Republic of Rwanda

Human Resources Development Project

                 Redacted Report




                            March 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 Human Resources Development Project (the Project) in Rwanda aimed to develop and
implement a sustained program of capacity through education and skills development. The Project
was financed by the International Development Association (IDA).1 The Project became effective
in January 2001 and closed in December 2009.

In 2008, Company A submitted a bid for a contract under the Project (the Contract).

Allegations

The World Bank Group Integrity Vice Presidency (INT) received an allegation that Company A
made improper payments to government employees to be awarded the Contract.

Methodology

INT’s investigation consisted of, among other steps, a review of the Project documents, as well as
documents and statements obtained from Company A’s parent company.

Findings

Evidence indicates that Company A made improper payments to government employees,
through undisclosed agents, to influence the procurement process of the Contract.

Evidence indicates that, through local agents, Company A made improper payments to government
employees of the Project Implementing Unit, in order to be awarded the Contract.

The bidding documents for the Contract required bidders to disclose payments made to agents in
connection with the bidding process. Evidence indicates that, contrary to such requirements,
Company A failed to disclose payments to the above-mentioned agents in its bid for the Contract.

Follow Up Action by the World Bank

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




1
  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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