Project Anti-Corruption System Standards

PS 11: Reporting

(Note:  Please refer to the Frequently Asked Questions (FAQs) at the end of this PACS Standard for further guidance on this standard)

This PACS Standard makes the following recommendations in relation to the reporting of suspected or actual corruption on infrastructure projects.

  1. There should be an effective process for reporting suspected or actual corruption in relation to the project, as provided below.
  2. Each major project participant should do the following:
    • It should set up a reporting process which ensures that:
      • its personnel can make reports in a safe and confidential manner
      • reports may be made anonymously
      • the identity of the person reporting the concern will be kept confidential
      • these reports will be passed on to the organisation’s compliance manager
      • the compliance manager, or other appropriate person, will investigate the matter and, where he considers there is cause for concern, he will report the matter to senior management
      • the reporting person will be informed as to the follow-up action that is being taken
      • personnel who report are not discriminated against (e.g. by bullying, demotion or dismissal) if they make a report in good faith, or based on a reasonable belief.
    • It should instruct its personnel as follows:
      • It should require its personnel to report corruption, suspicion of  corruption, any cause for concern, and any failure to comply with the anti-corruption commitments.
      • Reports should be made using the organisation’s reporting process, unless the reporting person fears that this process is not safe or will not be effective.  These reporting channels should be fully explained to personnel.
    • If it believes there is evidence of corruption, or breach of any anti-corruption commitment, it should, within 7 days, report the relevant facts to the independent assessor.
  3. The independent assessor should be required to make reports to other project participants, professional bodies and the criminal authorities, in accordance with his terms of appointment.
  4. In order to enable the public to report suspected or actual corruption in relation to the project, the project owner should do as follows:
    • It should publish the contact details of the independent assessor (apart from his home address where he is an individual).  It should also publish details which will help to assure the public of the qualifications, integrity and independence of the independent assessor.
    • It should inform the public that reports of corruption, or suspicion of corruption, may be made to the independent assessor, anonymously or otherwise.
    • It should inform the public how to make such reports.
    • It should ensure that the reporting person is informed as to the follow-up action that is being taken.
  5. See Reporting for further guidance on reporting processes.

Frequently Asked Questions

FAQ (1):  Why is it important to have proper reporting mechanisms?

Corruption will only be materially reduced or prevented if individuals are aware that there is a real probability that corrupt activity will be reported, and that it will then be properly investigated and prosecuted.  In order for reports of corruption to be made, individuals who wish to make a report need to be confident that they will not be subject to discrimination or physical harm, and that their reports will be properly investigated.  Consequently, safe and effective reporting processes must be set up.

FAQ (2):  Who are the “major project participants”? (clause 2 above)

These are the project participants whose role in the project could result in significant corruption.  Consequently, this is likely to include the project owner, project funders, major contractors, and major sub-contractors.  The decision as to who is a “major” contractor or sub-contractor will depend on the size of the project and size of the relevant contract or sub-contract.

FAQ (3):  What sort of reporting processes should be set up?

In order to reassure personnel of the safety and confidentiality of making reports, many organisations appoint a professional external third party organisation to receive reports from personnel.   In addition to receiving reports of suspected corruption, this organisation may also receive reports relating, for example, to employment, health, safety and quality issues.  This organisation will be instructed to feed back the reports to the relevant manager within the organisation (e.g. the compliance manager).   

Updated on 10th April 2020