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Checklist for Corruption Prevention Intervention
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Continuous monitoring and evaluation of the results/outcomes.

This checklist therefore provides guidance on a positive approach that can be implored during a corruption prevention intervention (e.g. assignment studies, presentations and advisory services). It is not meant to be exhaustive as every situation often comes with its own unique challenges and many thus need one to constantly change the approach in order to adapt well to the prevailing circumstances.

The Approach

·         Target areas/Analysis of the work environment:

o   Describe the work environment by paying closer attention to the following:

-        Inventory control mechanisms

-        Safety of inventory in respect of theft, exposure to weather elements, physical, chemical damage, etc.

-        Security of records and proper records keeping.

-        Position and orientation of receipt and dispatch areas.

-        Access or restrictions to storage areas, etc.

 

o   Compare with other institutions involved in similar operations.

o   Study records of what had gone wrong in the past as a result of the environment.

o   Interrogate what could go wrong given the current environment.

o   Compare the current scenario with the set standards or other requirements.

 

 

·    Identify stakeholder being served, impacted, or operated by the client:

o   Who are suppliers

-        What do they supply?

-        How are they assessed?

-        Are they registered?

-        What ethical standards are they adhering to?

-        Are their premises/ area operation checked?

-        Criminal records? Etc.

 

 

 

o   Who are Clients

-   What are their expectations?

-   Service delivery

-   Quality of service

-   Service charter

-   How are their questions and queries responded to? Etc.

 

o   Who are competitors

-   Compare performance with others in similar operations.

-   Fair competition.

 

o   Employees

-        Health and safety

-        Training and development

-        Motivating/mentoring.

 

·         Look for the existence, appropriateness and implementation(enforcement) of the following:

o   Procurement and gifts policy

-   Various forms of contracts which the company may enter into when procuring different supplies, services and works; contract conditions or terms acceptable reasons for permitting waivers; staff training on procurement procedures; purchasing limit methods; inventory control methods; records management; procurement information security; ownership of intellectual property (e.g. architectural and engineering drawings); procurement officers may find themselves having to make discretionary decisions.

-   Acceptable methods of procurement.

 

o   Whistle blowing policy

-   What behavior should be reported

-   How to report

-   Safety of informers

-   Presence of convenience means of reporting(e.g. hotlines)

-   Proper feedback mechanisms

Rewarding of informer

o   Ethics policy

-   Ethical standards for employees.

-   Ethical standards for suppliers

-   Ethical standards for other stakeholders

-   Enforcement strategy

-   Continuous training and monitoring.

 

o   Code of conduct, etc.

Solicitation and acceptance of gifts as kickbacks; professional negligence; negligence leading to loss of a company finance and property; deliberate and malicious deviation from the organizations policies; failure to the declare conflict of interest; theft or pilfering; personal conduct when dealing with suppliers and contractors; and adherence to statutes and regulations governing the operations of the organization. Appropriate action on non adherence and disciplinary action against managers, supervisors when their acts have contributed to the situation.

 

 

·         What regulatory/ statutory instruments govern the operations of the client in this area of operation?

a.    Adherence to available procurement legislations

b.    Adherence to available government policies( e.g. citizen preferences and reservations)

c.    Environmental considerations

d.    Observance of ceilings and supplier categorizations

e.    Adherence to procurement procedures and asset disposal processes

 

·         Who is responsible for what? In the context of the presidential road-map, the four Ds. Report any weakness they identify when carrying out their duties- thus playing their part in compliance.

 

·         Identify possible watchdogs and exploit the possibility of working harmoniously ( more effectively) with them:

o   Giving false information

o   Defrauding/manipulation of records and other documents.

o   Destruction of evidence

o   Obstruction or refusal to give assistance(section 18 of CEC Act)

o   Giving assistance in relation to contracts (including cancellations) or auctions( Sections 29,30,32 of CEC Act)

 

·         Draw possible solutions ( recommendations ) to address the identified problems:

o   As recommendations in corruption prevention reports.

o   Or as advice during presentations.

o   Or as a proceedings report after other corruption prevention interventions( e.g. workshops and other advisory services)

 

·         Formulate an implementation strategy for the recommendations:

o   Set target completion dates.

o   Discuss and agree on the recommendations with client

o   Propose budgets for the activities

o   Sell the ideas to other stake holders who are crucial for the success of the exercise.

 

·         Monitoring and evaluation of the results/ outcome:

o   Through surveys and questionnaires

o   Interrogation of intelligence database (intelligence is an asset only during its usage). After receiving our warning –act quarterly. Criticise all the information in a systematic way.

o   Interviews

o   Risks and controls monitored, reviewed and updated at regular intervals by management (i.e. time lines and schedules towards delivery) also refer to target area at paragraph 1.

o   Visits to clients

 

Conclusions

This checklist is a guideline that can be used as a positive approach in many corruption prevention interventions that are carried out in procurement and contract dealings. It can be particularly good for beginners who often find themselves confronted by the need to tackle corruption in their procurement and contract dealings but without any readily available reference materials. It is hoped that it will be particularly of great assistance to members of the Corruption Prevention Committees ( CPC’s) and others in ministries and departments who have been tasked with the responsibilities of driving anticorruption initiatives through risk management process.

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