Bribery and kickbacks for favourable evaluation, shortlisting and award decisions
Officials, advisers or intermediaries solicit or receive kickbacks in exchange for favourable evaluations, shortlisting, contract awards or contract terms.
Red Flags & Indicators
- Unofficial contact between evaluators, advisers, intermediaries, and bidders increases during shortlisting or scoring stages.
- Gifts, hospitality, or personal benefits are offered or requested to influence access to evaluators or tender outcomes.
- Agents or consultants have unclear roles, unusually high fees, hidden payment arrangements, or payments linked to winning the tender.
- Scoring sheets, evaluation reports, or award decisions contain inconsistencies, unexplained changes, missing records, or weak technical justification.
- Conflicts of interest involving evaluators or advisers are not fully disclosed, checked, or properly managed.
Stakeholder Guidance
Stakeholder Exposure
Exposure includes solicitation pressure via officials or agents; anti‑bribery, debarment and criminal risk; unfair evaluation outcomes and lost opportunities; higher bid costs (agents, hospitality, “facilitation” attempts); and reputational risk if linked to kickbacks.
Decision Point
During the bid process, use official tender channels, and withdraw if solicitation signals arise.
Mitigation Actions
• Adopt a lobbying policy that sets clear limits on gifts and hospitality and applies to agents and intermediaries
• Whistleblower policy for reporting and handling unethical or illegal activities within the organisation
• Require pre-approval and adequate record keeping of all tender interactions with officials, sponsors and intermediaries, meetings, and hospitality exceptions (if any are permitted by policy)
• Document all tender communications and submissions
• Use formal tender clarification channels only
• Require transparent contractual and fee terms from agents, consultants and intermediaries and ban/reject unclear scope, opaque payments and success fees linked to award outcomes
• Use internal compliance escalation processes and whistleblower channels, where available, to report any solicitation, irregular scoring signals, or undue influence attempt
• Recommend that procuring entities use independent monitors and observers in high-risk tenders
Mitigation Resources
Set and enforce anti-bribery controls for tender interactions linked to evaluation and award decisions; prohibit gifts, kickbacks, facilitation payments, and other inducements, require logged contacts and controls on agents or intermediaries, and escalate solicitation or improper payment risks.
Anti-bribery management and controls — https://toolbox.infrastructuretransparency.org/resource/anti-bribery-management-and-controls/Use a senior reporting or escalation channel to raise suspected bribery, kickbacks, solicitation, or bid interference linked to tender interactions, evaluation, or award decisions quickly and safely.
Rapid escalation and resolution of suspected bribery or unfair business practices — https://toolbox.infrastructuretransparency.org/resource/rapid-escalation-and-resolution-of-suspected-bribery-or-unfair-business-practices/Commit to independent monitoring to oversee the tender process, reducing risks of bribery, corruption, and collusion, and strengthening transparency, accountability, and confidence in the process.
Independent monitoring, assurance, and social accountability — https://toolbox.infrastructuretransparency.org/resource/independent-monitoring-assurance-and-social-accountability/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes elevated risks to project bankability due to vulnerabilities in award integrity; potential financing delays or withdrawal if allegations arise; contagion of debarment or sanctions through contractors and agents; reduced returns due to inflated pricing; and reputational risk.
Decision Point
At the bid evaluation and award milestone, verify whether integrity policies are in place, and require independent review of evaluation documents if signs of bribery arise.
Mitigation Actions
• Treat lack of integrity controls as a no-go financing condition
• Treat credible solicitation/bribery concerns as a suspension trigger for investment
• Condition financing on disclosure of award rationale, evaluator/adviser conflict management, and any material communications/addenda
• Include disclosure covenants and verification/audit rights
• Require an accessible complaints mechanism, supported by a documented system for handling and reporting complaints
• Pause disbursement if tender complaints are unresolved or records are incomplete
• Request that procuring entities use independent monitors and observers for high-risk tenders
Mitigation Resources
Conduct integrity due diligence and issue tracking on evaluation and award decisions, including scoring records, procurement interactions, complaints, and award rationale; set conditions, enhanced-review triggers, and pause support where bribery or kickback risks remain unresolved.
Investor integrity due diligence and monitoring — https://toolbox.infrastructuretransparency.org/resource/investor-integrity-due-diligence-and-monitoring/Require, through financing conditions, standard procurement documents and formal tender records for evaluation and award decisions, including scoring records, conflict management, procurement interactions, complaints, and award rationale; verify that key decisions and complaints are documented and traceable.
Tendering, evaluation, and complaints integrity — https://toolbox.infrastructuretransparency.org/resource/tendering-evaluation-and-complaints-integrity/Use independent monitoring to oversee the tender process, reducing risks of bribery, corruption, and collusion, and strengthening transparency, accountability, and confidence in the integrity of the process.
Independent monitoring, assurance, and social accountability — https://toolbox.infrastructuretransparency.org/resource/independent-monitoring-assurance-and-social-accountability/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes overpricing and weak contractor selection; increased risk of audit, investigation, and legal liability; a higher likelihood of bid challenges and re-tendering delays; and loss of public trust in award decisions.
Decision Point
Before bid award, verify application of documented evaluation criteria, pause the award decision if credible kickbacks/bribery concerns are present.
Mitigation Actions
• Maintain a complete tender file and auditable evaluation record, documenting the scoring and rationale with evidence
• Publish the complete set of tender process documents, including the award decisions and evaluation summaries
• Use independent monitors and observers for high-risk tenders
• Implement a timely complaints mechanism, documenting responses and corrective actions transparently
• Refer credible solicitation and bribery concerns to independent oversight bodies for investigation, documenting outcomes and corrective actions
• Decide to re-tender when integrity is compromised
• Publish project information based on recognised infrastructure data standards such as the OC4IDS
Mitigation Resources
Set and enforce anti-bribery controls for evaluation and award decisions; prohibit gifts, kickbacks, facilitation payments, and other inducements, require auditable records of material evaluation-related interactions and secure handling of bids and scoring records, and refer credible bribery or solicitation concerns through formal channels.
Anti-bribery management and controls — https://toolbox.infrastructuretransparency.org/resource/anti-bribery-management-and-controls/Require conflict-of-interest declarations and documented conflict management for evaluators, advisers, and decision-makers involved in evaluation and award decisions; exclude conflicted parties until conflicts are resolved and recorded.
Conflict-of-interest management and ethics controls — https://toolbox.infrastructuretransparency.org/resource/conflict-of-interest-management-and-ethics-controls/Publish and maintain public access to key evaluation and award records, including evaluation summaries, award decisions, complaints outcomes, and reasons for award, with only lawful redactions.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Use independent monitoring to oversee the tender process, reducing risks of bribery, corruption, and collusion, and strengthening transparency, accountability, and confidence in the integrity of the process.
Independent monitoring, assurance, and social accountability — https://toolbox.infrastructuretransparency.org/resource/independent-monitoring-assurance-and-social-accountability/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes opaque scoring and award criteria; increased safety, quality and impact risks; limited access to evaluation records; reduced accountability for costs and outcomes; and retaliation risk when bribery allegations are reported.
Decision Point
During the tender process, submit access to information to request clarification on the evaluation rationale. Decide whether to (a) escalate through oversight channels to report suspected credible irregularities or (b) monitor while safely gathering evidence.
Mitigation Actions
• Monitor tender awards and evaluation patterns (repeat winners, disqualifications, score anomalies, disclosure gaps, unexplained award decisions)
• Mobilise communities around the importance of full transparency in tender processes and equal conditions for all bidders, given the impact on competition and fiscal outcomes
• Engage oversight and competition bodies to raise credible solicitation or irregularity concerns (use safe, confidential reporting and anonymisation where the risk of retaliation is significant)
• Support formal tender complaints with structured evidence (timeline, concerns of solicitation or retaliation)
• Advocate for independent monitors and observers for high-risk tenders
• Advocate for disclosure of project information based on recognised infrastructure data standards such as the OC4IDS
Mitigation Resources
Use protected complaints and grievance channels to report suspected solicitation, bribery, kickbacks, or irregular evaluation and award decisions; document evidence, timelines, case handling, and remedies sought, and protect complainants from retaliation.
Grievance, complaints, and protected reporting — https://toolbox.infrastructuretransparency.org/resource/grievance-complaints-and-protected-reporting/Screen evaluation and award records, complaints, and related procurement documents for red flags, such as score anomalies, repeat winners, unexplained disqualifications, conflicted interactions, or other irregular patterns; raise suspected irregularities through oversight or complaints channels.
Procurement red-flag detection, analytics, and escalation — https://toolbox.infrastructuretransparency.org/resource/procurement-red-flag-detection-analytics-and-escalation/Review publicly disclosed evaluation and award records at an early stage, including evaluation summaries, award decisions, and available reasons for award; identify disclosure gaps, missing scoring rationales, or unexplained award decisions, and raise concerns about non-disclosure with an oversight body.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Use independent monitoring to oversee the tender process, reducing risks of bribery, corruption, and collusion, and strengthening transparency, accountability, and confidence in the process.
Independent monitoring, assurance, and social accountability — https://toolbox.infrastructuretransparency.org/resource/independent-monitoring-assurance-and-social-accountability/