I have been asked to pay

1.2.3.1      A fee

A fee

 A fee is the price one pays as remuneration for services. However, “unofficial fees” can be a form of hidden corruption or in some cases seen as facilitation payments. Therefore, you should be careful when being asked to pay unexpected fees in cash.

Make the payment if it’s clear that the fee is official, fixed and published and if it has been asked for in an open and transparent way. Obtain a receipt detailing the reason for and the amount of the charge. Record the transaction appropriately in your expenses claim.

When this is not the case you should strongly resist any demand for this kind of payment. The reason for this is that you are being asked to make an unauthorised payment. Paying a small sum of money to an official to perform their normal or routine duty or function, or to speed up their actions is known as a facilitation payment.

In Stora Enso we never make facilitation payments and we do not allow others who work for or represent us to make them. No matter how small the amount demanded facilitation payments are illegal in most countries in the world and also prohibited according to Stora Enso rules.

If you are asked to make a facilitation payment:

  • Remain calm and be prepared to wait.
  • Remain courteous, respectful and if possible friendly.
  • Ask for name and official title of person asking and any identity number.
  • Suggest that you would need an official receipt if you were to pay the fine.
  • Make it clear that as an employee of the company you are not allowed to make this kind of payment.
  • Ask to speak to the supervisor/manager of the person making the demand to discuss why you can’t pay.
  • Mention that you will contact the embassy / consulate to discuss / report the issue.
  • Explain that you must call your company first to report the issue and to get permission to pay the fee.
  • Take notes or make mental note of the conversations and the time and place for a later report.

On rare occasions you may be coerced or forced into paying. If your safety or liberty or that of a family member is threatened, then you should pay.

However, we recognise that there may be exceptional circumstances, where the health and safety of an employee could be at risk if a Facilitation Payment is not made. If you find yourself in danger, you may make the payment and promptly report it to Legal, Ethics and Compliance.

In the event you are asked to pay a fee you suspect to be a Facilitation Payment, you should promptly make a report to Legal, Ethics and Compliance.

1.2.3.2      A donation (Charitable contribution)

A donation (Charitable contribution)

A request for a donation may be a legitimate request for or a charitable contribution with no ulterior motive but if there is a tender, bid, contract or other negotiation process currently running between this person or their company, the request for a donation of any sort at this time is inappropriate.

Do not be embarrassed to ask to see evidence of the donation and the reason for it.

In Stora Enso all Donations must be approved by the CEO or the CFO so you should never make any commitments to make Donations without having consulted Division Management and Legal, Ethics and Compliance.

Please remember, that any questions regarding Donations should be reviewed with Legal, Ethics and Compliance.

1.2.3.3      A bribe

A bribe

 Stora Enso has a zero tolerance to any kind of corruption including bribery. This means that you under no circumstances may pay a Bribe. Any form of bribery is illegal even if done unintentionally.

If you have been asked to pay a Bribe in any form:

  • Decline and clearly state Stora Enso does not accept corruption and bribery in any from.
  • Record all the details you have about the request (time, date, by whom and how it was asked for).
  • Contact Legal, Ethics and Compliance, the Legal department or your manager for further assistance.

If you have been asked to pay a bribe or have questions regarding Bribes please contact Legal, Ethics and Compliance.

1.2.3.4      A cash payment

A cash payment

 In Stora Enso we always reflect our business transactions openly, accurately and fairly in the accounts of the company.

Making a cash payment is not a standard business procedure. There is a risk that you are being asked to authorise a payment that is a Bribe or a Facilitation Payment. Approving an irregular payment to facilitate business processes could be a form of bribery which is illegal even if done unintentionally.

Investigate the reasons for the cash payment further before taking any action. Record all the details you have about the request (time, date, by whom and how it was asked for).

Any doubts about a cash payment however small should be raised with Legal, Ethics and Compliance before doing anything.

 If you have been asked to pay a cash payment, please contact Legal, Ethics and Compliance.

1.2.3.5      A Facilitation Payment

A Facilitation Payment

Paying a small sum of money to an official to perform their normal or routine duty or function, or to speed up their actions is known as a Facilitation Payment.

In Stora Enso we never make facilitation payments and we do not allow others who work for or represent us to make them. No matter how small the amount demanded facilitation payments are illegal in most countries in the world and also prohibited according to Stora Enso rules.

If you are asked to make a facilitation payment:

  • Remain calm and be prepared to wait.
  • Remain courteous, respectful and if possible friendly.
  • Ask for name and official title of person asking and any identity number.
  • Suggest that you would need an official receipt if you were to pay the fine.
  • Make it clear that as an employee of the company you are not allowed to make this kind of payment.
  • Ask to speak to the supervisor/manager of the person making the demand to discuss why you can’t pay.
  • Mention that you will contact the embassy / consulate to discuss / report the issue.
  • Explain that you must call your company first to report the issue and to get permission to pay the fee.
  • Take notes or make mental note of the conversations and the time and place for a later report.

On rare occasions you may be coerced or forced into paying. If your safety or liberty or that of a family member is threatened, then you should pay.

However, we recognise that there may be exceptional circumstances, where the health and safety of an employee could be at risk if a Facilitation Payment is not made. If you find yourself in danger, you may make the payment and promptly report it to Legal, Ethics and Compliance.

In the event you are asked to pay a fee you suspect to be a Facilitation Payment, you should contact Legal, Ethics and Compliance.

1.2.3.6      I feel I am in danger

I feel I am in danger

 We recognise that there may be exceptional circumstances, where the health and safety of an employee could be at risk if a bribe, a cash payment or facilitation payment is not made.

On rare occasions you may be coerced or forced into paying. If your safety or liberty or that of a family member is threatened, then you should pay.

However, we recognise that there may be exceptional circumstances, where the health and safety of an employee could be at risk if a Facilitation Payment is not made.

Stora Enso shall not take disciplinary action against any officers or employees who make a payment in such circumstances if they genuinely believe that they would have been put in danger if they had not done so, provided that the employee promptly notifies Legal, Ethics and Compliance.

If you find yourself in danger, you may make the payment and promptly report it to Legal, Ethics and Compliance.

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