Constituent Mitigations

11.6 Limited reliance on and control of subcontractors, agents and intermediaries

Mitigate corruption risks by limiting and/or controlling the use of third parties in the supply chain. Impose obligations on primary contractors with regard to controlling the performance and integrity record of subcontractors.

Given the risks inherent in diluting the supply chain relationships by employing subcontractors, agents and intermediaries, making their use transparent and controlled is a key way to prevent corrupt networks from profiting from mission resources. In addition, mission leadership should require that primary contractors work to ensure that suppliers and subcontractors abide by integrity standards, and that breaches are reported and followed up on.

Measures that the contracting authorities could implement include:

  • Requiring the primary contractor to disclose the use of agents, intermediaries and contractors, and the fees paid to them
  • Verifying the bona fides of agents and intermediaries and vetoing their use if they appear to be shell companies
  • Performing due diligence on subcontractors to the same standard as on primary contractors, and disallowing their use if they appear to be linked to corrupt networks
  • Verifying the performance and integrity records of agents, intermediaries and subcontractors
  • Requiring anti-corruption and integrity programmes for subcontractors
  • Ensuring reporting lines for contractor and subcontractor misconduct, and protecting whistleblowers
  • Following up on allegations of wrongdoing.

Examples


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External Link

Requiring disclosure: The World Bank

The World Bank requires that all agents and intermediaries a bidder intends to work with are disclosed, as are the fees paid to them. While some companies still manage to avoid controls, the appearance of previously undisclosed agents during the bidding process or the duration of the contract constitutes a red flag that could prompt an audit.

View external case study

Key Personnel

  • J8
  • J4
  • J2