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
• 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/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes hidden impacts; ESG backlash; a higher risk of stoppages, litigation, and cost escalation; decrease of project value; and reputational risk.
Decision Point
Before signing the term sheet and committing resources, request environmental and social impact results or commission an independent review.
Mitigation Actions
• Verify consultant independence, conflicts, data integrity and reproducibility
• Condition financing on disclosure of complete assessment findings, mitigation commitments, budget allocation for monitoring and mitigation plan compliance, and covenants covering mitigation compliance and progress reporting
• Request enhanced due diligence and review assessment when findings or mitigation requirements change materially without evidence or when pressure, conflicts or irregularities are reported
Mitigation Resources
Apply anti-bribery controls to impact assessment processes; prohibit payments, gifts, or incentives linked to favourable findings, condition support on formal channels and auditable records, 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/Appoint an independent technical adviser to review impact assessments, test key assumptions, verify consultant independence, and challenge findings or mitigation plans that lack evidential support.
Independent technical due diligence and monitoring — https://toolbox.infrastructuretransparency.org/resource/independent-technical-due-diligence-and-monitoring/Require conflict-of-interest declarations and documented conflict management for advisers and reviewers involved in impact assessments; exclude conflicted parties until conflicts are resolved and recorded, and record gifts, financial interests, and any prior role in project 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/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes approvals based on biased environmental and social impact assessments; a higher risk of legal challenges and project stoppages; community conflict over undisclosed, unmitigated impacts; and loss of trust in safeguards.
Decision Point
Before approving environmental and social impact assessments, verify the credibility of the findings and the team responsible for preparing the analysis, and return them for correction and further verification if the findings are not reliable and based on evidence.
Mitigation Actions
• Require early, meaningful social consultation, recording feedback on social and environmental impacts
• Publish environmental and social impact assessments, along with mitigation plans and monitoring commitments as a transparency rule
• Publish project information based on recognised infrastructure data standards such as the OC4IDS
• Ensure consultant independence and manage conflicts (selection, declarations, recusals)
• Maintain a record of approvals and decisions issued during the preparation of environmental and social impact assessments, along with an evidence file containing reproducible data and models where applicable
• Refer credible allegations of bribery or manipulation to independent oversight bodies for investigation, documenting outcomes and corrective actions
• Pause permitting decisions pending review of challenged assessments, documenting outcomes and corrective actions
• Ensure confidential channels for whistleblowers and complainants, and enforce non-retaliation measures
• Commission independent review when assessments are weak or contested
Mitigation Resources
Set and enforce anti-bribery controls for impact assessments; prohibit unofficial payments, gifts, or incentives linked to assessment findings, keep a record of important interactions with applicants and assessors relevant to the assessment or approval process, and refer credible bribery allegations through formal channels.
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, reviewers, and approving officials involved in impact assessments; exclude conflicted parties until conflicts are resolved and recorded, and record gifts, financial interests, and any prior role in approval or lobbying before review or approval.
Conflict-of-interest management and ethics controls — https://toolbox.infrastructuretransparency.org/resource/conflict-of-interest-management-and-ethics-controls/Publish and maintain public access to impact assessment records, including key findings, consultant declarations, mitigation and monitoring commitments, review comments, and reasons for approval, with only lawful redactions.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes biased environmental and social impact findings; restricted access to assessment data; limited ability to assess and test mitigation measures; unmitigated community harm; conflict over undisclosed impacts; and risk of retaliation against communities.
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 environmental and social impact assessments. Decide whether to (a) escalate through oversight channels to report material gaps, or (b) monitor while safely gathering evidence.
Mitigation Actions
• Mobilise communities around the importance of full transparency in environmental and social impact processes, and the need to ensure 'Free, Prior and Informed Consent'
• Collect community evidence on actual impacts and on the types of consultation and engagement processes conducted
• Engage oversight bodies to raise concerns about manipulated assessments, implausible baselines and relevant omissions (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
Compare disclosed impact assessment findings and mitigation commitments with observed impacts, consultation records, and community evidence; document gaps between the published assessment and on-the-ground conditions, and escalate unexplained discrepancies through oversight channels.
Independent monitoring, assurance, and social accountability — https://toolbox.infrastructuretransparency.org/resource/independent-monitoring-assurance-and-social-accountability/Request access to non-public impact assessment records, such as baseline studies, reviewer comments, or records explaining changes to findings or mitigation measures, so suspected manipulation, omitted impacts, or unexplained changes 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/Review publicly disclosed impact assessment records at an early stage; identify omitted impacts, weak mitigation commitments, unexplained changes, or gaps in disclosure, and raise concerns about non-disclosure with an oversight body.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/