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 (through Companies Registry or other appropriate records).
  • 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, and obtain bank records for an appropriate period.  Identify whether the CEO has received any payment from BuildWell, or other unexplained income.
  • Identify the bank accounts of BuildWell, and obtain bank records for an appropriate period.  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, or has received any payment from Buildwell.

If such an interest or payment is revealed:

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

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

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April 2025
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