Liberia

Public Financial Management (IFMIS) Project




                   Redacted Report




                                   March 2019
                                Statement of Use and Limitations

This Report was prepared by the World Bank Group (the “WBG”) Integrity Vice Presidency
(“INT”). It provides the findings of an INT administrative inquiry (the “Investigation”) into
allegations of corrupt, fraudulent, collusive, and/or coercive practices, as defined by the WBG for
purposes of its own policies, rules and procedures (the “WBG’s Framework regarding Anti-
corruption”), in relation to the WBG-supported activities. The purpose of the Investigation was to
allow the WBG to determine if the WBG’s Framework regarding Anti-corruption has been
violated.

This Report is being shared to ensure that its recipients are aware of the results of the INT
Investigation. However, in view of the specific and limited purpose of the Investigation underlying
this Report, this Report should not be used as the sole basis for initiating any administrative,
criminal, or civil proceedings. Moreover, this Report should not be cited or otherwise referred to
in the course of any investigation, in any investigation reports, or in any administrative, civil, or
criminal proceedings.

This Report is provided without prejudice to the privileges and immunities conferred on the
institutions comprising the WBG and their officers and employees by their respective constituent
documents and any other applicable sources of law. The WBG reserves the right to invoke its
privileges and immunities, including at any time during the course of an investigation or a
subsequent judicial, administrative or other proceeding pursued in connection with this matter.
The WBG’s privileges and immunities cannot be waived without the prior express written
authorization of the WBG.




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Background

The Financial Management Project (the “Project”) in Liberia was funded through a Trust Fund
administered by the International Development Association (the “World Bank”). It became
effective in March 2009, and closed in May 2012. The Project sought to improve the efficiency
of the Liberian Government’s accounting system through the provision and installation of a
computerized financial management information system in the Liberian Ministry of Finance, and
through strengthening manual accounting systems in line ministries and counties.

Company A bid for and was awarded an approximately US$ 1.5 million Project-financed
contract (the “Contract”).

Allegations & Methodology

While investigating allegations against Company A under another World Bank-financed project,
INT received allegations against Company A under the Project. Subsequently, INT received
additional allegations against Company A in connection with the Project.

Findings

       Evidence indicates that Company A retained an undisclosed agent during the Contract
       tender process.

Evidence indicates that following issuance of the Contract bidding documents, Company A
sought the assistance of a local agent (“Agent A”) to win the Contract and, potentially, hire
Agent A as a subcontractor in the event of Contract award.

Evidence indicates that, during the tender process, Company A and Agent A had an agreement
that Agent A would help Company A win the Contract in exchange for a percentage of the
Contract value (paid either as a fee or via a subcontract).

The Contract bidding documents required disclosure of any commissions or gratuities paid or to
be paid to agents relating to the bid and to contract execution in the event of contract award.
Evidence indicates that, in response, Company A indicated it had “None.”

Evidence indicates that after Contract award and signing, Company A and Agent A formalized
their agreement, which provided that Company A would make commission-based payments to
Agent A.

Evidence indicates that, while Company A disclosed that Agent A was its subcontractor for
Contract execution, it did not disclose Agent A’s role as its agent during the Contract tender
process.




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Corrective Actions

The World Bank imposed the sanction of debarment followed by a period of conditional non-
debarment on Company A. This sanction extends to any legal entity Company A directly or
indirectly controls.




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