Republic of South Sudan

Multidonor Education Rehabilitation Project

                       Redacted Report




                                 November 2018
                                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 Multidonor Education Rehabilitation Project (the “Project”) was designed to improve access
to education in South Sudan, including increasing the availability and quality of textbooks for
primary school students. The Project was financed by, among others, the Government of South
Sudan and a trust fund administered by the International Development Association (“IDA”).1 The
Project closed in December 2012.

Allegations & Methodology

The World Bank Group Integrity Vice Presidency (“INT”) received allegations that Company A
paid bribes in order to influence the award of a contract under the Project (the “Contract”).

INT’s investigation consisted of, among others, a review of Project documents and correspondence
allegedly exchanged among the individuals alleged to be involved in the bribe payment.

Findings

        Evidence indicates that Company A provided improper favors to government employees
        to influence the award of a contract under the Project.

Evidence indicates that Company A’s employees gave cash and other items of value to government
employees to influence their decision on the award of the Contract. Evidence indicates that a
Company A employee, based in Company A’s headquarters, worked with local representatives of
Company A—and also traveled to South Sudan—to make payments to government employees.
Evidence also indicates that Company A’s management appears to have coordinated and
sanctioned these bribe payments, in that Company A employees at headquarters arranged for funds
to be sent to South Sudan.

Subsequently, government employees sent a letter to the World Bank seeking to award the
Contract to Company A on a sole-source basis. The World Bank refused this request, and
suggested that the Contract be procured through competitive tendering. Evidence indicates that
Company A employees continued to provide favors to government employees, such as paying for
holidays for such government employees, following this refusal by the World Bank.

Corrective Actions

The World Bank Group imposed the administrative sanction of debarment with conditional release
on Company A. The ineligibility extends to any legal entity directly or indirectly controlled by
Company A.




1
  The IDA is one of the five institutions comprising the World Bank Group. The International Bank for Reconstruction
and Development (“IBRD”) and IDA constitute the World Bank. IDA and the World Bank are used interchangeably
throughout this Report.


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