This section applies to both public and private sector project owners (i.e. an organisation which owns or is developing an infrastructure project).

Corruption on an infrastructure project can occur in any project phase, including project identification, financing, design, tendering, execution, maintenance and operation.  See How Corruption Occurs.  The project owner and its individual directors and managers are at risk of incurring civil and/or criminal liability, financial loss and reputational damage for involvement in corruption.

Project owners play a vital role in corruption prevention in relation to infrastructure projects, as they control the procurement and project management mechanisms.  It is, therefore, largely incumbent on the project owner to take the lead in limiting the corruption that takes place on its projects. 

To minimise the risk of corruption on their projects, project owners should take anti-corruption action by implementing an effective programme to prevent, detect and deal with corruption both within their organisation and in relation to their projects.

GIACC in this section provides outline recommended actions for project owners to help reduce the risk of corruption.  Links are provided to other GIACC web-pages which provide more detailed recommendations.

Anti-Corruption Programme

1. Project owners should implement the following anti-corruption programmes:
   • An organisational anti-corruption programme designed to prevent, detect and deal with corruption in relation to the project owner’s activities. (See Anti-Corruption Programme for Organisations which provides requirements, supporting guidance and templates for such a programme).
   • In respect of a major public sector project, a project anti-corruption programme designed to prevent, detect and deal with corruption in relation to the project.  (See Project Anti-Corruption System which provides requirements, supporting guidance and templates for such a programme).
2. All contractors, consultants, suppliers and other organisations which bid to the project owner for contracts over a reasonable minimum value threshold should only be permitted to bid if they can provide sufficient proof that they have implemented an organisational anti-corruption programme designed to prevent, detect and deal with corruption in relation to their activities on the project. (See Anti-Corruption Programme for Organisations which provides requirements, supporting guidance and templates for such a programme).
3. The project owner should:
   • Publicly disclose that it is the project owner of the relevant project.
   • Publicly encourage organisations and individuals involved in the project, and members of the public, to report matters of concern relating to the project in a confidential manner to an appropriate senior manager of the project owner, or appropriate third party.
   • Report allegations of corrupt practices in relation to the project to the authorities, and to any applicable trade or professional association.