Frequently Asked Questions


Who is a whistleblower or complainant?

A whistleblower is any party who, in good faith, conveys or is proven to be about to convey a concern, an allegation or any information indicating that a prohibited practice such as fraud or corruption is occurring or has occurred in the Bank or in a Bank-financed project.

Why protect whistleblowers?

To combat corruption and culture of corruption:

  • Increase accountability and transparency in the operations and management of the Bank
  • Identify and address costly problems early
  • Encourage compliance through deterrence
  • Increase trust and confidence in Bank operations

How does the Bank protect whistleblowers?

Reprisals against anyone making a report will not be tolerated. Any reprisal against a party for using the Bank's complaint reporting procedures is subject to sanction according to Bank rules and procedures. IACD shall guarantee confidentiality of the identities of whistleblowers and complainants.

What happens after I make a report?

Each complaint is treated with utmost rigour. IACD will immediately register the information. The information will then be analyzed and a preliminary report will be prepared. The preliminary report evaluates the evidence to determine its credibility, materiality and verifiability. Where possible, IACD.2 will seek corroboration of the information it receives IACD will also ensure that matters alleged in the complaint relate to sanctionable practices including or related misconduct. If your complaint is not sufficiently specific and is more directly concerned with another Bank standard as the Bank’s Code of Ethics, IACD will refer the matter to the appropriate body. 

Where the allegations are found to provide a legitimate basis, IACD subsequently conducts a full investigation. The results of the investigation will then be forwarded to the appropriate body under the sanctions system 

Can't someone be seriously harmed by some anonymous report that is untrue?

Anonymous complaints cannot be used to apply sanctions or to refer a matter to national authorities for prosecution unless the facts are confirmed by an independent investigation according to Bank procedures.

Anonymous complaints, if credible, can only serve as the basis for launching an investigation. Only if an investigation supports an anonymous complaint will any action be taken. Furthermore, investigations are conducted at the highest level of confidentiality, and everything possible will be done to prevent the information leaking out. All records are maintained in locked files, and a log is kept of all access to any confidential document. In the case of Bank, there will be absolutely no reference to an anonymous report placed on the person’s personnel file.

What does the Bank do about people who deliberately file false reports?

Any Bank employee, or any person or entity that does business with the Bank that knowingly submits a frivolous complaint is subject to sanction. In cases where such conduct is a legal offence, the Bank may also refer the matter to national authorities for prosecution.

If I make a report that I think is accurate but turns out to be false will I be punished?

No. The key premise is that you believe on reasonable grounds that the facts reported are accurate. That is all that the Bank requires. The Bank is asking you to report any activity that appears to you to involve fraud, corruption, collusion, coercion or related staff misconduct in the Bank or Bank-financed projects. The Bank will investigate the report and determine whether it is well founded. Even if it is determined that it is not well founded, if you made the allegation in good faith, you have nothing to worry about.

Are there any rewards for turning in someone who is found to have committed fraud or corruption?

No. The Bank does not offer monetary or any other forms of reward for reporting allegations.

Who is told about what I report? Are allegations shared with others either inside or outside the Bank?

The allegations, and the investigation, are all kept confidential. We will respect your privacy and the confidentiality of the material provided. Once the matter is resolved, if sanctions have been applied to a staff member, then his or her personnel record will reflect that. The results of investigations will be included in periodic reports, but the identity of the person who brought the original allegation and of other parties involved in investigations will not be revealed

What is retaliation?

Retaliation is any act direct or indirect, recommended, threatened or taken against a whistle blower or complainant by any person because the whistle blower or the complainant has made a disclosure pursuant to the Policy.

Retaliation shall not be permissible against any whistle blower or complainant.

Retaliation includes:

  • Discrimination
  • Reprisal
  • Harassment
  • Vengeance

As a matter of general deterrence, the Bank shall publicly inform Bank staff of the penalty imposed on a supervisor for misconduct arising from retaliation.

The Bank will insert clauses in Bank loan agreements and grant agreements, undertaking to take punitive action against parties that engage in retaliation.

What remedies are given to a Complainant?

Employment remedies available to a whistle blower against whom there has been retaliation shall be determined by the President based upon the findings and recommendations of IACD and shall include but not be limited to:

  • Reinstatement
  • Back pay and benefits
  • Compensatory damages
  • Adjudication expenses, including representation fees, costs of expert witnesses, travel and other costs associated with the claim of retaliation
  • Transfer upon the request of the prevailing whistle blower to another unit of the Bank
  • Intangible benefits, including public recognition of the vindication of the whistle blower, and in appropriate circumstances, public recognition of the contributions of the whistle blower to the Bank
  • Any other further relief to be recommended by IACD

What are the Obligations and Rights of the Bank and its Personnel?

In furtherance of the Policy objectives, the Bank and its Personnel shall have obligations and rights, amongst which are the following: 

  • Bank Personnel are duty bound to disclose any prohibited practice including fraud, corruption, collusion or coercion that come to their attention immediately but in any event not later than seven (7) days after becoming aware of the practice.
  • As a matter of general deterrence, the Bank shall publicly inform Bank Personnel of the penalty imposed and discipline of a supervisor for misconduct arising from retaliation.
  • The report of IACD recommending relief against retaliation shall be furnished to the whistle blower.
  • The whistle blower shall have a prior opportunity to review any communication that would lead to exposure.
  • The reporting of the retaliatory cases related to this Policy shall, as with other investigative activities of IACD, be publicly reported and made available on the Bank website, taking into account the privacy of the Party/Parties concerned.
  • Bank personnel are to cooperate fully and assist IACD in its investigations.

What are corrupt practices?

Corruption is a term that has many meanings. Generally, people understand what is meant when an activity is said to be "“corrupt”. In the Bank, the accepted definition of “Corrupt Practice” is as follows: “A Corrupt Practice means the offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the actions of another party.”

What are fraudulent practices?

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.

What are collusive practices?

“Collusive Practice” is an arrangement between two or more parties designed to achieve an improper purpose, including to influence improperly the actions of another party.

What are coercive practices?

“Coercive Practice” is impairing or harming, or threatening to impair or harm, directly or indirectly, any party or the property of the party to influence improperly the actions of a party.

What are obstructive practices?

The Bank defines obstructive practice as the deliberate destruction, falsification, altering or concealment of evidence material to the investigation or making false statement to investigators in order to materially impede a Bank 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 acts intended to materially impede the exercise of the Bank’s inspection and audit rights.

What does the Bank mean when it talks about "Corrupt Practice"?

Corruption is a term that has many meanings. Generally, people understand what is meant when an activity is said to be "corrupt". In the Bank, the accepted definition of “Corrupt Practice” as follows: A Corrupt Practice means the offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the actions of another party"

What does the Bank mean when it talks about "Fraudulent Practice"?

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.

What does the Bank mean when it talks about "Collusive Practice"?

“Collusive Practice” is an arrangement between two or more parties designed to achieve an improper purpose, including to influence improperly the actions of another party.

What does the Bank mean when it talks about "Coercive Practice"?

“Coercive Practice” is impairing or harming, or threatening to impair or harm, directly or indirectly, any party or the property of the party to influence improperly the actions of a party.

If I make a report that I think is accurate but turns out to be false will I be punished?

No. The key premise is that you believe on reasonable grounds that the facts reported are accurate. That is all that the Bank requires. The Bank is asking you to report any activity that appears to you to involve fraud, corruption, collusion, coercion or related staff misconduct in the Bank or Bank-financed projects. The Bank will investigate the report and determine whether it is well founded. Even if it is determined that it is not well founded, if you made the allegation in good faith, you have nothing to worry about.

There are no references to bribery. Does that mean that bribery is excluded?

No. Bribery is a specific form of corruption and is included within the mandate of the Integrity and Anti-Corruption Department.

What is “Misconduct”?

Misconduct is a failure by a staff member to observe the rules of conduct or the standards of behaviour prescribed by the Bank. IACD will investigate cases of misconduct if the alleged practice is related to fraud, corruption, collusion or coercion. Other cases of misconduct will be referred to appropriate organs within the Bank for their action.

What is the standard of proof used by the Bank to substantiate a complaint?

The standard of proof that shall be used to determine whether a complaint is substantiated is defined for the purposes of an investigation as information that, as a whole, shows that something is more probable than not.

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