Phase 3: Planning & Design

Insufficient disclosure of designs, assumptions, and the rationale for changes

Limited transparency on designs, key assumptions and rational for changes reduces accountability and enables discretionary decisions that favour narrow interests.

Red Flags & Indicators

  • The design basis, key assumptions, and cost calculations are missing, submitted late, or lack clear technical support and version records.
  • Major design changes are approved without a complete change log, clear justification, or assessment of cost, risk, and safeguard impacts.
  • Stakeholder feedback is not properly recorded, addressed, or linked to design decisions.
  • Scope, cost, and safeguard commitments are spread across different documents, making it difficult to understand the full set of obligations.
  • Information is released inconsistently or access is restricted, preventing timely and meaningful review.

Stakeholder Guidance

Stakeholder Exposure

Exposure includes increased bid uncertainty and design change risk; a higher risk of disputes and claims; reputational risk from perceived secrecy; and rising transaction costs.

Decision Point

Before design approval, require procuring entities to publish the complete design basis and the change log from the design review process.

Mitigation Actions

• Maintain a complete design package (key assumptions, standards, baseline quantities/cost drivers) with version control
• Implement a formal system to control material design changes, documenting the rationale of the design change, costs involved, schedule, risk, safeguard impacts and approvals
• Do not implement design changes until the change record is complete and justified
• Record stakeholder inputs relevant to design (issues raised, responses, decisions) and keep a consolidated register linking scope, cost, and safeguard commitments to design versions
• Use internal compliance escalation processes and whistleblower channels, where available, to flag unsubstantiated design changes

Mitigation Resources

Maintain internal oversight of the company’s design disclosures and change records; require complete and accurate disclosure of key assumptions, standards, baseline quantities, cost drivers, design changes, and material updates, and track corrective action where control failures are identified.

Risk-based internal audit planning — https://toolbox.infrastructuretransparency.org/resource/risk-based-internal-audit-planning/

Use the company’s compliance process to review and escalate requests to omit, delay, or restrict key design information without documented justification; require documented rationale and compliance or legal sign-off before design changes, submissions, or releases proceed.

Compliance management system — https://toolbox.infrastructuretransparency.org/resource/compliance-management-system/