Frequently Asked Questions

The Department of Institutional Integrity (INT) is often asked the following questions by its callers and website browsers. Answers are provided by "clicking" on the questions below. For ease of reference, the list of questions is categorized below.

I. Reporting Fraud and Corruption
II. About the Integrity Department
III. World Bank Sanctions and Integrity
IV. Whistleblowers

I. Reporting Fraud and Corruption

How do you report an account of staff or World Bank misconduct, fraud or corruption?

How is the Hotline operated?

How Long Does it Take to Resolve a Hotline Complaint?

Do I need to identify myself when making a complaint or allegation?

II. About the Integrity Department

What is the total amount of financial resources committed by the World Bank to the Department of Institutional Integrity? ^{updated February 2007}

How many people work in INT?

How is the Department of Institutional Integrity structured to handle investigations into fraud and corruption in World Bank-financed and -supported projects? ^{updated February 2007}

What types of actions are investigated by INT? ^{updated February 2007}

What is the Integrity Department's strategy or approach towards case management in regard to allegations of fraud and corruption in Bank projects? ^{updated February 2007}

What are some other efforts or policy tools being undertaken by INT to combat fraud and corruption?  ^{updated February 2007}

What methods of deterrence or penalties are employed by the Bank against those who commit fraud or corruption? ^{updated February 2007}

What other deterrence strategies are being employed by INT?

What challenges lie ahead for INT?   ^{updated February 2007}

III. World Bank Sanctions and Integrity

What is the difference between INT and the other various parts of the Conflict Resolution System (CRS: Ombudsman, Mediation, or Ethics)?

Does INT make the final determinations or decisions regarding employment termination and debarment?

How have INT and the World Bank Group contributed to the fight against fraud and corruption recently? ^{updated February 2007}

What is the percentage of World Bank lending in comparison to development funding?

Why does the Bank keep lending to countries that are on the top ten list of Transparency International’s corruption perceptions index?

IV. Whistleblowers

What is a Whistleblower? ^{updated February 2007}

What protections are afforded a Whistleblower? ^{updated February 2007}

Please contact the Department of Institutional Integrity directly via any of the following methods:

Contact INT directly:

Telephone:        202-458-7677

Fax:                  202-522-7140

Email:               investigations_hotline@worldbank.org

Website:           http://www.worldbank.org/integrity (Click on "Online Complaint Form")

We encourage you to make use of a free email service (such as Hotmail or Yahoo) to create a temporary email account using a pseudonym, so that we may correspond with you as necessary.  This can be helpful in pursuing your allegation.

Contact INT through an external Fraud and Corruption Hotline (24 hours/day):

Toll-free: 1-800-831-0463 (translation facilities available)

To reverse the charges (collect calls): 704-556-7046

Mail:

PMB 3767

13950 Ballantyne Corporate Place

Charlotte, NC 28277

USA

Anonymous calls are accepted.  Please be as specific as possible and include at least the basic details of who, what, where, when, and how.  Let us know how you can be reached for further information or clarification if you can, or tell us the name of a temporary email account you have created for this purpose.

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How is the Hotline operated?

The hotline is operated 24 hours per day, seven days a week, by an outside firm staffed by trained specialists. Qualified interpreters are available, upon request. All matters reported via the hotline will be turned over to the Department of Institutional Integrity.

How long does it take to resolve a Hotline complaint?

Normally, inquiries are completed within five months. However, the time required to complete the inquiry may vary depending on the complexity and number of the allegations received.

Do I need to identify myself when making a complaint or allegation?

No, only if you wish. When you telephone the hotline, you may remain anonymous. The call will not be recorded, and no attempt will be made to determine the number from which you are calling.  If you choose to give your name, but want your name to be kept confidential, the Bank will not reveal any information that may disclose your identity to anyone outside the investigative team and its managers and attorneys unless the Bank determines you have made an intentional misrepresentation or omission, or the Bank is required to do so by law.

We understand the value of complaints provided by individuals who desire to maintain their anonymity. We also understand the value of being able to contact complainants to ask for additional information or clarification of their complaint.  Often, additional information or clarification is necessary for successful conclusion of an investigation.  We encourage you to identify yourself; however, it is not required.  If you choose to identify yourself, but request confidentiality, we will not divulge your identity to outside agencies without your expressed consent unless the Bank determines you have committed a crime.  If you wish to remain anonymous, if possible, provide a means by which we may contact you, for example, a temporary email account using a pseudonym you have created for this purpose.

In order to protect the reputations and privacy rights of all parties, and to promote due process and the fairness of investigations, it is important that the information you provide be truthful, accurate, and given in good faith.

INT has a budget of US$13 million, which it employs to lead the effort to fight fraud and corruption among all multilateral development banks. 

How many people work in INT?

INT is a unit of over 50 staff and consultants working on integrity issues and investigations.   Staff members hail from all over the globe and include former prosecutors, lawyers, investigators, forensic accountants, and communications staff. 

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How is the Department of Institutional Integrity structured to handle investigations into fraud and corruption in World Bank-financed and -supported projects? ^{updated February 2007}

The Department is comprised of two units that handle external investigations in the World Bank regions.  These units also manage the Voluntary Disclosure Program (VDP) the Detailed Implementation Reviews (DIR).  A third unit covers internal investigations, and a fourth coordinates the intake and prioritization of all allegations. 

What types of actions are investigated by INT? ^{updated February 2007}

INT is charged with investigating complaints of fraud and corruption in World Bank-financed projects (external) as well as allegations of possible misconduct involving Bank staff (internal). External investigations pertain to procurement fraud and collusion, kickbacks, and bribes on Bank-financed projects, accounting fraud and overcharging, the misuse of project assets, and other activities such as misrepresentation of qualifications in bid submissions. Internal investigations include allegations of fraud and corruption involving Bank Group operations or affecting the Bank Group's administrative budgets; workplace misconduct, such as sexual harassment, harassment, retaliation, and abuse of authority; and other serious violations of Bank Group rules and policies.

Due to recent sanctions reforms, "obstructive practices," including the destruction of evidence and the intimidation of witnesses, have now become sanctionable, along with corruption, fraud, collusion and coercion.

What is the Integrity Department's strategy or approach towards case management in regard to allegations of fraud and corruption in Bank projects? ^{updated February 2007}

Allegations received are rated as to their relative priority using a standard set of criteria.   All allegations of staff misconduct received by the Integrity Department are considered extremely important and are given a high priority rating, reviewed and investigated to the full extent necessary in order to achieve closure.  All external cases go through a preliminary inquiry, with the information gathered used in the rating process.  Cases rated low priority are usually closed without further investigation, but all relevant information is entered into INT’s database for future reference and analysis.  Such cases may be reopened if the Integrity Department receives additional information.  Medium and high priority cases are included in the work program, with high priority cases scheduled for investigation based on the Integrity Department’s discussions with the relevant regional counterparts.

What are some other efforts or policy tools being undertaken by INT to combat fraud and corruption? ^{updated February 2007}

INT has promoted two key, proactive tools within its arsenal in the fight against World Bank-financed fraud and corruption. 

First, the Board of Executive Directors approved the final programmatic elements for the innovative Voluntary Disclosure Program (VDP) on August 1, 2006. Through the VDP, the Bank encourages firms who have engaged in fraudulent or corrupt practices in relation to Bank-financed projects to cease misconduct for good, and to fully disclose the details of those practices. The firms are required to install a best practice internal compliance system and hire a Compliance Monitor reporting to the Bank for a period of three years.  In exchange, the participating firms will not be debarred and the Bank will make its best efforts to keep their identity confidential. The information gleaned will be used by the Bank to strengthen the Bank’s internal controls and to inform the identification, preparation, appraisal and supervision of future Bank-financed projects.  Disclosed information will be provided in redacted reports (to protect the firms' identity) to relevant government authorities and other stakeholders. more on the VDP...

Second, the Integrity Department has continued its Detailed Implementation Review (DIR) program to include several projects in multiple sectors in relatively high risk countries, as opposed to the single project of a relatively high risk sector examined in an earlier review.  Going beyond the normal requirements of project supervision by Bank Task Teams, these reviews are able to reveal indicators of fraud and/or corruption that occur “under the existing radar” but can have a significant impact on the success and sustainability of a development project. more on DIRs...

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What methods of deterrence or penalties are employed by the Bank against those who commit fraud or corruption? ^{updated February 2007}

After INT has concluded its investigation and substantiated the allegation(s), the Bank’s provisions for sanctioning depend upon whether the wrongdoing involved a Bank Group staff member (internal), or an external party or entity involved in a Bank Group financed operation or project (external).

For substantiated cases of staff misconduct, including acts of fraud, corruption or other forms of misconduct, INT’s submits its findings, conclusions, and all supporting evidence in a final report to the Bank’s Vice President of Human Resources for a final determination on whether misconduct occurred and what disciplinary measures to impose, if any, up to and including termination and/or permanent bar to rehire in any capacity anywhere in the Bank Group.

For external allegations of fraud and corruption, the Bank's sanctions procedure consists of a two-tier process involving the Evaluation and Suspension Officer and the Sanctions Board.   INT sends a proposed Notice of Sanctions Proceedings to the Evaluation and Suspension Officer who reviews INT's evidence and determines whether or not that evidence is sufficient to support a finding that the firm or individual in question (the Respondent) more likely than not engaged in a Sanctionable Practice.  The Evaluation Officer is then responsible for either issuing a Notice of Sanctions Proceedings to the Respondent, or referring the case back to INT.  If the Respondent chooses to appeal the Evaluation and Suspension Officer's decision, the Sanctions Board will hear the case.

Sanctions may include, among other things, letters of reprimand, restitution, and temporary or permanent debarment.  Respondents may also be temporarily suspended from being awarded additional contracts for Bank projects or other World Bank Group financing, or otherwise participate in new activities under Bank projects, pending a final outcome of sanctions proceedings.  A referral letter may be submitted to the borrowing country in cases where INT may reasonably conclude that the law of that country may have been violated.

What other deterrence strategies are being employed by INT?

Communications is vital to deterrence of fraud and corruption and to the proactive approach used by the Integrity Department.  The World Bank is currently the only multilateral development bank to publish its sanctions of companies and individuals on the worldwide web, and has increased the amount of information released about such cases.  To meet the need for more general deterrence and prevention, in July, 2004, the World Bank Management and Board of Executive Directors approved an affirmative approach to communications related to investigations and sanctions of fraud and corruption in World Bank-financed projects, carefully balanced with concern for legal safeguards.  This strategy was disclosed to the public.  The World Bank does not discuss ongoing investigations and as a matter of Bank rules, does not release the names of Bank staff. It issues an annual report on integrity activities, with aggregate data on cases, outcomes, and policy developments.  The communications advisor of the Integrity Department is David Theis, who can be reached at dtheis@worldbank.org or 202-458-8626.

What challenges lie ahead for INT? ^{updated February 2007}

World Bank investigations are not just about enforcing rules and producing sanctions; they are about gaining knowledge and creating behavioral change.  The specific patterns of corruption being documented by INT, and by others in public procurement, will provide guidance on how to better protect funds in the future.  Using both reactive (post facto investigations) and proactive approaches (the Voluntary Disclosure Program and Detailed Implementation Reviews), the World Bank will be working with partner countries and the broader development community to harness this information toward more efficient and transparent systems of financial accountability and better governance.

INT will continue to contribute to the World Bank's efforts to:

• move to more common systems and standards with other International Financial Institutions, as well as with other donors such as the bilateral agencies;
• move toward better, more integrated compliance systems and encouraging companies and borrowers to ensure they have in place effective systems for enforcing high standards and for self-reporting when standards fail;
• improve the ethical environment inside all organizations, including the ability to talk frankly about corruption when one sees it happening internally or in projects financed by the organizations;
• support stronger laws against fraud and corruption - with consequences for white-collar criminals - and more successful enforcement;
• reduce grand corruption through international cooperation and better governance.

During both the initial intake and the preliminary inquiry stages, each case is examined against the various alternatives available under the World Bank’s CRS and a judgment is made about the most appropriate approach to resolving the issues in dispute. 

Whenever the best alternative is not obvious, INT may consult with various parts of the CRS (Ombudsman, Mediation, or Office of Ethics and Business Conduct) as well as with the Legal Department, Human Resources, and the relevant Bank managers, depending on the nature of the issue, to arrive at the most appropriate answer.   This has allowed the Integrity Department to focus its resources on those cases where referral is not appropriate (e.g. due to the egregious nature of the allegations) or where the CRS system has already been exhausted. 

Does INT make the final determinations or decisions regarding employment termination and debarment?

No.  INT is solely an investigative body of the World Bank into allegations of fraud and corruption in relation to any part of the World Bank Group.  INT has no authority to decide upon the resolution or penalties of any action or investigation.     

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How have INT and the World Bank Group contributed to the fight against fraud and corruption recently? ^{updated February 2007}

INT has:

• Closed over 2,400 cases, both internal (staff) and external since 1999;
• Completed over 150 high priority external cases in FY05/06;
• Substantiated allegations in 77 staff cases involving 78 staff members in FY05/06;
• Completed 4 Detailed Implementation Reviews (DIR) in Indonesia, Vietnam, Cambodia, and Kenya, the results of which are followed-up by the respective Governments in partnership with the Bank.
• Designed the final programmatic elements of the innovative Voluntary Disclosure Program (VDP) and publicly launched the new proactive anti-corruption tool.

The Bank has:

• Sanctioned 355 firms and individuals for fraud and corruption in Bank-financed projects since 1999, including 337 debarments and 18 letters of reprimand;
• Debarred 58 firms, 54 individuals and issued 6 letters of reprimand in FY05/06;
• Taken a lead role in the IFI Anti-Corruption Task Force to harmonize efforts at fighting fraud and corruption worldwide, including greater information sharing among the institutions, common definitions of fraud and corruption, and common investigative procedures.

What is the percentage of World Bank lending in comparison to development funding?

We estimate that World Bank lending represents about 1% of worldwide public procurement. Misuse of public expenditure is a problem for everyone, everywhere, from the least developed to the most developed nations, as illustrated by Transparency International and the World Bank Institute.  It is not remarkable that there is some corruption within an institution such as the World Bank, given the nature of the Bank's development work.  For a fuller view of these issues, Transparency International's Global Corruption Report 2005 looks at corruption in the construction sector and in large-scale infrastructure projects.

Why does the Bank keep lending to countries that are on the top ten list of Transparency International's corruption perceptions index?

Disengagement is not an option for us, in most cases, because the poorest people in the world often live in countries where corruption is a real issue, not just for the Bank, but also for the whole of society.  But our country offices are actively engaged with their counterparts in structuring country assistance programs that have a major emphasis on governance and anticorruption systems and capacity.

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IV. Whistleblowers

What is a Whistleblower? ^{updated February 2007}

A "whistleblower" is a staff member who reports suspected misconduct of a nature that may threaten the operations or governance of the Bank group.  In order to encourage staff to raise concerns and enable the Bank Group to effectively address such cases, manage risks, and uphold standards of good governance, the Bank Group provides protections to staff who report such misconduct.  Staff members who cooperate or provide information during an ensuing review or investigation of such allegations are also provided protections.

A staff member's right to be protected from retaliation is not contingent upon whether the staff member's report of suspected misconduct results in a final determination by the Bank Group that misconduct has occurred.  Nor is the staff member required to determine individually whether the suspected misconduct meets a specific degree of gravity or gross misconduct.

However, these protections do not apply to staff members who make allegations that are knowingly false or made with reckless disregard as to whether they are true or false.

What protections are afforded a Whistleblower? ^{updated February 2007}

Staff members who report suspected misconduct or who cooperate or provide information during an ensuing review or investigation under this Rule are accorded the following protections:

• Anonymous Reporting: A staff member who reports suspected misconduct may choose to remain anonymous.  Avenues for reporting anonymously include telephoning the Fraud and Corruption hotline, and sending an e-mail to INT using a pseudonym via a free, commercial e-mail service such as Hotmail or Yahoo. However, please bear in mind that anonymous allegations may be difficult to pursue if the anonymous source does not provide a means for INT to communicate with the individual (e.g. anonymous e-mail address) in instances where clarification and/or further information might be required. INT will respect your wish not to provide your name. 
  
  
• Confidentiality: A staff member may request to have their identity kept confidential during the investigative process.   This means that their identity would not be disclosed outside the investigative team unless the staff member consents to the disclosure or it is determined that the staff member knowingly made a false allegation of misconduct.
  
  
• Deterrence Against Retaliation: Managers and other staff are expressly prohibited from engaging in any form of retaliation against a staff member whom they believe to have reported suspected misconduct or to have cooperated or provided information regarding suspected misconduct in the course of an ensuing review or investigation. Retaliation includes any direct or indirect detrimental action recommended, threatened, or taken because an individual engaged in a protected disclosure.   Retaliation by a manager or other staff member against any person who reports suspected misconduct, or cooperates or provides information during an ensuing review or investigation, shall subject the manager or other staff member to disciplinary action under Staff Rule 8.01.
  
  
• Interim Protections:   Staff members who report suspected misconduct as well as staff who cooperate or provide information regarding suspected misconduct in the course of an ensuing review or investigation, shall be accorded interim protections during the course of review or investigation as necessary to safeguard the interests of such staff.  Such interim protections may include, at the direction of the Vice President, Human Resources, and with the consent of the staff member, temporary reassignment to another unit in accordance with Staff Rule 5.01, “Reassignment” or, in exigent circumstances, temporary placement on administrative leave in accordance with Staff Rule 6.06, “Leave.”
  

A staff member who has participated in misconduct may not avoid disciplinary action simply by reporting the misconduct and seeking protection.  Depending upon the circumstances, a staff member's reporting and degree of cooperation may be taken into consideration in determining the appropriate disciplinary actions for that staff member pursuant to Staff Rule 8.01, "Disciplinary Proceedings."

INT is responsible for ensuring a fair, prompt and thorough review of the facts and circumstances regarding reports of misconduct, and also for ensuring that the whistleblower is informed of the outcome of the Bank Group’s review or investigation into the matter, including whether misconduct has been substantiated and whether disciplinary measures, sanctions, or other remedial measures have been taken.

Staff may seek confidential guidance and advice from the Ombudsman or the Office of Ethics and Business Conduct as appropriate, [as well as from INT] before raising a particular concern regarding misconduct.

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