Project Anti-Corruption System Standards

PS 7: Government anti-corruption commitments

(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 government anti-corruption commitments. 

  1. Many government departments may already have in place some or all of the procedures recommended in this PACS Standard.  To this extent, the project owner may not need to carry out some or all of the recommendations below.
  2. The project owner should request each government department which will have an involvement with the project, and which does not already have such procedures in place, to provide a commitment that the government department will undertake the actions in clauses 3 to 8 below.
  3. It will publish details of the official rates and fees payable, and the official time-scales which should apply, in relation to activities of the department which may affect the project, such as the granting of permits or licences or other such matters.
  4. It will publish the name of a senior representative in the department to whom reports may be made of any actual or attempted extortion, or any delay or obstruction, by any officers or employees of the department.
  5. It will take all reasonable steps to ensure that its officers and employees do not:
    • extort bribes or other illicit payments in relation to the project;
    • charge fees where fees are not legally due;
    • charge fees in excess of fees legally due;
    • unreasonably delay or obstruct the granting of permits etc.
  6. It will take appropriate action against any officer or employee who has been or is suspected to have been involved in any of the activities in clause 5 above, including reporting such matter to the criminal authorities.
  7. It will permit the information in clauses 3 and 4 above, and the obligations in clauses 5 and 6 above, to be made public on the project and/or department website.
  8. The commitment will be issued under the authority of the head of the department.
  9. Once the government department has provided the commitment, the project owner should, as soon as reasonably possible, make each project participant aware of the terms of the commitment.
  10. This Standard may be implemented on its own.  It is, however, recommended that it is implemented in conjunction with all other PACS Standards, as far as appropriate.

See Anti-Corruption Notice to Government  for a sample request by the project owner to a government department.

See Anti-Corruption Government Commitment  for a sample commitment which may be provided by a government department.

Frequently Asked Questions

FAQ (1):  What government departments are relevant?

The government departments which should give this commitment are those that issue any approvals or permits in relation to the project.  Permits may include planning permission, building approvals, work permits, visas, customs clearance, payment approvals, foreign currency clearance etc. 

FAQ (2):  Why is this commitment necessary?

Refusing or delaying the issue of a permit which is validly due can have major cost impact on the project participants who need the permit (for example, their equipment may be trapped at customs).  Issuing these permits therefore gives disproportionate power to relatively junior government officials, who may seek to abuse their position in return for a bribe.  Alternatively, it may be advantageous to a company to bribe the official to issue it with a permit which is not validly due.  It is therefore imperative that government departments closely control the issuing of permits by their officials, have effective procedures for making complaints, and have proper disciplinary procedures.

FAQ (3):  When is this commitment necessary?

Government departments should, as a matter of good management, closely control the issuing of permits by their officials, have effective procedures for making complaints, and have proper disciplinary procedures.  If these procedures are already in place, the project owner will not need to seek the commitments which are contained in this PACS Standard.  However, if any relevant government department does not have these procedures in place, then it is recommended that the project owner tries to obtain from the government department the commitments contained in this PACS Standard.  It can use the following PACS templates to do so:

FAQ (4):  What if the project owner is also a government department?

If the project owner is a public sector entity, then it will probably be part of the same government which has responsibility for permit issuing.  However, permit issuing will normally be undertaken by a separate government department(s) from the project owner, so the commitment will still be necessary or useful.

Updated on 10th April 2020