Which participants are responsible

It is important in an investigation to be alert to the possibility that more than one project participant could be involved in the corruption. 

For example, if there is a cartel between the contractors bidding for the project:

• all the bidding contractors may be involved in the cartel, or some contractors may have avoided involvement
• the cartel may have only involved the bidding contractors; alternatively, it could also have relied on information being submitted to the cartel members by an RA manager or by an RA consultant with access to that information (e.g. the confidential budget price, so that the winning cartel member can submit a bid close to the budget price to avoid suspicion).

A corrupt act is always undertaken by a person.  It is important to identify whether this person is acting for their personal benefit, or is acting on behalf of the organisation they are employed by.  In the latter case, depending on the relevant country’s laws, both the person and their employer could be criminally liable.