Module 7:  Investigating corruption in project procurement

CEO has secret interest in BuildWell

The whistleblowing report alleges that the Chief Executive Officer (CEO) of the RA has a secret interest in the winning bidder, BuildWell. The investigator could examine the following matters.

  • Identify the owners of BuildWell.
  • If possible and reasonable, interview the owners of BuildWell as to whether they hold their ownership interest as nominee for another party, and, if so, who.
  • Interview the CEO as to whether he has an ownership or other interest in BuildWell (directly or through a third party).
  • Inspect the conflict of interest or asset declarations (if any) of the CEO (in an RA or public register).
  • Identify the bank accounts of the CEO.  Identify whether the CEO has received any payment from BuildWell, or other unexplained income.
  • Identify the bank accounts of BuildWell.  Identify whether BuildWell has made any payment to the CEO, or any other suspicious payment.
  • Undertake an internet search on the CEO, BuildWell and its owners to see whether any link between the CEO and BuildWell is identified.

As a result of the above investigations, is there any evidence that the CEO has an ownership interest in BuildWell.

If such an interest is revealed:

  • is this a legitimate and disclosed relationship; or is it secret and undisclosed
  • is there anything illegal or improper in the relationship, or non-disclosure, or way in which the relationship has been managed
  • is there any evidence, or can it be inferred, that the relationship improperly benefitted the CEO or BuildWell?

If the CEO had a secret ownership interest in Buildwell, and played any role in the appointment of Buildwell, then it is highly likely that this would amount to corrupt conduct.

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January 2025
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