Sanctionable Practices

Sanctionable Practices have been defined in the Bank’s procurement policies as corrupt, fraudulent, collusive, coercive and obstructive practices in relation to Bank Group financed operations. These policies apply to individuals and firms. These practices are further defined below:

• Corrupt practice: The offering, giving, receiving or soliciting, directly or indirectly, of anything of value to influence improperly the actions of another party. “Another party” is defined as a public official acting in relation to a contract execution, procurement process or selection process. “Public official” includes Bank staff and employees of other organizations taking or reviewing procurement or selection decisions.
• Fraudulent practice: Any act or omission, including a misrepresentation, that knowingly or recklessly misleads, or attempts to mislead, a public official to obtain a financial or other benefit or to avoid an obligation. The terms “benefit” and “obligation” refer to a contract execution, procurement process or selection process. “Act or omission” refers to any act that intends to influence a contract execution, procurement process or selection process. 
• Collusive practice: An arrangement between two or more parties designed to achieve an improper purpose, including to improperly influence the actions of another party. “Parties” refers to participants in the procurement or selection process, including public officials, acting either by themselves or through a non-participant in the procurement or selection process. Collusive practices include the attempt to stimulate competition or to establish bid prices at artificial, non-competitive levels or share bid prices or other conditions. 
• Coercive practice: Impairing or harming, or threatening to directly or indirectly impair or harm any party or the property of the party, in order to improperly influence the actions of a party. “Party” refers to a participant in the contract execution, procurement process or selection process. 
• Obstructive practice: 
  • Deliberately destroying, falsifying, altering, or concealing of evidence material to the investigation or making false statements 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.