Project Anti-Corruption System (PACS)



PS  9:  Compliance

(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 compliance on public sector projects. 

  1. Each major project participant should appoint a senior manager (“compliance manager”) who is responsible for ensuring as far as possible that it complies with its anti-corruption commitments.

  2. The project owner’s compliance manager should ensure that:

(1)  The independent assessor is appointed (PS 1).

(2)  The project transparency policy is followed (PS 2).

(3)  The procurement procedures are followed (PS 3).

(4)  Anti-corruption commitments are obtained (PS 5, 6, 7)

(5)  Audits are carried out (PS 10)

(6) The project owner complies with clause 3 below.

  1. The compliance manager of each major project participants should ensure that:


    (1)  Disclosures are properly exchanged and assessed (PS 4).

(2)  Anti-corruption commitments are met (PS 5, 6, 7).

(3)  Training is given, rules are posted up, and gifts and hospitality procedures are followed (PS 8).

(4)  Corruption reporting procedures are in place, and reports of corruption are made and followed up (PS 11).

(5)  Proper steps are taken to implement enforcement procedures in the event of corruption (PS 12).

  1. The compliance manager should have a duty to investigate any suspicions of corruption and to report such matters promptly to senior management.

  2. The compliance manager should be appropriately qualified, and should have received training in anti-corruption compliance.

  3. The compliance manager may combine his compliance role with other responsibilities.  For example, he may also undertake the role of project manager, financial manager, commercial manager, safety manager etc., provided that he has sufficient time available properly to undertake his compliance role.


Frequently Asked Questions


FAQ (1):  Who are the “major project participants”?  (See clause 1)

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 the relevant contract or sub-contract.



Return to:

PACS home page

PACS Standards:

PS 1:   Independent assessment

PS 2:   Transparency

PS 3:   Procurement

PS 4:   Pre-contract disclosure

PS 5:   Project commitments

PS 6:   Funder commitments

PS 7:   Government commitments

PS 8:   Raising awareness

PS 9:   Compliance

PS 10:  Audit

PS 11:  Reporting

PS 12:  Enforcement




Page updated on 1st November 2008

© 2019 GIACC