Requirements

1. Training for Project Owner personnel:  The Project Owner should provide appropriate anti-corruption training on a regular basis to all of its relevant Project personnel.
2. Training for Supplier and Sub-supplier personnel:  All relevant Project personnel of Suppliers and Sub-suppliers should be provided with appropriate anti-corruption training on a regular basis.  This training should be provided:
   1. either by the Project Owner
   2. or by the Suppliers and Sub-suppliers (in which case the Suppliers and Sub-suppliers should provide reasonable evidence to the Project Owner that such training has been provided).
3. Training requirements:  The anti-corruption training in paragraphs 1 and 2 above should comply with the requirements of paragraphs 4 to 8 below.
4. Identifying the level of anti-corruption training:  The anti-corruption training should be appropriate to the skills and roles of the trainees and the corruption risks faced by them and by their organisation in relation to the Project:
   1. Trainees who in their day-to-day functions face a low level of corruption risk may receive a simple level of training as specified in paragraph 5 below.
   2. Trainees who in their day-to-day functions face a more than low level of corruption risk should receive a comprehensive level of training as specified in paragraph 6 below.
   3. Personnel who are likely to face no corruption risk (such as cleaners and canteen serving staff) may receive no training.
5. Simple anti-corruption training:  The simple level of anti-corruption training provided to trainees should include at minimum the following elements:
   1. the Project Code of Conduct
   2. a simple explanation of the different relevant types of corruption offences and penalties
   3. the reason why corruption is damaging to the public, the organisation and the trainee
   4. that the trainee must not get involved in any types of corruption
   5. the disciplinary and criminal penalties that the trainee could face if s/he gets involved in corruption or breaches the Project Code of Conduct
   6. an explanation of the reporting system and of the trainee’s reporting obligations, rights and protections under PACS Standard 13
   7. the name of the person in the organisation to whom the trainee can speak if s/he has questions or concerns.
6. Comprehensive anti-corruption training:  The comprehensive level of anti-corruption training provided to trainees should include at minimum the following elements:
   1. the Project Code of Conduct
   2. the organisation’s anti-corruption procedures relevant to the trainee’s role
   3. the importance of compliance with the Project Code of Conduct and anti-corruption procedures
   4. a simple explanation of the different types of corruption offences and penalties
   5. a more detailed explanation of the different corruption offences, laws and regulations relevant to the trainee’s role, and the penalties that apply
   6. how these corruption offences might occur in the role or function in which the trainee is employed, and how to identify them
   7. what actions relevant to the trainee’s role would be corrupt, and what actions would not be corrupt
   8. the damage caused by corruption generally and the damage it may cause specifically to the public, the organisation, and the trainee, in relation to the activities in which the trainee is engaged
   9. that the trainee must not get involved in any types of corruption
   10. the risk, for the trainee personally and for the organisation, of disciplinary, civil, administrative, and criminal sanctions for involvement in corrupt activity or breach of the Project Code of Conduct
   11. the steps that the trainee should take to prevent and avoid corruption
   12. what the trainee should do if the trainee encounters corruption
   13. an explanation of the reporting system and of the trainee’s reporting obligations, rights and protections under PACS Standard 13
   14. the name of the person in the organisation to whom the trainee can speak if s/he has questions or concerns.
7. Trainer skills:  The persons who write and/or provide the anti-corruption training should be suitably skilled in the subject.
8. Third party trainer:  The above training may be provided by a third party trainer.