Examples of Corruption during the project execution phase
The webpage “How Corruption Occurs” provides an overview, with some summary examples, of the circumstances in which corruption can take place throughout all phases of a project.
The section below is supplementary to the above webpage, and gives some more detailed examples, with explanation, of how corruption can take place during the project execution phase.
The examples below provide specific facts for ease of understanding, but the examples and explanation can be applied to numerous similar factual circumstances.
When in an example below it is commented that a criminal offence has been committed, this comment is based on the generally applicable principles explained in the webpage “What is Corruption” (which explains the different corruption offences which can occur, including bribery, extortion, fraud, cartels, abuse of office, embezzlement and money laundering). However, in some countries the actual applicable law may result in a different outcome.
1. Over-claim for equipment
Example:
An excavation contractor is undertaking work for the project owner on a daywork basis. The contract entitles the contractor to charge the project owner a specified price per day for each item of equipment which is actually working on site. The contractor is required to submit daywork records which record the equipment which is working on site each day.
On Day 1, the contractor’s site manager submits a daywork record to the project owner which records that 12 items of equipment were working on site. This was an honest mistake by the site manager. There were only 10 items. He had double counted two items of equipment. On Day 2, he realises that he had made a mistake, but he does not correct the site record for Day 1. Therefore, the documentation submitted to the project owner continues to incorrectly show that 12 items of equipment were working on Day 1, when in fact only 10 were working.
On Day 7, the contractor’s site manager is too busy to count the number of items of equipment working on site. He estimates that 15 were working, but he is not sure if that is correct, and does not check. He submits a daywork record to the project owner which records that 15 items of equipment were working on site. He does not state in the record that this is an estimate, and may be incorrect. There were in fact only 12 items of equipment working that day. He takes no steps at a later date to check and correct the figure.
On Day 20, the contractor’s site manager realises that the project owner is not checking the items of equipment on site, and is entirely relying on the site manager’s record. The contractor is starting to lose money on the contract due to under-pricing of equipment day rates. The site manager therefore, from Day 20 until completion of the contract on Day 40, always adds an additional two items of equipment to every day’s work record. These additional two items do not exist. The purpose of doing so is to try to recoup some of the contractor’s lost money.
Explanation:
On Day 1, the site manager makes an honest error. He was not deliberately or recklessly mis-stating the number of items of equipment on site. Therefore, he has not committed fraud. However, as soon as he realises his mistake, he must as soon as possible notify the project owner and correct it. He fails to do so. Therefore, he now knows that his previous statement is incorrect, and he knows that a payment will be made by the project owner to the contractor based on his incorrect statement. He is therefore now committing fraud by knowingly allowing the incorrect statement to stand uncorrected, and payment to flow from it. To avoid fraud in these circumstances, you must always correct an error as soon as possible after you discover it.
On Day 7, the site manager makes a reckless error. Recklessness is where you are aware that a fact may be incorrect, and take no reasonable steps to verify it. The site manager took no steps to verify. Nor did he state in the daywork record that he was unsure of the figure, and would check later. Therefore, the daywork record appeared to the project owner to be a statement of fact, and to be accurate. Recklessness in these circumstances is normally sufficient to constitute fraud. To avoid fraud in these circumstances, you must always state on the record if you are unsure of its contents. You must not represent facts to be correct if you are unsure about them.
From Day 20 until completion of the contract on Day 40, the site manager is deliberately claiming an additional two items of equipment each day. He knows that this is incorrect. This is therefore fraud in that he is deliberately making a false representation.
For acts such as the above to constitute fraud, it is normally necessary that the purpose of the false statement is to make a gain or avoid a loss (i.e. there must be intention of some financial impact). The purpose of submitting the day works records is to enable the contractor to receive payment in relation to its actual or alleged equipment supply. Therefore, this requirement is satisfied in all of the above cases.
For fraud to have been committed, it does not matter whether or not the project owner identifies the incorrect statement, and therefore does not actually pay for the equipment which was not provided. The mere fact of deliberately or recklessly making the false claim with a view to making a gain is sufficient to result in the maker of the statement committing fraud.
This type of fraud involving deliberate or reckless submission of falsely inflated claims for supply of equipment, labour or materials is common on construction projects. The false claim could be submitted by sub-contractors or suppliers to the contractor, and/or could be submitted by the contractor to the project owner. A considerable amount of money can be made by a corrupt party if it can charge for equipment, labour or materials which were not provided or were not working. On a site where there are numerous items of plant, a large volume of materials, or a large number of personnel, or where the site is very large, it can be difficult for the party which is the victim of such fraud to verify the actual number of items of equipment, the volume of materials, or the number of personnel on site, and the actual hours of working.
2. Over-claiming for materials with false work certificates
Example:
An earth-moving sub-contractor signs a contract with the contractor to remove unsuitable material from site and to replace it with suitable material. The sub-contractor will be paid by the load. The contractor appoints a supervisor to count on site the number of loads removed and replaced by the sub-contractor. Each load will have a written load certificate which will be signed by the sub-contactor and counter-signed by the supervisor. The manager of the sub-contractor agrees with the supervisor that the supervisor will falsely certify more loads than the sub-contractor actually undertakes. In return, the sub-contractor will pay the supervisor 30% of the payment received by the sub-contractor for each false load. In addition to certifying the genuine loads removed and replaced, the supervisor certifies 50 false removals and 50 false replacements. The sub-contractor submits both the genuine and false certificates to the contractor for payment. The contractor pays the sub-contractor, who in turn pays the supervisor his agreed share.
Explanation:
The above conduct would constitute all of:
- payment of a bribe by sub-contractor
- receipt of a bribe by supervisor
- fraud by sub-contractor in deliberately claiming payment for work not carried out
- fraud by supervisor in deliberately signing work records for work not carried out
- abuse of office by the supervisor in failing to carry out his functions correctly in return for a personal payment.
In many cases on construction projects, work done by one party needs to be supervised and approved by another party. This acts as a control against error or fraud. Therefore, if a party wishes to act fraudulently on a project by claiming payment for work not done, or for equipment and materials not supplied, or for defective or inadequate work, they will normally need the supervisor to be negligent, or to deceive the supervisor, or to bribe the supervisor. Consequently acts of fraud on construction projects are frequently accompanied by bribery.
3. Supply of inferior quality materials
Example:
A project owner appoints a road contractor to build a road. The specification requires that the base course of the road should be of a particular type of aggregate provided in the contract. The contractor deliberately supplies aggregate of a cheaper and inferior specification. The contractor’s purpose in doing so is to make an additional gain. The contractor provides false aggregate delivery records to the project owner which falsely state that the aggregate meets the contract specification. The contractor invoices the project owner for the cost of the aggregate required by the contract, not the cheaper product that was actually supplied.
Explanation:
The deliberate supply by the contractor of an inferior quality aggregate, and the subsequent invoicing for the correct quality, is a fraudulent act.
Road projects and foundation projects are particularly vulnerable to this type of quality fraud, as it is impossible to visually ascertain the quality of materials used once they have been covered over by other materials. Ascertaining the quality would then require some form of destructive or non-destructive testing which can be costly and disruptive.
It is more difficult to supply and conceal inferior quality in relation to items which are visible upon completion (e.g. lights, air conditioning units, doors etc.)
Large amounts of money can be made by supplying cheaper quality materials on large projects. For example, if on a large road project, 100,000m3 of aggregate should be supplied at $30 / m3 for the correct aggregate, supplying a slightly inferior aggregate at $28 / m3 would gain the contractor an additional $200,000 profit.
4. Supply of inadequate quantities
Example:
A project owner appoints a foundation contractor to construct foundations for a building for the fixed price of $2 million. The contract requires the contractor to excavate down to minus 10 metres, remove from site all excavated materials, then fill the excavations to specified dimensions with foundations of steel reinforcement and concrete. The contractor only excavates down to minus 9 metres, thereby saving 1 metre of excavation and earth removal. As the excavation area is now 10% smaller, the contractor also saves on the installation cost and time equivalent to 10% of the concrete and steel. The foundation contractor informs the project owner that it has completed the foundations in accordance with the contract requirements, and bills the project owner for the full $2 million.
Explanation:
The deliberate supply by the contractor of inadequate quantities of excavation, earth removal, steel, and concrete, and the subsequent invoicing for the correct quantities, is a fraudulent act.
Road projects and foundation projects are particularly vulnerable to this type of quantity fraud, as it is impossible to visually ascertain the quantity of materials used once they have been covered over by other materials. Therefore, once concrete had been poured into the foundations, it will be impossible visually to confirm whether the foundations were excavated to the correct depth. Ascertaining the quantities would then require some form of measurement comparing actual final level with contract level, or destructive or non-destructive testing which can be costly and disruptive. In the case of the above example, a measurement of final level would not reveal the fraud, as the top level of the foundation will be at the correct contract level – it is the base level which will be incorrect by 1m.
It is more difficult to supply inadequate quantities in relation to items which are visible upon completion (e.g. lights, air conditioning units, doors etc.)
Large amounts of money can be made by not excavating to the correct depths, and supplying inadequate quantities to fill the excavation. For example, on a $2 million project as per the above example, a 10% saving in work and material could equate to an additional profit for the contractor of $200,000.
5. Concealing defects
Example:
A water-proofing sub-contractor installs a waterproof roof membrane under a contract with a contractor. The membrane is accidentally perforated in several places by the sub-contractor’s personnel during installation, which means that it is likely to leak. The membrane should therefore be rejected and replaced, or appropriately repaired if repair would render the membrane in accordance with the contract. The contractor’s site supervisor does not notice the perforations. Replacing or repairing the membrane would delay handover of the roof back to the contractor (which could result in a delay claim against the sub-contractor), and would result in additional labour and material cost for the sub-contractor. The sub-contractor decides not to replace or repair the damaged membrane, or to disclose the perforations to the contractor or the project owner. The sub-contractor claims payment from the contractor for the roofing works on the basis that they are properly completed.
Explanation:
The sub-contractor knows that the membrane is defective. The sub-contractor is committing fraud by not replacing or repairing the membrane, and by billing the contractor on the basis that the works are in accordance with the contract. The sub-contractor should either have replaced or repaired the membrane, or should have disclosed the issue to the contractor and agreed a consequent course of events with the contractor.
6. Bribes to win contracts concealed in variation claim
Example:
A contractor bidding for a contract and the chief executive of the project owner agree to a corrupt arrangement under which the chief executive will ensure that the project owner awards the contract to the contractor. No payment will be made by the contractor to the chief executive at that time, so any audit or investigation of the procurement process would not uncover any suspicious financial transfers. However, once construction of the project commenced, the chief executive would ensure that some major variations to the contract scope of work were issued, and that a highly profitable price for the contractor would be agreed in respect of these variations. The contractor would then make secret payments to the chief executive out of the variation profits.
Explanation:
The above example illustrates one of many methods of concealment of bribes. Many project owners’ controls over project construction, including the issuing of variations, are much lower than their controls over procurement, therefore making it more likely that these transactions can proceed undetected. There is also normally no competitive pricing process in relation to variations (unlike most tenders) so verifying whether the contractor’s price for the variations is reasonable can be difficult.
In the above case, the contractor would be guilty of bribery and fraud, and the chief executive of bribery, fraud and abuse of office. The fraud would be the issuing of false or unnecessary variations for the purpose of enabling a bribe payment.
7. False variation claim
Example:
A flooring contractor lays a concrete floor for the project owner, but fails to instal expansion joints in the floor as required by the contract. Rectifying this would require the entire floor to be jacked up, the rubble removed, and the floor relayed. This would cost the contractor far more than the original contract price just for laying the floor. Under the contract, the project engineer is responsible for issuing variations. The contractor offers the engineer a bribe if he issues a variation to the contract specification which deletes the requirement for the floor to be built with expansion joints. The engineer does so. No consequent adjustment is made to the contract price. The floor is therefore now in theory in compliance with the contract specification, and the engineer accordingly issues a certificate of completion for the floor which entitles the contractor to payment for the flooring works. However, the floor is now more likely to crack and break up as a result of the absence of expansion joints, so the project owner has received an inferior product. At no stage is the project owner consulted on the variation.
Explanation:
The above circumstances constitute both bribery and fraud by both the contractor and the engineer. The acts of the engineer also constitute an abuse of office.
The engineer should only issue a variation to the contract specification if this in the best interests of the project owner, and there should be a consequent price adjustment to take account of any additional costs or savings. This variation is not issued for the benefit of the project owner, but in return for a bribe, and so as to protect the contractor from the consequences of its construction error. The facts are concealed from the project owner, who pays the full price for an inferior product. The circumstances should have been fully disclosed to the project owner, who could determine whether it wished to receive a floor which fully complied with the specification (which would therefore require rectification by the contractor) or whether it was willing to accept the defective floor (which would presumably only be in return for a price discount to reflect the project owner’s greater risk of incurring rectification costs later).
8. False extension of time application
Example:
A contract entitles the contractor to an extension of time and payment of additional costs in the event of delays caused by the project owner. The contract also provides that the contractor should pay damages to the project owner, and bear its own additional costs, in the event of delays caused by the contractor. Under the contract, the project engineer is required to impartially determine questions of delay and additional cost. The contractor has been delayed by 60 days in completing the project. The contractor is aware that two reasons account for the delay. The first cause is the delayed delivery of materials by one of the contractor’s suppliers for which delay the contractor is responsible under the contract and for which it would be liable to pay liquidated damages to the project owner. This accounts for 30 days delay. The second cause is a change to the specification for which delay the project owner is responsible under the contract and for which the contractor would be entitled to receive an extension of time and additional cost. This accounts for 30 days delay. The contractor submits a written claim to the project engineer which alleges that the whole 60 day delay was attributable to the change in specification. The contractor does not refer in the claim to the supply contract delay, and does not disclose to the project engineer documentation in relation to the supply contract which would reveal the supplier delay.
Explanation:
The contractor knows that 30 days delay is caused by the supplier, and that only 30 days is attributable to the project owner. However, the contractor claims the full 60 days. The contractor is committing fraud by two means; (1) falsely representing that the full 60 days is the project owner’s responsibility; and (2) failing to disclose evidence which would have shown that the 60 clay claim was false.
The above example attributes an exact number of days to each cause of delay. However, in many cases, the exact number of days delay may be difficult to calculate. The parties may be aware that there are several causes of the delay, some attributable to one party and some to the other, but they may be unsure of actual cause and effect. In that case full disclosure of all circumstances should be made by all relevant parties, so that the adjudicator can make the best decision possible. Parties should not mispresent facts or withhold evidence.
9. Issue of false delay certificate
Example:
In relation to the same facts as are contained in Example 8, the project owner receives a copy of the extension of time application by the contractor. The project owner is aware that the contractor is entitled to an extension of time in relation to the late drawings, but is unsure of how many days should be granted. Both the project engineer and the project owner are unaware of the supply contract delay. The project engineer informs the project owner that in its objective view, it believes that 20 days extension of time should be issued to the contractor for the late drawings, but the rest of the application should be rejected. The project owner is unwilling to bear the additional contractor costs which a 20 day extension of time would result in, and so persuades the engineer, with the promise of employment on the project owner’s next project, that the engineer should refuse the contractor’s claim in its entirety, and should instead issue a certificate requiring the contractor to pay the project owner liquidated damages for 60 days delay. The engineer does so.
Explanation:
The project owner knows that some days of delay are attributable to the project owner. The project engineer has indicated that 20 days delay are attributable to the project owner. The project owner is entitled to provide evidence to the project engineer which shows otherwise, with a view to changing the engineer’s mind. However, the project owner is not entitled to improperly influence the objective decision making function of the project engineer. In this case, the project owner attempts to improperly influence the project engineer through the offer of future employment. This is bribery by the project owner of the project engineer. The project engineer accepts, which is both bribery and abuse of office by the project engineer.
10. Set-off of false rectification costs
Example:
A contractor has completed the project works satisfactorily in accordance with the contract, and applies for its final 10% payment from the project owner, as is provided by the contract. The project owner has spent more on the project than it had budgeted, and wishes to make cost savings. It therefore determines that it will attempt to reduce the contractor’s final payment by 5%. It therefore sends the contractor a schedule of purported defects in the works. The schedule is false. There is nothing actually wrong with these items of works, and the project owner knows this to be the case. The project owner calculates that the rectification of these issues will cost the equivalent of 10% of the contract price. This calculation is false. The project owner then sets off the alleged cost of rectification of these defects against the balance due to the contractor, with the outcome that nothing further is paid by the project owner to the contractor. The contractor disputes the deduction. The project owner offers to pay the contractor a reduced final payment of 5% immediately, but informs the contractor that, if the contractor does not accept this reduced sum, then the project owner will pay nothing, and the contractor will have to go to court if it wishes to obtain any payment from the project owner. The contractor cannot afford a court action, and is experiencing cash flow difficulties, so it accepts the reduced amount of 5%.
Explanation:
The project owner commits fraud by deliberately creating a false list of defects, and forcing the contractor to accept a lower payment through its threat of recovering these false claims in court.
It is legitimate to refuse to pay for work which is defective or not undertaken. It is also legitimate to threaten legal action if you honestly believe that your claim is justified. However, you cannot threaten legal action based on a claim which you know is false in order to make a profit.
11. Including a false “negotiation margin” in a claim
Example:
A contractor is preparing a claim against the project owner for additional costs incurred by the contractor as a result of a delay caused by the project owner. The contract allows the contractor to claim its proven actual costs directly consequent on any delay caused by the project owner. The contractor prepared records of its actual additional labour and equipment costs and site overheads incurred as a result of the delay. These totalled $350,000. The contractor was concerned, however, that the project owner would try to negotiate the contractor’s costs down from this figure, and any outcome less than $350,000 would mean that the contractor had not achieved full recovery of its actual additional costs. The contractor therefore added an additional $50,000 to the claim as a “negotiation margin”. It could therefore give away this $50,000 in negotiation with the project owner, and therefore appear to be reducing its claim, but in reality, it would not be reducing its claim as long as it did not drop below $350,000. The contractor needed to be able to evidence this additional $50,000 claim, and so submitted some false time sheets and overhead costs so as to justify this additional figure.
Explanation:
The need to resolve claims in relation to additional costs, variations and extensions of time is common on construction projects. Frequently these claims can be contentious, and can result in court action or arbitration. Mutual suspicions between parties about the integrity of each others claim process can frequently lead to the addition of false negotiation margins by both parties. The outcome of this conduct is circular. If one party believes that the other party will negotiate down its valid claim, it will be tempted to add an extra margin for negotiations. If the other party believes that a negotiation margin will be added, it will be tempted to negotiate the claim down. So, this mutual belief is self-fulfilling.
It is entirely legitimate for parties to claim the full extent of their legitimate entitlement, and to compromise their respective claims by each party giving away part of their legitimate claim with a view to achieving a settlement.
However, it is fraudulent to create false additional costs with a view to giving these away. In doing so you are representing to the other party that these are genuine actual costs which you have incurred and which you are compromising on, whereas in fact this is not the case. The purpose of you doing so it to make a gain or avoid a loss.
12. Refusal to issue final certificate
Example:
A contractor has properly completed the works and is entitled to receive a final certificate which will entitle it to receive its final payment of $500,000 from the project owner. The project engineer has a duty under the contract to issue the final certificate if the works have been properly completed. The engineer knows that the works have been properly completed and that the certificate should therefore be issued, but refuses to issue the final certificate to the contractor unless the contractor pays him personally 10% of the final certificate value ($50,000).
Explanation:
This is extortion and abuse of office by the project engineer. The engineer should issue the final certificate due without demanding personal payment.
If the contractor makes the payment to the project engineer in order to receive the certificate, the contractor will be liable for bribery. In this situation, there is no threat by the project engineer of any personal harm to any of the personnel of the contractor, so the defence of payment to avoid personal harm is not available. It is unlikely to be a defence if you make the payment in order to avoid financial harm.
13. Facilitation payment
Example:
A contractor is importing equipment and materials into a country where it is constructing a project. An important delivery of materials is withheld in customs. The contractor needs the equipment at the beginning of the following week, otherwise the project construction will be delayed. The cost of delay to the contractor would be $50,000 per day. The contractor appeals to the customs official handling the matter to deal with the application. The customs official indicates that he will release the equipment that day if he is paid a “speed up” fee of $200. The contractor checks the legitimacy of the fee, and finds that no such fee is legally payable. The contractor has completed all necessary paperwork, and has paid the relevant import duties and fees, so the equipment should be released without this “speed up” fee. It is clear that this fee is an unofficial payment demanded by the official for his personal benefit. The contractor needs the equipment urgently, and the fee of $200 is much lower than the daily additional cost of $50,000 if the equipment is unavailable. The contractor therefore makes the payment, and the equipment is released.
Explanation:
This example is similar in concept to Example 12 above. Both examples have been given as Example 12 deals with a major event of extortion by a key participant on the project (the project engineer) whereas this Example 13 deals with extortion of a much smaller amount by a public official who has no role on the project. However, the outcome is the same. The fact that the second example involves a small amount of cash does not change the underlying principle.
The customs official should release the equipment without demanding a personal additional payment. In demanding such payment in order to properly perform his function, the official is both abusing his office and extorting payment from the contractor.
If the contractor makes the payment to the customs official in order to receive the certificate, the contractor will be liable for bribery. In this situation, there is no threat by the customs official of any personal harm to any of the personnel of the contractor, so the defence of payment to avoid personal harm is not available. It is unlikely to be a defence if you make the payment in order to avoid financial harm.
14. Extortion at road block
Example:
A truck driver delivering materials to a construction site is stopped at a police roadblock. The policeman is armed and acting in a threatening manner. The policeman tells the driver that the vehicle has defective tyres, and that the driver will be arrested for driving a dangerous vehicle and held in the police cell over night. However, the policeman states that if the driver pays him $20, he will be let through. The driver knows that his vehicle tyres are in good condition, and that the $20 is not a legitimate payment. However, he fears for his safety, and what could happen to him in a cell overnight. He therefore makes the payment and is let through the roadblock.
Explanation:
This type of incident can be common in some countries. In this case the driver can legitimately claim that he feared for his personal safety if he did not make the payment. Under many countries’ laws, it is a defence to make an extorted payment if you legitimately fear for your safety. So, it would be unlikely that the driver has committed a crime. The policeman would be guilty of extortion and abuse of office.
The driver should report the incident to his employer as soon as possible. Neither the driver nor the employer should conceal the payment by pretending it was a legitimate expense. This could then constitute an accounting offence (false statement of the nature of the payment) and a tax offence (as illegal payments normally cannot be deducted from income in calculating tax due). Depending on the country’s laws and on whether it is safe to do so, it is better to record it correctly in the accounts as an extorted payment, and consideration should be given to reporting the matter to the authorities.
15. False job application
Example:
In order to obtain employment from a contractor, an applicant for the post of project manager deliberately states in his job application that he has previously worked as a project manager for five years. In fact, he has only previously held such a position for six months, and so is significantly less experienced than he is representing. The contractor employs him as project manager for an important contract without checking with his previous employer the length of his relevant experience.
Explanation:
This an example of fraud by an individual against an employer, for the individual’s personal benefit, and where the employer is the victim.
The examples of fraud in the other examples given above would have been carried out by individual employees, but primarily for their employer’s benefit. Deliberately or recklessly exaggerating work experience on a CV in order to obtain employment is an act of fraud by an individual against their employer.
16. Excessive entertainment
Example:
The role of the project owner’s site supervisor is to monitor the contractor’s work day to day on site, and to approve, for the purposes of monthly payments, the contractor’s work quality and quantities, and the amount of their equipment and labour on site. The contract length was six months. The contractor’s project manager informs the site supervisor that the contractor’s project staff were planning to go every weekend together to major club football matches, and then go for dinner afterwards. This was in order to keep site morale high, and to facilitate good working relations on site between the contractor’s personnel. The contractor proposed that the supervisor should join them at these weekly gatherings, as it would help the working relationship between the contractor’s and project owner’s personnel. The contractor said that the contractor would pay for all the tickets and meals of the supervisor.
Explanation:
Paying for entertainment in business circumstances is not necessarily corrupt. However, it can amount to a bribe if the purpose of the entertainment is to influence someone to perform a function improperly.
The contractor offering to pay the site supervisor’s tickets and meals every weekend for six months is a very significant and frequent expenditure, and is highly likely to influence the supervisor’s decision making over the contractor on site. It is difficult to act impartially in situations where you may have to reject the contractor’s work and timesheets when you are being entertained by the contractor every week, and where you increasingly regard the contractor’s personnel as friends rather than business colleagues.
Even if the offer and acceptance of this entertainment is not actually intended to be corrupt, it is highly likely that a third party (e.g. a member of the public, a newspaper, or a judge) would regard it is a corrupt.
The supervisor should in the above circumstances therefore refuse the contractor’s offer. The amount and frequency of the above offer makes it highly likely that it would be regarded as corrupt.
The offer by the contractor of entertainment of the supervisor at only one match, which was not repeated, would be far less likely to be regarded as corrupt, provided that the match ticket and meal were of reasonable cost, and would be unlikely to influence the supervisor. However, as the supervisor has such a critical role over the contractor day to day, it would be far safer and wiser for the supervisor to refuse any entertainment whatsover from the contractor.
If the supervisor receives any such offer from the contractor, he should disclose this as soon a possible to his manager.
Updated on 20th April 2024
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