Questions are grouped under the following thematic headings: I. What is the VDP and who can participate?
II. How does the VDP manage Information Disclosure and Confidentiality?
III. Which firms can participate in the VDP, and how does it affect them?
IV. How are countries affected by the VDP?
V. Is the VDP the right approach to fight corruption?
I. What is the VDP and who can participate?
1. What is the Voluntary Disclosure Program?
2. What is the purpose of the Voluntary Disclosure Program? 3. What is the value of the VDP anti-corruption approach? 4. Who is eligible to enter the VDP? 5. According to the “VDP Guidelines,” the World Bank determines eligibility through the “Background Data Sheet.” But once this form is submitted, isn’t the applicant exposed? Back to the top
II. How does the VDP manage Information Disclosure and Confidentiality? 1. How will the Bank report the results of the VDP program? 2. Can the Bank reveal its sources of information?
3. Can the Bank keep the identity of VDP Participants confidential from member countries?4. What is redacted information? 5. Will redaction always be enough to protect the identity of a Participant? 6. Why does the Bank keep the identity of VDP Participants confidential? 7. What if the identity of a VDP Participant is publicly disclosed from some other source? 8. How long does the Bank keep a VDP Participant’s identity confidential? 9. Are there any exceptions to the confidentiality provisions of the VDP? 10. What if a VDP Participant wishes to publicize its involvement in the VDP? 11. Which countries receive VDP disclosures? 12. How can a country prosecute corrupt government officials exposed through the VDP while maintaining the VDP Participant’s confidentiality? Back to the top
III. Which firms can participate in the VDP, and how does it affect them? 1. What business entities will be eligible to participate in the VDP? 2. What if a company has an affiliate that is under active investigation by the World Bank? 3. Is a firm that is or has been under criminal investigation by a national authority eligible to participate in the VDP? 4. What incentive does a firm have to join the VDP? 5. Does the VDP give preferential treatment to certain firms? 6. Is participation in the VDP only open to firms based in rich countries? 7. Won’t the cost of VDP participation prohibit small and medium sized enterprises from entering the program, making it available in practice to rich firms only? 8. Can VDP Participants continue to bid on Bank projects? If so, will they have an advantage in winning Bank business by entering the VDP? 9. How can a firm be sure that the Bank will not “go after it” once it has stepped forward, without allowing it to enter into the VDP? 10. Do VDP Participants have to pay any penalties for their past corrupt practices? 11. What are the obligations for firms that have been accepted into the VDP? 12. If a VDP Participant implicates a partner or partners who are then investigated and/or sanctioned by the World Bank, won’t it be obvious that the one who wasn’t sanctioned was the informant? 13. Can Participants use the VDP as a competitive tool, trying to eliminate their competitors by denouncing them through disclosures? Back to the top
IV. How are countries affected by the VDP? 1. What countries are affected by the VDP program? 2. What does the Bank expect a government to do with information disclosed by the VDP in the redacted reports? 3. What can countries do themselves to give incentives to firms and government officials to cooperate? 4. Does the Bank obtain information about corruption in a country in other ways? 5. What happens if government officials wish to learn the identity of a VDP Participant? 6. Why are public officials not allowed to become Participants in the VDP? Back to the top
V. Is the VDP the right approach to fight corruption?
1. Isn’t there a substantial moral hazard issue? 2. You expect a government to prosecute its corrupt officials, but will the Bank act against its own staff members involved in the corruption disclosed by a VDP Participant? 3. How can you justify a VDP where the Bank is acting as prosecutor, judge, and jury at the same time? 4. Couldn’t a firm avoid an investigation by coming forward to enter the VDP? 5. Aren’t the firms that want to enter VDP those that are likely to be found out by the Bank anyway? 6. Won’t VDP Participants be able to hide information about past Misconduct from the Bank? 7. Won’t the VDP just give firms practice in avoiding detection of Misconduct? 8. Won’t the VDP end up skewing the market for consultants, suppliers, and contractors? 9. Are there similar voluntary disclosure programs elsewhere? Back to the top
I. What is the VDP and who can participate?
1. What is the Voluntary Disclosure Program?
The VDP gives firms, other entities, or individuals who have entered into, been a party to, or were involved in the procurement and selection process for contracts related to projects financed or supported by the International Bank for Reconstruction and Development (IBRD), the International Development Association (IDA), International Finance Corporation (IFC), or Multilateral Investment Guarantee Agency (MIGA) the opportunity to: cease corrupt practices; voluntarily disclose information about Misconduct that is sanctionable by the Bank (e.g., fraud, corruption, collusion, coercion) by conducting an internal investigation at the VDP Participant’s cost; adopt a robust “best practice” corporate governance Compliance Program, which is monitored for 3 years by a Compliance Monitor; receive World Bank guidance throughout the VDP process; avoid public debarment for disclosed past Misconduct; and obtain confidentiality for their identity in exchange for full and proactive cooperation
If, however, a Participant does not disclose all Misconduct voluntarily, completely, and truthfully; continues to engage in Misconduct; or violates other material terms of the VDP Terms and Conditions, that Participant faces a mandatory 10-year public debarment in accordance with regular World Bank sanctions procedures.
2. What is the purpose of the Voluntary Disclosure Program?
The purpose of the VDP is to scale up the World Bank’s fight against corruption by partnering with the private sector and civil society organizations. The program provides firms, other entities, and individuals with incentives to disclose their knowledge of fraudulent and corrupt practices in Bank-financed projects and to comply with World Bank rules and guidelines. The program aims to improve development effectiveness by promoting a business climate surrounding World Bank-financed and supported projects that is free of fraud and corruption, and to reduce the risk of fraud and corruption in ongoing and planned Bank projects by providing the World Bank with information about specific wrongdoing. 3. What is the value of the VDP anti-corruption approach? The VDP encourages corporate compliance with Bank rules. It aims to change the behavior of the firms that receive Bank-financed contracts. The VDP permits the World Bank, its member countries, and civil society to gain a much more complete picture of corruption in a faster and more cost-effective manner. The VDP permits the Bank and the borrowing country to become more operationally effective by learning how corruption works and cooperating to fix ineffective systems. The VDP shifts enforcement costs to Participants, because they pay for the investigation, report, Compliance Program development, and Compliance Monitoring. The VDP fosters a level playing field for honest firms. Ultimately, the VDP leads to a more effective use of development funds.
4. Who is eligible to enter the VDP? The VDP is open to any firm, other entity, or person except for (i) World Bank Group staff; (ii) Executive Directors of the IBRD, IDA, MIGA, or IFC; and (iii) firms, other entities, or persons under active investigation by the World Bank. Firms, entities, or persons may enter if they have entered into, been a party to, or were involved in the procurement and selection process for contracts related to projects financed or supported by the IBRD, IDA, MIGA, or IFC. The VDP is not available to firms providing goods or services directly to the Bank through the General Services Department (GSD). 5. According to the “VDP Guidelines,” the World Bank determines eligibility through the “Background Data Sheet.” But once this form is submitted, isn’t the applicant exposed? The eligibility requirement is not a mechanism for the Bank to “bait and trap” potential VDP Participants. Such a practice on the part of the Bank would clearly be counterproductive to the objectives of the VDP. In fact, the Bank intentionally puts extensive VDP information on its website, including the VDP Terms & Conditions and Guidelines, so that firms can evaluate the program and their eligibility anonymously, before they submit the Background Entry Request Form. Back to the top
II. How does VDP manage Information Disclosure and Confidentiality?
1. How will the Bank report the results of the VDP program?
The World Bank shares non-confidential information resulting from a Participant’s disclosures—in a rigorously redacted format that protects the identity of the Participant and guards against the possibility of deduction of that identity—with World Bank management and staff, member countries, donors, other multilateral development banks, and other interested stakeholders. The Bank also will disclose VDP information, in aggregate form, in annual reports to discuss lessons learned. 2. Can the Bank reveal its sources of information? The Bank can reveal information obtained from VDP Participants, but not those Participants’ identities. The Bank must protect the confidentiality of its sources to create the necessary incentives for full disclosure. Within the Bank, certain staff of the Department of Institutional Integrity will receive certain un-redacted information as required for their investigations. The Bank’s President and General Counsel will receive un-redacted information. All others, including the Bank’s Executive Directors, member countries, other multilateral development banks, international organizations, NGOs, and civil society at large, will receive only redacted information on a need-to-know basis. 3. Can the Bank keep the identity of VDP Participants confidential from member countries?
Yes. While the Bank has an obligation to inform member countries of problems with projects in their country, it has discretion regarding the timing, manner, and content of those disclosures. The Bank can, therefore, withhold information that it received under a promise of confidentiality. The Legal Department has issued a legal note on this.
4. What is redacted information? VDP information will be redacted to protect the identity of the Participant. The redaction process involves the omission of any information that would allow a reader to deduce the identity of a Participant, including through “reverse engineering” of the information provided. 5. Will redaction always be enough to protect the identity of a Participant? Under certain circumstances, it is possible that a thorough redaction would not be enough to protect the confidentiality of the Participant. In this case, the Bank would delay the release of the information until such time as it would no longer be possible to deduce the identity of the Participant. The redacted information could also be aggregated together with other information to ensure that the Participant could not be identified. 6. Why does the Bank keep the identity of VDP Participants confidential? The confidentiality guarantee is a key incentive for Firms to come forward and participate in the VDP. The Bank realizes that significant risks accompany a Participant’s decision to disclose information about Misconduct. Participants must feel secure that disclosure to the Bank will not put them at risk of physical harm, reprisal, or retaliation. This is why the Department of Institutional Integrity (INT) commits to use its best efforts to eliminate the risk of the identification of Participants as sources of information to the Bank. 7. What if the identity of a VDP Participant is publicly disclosed by some other source? The Bank will make every reasonable effort to keep the identity of the VDP Participant confidential. Any public disclosure of a Participant’s identity could jeopardize the efficacy of the VDP as an anti-corruption tool, even if it is clear that the Bank is not responsible. In such a situation, the Bank has the obligation not confirm that a firm, entity, or individual is a VDP Participant without that Participant’s consent. So if the Participant itself does not confirm its participation, any such “leak” would remain hearsay. 8. How long does the Bank keep a VDP Participant’s identity confidential? Permanently, unless the Participant violates the material Terms and Conditions of the VDP and is publicly debarred. 9. Are there any exceptions to the confidentiality provisions of the VDP? Yes: A VDP Participant’s identity is made public if that Participant is debarred for violating the program’s material terms. In addition, IFC and MIGA’s agreements with third parties, and IBRD/IDA’s partial risk and credit guarantee operations, may obligate them to disclose confidential VDP information in certain situations. The VDP Terms and Conditions make this clear. 10. What if a VDP Participant wishes to publicize its involvement in the VDP? VDP Participants must seek the agreement of the Bank before making their involvement in the VDP public, and before publicly discussing their disclosures to the Bank. The final decision regarding the manner, content, and timing of any disclosures of information provided by a Participant rests with the Bank. 11. Which countries receive VDP disclosures? The Bank provides countries affected by disclosed Misconduct with redacted reports containing information provided by VDP Participants. Those countries are the home country of the Participant and the countries where the corrupt acts took place. The reports are redacted in such as way as to protect the identity of the Participant. 12. How can a country prosecute corrupt government officials exposed through the VDP while maintaining the VDP Participant’s confidentiality? A country provided with VDP disclosures in a redacted report can use those disclosures to guide its own independent investigations. Those investigations can then uncover additional corroborating evidence for use in prosecuting corrupt parties, thus allowing prosecution without revealing the VDP Participant’s identity. Of course, there is a risk that a country’s own independent investigation could result in the discovery of a VDP Participant’s corrupt acts, notwithstanding the quality of the Bank’s redaction. The VDP does not preclude a country from taking action against any entity it discovers and finds liable under its laws. Back to the top
III. Which firms can participate in the VDP, and how does it affect them?
1. What business entities will be eligible to participate in the VDP?
Any firm or other entity that is not under active investigation by the Bank’s Department of Institutional Integrity is eligible to participate in the program. 2. What if a company has an affiliate that is under active investigation by the World Bank? Because the entire firm, including its affiliates, enters the VDP, a firm with affiliates under active Bank investigation would be ineligible to enter the VDP. 3. Is a firm that is or has been under criminal investigation by a national authority eligible to participate in the VDP? A firm’s eligibility to enter the VDP depends on whether it is under active investigation by the World Bank’s Department of Institutional Integrity (INT). While the Bank is typically not informed of a criminal investigation by local authorities, there may be cases in which INT would be aware of an ongoing criminal investigation by a national authority. If this criminal investigation related to an activity financed or supported by the Bank, INT would open its own investigation in the case, and the firm would be ineligible to enter the VDP because of that Bank investigation. 4. What incentive does a firm have to join the VDP? Because both the U.N. Convention Against Corruption (UNCAC) and the OECD Anti-Corruption Convention have come into force, firms now face greater law enforcement risks. Moreover, in many countries the cost of paying bribes is becoming prohibitive for many firms. In addition, companies do not know which other companies are disclosing information under the VDP and may want to avoid being named by a VDP Participant. Entering the VDP therefore makes good business sense for many firms: The program gives Participants an opportunity to come clean while continuing to do business with the Bank. Firms also benefit from establishing a robust in-house Compliance Program which will give predictability and clarity to their employees regarding what is legal or illegal, and can enhance the firm’s public reputation. In the long term, both member countries and firms will benefit from a level playing field where honest and technically strong firms can compete. 5. Does the VDP give preferential treatment to certain firms? No. The Voluntary Disclosure Program treats all Participants the same, regardless of their nationality, size, or sector. The program sets forth specific criteria that must be met equally by all Participants, and establishes uniform duties to be undertaken by any entity participating in the program. 6. Is participation in the VDP only open to firms based in rich countries? Not at all. Eligibility to enter into a VDP agreement has nothing to do with the nationality of the interested firm. Any firm, other entity, or individual involved in Bank-financed or sponsored projects that is not under active Bank investigation is eligible to enter the program. 7. Won’t the cost of VDP participation prohibit small and medium sized enterprises from entering the program, making it available in practice to rich firms only? No. The VDP automatically adjusts to the size of the Participant. The Bank can provide firms with fewer than 50 employees with technical assistance to help them meet their VDP obligations. This assistance can include performing the internal investigation, drafting the investigation report, developing the firm’s Compliance Program, and monitoring that program’s implementation. Smaller firms’ participation costs also are likely to be much lower because of the lower volume of documentation and work involved in the investigation and verification phases. 8. Can VDP Participants continue to bid on Bank projects? If so, will they have an advantage in winning Bank business by entering the VDP? VDP Participants can continue to bid and work on Bank-financed or supported projects, but they gain no advantage in obtaining additional Bank business. 9. How can a firm be sure that the Bank will not "go after it" once it has stepped forward, without allowing it to enter into the VDP? The Bank has no interest in luring firms into expressing interest in the VDP and then investigating them instead; that would be a surefire way for the VDP to fail. Indeed, the Bank posts the VDP Guidelines as well as the Terms & Conditions on its website so firms can learn about the program—and know exactly what their obligations will be, what the procedures are, and how the Bank will use their disclosures — before they contact the Bank to enter the VDP. 10. Do VDP Participants have to pay any penalties for their past corrupt practices?
The VDP does not impose a monetary “penalty,” such as a fine, on Participants. VDP Participants are, however, obligated to pay for most costs associated with the VDP process, and the size of this obligation should not be underestimated, particularly for firms with activities in multiple countries, many employees and agents, and a history of involvement in Bank projects.
11. What are the obligations for firms that have been accepted into the VDP? VDP Participants must disclose all information about fraud or corruption in Bank-financed or supported projects during the five years prior to their entry into the VDP. Participants also must cease corrupt and fraudulent behavior and enhance their compliance system and controls. If a Participant does not have a compliance system and controls, it must develop and enforce them. Finally, Participants must hire a Compliance Monitor acceptable to the Bank, who will report to the Bank for a period of three years. Participants bear the costs of all of these obligations unless they are small firms to which the Bank decides to provide technical assistance. 12. If a VDP Participant implicates a partner or partners who are then investigated and/or sanctioned by the World Bank, won’t it be obvious that the one who wasn’t sanctioned was the informant? In theory yes, but in practice the World Bank will not permit that situation to occur. If the Bank would necessarily identify a VDP Participant by acting on its disclosures (thus making reverse engineering of the Participant’s identity possible), then the Bank will wait to aggregate or independently confirm those disclosures before taking action against other parties. In this way the parties eventually sanctioned or investigated will not know who disclosed their Misconduct. 13. Can Participants use the VDP as a competitive tool, trying to eliminate their competitors by denouncing them through disclosures? In theory some Participants may attempt to do so. The Bank, however, always verifies all disclosures. If a company makes any false disclosures, including regarding any of its competitors, it likely will be found out and publicly debarred for 10 years. Back to the top
IV. How are countries affected by VDP?
1. What countries are affected by the VDP program?
The VDP will affect (1) any country in which government officials and other individuals either request or receive bribes in relation to Bank-financed or supported projects, and (2) the home countries of firms engaging in Misconduct. 2. What does the Bank expect a government to do with information disclosed by the VDP in the redacted reports? Information provided by VDP is useful for supporting and encouraging countries as they act on corruption related to World Bank financing. For example, it may be particularly useful for member countries to know specific or recurring patterns of corruption, as well as the names of corrupt government officials in their countries. The Bank will ask member countries to take timely and appropriate action to prevent and or stop fraud and corruption by addressing such practices when they occur. 3. What can countries do themselves to give incentives to firms and government officials to cooperate? Countries that are a party to the U.N. Convention Against Corruption, are called upon to take note of the anticorruption initiatives of international institutions. Article 37 of the Convention specifically urges countries to encourage persons who participate or have participated in the commission of an offence to supply information useful to competent authorities for investigative and evidentiary purposes, in exchange for mitigated punishment. This is the approach of the Bank’s VDP. 4. Does the Bank obtain information about corruption in a country in other ways? Yes. The Bank obtains information about corruption from many sources, most notably its own investigations. The Bank undertakes investigations when it receives credible allegations of Misconduct in the projects it supports. The information obtained through the VDP often will be even more useful because it covers entire sectors and is fully documented and verified through interviews with employees and agents and reviews of corporate records. 5. What happens if government officials wish to learn the identity of a VDP Participant? The Bank will not disclose information that it has obtained under conditions of confidentiality, including the identity of VDP Participants. Given that the Bank receives VDP information on the condition of confidentiality – and without confidentiality the Bank would not receive such information – it is appropriate that the Bank not disclose the identity of VDP Participants. 6. Why are public officials not allowed to become Participants in the VDP? The VDP is open to all entities, including firms, consultants, and NGOs, that the Bank can sanction. Since the World Bank does not have the authority to sanction or punish public officials, such officials are not eligible to enter into the program. Back to the top
V. Is VDP the right approach to fight corruption? 1. Isn’t there a substantial moral hazard issue? (a) Aren’t firms that sign up for the VDP “getting away” with past Misconduct, even when the amount of the bribe is substantial? No. While it is true that firms that satisfy the Terms and Conditions of the VDP will not be publicly debarred, they face significant financial obligations associated with every step of the VDP process. For example, Participants pay for their internal investigations and the Bank’s verification of their disclosures. Furthermore, firms must cease corrupt practices, and the Bank ensures that they do so through a structured and rigorous compliance and monitoring program—all of which is done at the firm’s expense. Typically, the larger the firm, and the more countries in which it does business, the larger the costs of its participation will be. If the Participant engages in continued Misconduct or otherwise violates the program’s material Terms and Conditions, it faces a mandatory 10-year debarment from all Bank-financed or supported projects. The Bank also will ask member countries to make every effort to remove government officials identified as corrupt from Bank projects to prevent them from repeating their corrupt behavior. (b) If the Bank is serious about corruption, doesn’t it need to punish both the corruptor and the corruptee? The Bank’s goal in addressing corruption is to stop it from occurring in the future so that Bank resources are used solely for their intended purposes. While punishment—including public debarment—is one way to stop corruption, the debarment process is costly, time-consuming, and does not necessarily change long-term behavior or yield the maximum amount of useful information. The VDP, in contrast, reduces corruption by providing incentives for firms to cease Misconduct and comply with the Bank’s rules and guidelines. This can be a more efficient, cost-effective, and lasting way to change firm behavior and make it more difficult for corrupt officials to continue corrupt behavior. Furthermore, the Bank benefits greatly from the extensive information it receives from VDP Participants regarding how corrupt practices were kept hidden, and with whose collaboration. This information is of great value to the Bank and will inform its future efforts to fight corruption in its projects. Ultimately, the VDP is all about reducing poverty more quickly and effectively. 2. You expect a government to prosecute its corrupt officials, but will the Bank act against its own staff members involved in the corruption disclosed by a VDP Participant? Yes. The Bank has a mandatory requirement to terminate employment of any staff found to be involved in corruption. Any allegations against staff arising from VDP disclosures are fully investigated by the Bank in order to seek corroborative evidence and avoid exposing the identity of any VDP Participants. If corroborative evidence is not readily available, INT will hold the allegations in abeyance pending the opportunity to develop such evidence in a manner which does not expose the Participant’s identity, and does not jeopardize ongoing corruption investigations linked to VDP disclosures. 3. How can you justify a VDP where the Bank is acting as prosecutor, judge, and jury at the same time? The Department of Institutional Integrity (INT), which manages the VDP, is neither prosecutor, nor judge, nor jury. All the VDP does is partner with a participating firm in order to uncover information about corruption that it would otherwise have not received. The VDP gives incentives to firms to cooperate with the Bank and, if they do so, they are not subject to public debarment. If a firm has violated the material terms of the VDP Terms & Conditions, INT refers the case to the Bank’s Sanctions Body to judge; i.e., which then determines whether a violation occurred. 4. Couldn’t a firm avoid an investigation by coming forward to enter the VDP? Yes. As long as a firm is not under active investigation, it is eligible to enter the VDP. It is hoped that many firms will choose to enter the VDP rather than risk an investigation and possible public debarment. 5. Aren’t the firms that want to enter VDP those that are likely to be found out by the Bank anyway? This is possible, but corrupt parties usually go to great lengths to hide their illicit transactions, making corruption often difficult to detect and prove. Because of this, data relating to corruption in general is scarce, and data relating to the likelihood of a corrupt party being identified by the World Bank is unavailable. With each passing day, however, the World Bank and its partners are improving their skills at detecting and rooting out corrupt practices, increasing the likelihood that corrupt firms will indeed be caught. Since its establishment in 2001, the Bank's Department of Institutional Integrity (INT) has handled more than 2,000 cases of alleged fraud, corruption or other misconduct, including theft, bid-rigging, bribes, kickbacks, collusion or coercion by bidders, fraud in contract performance, product substitutions and misuse of World Bank funds. As a result, the Bank has sanctioned more than 330 companies and individuals, with these sanctions publicly available on the Bank's website. In 2006, INT further increased its investigative capacity. Investigating for corruption is costly, and the more instances of corruption we can prevent, the better. The VDP was launched as an incentive for good faith firms to become a part of the solution, rather than remain a part of the problem. 6. Won’t VDP Participants be able to hide information about past Misconduct from the Bank? This is an unlikely possibility. The Bank investigates a sample of the contracts that a Participant claims are not tainted by fraud and corruption to ensure that the Participant is not hiding information. The Bank also verifies the Participant’s internal investigation. VDP Participants have no incentive to withhold information about past Misconduct because they only avoid public debarment for Misconduct that they disclose, and they will be debarred for 10 years if the Bank finds that they have withheld information. 7. Won’t the VDP just give firms practice in avoiding detection of Misconduct? No. Fighting corruption is a dynamic process, and the Bank is constantly evolving and improving its knowledge base and investigation toolkit. A firm’s participation in the VDP would not give it a snapshot of a static procedure that it could learn to “outsmart.” Rather, it allows the World Bank to “x-ray” the corruption environment and stay up to date on the latest corrupt techniques. 8. Won’t the VDP end up skewing the market for consultants, suppliers, and contractors? Rather than skewing the market, the VDP is designed to remove corruption-related distortions in the current market. The VDP is open to firms of any size from any country, and the Bank may provide technical assistance to small, needy firms so that the costs of VDP participation do not prohibit them from entering the program. The VDP will work with member country governments to remove corrupt officials from Bank projects, and thereby permit firms from countries with better-enforced anti-corruption laws and codes to continue to bid and work on Bank-financed projects—even in countries where bribes are currently seen as “necessary.” The information provided through VDP disclosures also will guide the Bank to areas where corruption is currently undetected to investigate it and deter it from recurring. All of these acts help level the competitive playing field in favor of honest, technically competent firms of all nationalities and sizes. 9. Are there similar voluntary disclosure programs elsewhere? Over 20 countries, on every continent and in every World Bank region, have legal provisions or programs similar to the VDP, as do some international organizations and supranational bodies. The common principle is to grant certain levels of leniency, immunity, or confidentiality in exchange for cooperation and the disclosure of useful information.The United Nations’ Oil-For Food investigation obtained information by granting confidentiality to many cooperating witnesses. The United Nations Convention against Corruption, which recently entered into force, also encourages states parties to consider implementing programs similar to the VDP.The World Bank’s VDP is unique in that it is wholly voluntary, standardized, and allows Participants the possibility to avoid administrative sanction by the Bank if they satisfy its non-negotiable Terms and Conditions. Back to the top |
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