances permit, the Regional Compliance Officer should be consulted before making any payment. After a Personal Safety Payment is made, and as soon as possible (but no more than seven days) after the danger has passed, the payment must be reported to the Regional Compliance Officer, and on an expense report, reflecting accurately the amount paid, the recipient, the means of payment, and the circumstances under which the payment was made. The Regional Compliance Officer will investigate and document the circumstances surrounding the Personal Safety payment and work with LS&CO. finance department to ensure that t...
Facilitating Payments. Anti-bribery laws permit payments to government officials in limited circumstances for the purpose of facilitating or expediting the administrative performance of routine governmental actions. No such payments may be made, however, without obtaining the prior approval of the designated compliance officer of the Company.
Facilitating Payments. A facilitating payment is a small payment to secure or expedite a routine government action by a non-U.S. government official, such as obtaining a visa. Facilitating payments are impermissible under the local laws of the countries where Insmed does business and are prohibited under Insmed policy.
Facilitating Payments. DISTRIBUTOR represents, warrants and covenants that no gratuity, gift or payment of any nature has been, or will be accepted or made where the intent of the offeror was, or is, to influence unlawfully the entering into or performance of this Agreement. DISTRIBUTOR also represents, warrants and covenants that any facilitating gratuity or gift offered or made that is expressly permitted under the FCPA and the terms of this Agreement shall meet the following conditions:
Facilitating Payments. Seller will make no facilitating payment in any form to any government official on behalf of Halliburton for the purpose of expediting or securing the performance of a routine, non-discretionary governmental duty or action.
Facilitating Payments. 5.1.1. There are limited circumstances in which the member of the Group concerned may be permitted to make a payment to a government official without violating the applicable Anti-Corruption Laws. Some Anti-Corruption Laws have a narrow exception for what are known as “facilitating payments” – payments to government employees to expedite or secure the performance of a routine governmental action (Facilitating Payments). Under this exception, for example, it may be permissible to make a Facilitating Payment to obtain permits, licenses or other documents to allow the member of the Group concerned to do business in a certain country; to process governmental papers such as visas and work orders; to provide police protection, mail pick-up and delivery or scheduling inspections; or to provide phone service, power and water supplies, or loading and unloading of cargo.
