Module 5: Preventing corruption in project procurement
Monitoring
- Appropriate senior management of the procuring organisation should monitor the procurement process, and be alert to possible corruption indicators; e.g:
- unusual or unnecessary selection of projects or contract scope
- splitting up of contracts so as to bring them below the threshold for competitive bidding
- apparent urgency requiring sole sourced or accelerated procedures
- evaluation criteria or contract specification favouring one bidder
- unsuitable design, materials, or construction methods
- unsuitable contract conditions, or omission of critical contract clauses
- bids accepted after the submission deadline
- an unusually low number of bids submitted
- unusually low or high bid prices
- complaints from losing bidders
- the appointment of contractors, consultants or suppliers who are not suitably qualified
- conflicts of interest in relation to the personnel of the procuring organisation or bidder
- unknown or suspicious beneficial ownership of bidders
- possible cartels (see below).
- Specific monitoring should be undertaken in order to detect possible cartels. If a cartel is well concealed by the bidders, it may not be possible to identify. However, carelessly concealed cartels may be identifiable. Possible monitoring actions include:
- comparing bidders’ prices for patterns (e.g. prices differ by the same percentage spread, or BOQ rates are the same for losing bidders)
- comparing bidders’ documents for similarities which suggest copying (e.g. identical method statements)
- checking for prices which materially exceed market
- identifying prices which are unusually close to the procuring organisation’s confidential estimate
- internet searches of the bidders to check for rumours of cartels.
- The person undertaking the monitoring should report any suspicious findings to the board of the procuring organisation.
- In the case of public sector contracts, the monitoring should ideally be undertaken by a reputable and suitably qualified independent third party who in addition to the above requirements:
- issues periodic public reports
- reports suspicions of corruption to the investigating authorities.
- Monitoring is distinct from auditing, in that:
- monitoring is a continuing ongoing process throughout the procurement phase by a manager or third party who is familiar with the project
- auditing is a distinct activity undertaken by an audit specialist which takes place after the procurement has been completed.
April 2025
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