FAQs – Reporting corruption allegations at the IDB

Allegations of prohibited practices should be reported to the Office of Institutional Integrity (OII). This can be done confidentially and securely by telephone, e-mail, fax, regular mail, in person, or through the allegations form on this website. Allegations may also be made to the President, Vice Presidents, Managers, or the Bank's Country Office Representatives in each of its borrowing member countries, as well as in Europe and Asia. Recipients of allegations are mandated to report them to the Office of Institutional Integrity immediately. Individuals submitting allegations are encouraged to identify themselves to facilitate the accurate corroboration of the information, knowing that the IDB Group will honor confidentiality.

Anybody who has any knowledge of fraud or corruption involving any IDB Group-financed activity is urged to report such information to the IDB Group in as much detail as possible, including the following information:

• 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 not only the city and country, but, if possible, an actual address, the name of the building, the office number, etc.
• Who do you think committed the corruption or fraud? Who else was implicated?
• How does your allegation relate to IDB Group-financed activities?

Yes. However, anonymous allegations are more difficult to investigate and cannot be used as evidence. Anonymous allegations can only serve as the basis for further investigation. Anyone who chooses to remain anonymous will be asked to contact the IDB Group again within a set timeframe so that investigators may request additional information that may have come to his or her attention or to provide any clarifications.

Yes, the Inter-American Development Bank’s provisions to guard confidentiality in investigations include:

• The IDB Group protects the confidentiality of complainants.
• All staff involved in an investigative process are obligated to preserve and protect the confidentiality of the subject, the witnesses and all other parties concerned.
• Allegations of fraud or corruption, the identity of complainants, the investigative process and investigative findings, as well as the Sanctions Proceedings are strictly confidential.
• Information gathered, received, or generated in the course of an investigation by OII or a third party on behalf of OII will not be disclosed, subject to the exceptions provided in other Bank policies concerning disclosure of information to national authorities and other affected international organizations.
• Any staff member who compromises the confidentiality of a complainant is subject to disciplinary action.
• The IDB Group accepts anonymous allegations.
• Employees of the IDB Group have an obligation to report suspected acts of fraud and corruption in activities financed by or related to the IDB Group.

In the case of Bank staff members who submit allegations, Staff Rule PE-328  Protection to Whistleblowers and Witnesses protects Bank employees and external parties who submit allegations of prohibited practices or other misconduct under Bank policies from retaliation.

According to the staff rule, reprisal against those who submit allegations or cooperate with the Bank’s authorities in the context of an investigation, audit or other inquiry is expressly prohibited. Reprisals are defined as any act of retaliation against a whistleblower.

Reprisal may include, but is not limited to, wrongful termination, harassment, improper assignment of work outside of the corresponding position description, unsubstantiated adverse evaluation of performance or determination of merit pay, the withholding of any other entitlement, any other unfounded adverse personnel action and such actions against others because of their association with a whistleblower.

A reprisal against an external party may also include, but is not limited to, retaliation in recruitment, in the award of contracts, in the administration of contracts, in evaluations of performance, and in the execution or negotiation of dealings with the Bank. Reprisal also includes such acts of retaliation even when based on a mistaken belief that reporting or cooperation has occurred, as well as such actions when they are threatened or recommended. Reprisal also includes actions undertaken to prevent or influence reporting or cooperation.

OII conducts a threshold analysis to determine whether an allegation

• concerns Prohibited Practices of the IDB Group;
• relates to an activity financed by the IDB Group; and
• provides sufficient credible information.

If the answer to each of these questions is “yes”, OII continues to investigate to determine whether the sufficient evidence of a Prohibited Practice exists.

At the conclusion of an investigation, OII categorizes allegations as unfounded, unsubstantiated or substantiated, based on the evidence.

The IDB Group’s sanctions procedures require that anyone subject to the sanctions process be notified of the charges and evidence supporting those charges. The respondent then has two separate opportunities to respond to the charges and provide evidence in his or her defense. Only after this process is concluded does the IDB Group make a decision with respect to the imposition of a sanction. Imposed sanctions may be made public on the IDB’s website.

Complaints concerning Bank staff should be filed with the Ethics Officer. Reports can also be filed with the Human Resources Department or any Bank manager.

The Sanctions Committee is comprised three Bank staff members and four external members appointed by the President and is responsible for reviewing the evidence discovered in the course of investigations into allegations of prohibited practices. The Committee determines whether sanctions are appropriate on the basis of the information provided by OII and parties subject to the investigation.

The Sanctions Committee may impose any sanction that it deems to be appropriate under the circumstances, including but not limited to reprimand, conditions on future contracting and debarment from participating in IDB Group-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 improperly influence 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 (a) deliberately destroying, falsifying, altering or concealing evidence material to the investigation or making false statements to investigators in order to materially impede a Bank Group investigation into allegations of a corrupt, fraudulent, coercive or collusive practice; and/or threatening, harassing or intimidating any party to prevent it from disclosing its knowledge of matters relevant to the investigation or from pursuing the investigation; or (b) acts intended to materially impede the exercise of the Bank’s inspection and audit rights.

The IDB Group's anti-corruption framework prohibits fraudulent or corrupt practices in any of its operations and applies to all Bank staff and firms or individuals involved in IDB Group-financed activities. The key elements of the IDB Group’s anti-corruption regulations and sanctions process are contained in the standard loan documentation,

• Procurement of Works and Goods Financed by the Inter-American Development Bank (GN-2349-9);
• Selection and Contracting of Consultants Financed by the Inter-American Development Bank (GN-2350-9);
• Corporate Procurement Policy (GN-2303-20);
• other IDB Group policies.

If a firm, entity or individual bidding for or participating in an IDB Group-financed project is found to have engaged in prohibited practices, the IDB Group may, among other things, decide not to finance portions of the project, or suspend disbursement of the loan

No. The IDB Group does not offer monetary rewards or any other kind of compensation for reporting allegations.

OII promotes awareness of the IDB’s integrity policies both within and outside the IDB Group by organizing and supporting outreach activities, such as integrity training for IDB Group staff and supporting anti-corruption activities of member countries. The Office also shares lessons learned from investigations to ensure they are considered in IDB Group policies and the design of future operations.

Aiming to harmonize their efforts, the IDB, the African Development Bank Group, the Asian Development Bank, the European Bank for Reconstruction and Development, the European Investment Bank Group, and the World Bank Group have agreed on a shared framework for fighting fraud and corruption within their activities and operations.