Tunisia

Road Transport Corridors Project


          Redacted Report



                          July 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

In October 2015, the International Bank for Reconstruction and Development (the “World Bank”)
and the Republic of Tunisia (the “Borrower”) signed a Loan Agreement for the Road Transport
Corridors Project (the “Project”) in Tunisia. The Project received additional financing from a
multi-donor Trust Fund.

The Project objectives are: (i) to reduce transportation cost and time and improve road safety on
select road corridors between lagging regions and more developed areas in the territory of Tunisia;
and (ii) to strengthen the capacity of the Ministry of Equipment, Habitat and Land Planning in road
asset management.

The Project Implementing Unit, Ponts et Chaussées (the “PIU”) published the notice for
procurement for a contract under the Project (the “Contract”). Company A submitted bids for five
Contract lots.

The PIU found that Company A had submitted a falsified document in its five bids and, on that
basis, disqualified Company A’s joint ventures from the bidding process.

Allegations & Methodology

The World Bank reported the PIU’s findings to the World Bank Group Integrity Vice Presidency
(“INT”). INT initiated an investigation, reviewed relevant documents, and sought appropriate
verifications.

Findings

       Evidence indicates that Company A misrepresented its experience and submitted
       falsified documents in support.

Bidders for the Contract were required to demonstrate that they had prior work experience similar
to the Contract. To satisfy this requirement, Company A submitted three documents purportedly
establishing that it had implemented a contract (the “Prior Contract”) for a public entity (the
“Public Entity”): (i) a purchase order addressed to a Company A joint venture for the Prior Contract
signed by the Public Entity; (ii) a pre-contractual agreement between the Company A joint venture
and the Public Entity; and (iii) a certificate of completion signed by the Public Entity attesting that
the Company A joint venture had completed a Prior Contract.

The PIU undertook due diligence, sought verifications from the Public Entity, and found that
documents (i) and (iii) were falsified. Further, INT’s investigation found evidence that all three
documents were falsified. Evidence indicates that, while the Prior Contract was a real contract,
Company A had not been awarded it and did not implement it either alone or as part of a joint
venture. Further, evidence indicates that the individual who purportedly signed all three
documents on behalf of the Public Entity had never worked there.



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INT provided Company A with notice of its findings and opportunity to comment. In response,
Company A denied wrongdoing and stated that an individual acting as their agent provided them
with the falsified documents. In support of this claim, Company A submitted a copy of a complaint
they had purportedly filed with the local police. INT sought verification of the complaint with the
local police, but received no response. Company A did not explain why it had claimed experience
on a prior contract that it had neither been awarded nor implemented.

Corrective Actions

The PIU disqualified Company A’s joint ventures Contract from the bidding process.

The World Bank imposed the sanction of debarment with conditional release on Company A,
extending to any entity that Company A directly or indirectly controls.




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