Module 6:  Preventing corruption in project construction

Contractor anti-corruption management system

  • During the procurement phase, the procuring organisation requires that:
    • any bidder which may win a contract over a reasonable value threshold should provide satisfactory evidence during the bid process that it has implemented an appropriate ACMS (see page 9, Bid Conditions, of Module 5: “Preventing Corruption in Project Procurement“).
    • the winning bidder should sign a contract which includes a term committing it to continue to implement an ACMS for the duration of the project, and to provide reasonable evidence of this implementation upon request (see page 10, Contract Conditions, of Module 5: “Preventing Corruption in Project Procurement“).
  • To ensure that the above commitment is being complied with, require verification from the relevant organisations which win contracts, upon their commencement of work on the project, and annually thereafter as long as their participation on the project continues, that they have effectively implemented an appropriate ACMS.
  • Evidence may be in the form of certification to ISO 37001 by a reputable third party certifier.  As ISO 37001 only applies to bribery, the organisation will in this case need to provide additional confirmation that their ACMS includes within its scope fraud, cartels, extortion and embezzlement in addition to bribery.
  • If no such certification exists, the organisation will need to provide alternative reasonable evidence of compliance.

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April 2025
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