•Whether the company has a clear and issued policy.
•Whether the company has written guidance available to employees as to the procedures they must follow where a facilitation payment is requested or expected.
•Whether such procedures are really being followed (monitoring).
•Evidence that gifts are being recorded at the company.
•Proper action, collective or otherwise, to inform the appropriate authorities in countries when a breach of the policy occurs.
•The company is taking what practical steps it can to curtail such payments.