Case Summaries

Date of Sanctionsort icon Case Case Number Entity Type Entity Number Period
7 Feb 2014

Collusive practice

An ADB project procurement-related review (PPRR), conducted in April 2012, found red flags and indications of possible collusive practice in two procurement processes conducted according to the shopping method.

On two occasions, a group of firms had submitted quotations for the supply of materials in a manner that was not in compliance with ADB’s Anticorruption Policy and Integrity Principles and Guidelines. In one procurement process, three out of the four firms that submitted quotations were associated with each other through ownership and management, while the fourth firm had a much higher bid price. In a second procurement process, two out of three firms were associated with each other, and the third firm was more likely than not non-existent.

The three firms and three individuals involved did not respond to any of OAI’s communications. The IOC sanctioned the three firms and three individuals for a period of 3 years for collusive practices.

12-068-1402 Firm 3 3 years
7 Feb 2014

Collusive practice

An ADB project procurement-related review (PPRR), conducted in April 2012, found red flags and indications of possible collusive practice in two procurement processes conducted according to the shopping method.

On two occasions, a group of firms had submitted quotations for the supply of materials in a manner that was not in compliance with ADB’s Anticorruption Policy and Integrity Principles and Guidelines. In one procurement process, three out of the four firms that submitted quotations were associated with each other through ownership and management, while the fourth firm had a much higher bid price. In a second procurement process, two out of three firms were associated with each other, and the third firm was more likely than not non-existent.

The three firms and three individuals involved did not respond to any of OAI’s communications. The IOC sanctioned the three firms and three individuals for a period of 3 years for collusive practices.

12-068-1402 Individual 3 3 years
7 Feb 2014

Fraudulent practice

During another ADB PPRR, OAI found indications of possible fraudulent practice in the procurement process for a contract to supply goods under national competitive bidding. The firm had submitted a manufacturer’s authorization letter, which, upon verification with the manufacturer, proved to be false.

The firm and two individuals involved did not respond to any of OAI’s communications. The IOC sanctioned the firm and two individuals for a period of 3 years for fraudulent practice.

12-082-1402 Firm 1 3 years
7 Feb 2014

Fraudulent practice

uring another ADB PPRR, OAI found indications of possible fraudulent practice in the procurement process for a contract to supply goods under national competitive bidding. The firm had submitted a manufacturer’s authorization letter, which, upon verification with the manufacturer, proved to be false.

The firm and two individuals involved did not respond to any of OAI’s communications. The IOC sanctioned the firm and two individuals for a period of 3 years for fraudulent practice.

12-082-1402 Individual 2 3 years
23 Jan 2014

Fraudulent and obstructive practices

A firm and its managing director engaged in fraudulent and obstructive practices related to its bid for a construction contract under an ADB-financed project.

The firm inflated the value of a previous contract it had been awarded and submitted a falsified copy of the contract in order to meet the bid requirements. The firm’s managing director also provided a falsified document related to its employee to materially impede OAI’s investigation.

The firm and its managing director accepted OAI’s proposed sanction of 5 years debarment commencing on 23 January 2014 up to and including 23 January 2019 and waived their right to appeal the sanction.

12-079-1401 Firm 1 5 years
23 Jan 2014

Fraudulent and obstructive practices

A firm and its managing director engaged in fraudulent and obstructive practices related to its bid for a construction contract under an ADB-financed project.

The firm inflated the value of a previous contract it had been awarded and submitted a falsified copy of the contract in order to meet the bid requirements. The firm’s managing director also provided a falsified document related to its employee to materially impede OAI’s investigation.

The firm and its managing director accepted OAI’s proposed sanction of 5 years debarment commencing on 23 January 2014 up to and including 23 January 2019 and waived their right to appeal the sanction.

12-079-1401 Individual 1 5 years
16 Jan 2014

Fraudulent practice

OAI received a complaint that an individual who was the Chairperson of a Consultant Selection Committee (CSC) was also one of the consultants hired by a bidding firm.

During the investigation, OAI established that the individual had regularly worked as a consultant for the firm in question, but that the employment information submitted by the individual varied in three different bid proposals. The firm claimed that it had relied on the individual consultant for the accuracy of the information, and the anomalies had slipped through internal controls.

The individual accepted OAI’s proposed sanction of three years debarment for submitting false information. In addition, the firm accepted OAI’s proposed sanctions of three years conditional non-debarment, during which the firm remains eligible to participate in ADB-related activities but is required to inform OAI of any expressions of interests and bid proposals it submits.

11-055-1401 Individual 1 3 years
30 Aug 2013

Fraudulent and collusive practices

An OAI investigation determined that a consultant misrepresented his experience as a translator in his CV, and colluded with an ADB staff member to obtain a contract from ADB.  The consultant did not dispute OAI’s findings of fraudulent and collusive practices and accepted OAI’s proposed sanction of 6 years.

13-030-1308 Individual 1 6 years
27 Aug 2013

Fraudulent practice

During post contract award review, significant similarities in bids submitted by Firms A, B, and C for an ADB-financed activity were identified by the concerned Resident Mission staff and referred to OAI. The contract was awarded to Firm A.

In the course of its review, OAI reconfirmed the similarities, and sought clarification from the three firms.  Firm A did not respond to OAI’s numerous communications sent via courier, e-mail, and facsimile. Firms B and C denied participation in the bid. OAI also conducted corporate due diligence checks on each of the three firms, but found no evidence of business or familial ties among Firms A, B, and C.

Based on (i) the corroborative information provided by Firms B and C; (ii) the results of the due diligence checks; and (iii) in the absence of any information to the contrary from Firm A, OAI concluded, on a more probable than not basis, that Firm A and its President, engaged in fraudulent practice by falsifying documentation and information belonging to Firms B and C, and submitting false bids on its behalf to ensure award of contract.

The IOC agreed with OAI’s conclusions and declared Firm A and its President ineligible to participate in any ADB-financed, administered, or supported activity for 5 years each. In deciding the period of sanction, the IOC considered the degree of planning, the number of firms that ended up being involved and inconvenienced as a result of Firm A’s actions, the extent and level of management involvement, the significance of the role played, and the lack of cooperation shown to OAI.

11-036-1308 Firm 2 5 years
27 Aug 2013

Fraudulent practice

During post contract award review, significant similarities in bids submitted by Firms A, B, and C for an ADB-financed activity were identified by the concerned Resident Mission staff and referred to OAI. The contract was awarded to Firm A.

In the course of its review, OAI reconfirmed the similarities, and sought clarification from the three firms.  Firm A did not respond to OAI’s numerous communications sent via courier, e-mail, and facsimile.   Firms B and C denied participation in the bid. OAI also conducted corporate due diligence checks on each of the three firms, but found no evidence of business or familial ties among Firms A, B, and C.

Based on (i) the corroborative information provided by Firms B and C; (ii) the results of the due diligence checks; and (iii) in the absence of any information to the contrary from Firm A, OAI concluded, on a more probable than not basis, that Firm A and its President, engaged in fraudulent practice by falsifying documentation and information belonging to Firms B and C, and submitting false bids on its behalf to ensure award of contract.

The IOC agreed with OAI’s conclusions and declared Firm A and its President ineligible to participate in any ADB-financed, administered, or supported activity for 5 years each. In deciding the period of sanction, the IOC considered the degree of planning, the number of firms that ended up being involved and inconvenienced as a result of Firm A’s actions, the extent and level of management involvement, the significance of the role played, and the lack of cooperation shown to OAI.

11-036-1308 Individual 1 5 years
27 Aug 2013

Fraudulent practice

Three firms formed a joint venture to undertake the construction and rehabilitation of a water pipeline project in a DMC.  One of the firms gave a power of attorney to the managing director of its subsidiary company to act on its behalf.  The managing director, allegedly without the knowledge of the firm, changed its work certificate from construction of trunk sewer to construction of water pipeline project.  The executing agency (EA) conducted due diligence on the work certificate and found that it was questionable.  The matter was referred to OAI.

OAI established that the original work certificate for the sewerage project had been doctored, in all probability by the managing director of the subsidiary firm.

During the investigation, the firm cooperated with OAI and this was considered as a mitigating circumstance. It was sanctioned for 2 years. The subsidiary firm has been sanctioned for 3 years and the managing director, who is no longer with the firm, has been sanctioned for 5 years, all for fraudulent practice.  The lead firm of the joint venture has been cautioned in relation to its lack of oversight of the accuracy of the bid that was submitted.

12-041-1308 Firm 1 2 years
27 Aug 2013

Fraudulent practice

Three firms formed a joint venture to undertake the construction and rehabilitation of a water pipeline project in a DMC.  One of the firms gave a power of attorney to the managing director of its subsidiary company to act on its behalf.  The managing director, allegedly without the knowledge of the firm, changed its work certificate from construction of trunk sewer to construction of water pipeline project.  The executing agency (EA) conducted due diligence on the work certificate and found that it was questionable.  The matter was referred to OAI.

OAI established that the original work certificate for the sewerage project had been doctored, in all probability by the managing director of the subsidiary firm.

During the investigation, the firm cooperated with OAI and this was considered as a mitigating circumstance. It was sanctioned for 2 years. The subsidiary firm has been sanctioned for 3 years and the managing director, who is no longer with the firm, has been sanctioned for 5 years, all for fraudulent practice.  The lead firm of the joint venture has been cautioned in relation to its lack of oversight of the accuracy of the bid that was submitted.

12-041-1308 Firm 1 3 years
27 Aug 2013

Fraudulent and obstructive practices

Three firms formed a joint venture to undertake the construction and rehabilitation of a water pipeline project in a DMC.  One of the firms gave a power of attorney to the managing director of its subsidiary company to act on its behalf.  The managing director, allegedly without the knowledge of the firm, changed its work certificate from construction of trunk sewer to construction of water pipeline project.  The executing agency (EA) conducted due diligence on the work certificate and found that it was questionable.  The matter was referred to OAI.

OAI established that the original work certificate for the sewerage project had been doctored, in all probability by the managing director of the subsidiary firm.

During the investigation, the firm cooperated with OAI and this was considered as a mitigating circumstance. It was sanctioned for 2 years. The subsidiary firm has been sanctioned for 3 years and the managing director, who is no longer with the firm, has been sanctioned for 5 years, all for fraudulent practice.  The lead firm of the joint venture has been cautioned in relation to its lack of oversight of the accuracy of the bid that was submitted.

12-041-1308 Individual 1 5 years
12 Jul 2013

Fraudulent practice

During their evaluation of a technical proposal, staff at a resident mission discovered that a firm included in its proposal the CV of its proposed team leader with false information. It also submitted a false certificate that the proposed team leader worked for another ADB-funded project.

The firm admitted to the fraud and cooperated with OAI’s investigation.

The firm accepted OAI’s proposed sanction of 2 years.

12-070-1307 Firm 1 2 years
20 Jun 2013

Fraudulent practice

In August 2012, the Office of Anticorruption and Integrity (OAI) received an allegation that a firm submitted a fraudulent bid security in its bid for a construction project. OAI investigated the case which resulted in the Integrity Oversight Committee (IOC) imposing sanctions on the firm for the submission of the fraudulent bid security and three other fraudulent bank documents.

After further investigation, OAI found that the Managing Director of the firm was involved in the submission of the four fraudulent bank documents and recommended sanctions against the Managing Director. The IOC concurred with OAI's findings and imposed a sanction of 4 years debarment on the Managing Director. In deciding the sanction period, the IOC took into account the Managing Director’s untruthful statements during the course of the investigation, his involvement and level of oversight, and the significance of his role in carrying out the integrity violation as aggravating circumstances.

12-080-1306 Individual 1 4 years
20 Jun 2013

Fraudulent practice

The IOC debarred a firm and its Executive Director/Chairperson for 4 years. The firm and its Executive Director/Chairperson engaged in fraudulent practices by submitting consultants’ curriculum vitaes (CVs) without consent and containing false information. They also misrepresented the consultants’ availability to undertake the consulting services. In response to OAI’s inquiries, the firm and its Executive Director/Chairperson submitted purported engagement and withdrawal letters from the consultants, which were later proved false. The IOC considered their submission of these falsified letters during OAI’s investigation as an aggravating circumstance, warranting an increase from the base sanction of 3 years by 1 year.

12-088-1306 Firm 1 4 years
20 Jun 2013

Fraudulent practice

The IOC debarred a firm and its Executive Director/Chairperson for 4 years. The firm and its Executive Director/Chairperson engaged in fraudulent practices by submitting consultants’ curriculum vitaes (CVs) without consent and containing false information. They also misrepresented the consultants’ availability to undertake the consulting services. In response to OAI's inquiries, the firm and its Executive Director/Chairperson submitted purported engagement and withdrawal letters from the consultants, which were later proved false. The IOC considered their submission of these falsified letters during OAI's investigation as an aggravating circumstance, warranting an increase from the base sanction of 3 years by 1 year.

12-088-1306 Individual 1 4 years
20 Jun 2013

Fraudulent practice

In late 2012, as a part of ADB’s routine internal review processes, concerns were raised with OAI about possible integrity violations in the bidding for a contract for a $19 million drinking water supply project. The firm of interest was the first-ranked bidder.

OAI assessed the complaint and found that less than 12 months earlier, the firm of interest had been declared technically non-responsive on a similar water supply project valued at $10 million, on the grounds that it had insufficient experience on similar projects.

OAI compared the technical proposals submitted by the firm of interest for the two different projects and found that a number of end-user certificates submitted for allegedly the same projects differed significantly in scope and cost.

Given the cogent evidence of fraudulent practice, and the fact that that the contract was about to be awarded, OAI sought from the IOC to temporarily suspend the firm for 6 months. This was approved and the firm was prevented from being awarded the contract. This likely prevented future delays during implementation.

Subsequently, OAI confirmed that a number of the end-user certificates submitted by the firm were fabricated. When presented with OAI’s findings, the firm admitted to engaging in fraudulent practice. The firm’s prompt acknowledgment of its wrongdoing was considered to be a mitigating factor in proposing the 3-year sanction. The officer of the firm who created and submitted the fraudulent documents, allegedly without the firm’s knowledge, was sanctioned for 7 years for fraudulent and obstructive practices. The sanction was aggravated as he attempted to mislead OAI and refused to supply requested documents.

12-108-1306 Firm 1 3 years
20 Jun 2013

Fraudulent practice

In late 2012, as a part of ADB’s routine internal review processes, concerns were raised with OAI about possible integrity violations in the bidding for a contract for a $19 million drinking water supply project. The firm of interest was the first-ranked bidder.

OAI assessed the complaint and found that less than 12 months earlier, the firm of interest had been declared technically non-responsive on a similar water supply project valued at $10 million, on the grounds that it had insufficient experience on similar projects.

OAI compared the technical proposals submitted by the firm of interest for the two different projects and found that a number of end-user certificates submitted for allegedly the same projects differed significantly in scope and cost.

Given the cogent evidence of fraudulent practice, and the fact that that the contract was about to be awarded, OAI sought from the IOC to temporarily suspend the firm for 6 months. This was approved and the firm was prevented from being awarded the contract. This likely prevented future delays during implementation.

Subsequently, OAI confirmed that a number of the end-user certificates submitted by the firm were fabricated. When presented with OAI’s findings, the firm admitted to engaging in fraudulent practice. The firm’s prompt acknowledgment of its wrongdoing was considered to be a mitigating factor in proposing the 3-year sanction. The officer of the firm who created and submitted the fraudulent documents, allegedly without the firm’s knowledge, was sanctioned for 7 years for fraudulent and obstructive practices. The sanction was aggravated as he attempted to mislead OAI and refused to supply requested documents.

12-108-1306 Individual 1 7 years
7 Jun 2013

Fraudulent practice

During the evaluation of technical proposals, the executing agency found that a firm included a false certificate that the proposed team leader worked for another ADB-funded project.

OAI found that the team leader indeed worked for the ADB project but the certificate was falsified. The firm admitted that the fraud was made by its project staff, cooperated with OAI’s investigation, and took steps to rectify the concern.

The firm accepted OAI’s 1-year proposed sanction while the individual who falsified the certificate accepted OAI’s 2-year proposed sanction.

12-069-1309 Individual 1 2 years
29 May 2013

Fraudulent practice

When reviewing a firm’s expression of interest, the executing agency noted that the firm made misrepresentations in its work experience. After verification, OAI confirmed that the firm fraudulently claimed to have completed at least 16 contracts previously. The firm admitted to the misrepresentations and did not dispute OAI’s findings of fraudulent practice. The firm and its executive director accepted OAI’s 3-year proposed sanctions.

11-048-1305 Firm 1 3 years
29 May 2013

Fraudulent practice

When reviewing a firm’s expression of interest, the executing agency noted that the firm made misrepresentations in its work experience. After verification, OAI confirmed that the firm fraudulently claimed to have completed at least 16 contracts previously. The firm admitted to the misrepresentations and did not dispute OAI’s findings of fraudulent practice. The firm and its executive director accepted OAI’s 3-year proposed sanctions.

11-048-1305 Individual 1 3 years
16 May 2013

Fraudulent practice

During the review of technical proposals for a project, the executing agency discovered that the CVs of two national consultants as submitted by the firm contained misrepresentations of work experience. The firm admitted to the misrepresentations and explained that it did not have time to verify the CVs submitted by the consultants. However, OAI discovered that the two national consultants were no ordinary consultants; one was a shareholder of the firm itself and the other was a deputy director in an associated firm. Moreover, the two consultants and the director of the firm were all officers in the associated firm. The firm, its director, and the two consultants did not dispute OAI's findings of fraudulent practice. The firm and its director accepted OAI's total proposed sanctions of 4 years each for this and the findings in the case below (I-11-079). The two consultants accepted OAI's proposed sanctions of 2 years each.

11-073-1305 Firm 1 4
16 May 2013

Fraudulent practice

During the review of technical proposals for a project, the executing agency discovered that the CVs of two national consultants as submitted by the firm contained misrepresentations of work experience. The firm admitted to the misrepresentations and explained that it did not have time to verify the CVs submitted by the consultants. However, OAI discovered that the two national consultants were no ordinary consultants; one was a shareholder of the firm itself and the other was a deputy director in an associated firm. Moreover, the two consultants and the director of the firm were all officers in the associated firm. The firm, its director, and the two consultants did not dispute OAI's findings of fraudulent practice. The firm and its director accepted OAI's total proposed sanctions of 4 years each for this and the findings in the case below (I-11-079). The two consultants accepted OAI's proposed sanctions of 2 years each.

11-073-1305 Individual 1 4
16 May 2013

Fraudulent practice

During the review of technical proposals for a project, the executing agency discovered that the CVs of two national consultants as submitted by the firm contained misrepresentations of work experience. The firm admitted to the misrepresentations and explained that it did not have time to verify the CVs submitted by the consultants. However, OAI discovered that the two national consultants were no ordinary consultants; one was a shareholder of the firm itself and the other was a deputy director in an associated firm. Moreover, the two consultants and the director of the firm were all officers in the associated firm. The firm, its director, and the two consultants did not dispute OAI's findings of fraudulent practice. The firm and its director accepted OAI's total proposed sanctions of 4 years each for this and the findings in the case below (I-11-079). The two consultants accepted OAI's proposed sanctions of 2 years each.

11-073-1305 Individual 2 2
16 May 2013

Fraudulent practice

A complainant was surprised to find that he was a proposed expert in a firm's bid proposal. The firm initially asserted to OAI that it had obtained the complainant's prior consent, but retracted when OAI presented contrary evidence. The firm accepted OAI's findings that the complainant's CV was used by the firm without the prior knowledge and consent of the complainant. The firm and its director accepted a total of 4 years proposed sanctions for this case and the case above (I-11-073) in which it was also found to have committed an integrity violation.

11-079-1305 Individual 1 4
16 May 2013

Fraudulent practice

A complainant was surprised to find that he was a proposed expert in a firm's bid proposal. The firm initially asserted to OAI that it had obtained the complainant's prior consent, but retracted when OAI presented contrary evidence. The firm accepted OAI's findings that the complainant's CV was used by the firm without the prior knowledge and consent of the complainant. The firm and its director accepted a total of 4 years proposed sanctions for this case and the case above (I-11-073) in which it was also found to have committed an integrity violation.

11-079-1305 Firm 1 4
6 May 2013

Fraudulent practice

During the evaluation of technical proposals, the executing agency found that a firm included a false certificate that the proposed team leader worked for another ADB-funded project.

OAI found that the team leader did work for the ADB project but the certificate was falsified. The firm admitted to the fraud, cooperated with OAI’s investigation, and took steps to rectify the concern. The firm accepted OAI's 1-year proposed sanction.

11-069-1306 Firm 1 1 year
22 Apr 2013

Fraudulent practice

The EA disqualified a firm that included in its bid documents identical work experience through both a work completion certificate and a separate schedule detailing works in progress. The EA confirmed that the works had in fact not yet been completed and that the completion certificate was falsified.

OAI independently confirmed that the firm, through its Vice President/Authorized Signatory, had submitted a falsified work completion certificate in the firm's bid.

The Integrity Oversight Committee (IOC) sanctioned the firm and its authorized signatory for 2 years, respectively. In imposing the sanctions, the IOC considered separate sanctions that had already been imposed on the firm, remedial actions that the firm had taken, and their cooperation with OAI's inquiries as mitigating circumstances.

11-077-1304 Individual 1 2 years
22 Apr 2013

Fraudulent practice

The EA disqualified a firm that included in its bid documents identical work experience through both a work completion certificate and a separate schedule detailing works in progress. The EA confirmed that the works had in fact not yet been completed and that the completion certificate was falsified.

OAI independently confirmed that the firm, through its Vice President/Authorized Signatory, had submitted a falsified work completion certificate in the firm's bid.

The Integrity Oversight Committee (IOC) sanctioned the firm and its authorized signatory for 2 years, respectively. In imposing the sanctions, the IOC considered separate sanctions that had already been imposed on the firm, remedial actions that the firm had taken, and their cooperation with OAI's inquiries as mitigating circumstances.

11-077-1304 Firm 1 2 years
22 Apr 2013

Fraudulent practice

The EA, during its bid evaluation process, verified the authenticity of several work certificates. One of these proved to be fraudulent, and as a result, the concerned bidder was disqualified. The matter was subsequently referred to OAI by the relevant ADB operations department.

OAI independently confirmed that the experience certificate was fraudulent. The IOC sanctioned the firm and its Managing Partner/Authorized Representative for 4 years, taking into account the firm's and individual's non-cooperation with OAI's inquiries as an aggravating circumstance.

12-025-1304 Individual 1 4 years
22 Apr 2013

Fraudulent practice

The EA, during its bid evaluation process, verified the authenticity of several work certificates. One of these proved to be fraudulent, and as a result, the concerned bidder was disqualified. The matter was subsequently referred to OAI by the relevant ADB operations department.

OAI independently confirmed that the experience certificate was fraudulent. The IOC sanctioned the firm and its Managing Partner/Authorized Representative for 4 years, taking into account the firm's and individual's non-cooperation with OAI's inquiries as an aggravating circumstance.

12-025-1304 Firm 1 4 years
8 Apr 2013

Fraudulent practice

In 2010, an ADB staff raised a concern to OAI regarding possible fraudulent practice in relation to a bid under a power project. Two firms, A and B, submitted manufacturer’s authorization purportedly issued by the same company. Both, however, claimed that the manufacturer’s authorization submitted by the other was fraudulent.

Upon investigation, OAI found that the manufacturer’s authorization submitted by A was genuine, while that of B was fabricated.  B and its Chief Executive Officer (CEO) accepted OAI’s findings and proposed sanction of 5 years.

OAI also found that there were two other firms related to B and proposed the same sanction in order to prevent sanction circumvention. The two firms had the same CEO and occupied the same office as that of B. The two firms likewise accepted OAI’s proposed sanction of 5 years.

11-068-1308 Individual 1 5 years
8 Apr 2013

Fraudulent practice

In 2010, an ADB staff raised a concern to OAI regarding possible fraudulent practice in relation to a bid under a power project. Two firms, A and B, submitted manufacturer’s authorization purportedly issued by the same company. Both, however, claimed that the manufacturer’s authorization submitted by the other was fraudulent.

Upon investigation, OAI found that the manufacturer’s authorization submitted by A was genuine, while that of B was fabricated.  B and its Chief Executive Officer (CEO) accepted OAI’s findings and proposed sanction of 5 years.

OAI also found that there were two other firms related to B and proposed the same sanction in order to prevent sanction circumvention. The two firms had the same CEO and occupied the same office as that of B. The two firms likewise accepted OAI’s proposed sanction of 5 years.

11-068-1308 Firm 3 5 years
21 Mar 2013

Fraudulent practice

OAI established that two firms and two individuals, acting as the firms' authorized representatives, engaged in fraudulent practices by submitting false work certificates as part of the firms' prequalification application for a civil works contract. Firm A and its authorized representative Mr. X did not respond despite receipt of OAI's requests for initial inquiries and findings. Firm B's and Mr. Y's cooperation during the investigation was outweighed by the misleading information provided in Firm B's response. Considering these, the IOC imposed debarment for 4 years for all the firms and individuals involved.

10-003-1303 Firm 2 4 years
21 Mar 2013

Fraudulent practice

OAI established that two firms and two individuals, acting as the firms' authorized representatives, engaged in fraudulent practices by submitting false work certificates as part of the firms' prequalification application for a civil works contract. Firm A and its authorized representative Mr. X did not respond despite receipt of OAI's requests for initial inquiries and findings. Firm B's and Mr. Y's cooperation during the investigation was outweighed by the misleading information provided in Firm B's response. Considering these, the IOC imposed debarment for 4 years for all the firms and individuals involved.

10-003-1303 Individual 2 4 years
21 Mar 2013

Fraudulent practice

Two Resident Missions collaborated and identified red-flags in a bid security submitted by one of the bidders for a Road Project. The red-flags included incorrect contact numbers, irregularities in the format of the bid security and the name and signatures of the bank officer. OAI confirmed from the issuing bank that the bid security was forged. Despite the firm's attempt to escape liability by claiming that its bid was submitted without authority, OAI's review of the bid submission and inquiries proved that the firm was responsible for the forgery. On the basis of the documents, information gathered during OAI's investigation, and application of Section 51 of the Integrity Principles and Guidelines, the IOC imposed debarment for 4 years for the firm and its manager.

12-042-1303 Firm 1 4 years
21 Mar 2013

Fraudulent practice

Two Resident Missions collaborated and identified red-flags in a bid security submitted by one of the bidders for a Road Project. The red-flags included incorrect contact numbers, irregularities in the format of the bid security and the name and signatures of the bank officer. OAI confirmed from the issuing bank that the bid security was forged. Despite the firm's attempt to escape liability by claiming that its bid was submitted without authority, OAI's review of the bid submission and inquiries proved that the firm was responsible for the forgery. On the basis of the documents, information gathered during OAI's investigation, and application of Section 51 of the Integrity Principles and Guidelines, the IOC imposed debarment for 4 years for the firm and its manager.

12-042-1303 Individual 1 4 years
13 Mar 2013

Sanction violation; fraudulent practice

OAI established that a firm violated its sanction by bidding

13-003-1303 Firm 1 1 year
28 Feb 2013

Collusive practice

OAI received an allegation pertaining to the refurbishment of an office financed under an ADB TA. OAI investigated the matter and found that the bidders (Firms A, B, and C) who submitted bids for the office refurbishment are connected/related. Miss X, the representative of firm A, is the owner of firm B. Miss X is also acquainted with the owner/representative of Firm C.

The IOC found that the individuals and firms prepared their proposals in collusion with each other in order to ensure that one of them wins the contract. The IOC sanctioned firm A and its owner for three years as there were no attendant mitigating or aggravating circumstances. The IOC sanctioned firms B and C, their respective owners and representatives for four years, taking into account the firms' and individuals' untruthful statements to OAI's inquiries as an aggravating circumstance.

11-054-1302 Firm 1 3 years
28 Feb 2013

Collusive practice

OAI received an allegation pertaining to the refurbishment of an office financed under an ADB TA. OAI investigated the matter and found that the bidders (Firms A, B, and C) who submitted bids for the office refurbishment are connected/related. Miss X, the representative of firm A, is the owner of firm B. Miss X is also acquainted with the owner/representative of Firm C.

The IOC found that the individuals and firms prepared their proposals in collusion with each other in order to ensure that one of them wins the contract. The IOC sanctioned firm A and its owner for three years as there were no attendant mitigating or aggravating circumstances. The IOC sanctioned firms B and C, their respective owners and representatives for four years, taking into account the firms' and individuals' untruthful statements to OAI's inquiries as an aggravating circumstance.

11-054-1302 Individual 1 3 years
28 Feb 2013

Collusive practice

OAI received an allegation pertaining to the refurbishment of an office financed under an ADB TA. OAI investigated the matter and found that the bidders (Firms A, B, and C) who submitted bids for the office refurbishment are connected/related. Miss X, the representative of firm A, is the owner of firm B. Miss X is also acquainted with the owner/representative of Firm C.

The IOC found that the individuals and firms prepared their proposals in collusion with each other in order to ensure that one of them wins the contract. The IOC sanctioned firm A and its owner for three years as there were no attendant mitigating or aggravating circumstances. The IOC sanctioned firms B and C, their respective owners and representatives for four years, taking into account the firms' and individuals' untruthful statements to OAI's inquiries as an aggravating circumstance.

11-054-1302 Firm 2 4 years
28 Feb 2013

Collusive practice

OAI received an allegation pertaining to the refurbishment of an office financed under an ADB TA. OAI investigated the matter and found that the bidders (Firms A, B, and C) who submitted bids for the office refurbishment are connected/related. Miss X, the representative of firm A, is the owner of firm B. Miss X is also acquainted with the owner/representative of Firm C.

The IOC found that the individuals and firms prepared their proposals in collusion with each other in order to ensure that one of them wins the contract. The IOC sanctioned firm A and its owner for three years as there were no attendant mitigating or aggravating circumstances. The IOC sanctioned firms B and C, their respective owners and representatives for four years, taking into account the firms' and individuals' untruthful statements to OAI's inquiries as an aggravating circumstance.

11-054-1302 Individual 3 4 years
28 Feb 2013

Fraudulent practice

In 2012, OAI received an allegation that a firm bidding for a package under an ADB financed project had been disqualified by the Executing Agency for including a falsified bid security in its bid submission. OAI confirmed that the firm, through its Director/authorized signatory, had submitted a falsified bid security in the firm's bid.

The IOC sanctioned the firm and its Director/authorized signatory for four years respectively. In imposing the sanctions, the IOC considered the firm's and individual's failure to cooperate with OAI's inquiries as an aggravating circumstance.

12-009-1302 Firm 1 4 years
28 Feb 2013

Fraudulent practice

In 2012, OAI received an allegation that a firm bidding for a package under an ADB financed project had been disqualified by the Executing Agency for including a falsified bid security in its bid submission. OAI confirmed that the firm, through its Director/authorized signatory, had submitted a falsified bid security in the firm's bid.

The IOC sanctioned the firm and its Director/authorized signatory for four years respectively. In imposing the sanctions, the IOC considered the firm's and individual's failure to cooperate with OAI's inquiries as an aggravating circumstance.

12-009-1302 Individual 1 4 years
28 Feb 2013

Fraudulent/obstructive practice

In 2012, an ADB staff member noted that a consultant being evaluated for an assignment had two versions of his CV recorded on CMS and that there were material inconsistencies between both. These concerns of potential misrepresentation were appropriately referred to OAI.

OAI carried out a comparative review of both CVs and found substantial differences in both. OAI's findings were presented to the consultant, who claimed to have aligned his CV to fit the corresponding TOR advertised and denied any misrepresentation. Notwithstanding the same, and despite volunteering a number of deadlines, the consultant failed to comply with his promises to provide OAI with copies of his academic and work records.

While OAI did not pursue inquiries with external sources on the alleged work experience, OAI sought and independently verified that the consultant had falsely claimed post graduate qualifications from the USA. Based on the above, OAI found that the consultant, on a more probable than not basis, misrepresented his academic achievements and accordingly, engaged in fraudulent practice as defined by ADB's Anticorruption Policy.

The IOC agreed with OAI's findings and sanctioned the consultant for four years, taking into account the obstruction caused to the investigative process because of his repeated assurances to provide substantiating evidence which failed to materialize.

12-072-1302 Individual 1 4 years
4 Feb 2013

Fraudulent practice

OAI was investigating Firm A for collusive practice due to the striking similarities of the contents of its bid with that of Firm B. When OAI presented its findings to Firm A for collusive practice, it provided a letter from Firm B admitting that it had fraudulently submitted the bid in the name of Firm A without the latter's knowledge and consent. Firm B and its President Director did not contest OAI's findings of fraudulent practice and accepted OAI's proposed sanction of 3 years debarment.

13-001-1304 Firm 1 3 years
4 Feb 2013

Fraudulent practice

OAI was investigating Firm A for collusive practice due to the striking similarities of the contents of its bid with that of Firm B. When OAI presented its findings to Firm A for collusive practice, it provided a letter from Firm B admitting that it had fraudulently submitted the bid in the name of Firm A without the latter's knowledge and consent. Firm B and its President Director did not contest OAI's findings of fraudulent practice and accepted OAI's proposed sanction of 3 years debarment.

13-001-1304 Individual 1 3 years
10 Jan 2013

Faudulent practice

OAI investigated and established that a firm and an individual, acting as the firm's authorized representative, engaged in fraudulent practices by submitting false certificate of compliance and inspection report as part of the firm's bid. When OAI presented its findings to the firm and the individual, they agreed not to contest OAI's findings of fraudulent practices and accepted OAI's proposed sanction of 1.5 years and 2 years, respectively; negating the need for IOC consideration of sanctions (Integrity Principles and Guidelines, paras. 63-65). Consequently, the firm was sanctioned for 1.5 years and the individual for 2 years.

12-015-1301 Individual 1 2 years
2 Jan 2013

Fraudulent practice

In 2012, OAI received allegations concerning multiple irregularities in contract implementation of a consultancy services contract under an ADB-financed project.
Upon examination of claims and supporting documents submitted by the consulting firm and on-site verification, the consulting firm and its key officer admitted to misrepresentation. The consulting firm submitted a time sheet and associated travel expense documentation which shows that its key officer, named as an expert under the consultancy services contract, worked and travelled on certain dates, when she did not.

The IOC sanctioned the consulting firm and the key officer for 1 year. In making its determination, the IOC considered both the unsatisfactory internal control environment of the firm, as well as the unhelpful role of project officers both in ADB and the government surrounding the misrepresentation.

12-045-1302 Firm 1 1 year