Bribery and extortion for permits, approvals and safeguards sign‑off
Procurement officials, regulatory bodies and gatekeepers demand bribes to issue approvals (planning, environmental, social, utility, right of way) and to sign-off on safeguards.
Red Flags & Indicators
- Requests or indirect pressure are made for gifts, facilitation payments, or the use of intermediaries to speed up approvals or avoid negative findings.
- Permit or inspection procedures involve repeated delays, changing requirements, or unexplained refusals that do not follow the standard process.
- Some applicants receive faster or more favourable treatment without clear and consistent criteria.
- Permit conditions or safeguard requirements are changed or applied in ways that weaken obligations or create room for discretionary decisions.
Stakeholder Guidance
Stakeholder Exposure
Exposure includes pressure to pay via intermediaries; schedule and cost escalation; and increased reputational and debarment risk if such conduct becomes public.
Decision Point
When permit or safeguard approvals stall or solicitation signals arise, refuse any improper payments and escalate through internal compliance channels.
Mitigation Actions
• Adopt a zero-tolerance policy regarding facilitation payments
• Adequate records of all engagements related to obtaining permits, approvals, and safeguards, including communications and meetings with officials, intermediaries, private partners, company employees, requests, and decisions
• Use formal channels to submit permits and safeguard requests
• Whistleblower policy for reporting solicitation or extortion
• Consider using judicial courts to obtain injunctions imposing the issuance of required approvals and sign-offs
Mitigation Resources
Apply anti-bribery controls to permit submissions and safeguard sign-off; log official contacts, prohibit facilitation payments, and escalate and pause where requests for unofficial payments, gifts, or favours arise.
Anti-bribery management and controls — https://toolbox.infrastructuretransparency.org/resource/anti-bribery-management-and-controls/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes permit delays that stall progress; compliance risks spreading through contractors; cost escalation and claims; and risk of pause or suspension if integrity concerns persist.
Decision Point
At permitting milestones, decide whether to continue or pause disbursements, proceeding only when permits are verified or incidents are reported through appropriate channels.
Mitigation Actions
• Treat credible solicitation and extortion concerns as a disbursement risk
• Include covenants requiring anti-bribery controls for permitting and inspections, the use of formal channels, and prompt incident reporting
• Provide suspension and exit rights in cases of unresolved or unreported incidents
• Request independent review when permitting outcomes show unexplained discretion, repeated delays tied to informal contacts, or weakening of safeguard conditions without written justification
Mitigation Resources
Condition support on anti-bribery controls for permit and safeguard approvals; require use of formal channels, written logs of contacts with permitting officials, and prompt reporting of bribe, extortion, or facilitation-payment demands.
Anti-bribery management and controls — https://toolbox.infrastructuretransparency.org/resource/anti-bribery-management-and-controls/Conduct integrity due diligence on permitting and safeguard approval processes and the parties involved; require complete permit files, interaction logs, and written reasons for delays or weakened conditions, and trigger enhanced review or pause support where solicitation, repeated delays, or unexplained discretion is identified.
Investor integrity due diligence and monitoring — https://toolbox.infrastructuretransparency.org/resource/investor-integrity-due-diligence-and-monitoring/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes a weakened perception of integrity; non-compliant approval processes; increasing liability; audit, investigation, and legal challenge risk; and loss of public trust.
Decision Point
Before issuing permits and approvals, require compliance checks, returning or refusing with documented reasons and audit trail.
Mitigation Actions
• Publish requirements and reasons for approvals, denials and any deviations from standard process
• Separate assessment, inspection, and approval roles
• Maintain a permit decision register with disclosure logs and an auditable file for each permit
• Refer credible solicitation/extortion concerns to independent oversight bodies for investigation, documenting outcomes and corrective actions
• Ensure confidential channels for whistleblowers and complainants, and enforce non-retaliation measures
Mitigation Resources
Set and enforce anti-bribery controls for permit decisions and safeguard sign-off; require contact logs, prohibit facilitation payments, and refer bribery or extortion allegations through formal channels.
Anti-bribery management and controls — https://toolbox.infrastructuretransparency.org/resource/anti-bribery-management-and-controls/Set approval limits, sign-off steps, and separation of duties for permit decisions and safeguard sign-off; ensure no single official assesses, approves, and records the same case.
Approval authority and segregation of duties — https://toolbox.infrastructuretransparency.org/resource/approval-authority-and-segregation-of-duties/Publish and maintain public access to permit and safeguard records, including criteria, fees, timelines, decisions, reasons for approval or denial, and any deviation from standard process.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes weakened safeguards and approvals; increased community harm; restricted access to permit and safeguard records; limited accountability; and risk of retaliation when reporting bribes.
Decision Point
At the time of pipeline publication or, where it is not available, during site mobilisation, submit access to information to request clarification on permits, approvals and safeguards processes. If access is declined or information is incomplete, decide whether to (a) escalate through oversight channels, or (b) monitor while safely gathering evidence.
Mitigation Actions
• Mobilise communities around the importance of full transparency in permits, approvals, and safeguard processes, given their social and environmental impacts
• Mobilise communities to collect and document reports of solicitation, extortion, or coercion linked to permit and safeguard inspections
• Engage oversight bodies to raise concerns about delays in the issuance of permits and safeguards connected to solicitation, extortion and coertion (use safe, confidential reporting and anonymisation where the risk of retaliation is significant)
• Advocate for disclosure of project information based on recognised infrastructure data standards such as the OC4IDS
Mitigation Resources
Submit protected complaints or reports through independent complaints, ombud, audit, or other oversight channels where bribery, extortion, or coercion affects permit decisions or safeguard sign-off; document evidence and timelines, and use source-protection measures where retaliation risk is material.
Grievance, complaints, and protected reporting — https://toolbox.infrastructuretransparency.org/resource/grievance-complaints-and-protected-reporting/Request access to non-public records on permit decisions and safeguard sign-off, such as fee schedules, decision notes, inspection records, or reasons for delay or denial, so suspected bribery, extortion, or coercion can be examined and raised through oversight channels.
Access-to-information and demand-side transparency — https://toolbox.infrastructuretransparency.org/resource/access-to-information-and-demand-side-transparency/