Phase 3: Planning & Design

Bribery for favourable impact assessments

Improper payments are made to secure favourable social or environmental impact assessments, facilitating approval despite material risks.

Red Flags & Indicators

  • Assessors or consultants are selected through unclear or non-competitive processes, and possible conflicts of interest or affiliations are not properly disclosed.
  • Baseline data, models, or key assumptions are unclear, incomplete, or presented in ways that reduce the apparent scale of important impacts.
  • Mitigation and monitoring requirements are weakened, delayed, or left without a clear budget, without sufficient evidence or justification.

Stakeholder Guidance

Stakeholder Exposure

Exposure includes pressure to soften or conceal findings; liability for misleading assessments; community conflict over undisclosed, unmitigated impacts; delays and redesign costs; and reputational risk.

Decision Point

Before considering environmental and social impact assessments for design and permit decisions, assess the independence of the process and the strength of the supporting evidence.

Mitigation Actions

• Maintain an auditable record of environmental and social assessments, baseline data, models, and assumptions
• Adopt an anti-bribery policy to prohibit any payments, gifts, or incentives linked to “favourable” findings
• Require conflict-of-interest declarations for environmental and social consultants and assessors, documenting the selection process
• Separate impact assessment work from engagement with officials related to approvals and from any lobbying activities
• Adopt a lobbying policy that sets clear limits on gifts and hospitality and applies to agents and intermediaries
• Use internal compliance escalation processes and whistleblower channels, where available, to report any pressure to alter findings or omit impacts
• Pause engagement and re-scope where integrity or data quality seems compromised

Mitigation Resources

Apply anti-bribery controls to the E&S assessment process; prohibit payments, gifts, or incentives linked to favourable findings, keep a record of important interactions with approving authorities relevant to the assessment or approval process, and escalate any request to alter, delay, or omit findings.

Anti-bribery management and controls — https://toolbox.infrastructuretransparency.org/resource/anti-bribery-management-and-controls/

Require conflict-of-interest declarations and documented conflict management for assessors, consultants, and relevant staff involved in the E&S assessment process; exclude conflicted parties until conflicts are resolved and recorded, and record any prior role in approval or lobbying before relying on the assessment findings.

Conflict-of-interest management and ethics controls — https://toolbox.infrastructuretransparency.org/resource/conflict-of-interest-management-and-ethics-controls/