Integrity Vice Presidency

The Integrity Vice Presidency (INT) is an independent unit within the World Bank Group that investigates and pursues sanctions related to allegations of fraud and corruption in World Bank Group-financed projects.  INT supports the main business units of the World Bank Group and external stakeholders, mitigating fraud and corruption risks through sharing investigative findings, advice, prevention and outreach efforts.

Report Suspected Fraud or Corruption


Leadership

Pascale Dubois

Vice President, Integrity Vice Presidency

Stefan Koeberle

Director, Strategy and Operations, Integrity Vice Presidency

Dave Fielder

Manager for Investigation and Forensic Audits, Integrity Vice Presidency

MEDIA CONTACTS
Julia Oliver
Email


HIGHLIGHTS
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Common Red Flags of Fraud and Corruption in Procurement

"Red flags" are indicators of potential issues regarding governance failure, collusion or corruption in projects.

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Integrity Vice Presidency FY2017 Annual Report

INT's FY2017 Annual Report details the World Bank Group’s ongoing commitment to fighting fraud and corruption, which is an integral part of the World Bank's efforts to end extreme poverty and boost shared prosperity.

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Corruption
How Can We Protect the Integrity of Development Projects?

Learn how the World Bank Group works with citizens to fight corruption.

WATCH
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World Bank Listing of Ineligible Firms & Individuals

The firms and individuals listed are ineligible to be awarded a World Bank-financed contract for the periods indicated because they have been sanctioned under the Bank's fraud and corruption policy.

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Frequently Asked Questions

Integrity Compliance at the World Bank Group

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Report Suspected Fraud or Corruption

Concerned about fraud or corruption in World Bank Group-financed projects?

Fill out the online Integrity Complaint Form



External Investigations

Complaint Intake

INT performs an initial assessment of every complaint that it receives.  This assessment determines whether: the complaint relates to a sanctionable practice in World Bank Group-financed projects, the complaint has credibility and the matter is of sufficient gravity to warrant an investigation.  Complaints outside of INT's jurisdiction are redirected to other areas of the World Bank Group as appropriate.  Complaints that fall under INT's jurisdiction are investigated if they are determined to be of a higher priority.  When a complaint does not reach this threshold, INT works with Operational staff to address the issues raised.  In assigning priority, INT also considers the possible reputational risk to the World Bank Group, amount of funds involved and quality of the information or evidence in INT's possession.

Investigation of Cases

Through investigations, INT ascertains whether firms and/or individuals have engaged in one of the World Bank Group's five sanctionable practices.  Since an INT investigation is administrative in nature, the standard of proof is akin to a "balance of probabilities" and therefore lower than the criminal standard of "beyond a reasonable doubt."  The World Bank Group, for that reason, has to prove that it is more likely than not that the alleged misconduct has occurred.  If INT finds sufficient evidence to prove the allegation, the allegation is considered substantiated.  The allegation is considered unsubstantiated if there was insufficient evidence to prove or disprove it, and unfounded if the allegation has no basis in fact.

Investigation Reports

When INT substantiates a case, it produces a Final Investigation Report (FIR).  In some cases, INT will produce an FIR even if there is not reasonably sufficient evidence to substantiate a complaint - for example, if INT believes that the investigation unearthed important lessons that should be shared with colleagues in the World Bank Group.  FIRs are sent to regional management for comment before being finalized and provided to the World Bank Group President.

INT strives to ensure that the maximum time between opening a case and completing an investigation report is twelve (12) months for normal cases and eighteen (18) months for complex cases.

FIRs also form the basis for two other INT outputs: referral reports, which INT sends to relevant national authorities if evidence indicates that the laws of a World Bank Group member country may have been violated; and redacted reports, which are provided to the World Bank Group's Board of Executive Directors and, after the completion of any related sanctions proceedings, posted on this site.


Sanctions

When firms or individuals are found through an INT investigation to have engaged in fraudulent, corrupt, collusive, coercive or obstructive practices, the World Bank Group may impose a sanction such as debarment.  Debarred entities are then ineligible to be awarded a World Bank Group-financed contract, either permanently of for a designated period of time.  Sanctions hold wrongdoers accountable for their misconduct and help deter others from engaging in similar behavior.

Compliance

Conditions for Release from WBG Sanction

Debarment with conditional release was established as the baseline WBG sanction, in part, to place greater emphasis on rehabilitation, such as by requiring sanctioned entities to develop and implement integrity compliance programs that are consistent with the principles set out in the WBG Integrity Compliance Guidelines  also available in Arabic, Chinese, French, Portuguese, Russian and Spanish.  In addition to serving a rehabilitative purpose, the implementation of such a program also seeks to reduce the likelihood of the sanctioned entity engaging in fraud or corruption in the future. 

Engagement with WBG Integrity Compliance Office

Invitation:  All parties sanctioned with conditions for release come into the WBG Integrity Compliance Office portfolio, regardless of how the sanction was imposed.  Following the imposition of such a sanction, the Integrity Compliance Office invites the sanctioned party (entities and individuals) to engage with it in working toward satisfaction of such conditions.  

Steps:  In engaging with a sanctioned entity, the Integrity Compliance Office first seeks to understand matters such as the entity’s: (i) size; (ii) corporate structure; (iii) organizational structure; (iv) operating model; (v) geographical areas of operation; (vi) sectoral areas of operation; (vii) risk profile; and (viii) existing integrity compliance-related controls (including any integrity compliance program).  Throughout the engagement, the Integrity Compliance Office works with the sanctioned entity, as well as independent integrity compliance monitors/advisors in some cases, to recommend enhancements to and assess the effectiveness of the entity’s integrity compliance-related controls.  

Determination: In determining whether a sanctioned entity has met its conditions for release, the Integrity Compliance Officer assesses whether it has put in place integrity compliance-related controls that: (i) are tailored to its risks and profile; (ii) are consistent with the principles set out in the WBG Integrity Compliance Guidelines; and (iii) have a demonstrated record of implementation.  

Collective Action

The ICO also encourages sanctioned parties, as well as released parties, to promote collective action for the advancement of integrity principles, such as through participation in workshops and mentorships.

The Summary of World Bank Group Integrity Compliance Guidelines incorporates standards, principles and components commonly recognized by many institutions and entities as good governance, and anti-fraud and -corruption practices.  They are not intended to be all-inclusive, exclusive or prescriptive; rather a party's adoption of these Guidelines, or variants thereof, should be determined based on that party's own circumstances.


Preventive Services Unit (PSU) was created in January 2008 in response to calls from staff in Operations for relevant, specific advice and assistance in the design of their projects, using lessons learned from the Integrity Vice Presidency's (INT) investigative and diagnostic work.

The creation of a preventive services unit was a key recommendation of the Indepent Panel Review of INT to share best practices in preventing and mitigating risk of fraud and corruption in Bank financed-projects.

The Preventive Services Unit turns the unique knowledge gained from INT investigations, diagnostic and analytical activities into practical advice and training on how to prevent corruption in World Bank-financed projects.

PSU's main objective is to help improve the integrity of Bank Group-supported activities and to enhance the development impact of Bank Group operations by working closely with task team leaders and members in designing pragmatic measures that can mitigate against fraud and corruption risks in projects.


Publications
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    Preventing Fraud & Corruption for Greater Development Impact

    Taking a more comprehensive approach to targeting fraud and corruption, INT provides World Bank Group staff and clients with guidance on how to build preventive measures into projects. The Preventive Services Unit (PSU), working in partnership with operational teams, turns the unique knowledge gained from INT investigations into practical measures that can deter or stop corruption in World Bank Group-financed projects.
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    Fraud and Corruption in Engineering Consultancy Contracts

    This is a study by investigators, for investigators. It focuses not on the big picture but on the small details. It follows a typical procurement process and details the corrupt negotiations and transactions that take place and that have been discovered during investigations. It reports on indicators at all stages that investigators should look for and act on.
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    Curbing Fraud, Corruption and Collusion in the Roads Sector

    This report covers global corruption trends in the roads sector and includes recommendations based on the experience of developed and developing countries. It draws from what INT has learned from its investigations of World Bank Group-financed roads projects; borrowing country governments' investigations and reports; and the experience of developed countries.
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    Most Common Red Flags of Fraud and Corruption in Procurement


Annual Reports