Investment decisions driven by influential private actors and weak strategic alignment
Investment decisions reflect the interests of influential private actors and do not align with long‑term national, regional, or sector strategies.
Red Flags & Indicators
- Projects are advanced outside formal strategies or planning cycles.
- Strategic alignment asserted without clear links to adopted plans, demand evidence, or agreed priorities.
- Scope and location choices follow informal lobbying engagement rather than a documented criteria-based review.
- Alternative and option analyses are limited and focused on a preferred solution
- Prioritisation and trade‑offs across sectors or regions are not documented transparently.
- Social consultation occurs late, sometimes as a checking-box exercise, and does not influence the decision rationale.
Stakeholder Guidance
Stakeholder Exposure
Exposure includes uneven market access; participation in projects with weak legitimacy and shapped by lobbying relations; higher cancellation/stranding risk if priorities shift; and long‑term reputational impact.
Decision Point
Before early engagement and the bid/no-bid decision, assess whether the project is grounded in existing and published policy or strategic plans and whether a credible appraisal has been conducted.
Mitigation Actions
• Document engagement with public authorities and require clear decision records and disclosure commitments, using only formal engagement routes and documented approvals
• Apply enhanced integrity controls, such as enhanced due diligence and PEP (Politically Exposed Persons) checks, and document findings before any engagement or commitment
• Use internal compliance escalation processes and whistleblower channels, where available, to flag concerns and when preferential access, facilitation/side payments, gifts/hospitality pressure, or undue influence is implied or requested
Mitigation Resources
Screen owners, sponsors, partners, agents, and advisers linked to project prioritisation or access decisions; verify beneficial ownership, PEP, sanctions, and related-party risks; escalate concerns and refrain from proceeding when undue-influence red flags remain.
Counterparty integrity screening and due diligence — https://toolbox.infrastructuretransparency.org/resource/counterparty-integrity-screening-and-due-diligence/Apply the compliance system to review and escalate engagement decisions linked to project prioritisation; require formal approvals, record commitments and interactions, and address breaches or requests for preferential treatment.
Compliance management system — https://toolbox.infrastructuretransparency.org/resource/compliance-management-system/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes stranded‑asset risk; policy reversal risk; reputational exposure; dispute and renegotiation risk; and poor returns when projects lack strategic and economic justification.
Decision Point
Before committing resources, test project strategic alignment and value-for-money justification; and require transparency, disclosure obligations and a clear decision trail as a condition for investment approval.
Mitigation Actions
• Conduct enhanced due diligence on key counterparties and intermediaries as well as conflict-of-interest, beneficial ownership and PEP checks where relevant
• Use independent review to test benefits, risks, and distributional impacts in case of mega projects
• Include covenants on disclosure, social consultation, and decision logs to trace material changes
• Track record of who decided what/when and avoid “off-process” commitments
• Include term-sheet protections for material changes: suspension/exit rights and verification/audit rights if strategic criteria shift without justification or undisclosed influence emerge
Mitigation Resources
Conduct integrity due diligence on sponsors, investees, counterparties, and intermediaries linked to project prioritisation; use covenants, monitoring, escalation, and pause or no-go conditions when strategic alignment evidence is weak or undue-influence risks remain unresolved.
Investor integrity due diligence and monitoring — https://toolbox.infrastructuretransparency.org/resource/investor-integrity-due-diligence-and-monitoring/Apply stage-gate reviews, readiness checks, and documented approval logs before approving investment engagement or financing linked to project prioritisation decisions; return cases for further work when strategic alignment, demand rationale, or value-for-money is weak.
Stage-gate governance and independent assurance — https://toolbox.infrastructuretransparency.org/resource/stage-gate-governance-and-independent-assurance/Benchmark integrity controls governing project prioritisation decisions; identify gaps in strategic alignment assessment, disclosure, decision logging, and control over off-process influence, and prioritise corrective action.
Integrity benchmarking, self-assessment, and control-gap diagnostics — https://toolbox.infrastructuretransparency.org/resource/integrity-benchmarking-self-assessment-and-control-gap-diagnostics/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes policy inconsistency; weak accountability; inter‑sector/regional grievances; loss of public trust; and inefficient investment when private interests distort priorities.
Decision Point
During project prioritisation, require consistent policy alignment, conformity with planning rules, evidence of needs and publication of the rationale for project prioritisation.
Mitigation Actions
• Publish the rationale/criteria of project prioritisation
• Require justification for projects approved without alignment with strategic plans and document instances where planning, appraisal and prioritisation rules were not followed
• Require early, meaningful social consultation and record how feedback influenced decisions
• Maintain an auditable and transparent decision log capturing selection criteria changes and written justifications
• Require conflict-of-interest checks for decision makers and advisers during project approval processes
• Record and manage external representations (e.g., lobbying relations/political direction) through a formal register
• Publish key assumptions and appraisal documentation as a transparency rule
• Refer allegations of undue influence to independent oversight bodies for investigation, documenting outcomes and corrective actions
Mitigation Resources
Apply stage-gate reviews, readiness checks, and documented approval logs before approving project prioritisation decisions; return cases for further work where strategic alignment, justification, or value-for-money is weak.
Stage-gate governance and independent assurance — https://toolbox.infrastructuretransparency.org/resource/stage-gate-governance-and-independent-assurance/Assess institutional corruption risks in project prioritisation decisions; assign mitigation actions to responsible units, set deadlines, and track whether risks linked to undue influence, rule bypass, or weak strategic alignment are addressed.
Institutional integrity risk assessment and mitigation — https://toolbox.infrastructuretransparency.org/resource/institutional-integrity-risk-assessment-and-mitigation/Publish and maintain public access to the project pipeline, project prioritisation criteria, decision logs, key assumptions, and written justifications for approvals, changes, or departures from strategic plans.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes community exclusion from priority‑setting and increased inequality when projects favour narrow interests.
Decision Point
During budget cycle allocation and/or pipeline publication, assess whether priorities match needs. Decide whether to (a) use access to information to request evidence of appraisal documentation and social consultation processes and escalate through oversight channels, or (b) monitor while gathering evidence safely.
Mitigation Actions
• Track budget allocations and/or project pipeline and compare proposed projects against social/service needs to highlight misalignment
• Use access to information to request clarification on criteria and selection rationale of projects when concerns may exist regarding potential policy and needs misalignment
• Engage oversight bodies to report instances of policy and needs misalignment (use safe, confidential reporting and anonymisation where retaliation risk is material)
• Advocate for early disclosure of appraisal documentation
• Support community participation and document concerns for oversight bodies regarding lack of community participation in project selection
• Mobilise communities affected by inadequate participation to raise concerns about lack of 'Free, Prior and Informed Consent'
Mitigation Resources
Request access to non-public strategic planning and prioritisation records, such as alignment assessments, prioritisation notes, or records explaining deviation from national, regional, or sector plans, so hidden preferences, unexplained changes, or weak justifications can be examined and raised through oversight channels.
Access-to-information and demand-side transparency — https://toolbox.infrastructuretransparency.org/resource/access-to-information-and-demand-side-transparency/Review publicly disclosed strategic planning and prioritisation records at an early stage; identify missing alignment rationale, omitted prioritisation criteria, or unexplained changes, 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/