Project Anti-Corruption System Standards

PS  9:  Compliance

(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 compliance on public sector projects.

  1. Each major project participant should appoint a senior manager (“compliance manager”) who is responsible for ensuring as far as possible that such participant and its personnel comply with the anti-corruption commitments.
  2. The project owner’s compliance manager should ensure that:
  3. The compliance manager of each major project participants should ensure that:
  4. The compliance manager should have a duty to investigate any suspicions of corruption and to report such matters promptly to senior management.
  5. The compliance manager should be appropriately qualified, and should have received training in anti-corruption compliance.
  6. The compliance manager may combine his compliance role with other responsibilities.  For example, he may also undertake the role of project manager, financial manager, commercial manager, safety manager etc., provided that he has sufficient time available properly to undertake his compliance role.

Frequently Asked Questions

FAQ (1):  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