Thank you very much.

This issue has come up a number of times. It's important to remember that the legislation applies to business transactions to retain or gain an advantage; it's not simply any bribe. If you have a payment where someone's in a situation in which they're under duress and they feel they have to pay it, then it's likely not going to be covered by the CFPOA. That's the answer to the question.

I think what you would also like to know is how we deal with it in a scenario.

TI, Transparency International, which is supported by a number of NGOs in humanitarian situations, has guidelines they have put out for how you deal with corruptions in humanitarian scenarios. They have a number of guidelines and best principles. Those guidelines and best principles emphasize monitoring; evaluation; preparation up front to avoid risky environments, such as scenarios where you're going for visas and issues like that; transparency of an organization; reporting up to management; and engagement with law enforcement. Then it refers to scenarios where you may be forced, under duress, to pay. But if you're under duress to pay, you don't have the intent of securing a business advantage.

So our view of the CFPOA and this legislation is that it's not going to affect humanitarian interventions. The support from the major civil society dealing with corruption has been to eliminate bribery. Under the Paris Declaration on Aid Effectiveness, the principle is for us to eliminate bribery, and in the most recent U.N. report in chapter 10 on their commitments to sustainable development for 2015, eliminating bribery is one of the key issues.

Our view is the legislation will not affect humanitarian intervention, and further, the measures proposed are supported by what is going on internationally by civil society and by government.

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