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COMMITTEE TO ADDRESS FACILITATING PAYMENTS (C.A.F.P.

MISSION STATEMENT: Global companies working together to address the potential future demand/risk of facilitation type payments in a thoughtful, proactive and appropriate manner. DESCRIPTION:
Country-by-country, a consortium of companies will form an industry commercial sponsored committee to address the demand/risk of potential facilitation payments in that country; C.A.F.P. A Global Steering Team of 8 to 10 global companies will be involved in selecting countries/areas of interest, and providing general oversight. For each country selected, companies doing business in that country will be encouraged to participate (10 to 15 companies, potentially representing various industries) on the C.A.F.P. Participation does not infer a company is involved in such payments; simply the company is providing collective support to reduce likelihood of future requests especially in countries where such payments have historically been common for nationals and companies - the C.A.F.P. focus will be on potential demand or risk. Participating companies will be requested to share any approved and necessary legal expenditures based on an agreed to formula. All recommended charter, joint representation agreements and anti-trust protocol will be put in place.

Two to three participating companies will be requested to act as a steering team for the country C.A.F.P. (Country Steering Team). Sharing of proprietary information by any member will be on a purely voluntary basis. C.A.F.P. will decide on retention of outside counsel. Will consider whether each C.A.F.P. will retain 1) UKBA Counsel, 2) FCPA Counsel, and/or 3) local country counsel. Outside counsel may provide assistance on a pro bono basis. Participant companies may decide to involve their own outside or in-house counsel. The C.A.F.P. Country Steering Team will develop a detailed action plan to address each area where facilitation payments may arise - for example, visa processing, work permits, customs clearance, overtime work, border crossing, etc. The action plan will include a detailed plan to address the potential demand for facilitation type payments in the country. It is anticipated that the plan would include agreed upon meetings with country government officials. The country C.A.F.P. may request the assistance of a global or regional NGO. 1/12

ADDRESSING POTENTIAL FUTURE DEMAND/RISK OF FACILITATION TYPE PAYMENTS

THE THREE Ps
In addressing the potential future demand/risk, all of the below should be carefully considered. 1. Procedures the What
What are the government process legal requirements? Do the legal requirements cover all business needs including emergency situations? Are there Government Service Fees that should be clarified or better documented including having published guidelines, fee schedules or process for obtaining receipts (ex. weekend clearance, expedited processing, expense allowances, etc.)?

2. Processes the How


What individuals/positions are involved in the government process approvals? How is required documentation handled or moved from one area to another? How are required fees paid (cash, check, wire transfer)? What is the degree of automation for filings, responses, etc.? Can it be improved?

3. People the Who


Are officials adequately trained and educated that side payments are not allowed? Are officials compensated for specific services provided such as overtime, travel, etc.? Are officials fairly compensated by the government for their jobs?

Focused on the 3 Ps, C.A.F.P. will proactively work with organizations to identify business situations or processes where future demand for small side payments could arise. C.A.F.P. will also identify processes that are not well understood or publicly documented. Such effort will benefit the country and businesses by encouraging additional economic development through increased transparency and clarity in business transactions.
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