Project Anti-Corruption System (PACS)
PS 11: Reporting
(Note: Please refer to the Frequently Asked Questions (FAQs) at the end of this PACS Standard for further guidance on this standard)
This PACS Standard makes the following recommendations in relation to reporting of potential or actual corruption.
There should be safe and effective mechanisms for reporting suspected or actual corruption in relation to the project.
Each major project participant should do the following:
(1) It should instruct its officers and employees as follows:
(a) It should request its employees to report corruption, suspicion of corruption or any cause for concern;
(b) It should require its senior managers and senior officers to report corruption, suspicion of corruption, any cause for concern, and any failure to comply with anti-corruption commitments;
(c) Reports should be made using the organisation’s reporting channels, unless the reporting individual fears that these procedures are not safe or will not be effective. These reporting channels should be fully explained to the officers and employees.
(2) It should set up reporting channels which ensure that:
(a) its officers and employees can make reports in a safe and confidential manner;
(b) reports may be made anonymously;
(c) these reports will be passed on confidentially to the organisation’s compliance manager (see PS 9);
(d) the compliance manager will be instructed to investigate the matter and, where he considers there is cause for concern, he will report the matter to senior management;
(e) the reporting officer or employee will be confidentially informed as to the follow-up action that is being taken.
(3) If it believes there is evidence of corruption or breach of any anti-corruption commitment, it should, within 7 days, report the relevant facts to the independent assessor (see PS 1).
The independent assessor should be required to make reports to other project participants, professional bodies and the criminal authorities, in accordance with his terms of appointment.
In order to enable the public to report suspected or actual corruption in relation to the project, the project owner should do as follows:
(1) It should publish the contact details of the independent assessor (apart from his home address where he is an individual). It should also publish details which will help to assure the public of the qualifications, integrity and independence of the independent assessor. (See PS 2)
(2) It should inform the public that reports of corruption or suspicion of corruption may be made to the independent assessor, anonymously or otherwise. (See PS 2)
(3) It should ensure that the reporting individual is confidentially informed as to the follow-up action that is being taken.
Frequently Asked Questions
FAQ (1): Why is it important to have proper reporting mechanisms?
Corruption will only be materially reduced or prevented if individuals are aware that there is a real probability that corrupt activity will be reported, and that it will then be properly investigated and prosecuted. In order for reports of corruption to be made, individuals who wish to make a report need to be confident that they will not be subject to discrimination or physical harm, and that their reports will be properly investigated. Consequently, safe and reporting mechanisms must be set up.
FAQ (2): Who are the “major project participants”?
These are the project participants whose role in the project could result in significant corruption. Consequently, this is likely to include the project owner, project funders, major contractors, and major sub-contractors. The decision as to who is a “major” contractor or sub-contractor will depend on the size of the project and size of the relevant contract or sub-contract.
FAQ (3): What sort of reporting channels should be set up?
In order to reassure officers and employees of the safety and confidentiality of making reports, many organisations appoint a professional external third party organisation to receive reports from officers and employees. In addition to receiving reports of suspected corruption, this organisation may also receive reports relating, for example, to employment, health, safety and quality issues. This organisation will be instructed to feed back the reports to the relevant manager within the organisation (e.g. the compliance manager). Consequently, it is important to ensure that officers and employees have some confidence in the integrity and ability of this manager.(See Reporting for further information on reporting systems).
PS 11: Reporting
Page updated on 1st November 2008
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