Sanctions Officer
Sanction Code


Project Name
Water and Sanitation Improvement Program (Agreement No. GRT/WS-12127-PE)
Prohibited Practice(s)
Fraudulent Practice
Type of Sanction
Conditional Non-Debarment
Debarment with Conditional Release


Prohibited Practice(s) Text

Fraudulent Practice: The Respondent Firm entered into a consortium agreement with several members for purposes of bidding on the Consulting Contract. The Respondent Firm and the other consortium parties were found to have misrepresented the authorship of the documents submitted during the implementation of its Consulting Contract. In addition, the Respondent Firm and the other consortium partners failed to disclose that the consortium subcontracted the essential technical aspects of its Consulting Contract to a third party.


The Respondent Firm (“Respondent”) was a member of a consortium, which was awarded a Consulting Contract (the “Contract”) in connection with the Water and Sanitation Improvement Program in Peru (the “Program”). The Office of Institutional Integrity (“OII”) submitted a Statement of Charges and Evidence against the Respondent, and the other parties composing the consortium, for allegedly engaging in fraudulent practices related to the Program. OII’s specific accusations were that during the implementation of the Contract, the Respondent and the consortium parties misrepresented the authorship of several documents submitted to the Executing Agency to obtain the first payment under the Contract. In addition, OII alleged that the Respondent and the other consortium members knowingly failed to disclose to the Executing Agency that the implementation of essential technical aspects of the Contract had been subcontracted to a third party, as required by the terms of the Contract, in order for the consortium parties to receive a financial benefit. Consequently, and in accordance with the Sanctions Procedures, the Sanctions Officer (“SO”) issued a Notice of Administrative Action (“Notice”) to the Respondent. In its Response to the Notice, the Respondent denied the allegations presented by OII.

The SO determined that it is more likely than not that the Respondent engaged in fraudulent practices. In determining the sanction, the SO considered the Respondent’s commitment to adopt an integrity strategy to prevent Prohibited Practices. Additionally, the SO took into account, as a mitigating factor, that the Prohibited Practices did not adversely affect the implementation of the Contract. As a result, the SO imposed a sanction of debarment with conditional release, with a minimum period of ineligibility of one year, during which time the Respondent will be ineligible to participate or be awarded contracts for projects or activities financed by the Bank Group. At the end of the period of one year and if the conditions imposed by the SO are met, the Respondent will be transferred to a conditional non-debarment for three years. Failure to meet the conditions will result in a debarment of an additional three years. In accordance with Section 8.3 of the Sanctions Procedures, the sanction was extended to an individual that exercised control over the Respondent.

The Determination of the SO was not appealed by the Respondent to the Sanctions Committee and, therefore in accordance with the Sanctions Procedures, the sanction imposed entered into force.