Grease

Kofi, we can't pay. No facilitation exemption under UK law. Two thousand dollars or two million — same offence.

Laws don't move containers, Alexa. What's the plan?

Three things. Document the demand — date, time, words, the official's name. I'll contact Austrade in Accra. Can you get me a reputable local broker?

Yaw Boateng — cleared shipments for Vinci and Skanska. Not cheap, but legitimate. I'll send his details.

Good. And Kofi — thanks for calling first. A lot of people wouldn't have.

I've seen what happens when people don't. It doesn't end well.

Kofi, before we do anything, I need you to ask the customs official one question: can you get an official government receipt for this payment? Issued by the Ghana Revenue Authority, with a reference number?

Alexa, I know what you're doing. You're trying to find out if it's a real fee or a bribe. I can tell you right now — there's no receipt. There never is.

Then we can't pay it. But I need you to ask formally, so we have a record of the response.

Fine. I'll ask. But when he says no — and he will say no — what's the plan?

Kofi, go ahead and pay the two thousand. Record it as port handling fees in the project accounts. Let's get the shipment moving.

Are you sure? I want you to be very clear about this, Alexa. I'm not going to be the one holding the bag if someone asks questions.

I'm sure. The commercial exposure is fifty thousand plus. Two thousand to make it go away is a business decision.

It's your call. I'll handle it. But Alexa — I want this in writing. An email from you authorising the payment.

Sarah Park is standing behind her desk when you arrive. She doesn't sit down.

Alexa, I've just had the MD on the phone. He's had the main contractor on the phone. They're talking about termination for default. Do you understand what that means for this company?

I understand the commercial position, Sarah.

Good. Then help me understand the compliance position. Because right now, the compliance position is costing us eight and a half thousand pounds a day. Starting Monday.

The customs official in Accra is demanding a payment. Under the Criminal Code (Cth)—

I don't need a lecture on the Criminal Code (Cth), Alexa. I need a solution. We're looking at fifty thousand plus in LDs, potential termination of a two-point-four million pound contract, and reputational damage with the main contractor we can't put a number on.

I'm not telling you to pay anyone anything. I'm telling you: find a way. That's what compliance is for, isn't it? Finding ways to do business without breaking the law?

Sarah, here's the other side. Criminal Code s.70.2: paying a foreign public official for business advantage. Ten years' prison. Unlimited fines. The AFP prosecuted Securency / NPA in 2021 — A$77 million.

Securency was millions in bribes. This is two thousand dollars.

No minimum threshold. And there's a corporate offence — Criminal Code s.70.5A, 'failure to prevent foreign bribery'. If anyone at Meridian pays, and we can't show adequate procedures, the company is liable.

So what do you propose? 'Don't pay' isn't a solution.

Kofi's engaging Yaw Boateng — broker who's cleared shipments for Vinci and Skanska. I'm contacting the Austrade commercial team. And I'll write formally to the Ghana Revenue Authority requesting clarification. Boateng says 5-7 working days if our docs are in order.

That's another forty to sixty thousand in LDs.

Versus criminal prosecution, debarment, and a conviction that follows Meridian for decades. I know which number is bigger.

Sarah, I think this decision needs to go to Helen. Commercial exposure and criminal exposure are both significant. This is a board-level risk call.

You want me to tell the CFO that compliance can't give me a clear answer on a two-thousand-dollar payment?

I can give you a clear answer: the payment is illegal under UK law. What I can't do is unilaterally accept fifty thousand pounds in commercial losses. That's a decision for someone with budget authority.

Fine. I'll set up the call. But Alexa — Helen is going to ask you the same question I'm asking. Have a better answer ready.

Sarah, I'm looking into options. I'll have an update for you by end of day Friday.

Friday? Alexa, LDs start Monday. I need an answer today, not a status update on Friday.

I understand the urgency. I'm exploring alternative channels to clear the shipment without—

Without what? Without paying? Alexa, I asked you to find a way. If you can't, tell me now so I can find someone who can.

Alexa drafts the Facilitation Payments Policy over the following two weeks. 14 pages, with appendices covering 6 countries where Meridian operates or is tendering.

The policy has five pillars: prohibition, pre-approved alternatives, mandatory reporting, country-specific protocols, quarterly review. I'm proposing a customs broker retainer in Ghana, Nigeria, and Kenya — approximately A$8,000 per year per jurisdiction.

Twenty-four thousand a year for customs brokers?

The Ghana incident cost us fifty-four thousand in five days, Sarah. A retainer means the broker is already engaged when the next shipment arrives. No delay, no scramble, no Thursday meetings.

Put it in the board paper. I'll support it.

Alexa updates the ABC training module to include a section on facilitation payments and emails the AFP's published position to all country managers.

Alexa, I read the AFP guidance you sent. It's useful — but it doesn't tell me what to do next time a customs official asks for money. Do I call you? Do I call a broker? Who's paying for the broker?

Call me. Same as this time.

And if it's a Friday afternoon and you're not answering your phone?