ABC Crossword Challenge

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Across
  1. 2. Another name for facilitation payments is ______ payments.
  2. 7. Offering, receiving or promising anything of value to gain an unfair advantage.
  3. 8. We must never initiate a ________ payment.
  4. 10. Avoid even the _________ of a conflict of interest.
  5. 12. Offering, receiving or promising anything of value to gain an unfair advantage.
  6. 13. _______ being alone when meeting public officials.
Down
  1. 1. ________ Support is contributing anything of value towards a political goal.
  2. 3. An exceptional _______ is an exception to never paying a facilitation payment.
  3. 4. All forms of social amenity, entertainment, travel or lodging, or invitation to to an event that is offered, promised, given or received.
  4. 5. Gifts must never oblige the ______ to the giver.
  5. 6. Any payment, gratuity, gratification, present or advantage offered, promised, given or received without any direct or indirect material or immaterial compensation.
  6. 9. ______of Interest.
  7. 11. Directly or indirectly communicating with public officials, including politicians.