15.05.2025

The following blog post is a guest contribution and reflects the views and opinions of the original author, which do not necessarily represent those of the Basel Institute. It is shared as-is for informational purposes only.

Image source: © UNICEF/UNI687651/Khan | Emergency supplies of water, sanitation and hygiene arrive at a warehouse run by the United Nations Children’s Fund (UNICEF) in Kabul, Afghanistan.

By Arco Iris Santos and Ken Graversen

In many high-risk countries, companies face a familiar dilemma: delays, red tape and questionable demands from public officials that culminate in requests for small “informal” payments. These facilitation payments, typically small amounts offered to speed up or secure routine services, may seem like a necessary evil. But in reality, they present ethical, operational and humanitarian challenges. Ultimately, they fuel a broader environment of corruption, weaken institutions and undermine the impact humanitarian actors are driving.

At the Fight Against Facilitation Payments Initiative (FAFPI), we believe the private sector has the power to drive systemic change. But not alone. To disrupt the normalisation of facilitation payments, companies must collaborate not just with governments but with each other. This is where collective action becomes a game-changer.

What are facilitation payments and why do they matter?

Delivering accountable, timely and effective responses to the needs of disaster-affected populations, whether in acute or prolonged crises, is a vital and ever-present demand on the humanitarian sector globally. Requests for facilitation payments can pose significant challenges to companies working with humanitarian organisations in emergency response efforts.

Consider, for example, a transport company operating under the World Food Programme-led Logistics Cluster. If stopped at a roadblock checkpoint by a local police officer requesting a “small contribution” – perhaps a food basket for their family – in exchange for allowing the truck to proceed without delay, the company faces a serious dilemma: delay the delivery, risking the lives of people experiencing severe hunger, or give in.

Threats to personal safety, the urgency of a life-saving delivery and the fear of broader consequences leave little room for alternatives. And yet, despite the circumstances, by fulfilling the demand, the company perpetuates a system where officials expect to receive “small gifts” for services that are supposed to be guaranteed and freely available. Moreover, it compromises the principles of neutrality and impartiality that humanitarian organisations uphold, ultimately eroding community trust in humanitarian agencies.

Facilitation payments, as we define them, are small payments, gifts or other benefits made to officials to secure or expedite the performance of a routine or necessary action, which you are entitled to have performed without the incentive. Common forms include cash, a pack of cigarettes, alcohol or even a sandwich.

It is tempting to explain facilitation payments as “just how things are done” in certain regions. And indeed, cultural norms often shape how these transactions are understood and justified. In some contexts, offering a small “gift” might be socially acceptable or even expected. Terms like kitu kidogo (Swahili for “small thing”) or raccomandazione (Italian for “recommendation”) hint at how informal exchanges are woven into daily transactions. These practices reflect deeper social expectations and may emerge in response to systemic inefficiencies or weak public institutions.

But while culture matters, it is not a destiny. Research across Africa, Asia and Latin America shows that these behaviours often emerge not because people inherently approve of them but because formal institutions fail. In contexts where public employees are underpaid, services are unreliable and oversight is weak, individuals may resort to informal practices to navigate daily life. This environment can cultivate informal workarounds such as facilitation payments.

So, rather than blaming culture, the real question becomes: how do we create environments where neither individuals nor companies are pressured into informal payments to access the services they are already entitled to?

The power of collective action

Traditionally, anti-corruption strategies rely on vertical enforcement – top-down mechanisms like transparency mandates, oversight bodies and audits. These are important, especially when paired with strong accountability. But in many high-risk countries, vertical enforcement alone is insufficient. Officials tasked with enforcement may be complicit or under-resourced. Reporting channels might exist on paper but lead nowhere in practice.

The result? Even when facilitation payment requests are exposed, they often go unaddressed.

This is where horizontal enforcement – peer-based accountability among companies – comes in. Rather than relying solely on state-led interventions, horizontal enforcement empowers ethical actors to band together, check each other, create shared standards, apply pressure on outliers and influence public reform.

Take the Maritime Anti-Corruption Network (MACN), a collective action that has brought together companies in the shipping industry to tackle undue port payment requests. Through collective data reporting, stakeholder dialogue and capacity building, MACN has reduced such demands in multiple countries.

FAFPI applies a similar model for facilitation payments. FAFPI collects and aggregates data on facilitation payment demands. By identifying recurring patterns, FAFPI can generate evidence of systemic issues. This data-driven approach supports informed engagement with local authorities in the fight against facilitation payments. This illustrates how horizontal enforcement could work in practice: through collective action, capacity building, coordinated pressure among ethical actors and targeted reform efforts driven by shared intelligence.

The private sector plays a central role in humanitarian response. By joining forces through collective action platforms such as MACN and FAFPI, companies not only protect their reputation but also the people their operations impact.

A call to action

The persistence of facilitation payments not only distorts competition in the corporate world, it also undermines humanitarian efforts by threatening supply lines, inflating costs and eroding trust. As we always emphasise, facilitation payments can be seen as the seeds of bribery and lead to more serious acts of corruption.

Companies, NGOs and donors operating in high-risk countries should not feel compelled to accept facilitation payments as a cost of doing business. Instead, they can proactively shape the ecosystem by joining forces with civil society and peer firms in collective action initiatives like FAFPI.

Uniting affected stakeholders – private sector, humanitarian NGOs and civil society – we can transform facilitation payments from a daily frustration into a shared target for systemic change. If your organisation operates in a high-risk region, consider joining FAFPI or a similar Collective Action initiative to be part of a movement driving meaningful reforms.

Learn more Read the chapter Culture and corruption: a complex relationship in Elgar Concise Encyclopedia of Corruption Law. Learn more about horizontal enforcement in ACE Anti-Corruption Evidence. If you want to know more about FAFPI, visit our website.