Phase 5: Project Execution

Corrupt subcontracting, labour exploitation and ghost workers

Subcontracting, labour hiring, and payroll are subject to patronage, extortion, and fraudulent practices, including ghost workers and inflated staffing.

Red Flags & Indicators

  • Subcontracts are awarded or changed without competition and repeatedly favour connected, newly established, or non-transparent firms.
  • Payroll and attendance records do not match the number of workers on site, including duplicate names, shared bank accounts, or unusually high cash payments.
  • Worker complaints report unpaid wages, coercion, or unexplained deductions, together with high staff turnover, work stoppages, or unrest.
  • Labour or security providers are linked to credible reports of intimidation, unclear ownership, or connections to influential individuals or networks.

Stakeholder Guidance

Stakeholder Exposure

Exposure includes inflated costs; labour abuse and extortion risk; increased labour, anti-money laundering, and anti-bribery and corruption risk; higher risk of workforce unrest and delays; and reputational risk.

Decision Point

Before approving payroll and labour subcontractors, verify worker records and conduct due diligence on subcontractors.

Mitigation Actions

• Verify worker identity and attendance (unique IDs, site headcounts, timesheets) and reconcile to payroll
• Use traceable wage payment systems and identify duplicate IDs, shared accounts, or unexplained cash use
• Conduct due diligence on labour subcontractors, security providers, and recruitment agents (ownership where feasible, conflicts, past violations)
• Require written contracts with defined rates and deductions, and no recruitment fees charged to workers
• Maintain complete and auditable labour records
• Maintain an accessible worker grievance mechanism, ensuring complaints are recorded and their resolution is tracked
• Use internal compliance escalation processes and whistleblower channels, where available, to report payroll inconsistencies, wage withholding, coercion, intimidation, or unsafe labour practices, documenting corrective actions
• Suspend and replace subcontractors and freeze disputed payments when credible exploitation or signs of ghost workers persist

Mitigation Resources

Require subcontractors, recruitment agents, security providers, and other third parties involved in workforce supply or payroll to comply with anti-corruption and integrity requirements; require reporting of ghost worker, payroll, coercion, or exploitation concerns, and apply the same requirements to lower tiers.

Supplier and subcontractor integrity controls — https://toolbox.infrastructuretransparency.org/resource/supplier-and-subcontractor-integrity-controls/

Screen subcontractors, recruitment agents, security providers, and related counterparties involved in labour supply and payroll arrangements; verify beneficial ownership where feasible, related-party links, PEP exposure, and sanctions risks, and escalate or stop engagement where unresolved red flags remain.

Counterparty integrity screening and due diligence — https://toolbox.infrastructuretransparency.org/resource/counterparty-integrity-screening-and-due-diligence/