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Integrity Vice Presidency

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Sanctions & Compliance

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 may impose a sanction such as debarment.  Debarred entities are then ineligible to be awarded a World Bank-financed contract, either permanently 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 Sanction

Debarment with conditional release was established as the baseline World Bank 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 Integrity Compliance Guidelines  also available in ArabicChineseFrenchKoreanPortugueseRussian 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 Integrity Compliance Office

Invitation:  All parties sanctioned with conditions for release come into the 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 Integrity Compliance Guidelines; and (iii) have a demonstrated record of implementation.  

Collective Action

The Integrity Compliance Officer 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.