Payment of bribes as inappropriate Gifts, Travel and Entertainment (GTE) often occurs in the early stage of a corrupt relationship. It is a relatively inexpensive way to try to influence the recipients and determine their ethical standards – will they accept the gifts, even if prohibited by the organization’s Gift Policy? If so, larger payments are likely to follow.
The payments may be offered by a party or demanded or extorted by corrupt officials. The benefits often are extended to the official’s spouses or relatives. Inappropriate travel may be covered as “study”or “plant” tours, which may involve a one afternoon tour followed by a paid week at a resort location.
In some areas, including the US, GTE is a primary method of corrupt payments, because, if detected, the parties believe the expenditures can be explained as acceptable business hospitality, with no corrupt intent.
As suggested above, as in all corruption cases, the prosecution must prove that the GTE benefits were offered or received corruptly. This may be proven by direct evidence (e.g., admissions in emails or by witness statements) or circumstantially (e.g., showing that the recipient took steps to improperly favor the gift giver after receiving the benefits).
An important point to note is that the acceptance of inappropriate GTE by officials, even without evidence of corrupt intent, may constitute a Conflict of Interest and be prosecuted as such. Typically the prosecution must prove only that the receipt of the GTE was not disclosed to and approved by the appropriate level of management.