Project Anti-Corruption System Standards

PS 8: Raising awareness

(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 raising awareness of corruption on public sector projects.

  1. Anti-corruption policy Each major project participant should ensure that its relevant project personnel are made aware of the organisation’s anti-corruption policy. 
  2. Anti-corruption rules For the duration of the project, each major project participant should post up anti-corruption rules in an easily visible location at their project offices and on site.  These rules should state that they apply to all personnel, and should provide as follows:
    • Require them at all times to act honestly and without deception.
    • Require that they do not knowingly or recklessly do any of the following, or participate in any activity which involves any of the following:
      • offer, give, demand or accept any bribe or other improper advantage
      • undertake any dishonest or deceptive activity in relation to the procurement process;
      • provide, conceal, or approve work, materials, equipment or services which are not of the quality and quantity required under contract
      • provide false, inaccurate or misleading information
      • dishonestly withhold information
      • make or submit false, inaccurate, misleading or exaggerated records, invoices, claims, applications for variations or extensions of time, or requests for payment
      • dishonestly refuse or fail to approve, or delay in approving, work, materials, equipment, services, invoices, claims, applications for variations or extensions of time, or requests for payment
      • dishonestly refuse or fail to pay, or delay in paying, sums due
      • unduly influence or interfere with the function of the independent assessor.
    • Inform them of the function and contact details of the independent assessor and require that they answer truthfully all enquiries made by the independent assessor.
    • Inform them of and require them to comply with the corruption-reporting procedures.
    • Require personnel with management responsibilities:
      • to make enquiries regarding any possible corruption
      • to take reasonable preventive measures to stop potential or actual corruption for which the organisation may be liable
      • not to authorise or condone any corrupt activity.
    • Inform them of the corporate policy relating to gifts and hospitality.
    • Advise them that they must not comply with these rules if doing so would endanger their personal safety or that of another person.
    • Advise them of the risk of personal criminal liability should they become involved in corrupt activity.
  3. Anti-corruption training Each major project participant should ensure that its personnel receive training, on a regular basis, which informs them of:
    • the nature of corruption in construction projects
    • how liability for corruption may be incurred
    • why corruption should be avoided
    • the organisation’s gifts and hospitality policy
    • relevant law and penalties
    • practical steps to be taken in a corrupt situation.
  4. Gifts and hospitality policy Each major project participant should have a gifts and hospitality policy whereby either:
    • all gifts and hospitality are prohibited; or
    • all gifts and hospitality above a maximum value are prohibited, and gifts and hospitality below this value are required to be recorded in a benefits register.  The register should be maintained by each project participant at its project and/or site office and should be available for inspection by the independent assessor.
  5. 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.
  6. The following tools support the above recommendations:

Frequently Asked Questions

FAQ (1):  Why is it important to raise awareness of corruption risks etc amongst personnel of major project participants?

Corrupt acts may be committed by personnel.  Often personnel commit these acts because:

  • They believe that these acts are normal business practice;
  • They believe that the organisation’s top management would approve of these acts;
  • They believe they are acting in the interests of their organisation;
  • They are not aware that they are criminal offences;
  • They are not aware of the serious criminal penalties that may apply to them personally and to their organisations;
  • They do not believe that there is any real possibility of these corrupt acts being discovered or punished.

Consequently, in order to limit corruption on a project, it is essential to ensure that personnel have proper training and are constantly reminded of the corporate anti-corruption rules.

FAQ (2):  Who are the “major project participants”?  (See clause 1 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 the relevant contract or sub-contract.

Updated on 10th April 2020