OII

OII’s prevention teams are responsible for assisting IDB Group operational units and management identify, assess and mitigate integrity and reputational risks on IDB Group-financed activities through training for IDB Group staff and borrowing member executing agencies, consultations, Integrity Due Diligence (IDD) for the IDB Invest and IDB Lab, and the formulation and implementation of integrity focused policies such as Integrity and Anti-Money Laundering frameworks. Key Documents.

OII’s investigations team is responsible for the conduct of investigations and submission of administrative charges to the Sanctions System against parties involved in Prohibited Practices. OII follows the Principles and Guidelines for Investigations, incorporated in the Uniform Framework for Preventing and Combating Fraud and Corruption adopted by the International Financial Institutions Anti-Corruption Task Force.

An investigation begins after an independent OII assessment deems an allegation of Prohibited Practices in an IDB Group-financed activity to be credible and actionable. As part of an investigation, OII may conduct interviews, site-visits, audits and/or inspections of relevant projects and companies. At the conclusion of an investigation, implicated parties are afforded an opportunity to respond to allegations to OII, either in person or in writing.

If OII establishes that it is more likely than not that a Prohibited Practice occurred, it submits a Statement of Charges to the Sanctions Officer. Alternatively, at any time prior to the submission of a Statement of Charges, implicated parties may choose to resolve investigations through a Negotiated Resolution Agreement with OII.

Detailed information about these procedures and Negotiated Resolutions are available in Key Documents: Sanctions Procedures, PE-328 Whistleblower Reporting and Protection Policy, Uniform Framework for Preventing and Combating Fraud And Corruption, MDB Harmonized Principles on the Treatment of Corporate Groups.

The IDB Group prohibits the following practices in all financed activities:

1. A “corrupt practice” is the offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the actions of another party;
2. A “fraudulent practice” is any act or omission, including a misrepresentation, that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation;
3. A “coercive practice” is impairing or harming, or threatening to impair or harm, directly or indirectly, any party or the property of the party to influence improperly the actions of a party;
4. A “collusive practice” is an arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party; and
5. An “Obstructive Practice” is: (i) destroying, falsifying, altering or concealing of evidence material to a Bank investigation, or making false statements to investigators, with the intent to impede a Bank investigation; (ii) threatening, harassing or intimidating any party to prevent it from disclosing its knowledge of matters relevant to a Bank investigation or from pursuing the investigation; or (iii) acts intended to impede the exercise of the Bank’s contractual rights of audit or inspection or access to information.
6. A “misappropriation” is the use of IDB Group financing or resources for an improper or unauthorized purpose, committed either intentionally or through reckless disregard (Effective 1/1/2020).

Please see Key Documents: Sanctions Procedures (2020 revision).

Do you have information about Prohibited Practices (fraud, corruption, collusion, coercion, or misappropriation) that occurred in an IDB or IDB-Invest project?

Use our online form to tell us.

Allegations may be made anonymously. If you prefer to remain anonymous, OII will respect your decision to withhold your identity. However, please note that anonymous allegations are often difficult to pursue as there may be no other way for OII to obtain the necessary information. If you choose to remain anonymous, please consider providing a means for OII to contact you if further information or clarification is needed. For example, you can create a free e-mail address (such as Yahoo or Gmail) using a pseudonym and provide it to OII as your contact information.

Online Form to submit allegations

If you wish to make a report about the conduct of an IDB Group employee, please contact the Ethics department

Deciding to report anonymously, or not

When you submit an allegation, you can identify yourself or you can choose to be anonymous. If you choose to identify yourself, your identity will be kept confidential by OII. More information about confidentiality in the context of reporting allegations may be found in the PE-328 Whistleblower Reporting and Protection Policy (as well as Uniform Framework for Preventing and Combating Fraud and Corruption, and elsewhere in Key Documents ).

Anonymous reporting may present disadvantages for you and for the investigation. Anonymous reporting may prevent OII from effectively following up on the allegation, as we may be unable to assess the credibility of an allegation or follow up with necessary questions. Typically, anonymous reporting is more difficult to investigate; so we ask you to provide as much detail and evidence as possible about the suspected Prohibited Practices.

Other ways to submit an allegation

E-Mail: OII-reportfraud@iadb.org
By Phone: (1-877) 223-4551
Toll free from the U.S. (Fees apply to calls from other countries.)

By Fax: (1-202) 312-4019
Long distance charges may apply.

By Mail Or In Person (Mail should be marked “Personal and Confidential”)

Inter-American Development Bank
Office of Institutional Integrity, B-600
1300 New York Avenue, N.W.
Washington, D.C. 20577, USA

Allegations made to Bank staff will be forwarded to OII immediately.

What to include in your allegation

Please provide as much detail as possible, including the following:

• If available, IDB Group-financed activity name and number.

• Who do you think committed the prohibited practice/s? Who else might be involved?
• What happened? (Describe the events with as much relevant detail as possible.)
• When did it happen? (Dates, time, how many times, etc.)
• Where did it happen? (Include the city and country, and also, if possible, an actual address, the name of the building, the office number, etc.)
• Who else might know about this?
• Does anyone know that you filed a report to us?

The IDB Group’s policy for whistleblower protection expressly prohibits acts of retaliation against Bank employees and external parties that report allegations of Prohibited Practices or cooperate with Bank authorities in the context of investigations, audits or other inquiries. This policy also establishes the measures the IDB Group will take to prevent retaliation against employees and external parties that make a report. (See Key Documents: PE-328 Whistleblower Reporting and Protection Policy.)

The Negotiated Resolution process is an alternative mechanism for resolving cases of Prohibited Practices, which allows an eligible company or individual the opportunity to resolve matters in a timely fashion and receive cooperation credit against any potential sanction, among other benefits. A company or individual that meets the eligibility criteria may seek a Negotiated Resolution with OII (i) during the course of an investigation or (ii) in the context of a self-disclosure, prior to the commencement of an investigation by OII. For more information on the process and eligibility criteria, please visit our Negotiated Resolutions Brochure.