Bribery or undue influence to secure financing or guarantees
Payments or influence are used to steer financing decisions, guarantees, or approvals toward preferred sponsors or delivery models.
Red Flags & Indicators
- Financing or guarantee decisions advance without a transparent rationale and documented criteria.
- Unusual conditions, fees, intermediaries, or side arrangements appear in the financing package and are poorly explained.
- Approvals bypass or alter normal appraisal and budgeting process
- Lack of a track record of funding and financing decisions.
- Material terms change late in the process with limited disclosure or audit trail.
Stakeholder Guidance
Stakeholder Exposure
Exposure includes pressure to offer inducements (often via intermediaries) to secure budget approval or guarantor support; distorted terms and contingent liabilities; delayed and denied financing if refusing; and reputational and legal risks connected to bribery exposure, including internationally.
Decision Point
Before accepting indicative terms or engaging authorities, lenders and guarantors, conduct due diligence checks on stakeholders including financial advisers involved in the project.
Mitigation Actions
• Require dual internal approvals for commitments, fees, intermediaries, and side letters
• Conduct enhanced due diligence on financial advisers, lenders, agents, and intermediaries
• Require transparent fee terms and ban/reject success fees clauses tied to approvals of project funds, private financing, guarantees, or access
• Use internal compliance escalation processes and whistleblower channels, where available, to report internally if any solicitation, facilitation, gift, or “special access” request arises.
Mitigation Resources
Apply anti-bribery controls to financing and guarantee decisions; refuse improper payments, gifts, facilitation, or other inducements intended to influence approvals, and escalate and pause where concerns arise.
Anti-bribery management and controls — https://toolbox.infrastructuretransparency.org/resource/anti-bribery-management-and-controls/Screen financial advisers, agents, intermediaries, and counterparties linked to financing or guarantee decisions; verify beneficial ownership, PEP, sanctions, and related-party risks, and escalate concerns or decline engagement where red flags remain.
Counterparty integrity screening and due diligence — https://toolbox.infrastructuretransparency.org/resource/counterparty-integrity-screening-and-due-diligence/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes endorsing biased financing package; risks of hidden fees; sanctions contagion via sponsors and agents; and delays or write‑downs if approvals are later challenged.
Decision Point
Before term sheet signing, agreeing on guarantees, or committing resources, conduct due diligence checks, including on financial advisers involved in the project.
Mitigation Actions
• Conduct beneficial ownership, PEP checks as well as verification of how fees and commissions are paid to advisers or intermediaries
• Verification of side letters conditions to identify undisclosed benefits
• Condition approval on full disclosure of financing terms, advisory contracts, and payment instructions
• Request clarification on opaque structures, unexplained payments and late provision changes that cannot be properly tracked or audited
• Include anti-corruption covenants as well as audit/information rights
• Include exit rights when covenants are breached, disclosures remain incomplete, intermediaries remain undisclosed and credible bribery allegations arise
Mitigation Resources
Conduct integrity due diligence on sponsors, lenders, advisers, intermediaries, and counterparties involved in financing or guarantee decisions; require full disclosure of beneficial ownership, fee flows, commissions, side letters, and advisory arrangements, and use covenants, monitoring, and escalation triggers before approval, disbursement, or waiver where red flags remain.
Investor integrity due diligence and monitoring — https://toolbox.infrastructuretransparency.org/resource/investor-integrity-due-diligence-and-monitoring/Apply anti-bribery controls to financing and guarantee decisions; refuse improper payments, gifts, or other inducements, and suspend, escalate, or exit where irregular payments, undisclosed intermediaries, or credible bribery concerns arise.
Anti-bribery management and controls — https://toolbox.infrastructuretransparency.org/resource/anti-bribery-management-and-controls/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes authorising funding and guarantees on weak justification; higher fiscal and contingent‑liability; higher audit and legal risks; loss of credibility; and lock‑in to poor financing terms.
Decision Point
Before authorising funding and project financing, review fiscal commitments as well as stakeholders involved in approval processes, including advisers and lenders.
Mitigation Actions
• Publish funding and financial contractual as well as any fees paid to intermediaries
• Publish appraisal documentation as a transparency rule
• Review financing proposals for red flags (unusual commissions, offshore structures, related-party links, and hidden side letters conditions)
• Require explanations for late material term changes in financing conditions
• Refer red flags to independent oversight bodies for investigation, documenting outcomes and corrective actions
• Ensure that the evaluation and approval of project financing are carried out by separate functions
• Maintain a transparent record of meetings and lobbying relations/representation relevant to budget and financing approvals
Mitigation Resources
Apply anti-bribery controls to financing and guarantee decisions; require written records, prohibit improper payments, gifts, hospitality, facilitation, or other inducements intended to influence approvals, and escalate suspected breaches.
Anti-bribery management and controls — https://toolbox.infrastructuretransparency.org/resource/anti-bribery-management-and-controls/Publish and maintain public access to financing and guarantee records, including key terms, evaluation rationale, and reasons for material changes, with only lawful redactions, to support auditability and public accountability.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Require conflict-of-interest declarations, maintain registers, enforce recusal, and document gifts, lobbying contacts, and revolving-door risks affecting financing and guarantee decisions before approval.
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 restricted access to appraisal and financing terms; constrained scrutiny of guarantees and liabilities; and weakened accountability related to project sponsors and financiers.
Decision Point
During the budget allocation cycle and/or pipeline publication, request disclosure of stakeholders involved in the project, including advisers and lenders, as well as contractual and financing arrangements. Decide whether to (a) escalate through oversight channels, or (b) monitor while gathering evidence safely.
Mitigation Actions
• Use access to information to request disclosure of project financing and guarantee terms, advisory contracts, and fees agreements with consultants and advisers
• Cross-check stakeholders named in project contracts with those named in financial and guarantee arrangements to identify potential opaque intermediaries, hidden beneficiaries, and related-party links
• Advocate for early disclosure of complete project financing documentation, financing structure, beneficiaries, and payment flows
• Use oversight channels to raise credible concerns about unexplained commissions, side arrangements, or late term changes linked to project financing (use safe, confidential reporting and anonymisation where retaliation risk is material)
• Advocate for disclosure of project information based on recognised infrastructure data standards such as the OC4IDS
Mitigation Resources
Request access to non-public financing and guarantee decision records, such as committee minutes, approval memoranda, advisory contracts, fee records, or records of changes to financing terms or guarantees, so hidden influence, irregular payments, 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 financing, guarantee, and appraisal records at an early stage; identify disclosure gaps, omitted terms, unexplained changes, or opaque intermediary arrangements, 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/Submit credible complaints or protected reports through safe reporting and oversight channels where irregular payments, undue influence, or unexplained financing changes are identified; use confidentiality and source-protection measures where retaliation risk is material.
Grievance, complaints, and protected reporting — https://toolbox.infrastructuretransparency.org/resource/grievance-complaints-and-protected-reporting/