The Project Owner, and all Suppliers and Sub-suppliers, should, for the duration of their participation in the Project:
All organisations and individuals participating in [name of Project] (“the Project”) must comply with the following obligations in relation to the Project:
You must not participate in any criminal activity. In particular, you must not:
You must not participate in any activity which could constitute, or be seen to constitute, an improper influence or conflict of interest. In particular, you must not:
You must not knowingly or recklessly:
Where you have a management responsibility over any function, activity or personnel, you must, in relation to such function, activity or personnel:
Where you have a duty to act impartially, such as in relation to the evaluation of tenders, or the approval or certification of payments, extensions of time, contract modifications, or the value, quantity, or quality of work, materials, products, equipment, services or claims, then you must make all decisions in this regard impartially and free from improper outside influence.
Direct and indirect actions: The above principles apply to any actions taken by you either directly or through or on behalf of any other person or organisation.
Co-operation with the independent monitor and independent auditor: In relation to the performance by the independent monitor and independent auditor of their duties in relation to the Project, you must at all times:
Reporting of breach of this Code of Conduct: If you believe in good faith or on reasonable grounds that any person has breached or is about to breach any part of this Code of Conduct, then you must report such suspicion as soon as possible under the reporting system set up by the Project Owner which can be accessed at [website link]. In all cases, you may report anonymously. If you do not make your report anonymously, you may, at the time of reporting, request that your identity is kept confidential.
The purpose of the Project Code of Conduct is to introduce a binding and clear set of integrity principles which must be complied with by all organisations and individuals involved in the Project.
The sample Project Code of Conduct contained in this PACS Standard applies to all Project participants, all types of corruption and all phases of the Project, and takes account of the different roles that personnel may have on the Project.
Corrupt activities which may take place in relation to a Project are numerous and varied. For example:
Project participants may also breach the Project Procedures or their Anti-Corruption Contractual commitments. For example, there may be a breach of the procurement procedures by the Project Owner awarding a contract without a competitive process, or a Supplier may breach its commitment to implement an anti-corruption management system or provide training to its personnel.
See GIACC’s resource “How Corruption Occurs” for a detailed analysis of the various types of corruption which can occur throughout the Project.
The Project Code of Conduct is designed to prohibit and deter all of these types of corruption.
The last provision of the sample Project Code of Conduct requires that suspected or actual breaches should be reported under the reporting system set up by the Project Owner. This is the reporting system which should be established by the Project Owner under PACS Standard 13.
PS 8: Project Code of Conduct
Updated on 1st November 2021