Anti-Corruption

HANDBOOK

December 2018
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Anti-Corruption
HANDBOOK

Document No.: CPL-G01

Revision No.: 01

Date: 21 December, 2018

Approval: The original of this document is signed for approval

Copyright: No part of this document may be photocopied or otherwise reproduced or

transferred to any third party without the prior permission in writing of
NORPLAN Tanzania Limited

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Table of Contents
Table of Contents 2

Message from Managing Director 3

1. INTRODUCTION 4

1.1 Purpose of this anti-corruption handbook 4

1.2 Anti-corruption activities – combating corruption 4
1.3 Forms of Corruption 5

2. RESPONSIBILITIES AND DUTIES WITH RESPECT TO COMBATING CORRUPTION 7

2.1 Management responsibility 7

2.2 Employees, contractors and other third parties 8
2.3 Particularly exposed employees, contractors and other third parties 9

3. MANAGING CORRUPTION RISK 11

3.1 Gifts (goods, services and money) 11

3.2 Entertainment, experiences 12
3.3 Reimbursing expenses of people who are not employees 13

4. TOOLS 14

4.1 Assessing corruption risk 14

4.2 Control measures 15
4.3 Integrity due diligence (IDD) 16

5. COMPLIANCE, THE ETHICS COMMITTEE AND WHISTLEBLOWING 18

5.1 Compliance and the Ethics Committee 18

5.2 Reporting of possible misconduct 18

6. APPENDICES 19

6.1 Definitions 19
6.2 References 21

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Message from Managing Director Approved by: E. Mushi Date: 21.12.18

Message from Managing Director

Dear colleague

NORPLAN’s business is based on trust. Over more than a century NORPLAN has built
a reputation for being responsible, honest and reliable in everything we do. This
includes a zero-tolerance policy towards corruption.

Working on several projects at any given time, varying in type, size, complexity and
geographic location, NORPLAN is exposed to many kinds of corruption risk. We have
therefore established an internal anti-corruption programme that aims to ensure
compliance with laws and regulations, and to prevent, identify, reduce and manage the
risk of corruption.

This handbook is part of our anti-corruption programme. It guides our response to

corruption risk in our day-to-day work, and helps to protect our actual and perceived
integrity in our dealings with customers, third parties and employees, as well as
authorities, users and the general public.

Exaud Mushi

MANAGING DIRECTOR

Dar es Salaam, December 21, 2018

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1. INTRODUCTION
1.1 Purpose of this anti-corruption handbook

This handbook has been drawn up for the benefit of employees and other NORPLAN
representatives such as contractors, partners and sub-contractors. Its purpose is to
raise awareness about corruption and to help individuals to recognize and
appropriately manage situations that could lead to corruption or to suspicion of
corruption. The handbook is based on Ethical guidelines provided by the Engineers
Registration Board (ERB), the authority responsible for monitoring practice of
engineering professionals in the country.

1.2 Anti-corruption activities – combating corruption

Corruption occurs both in developed and less developed countries. Corruption

undermines democracy and social justice, distorts competition, prevents an open and
efficient market economy, hinders economic development and obstructs the fight
against poverty. In recent years, international laws against corruption have become
more stringent. Meanwhile, more resources are being put into investigating corruption
and the sanctions and punishments are becoming stricter. NORPLAN shall at all times
comply with current national and relevant international laws and regulations on
corruption. In accordance with international guidelines and generally recognized
practice, NORPLAN’s Anti-corruption programme includes the following elements:

- Communication of expectations
- Anti-corruption training
- Integrity due diligence of third parties
- Implementation of appropriate control measures to prevent corruption
- Documentation of measures to combat corruption risk
- Supervision and monitoring

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INTRODUCTION Approved by: E. Mushi
1.3 Forms of Corruption
TYPES OF EXAMPLES AND
CORRUPTION AREAS OF RISK
Bribery: • Receiving benefits Receiving
Making/Receiving benefits in return for
payments to influence influencing decisions. Can also
decisions to your involve influencing
own/the company’s recommendations and
benefit conclusions in conjunction with
bids, investments, reports, etc.
• Success-based fees paid to
representatives or agents.
Facilitation payments: • Minor payments to push
Payments for services through or speed up
that you are entitled to. administrative procedures (such
Under Tanzanian law as licenses, permits, customs
this is equivalent to clearance, passport controls,
bribery. etc.)
• In some countries this is part of
the business culture and
remuneration system.
Gifts, hospitality and • Items, meals, trips, etc. provided
reimbursement of to customers or public officials
expenses that could or received from suppliers
affect actual or
perceived integrity • Benefits of an unusual nature or
significant value, that could be
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CONTROL
MEASURES
• Ethical guidelines and Anti-
corruption policy prohibit
this.
• Training to identify these
kinds of situations.
• Contractual clauses
• Checking expenses and
invoices, perform peer
review of work delivered.
• For third parties conduct
IDD
• Ethical guidelines and Anti-
corruption policy prohibit
this.
• Budget additional time in
project in order to endure
waiting processes and
reduce vulnerability for
time pressure.
• Training in dealing with
these kinds of requests.
• Incidents should be
reported to Compliance
and Finance, and reported
in the accounts
• For third parties conduct
IDD
• Ethical guidelines
• Invitations to be approved
by line manager
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 Anti-Corruption Handbook
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INTRODUCTION Approved by: E. Mushi
TYPES OF EXAMPLES AND
CORRUPTION AREAS OF RISK
perceived as providing an
“improper advantage”.
• The risk increases in
conjunction with bids, negoti-
ations and contract signing.
Conflict of interest that • Favoring particular relationships
leads to lack of or interests on non-objective
integrity or grounds.
independence, actual
or perceived, in • A lack of transparency about
decision-making your own relationships, roles or
processes. ownership interests that might
reduce your or NORPLAN’s
actual or perceived integrity
and independence.
• Also applies to the interests of
related parties.
Lobbying activities • Improper and covert pressure
involving ”trading in exerted by people with political
influence” influence
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CONTROL
MEASURES
• System for reporting of
possible misconduct.
• Checking expenses and
vouchers for events
organized by company.
• Clarify with Compliance if in
doubt.
• For third parties conduct
IDD
• Ethical guidelines.
• Establishing and reporting
relationships and
ownership interests.
• System for reporting of
possible misconduct
• For third parties conduct
IDD
• Ethical guidelines and
policies
• Contractual clauses
• Reporting and invoicing
• For third parties conduct
IDD
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RESPONSIBILITIES AND DUTIES WITH
RESPECT TO COMBATING CORRUPTION Approved by: E. Mushi Date: 21.12.18

2. RESPONSIBILITIES AND DUTIES WITH

RESPECT TO COMBATING CORRUPTION
2.1 Management responsibility

To fulfil its responsibility for combating corruption, the management must clearly
express its attitude towards corruption and explain how it wishes employees to handle
the risk of corruption. The management must also ensure adequate internal control,
and that the necessary expertise and appropriate tools are available and being used by
the organization.

Managers therefore have a responsibility to:

- Set a good example in practice

- Make employees aware of what is illegal
- Make employees aware of what is unethical
- Establish Ethical guidelines -
- Ensure that there are procedures, tools, aids and guidelines that clearly set out how
the risk of corruption should be managed, documented and reported
- Make sure that employees have the necessary skills, or have access to those skills,
and receive help with identifying and managing the risk of corruption
- React firmly to breaches of the guidelines

In bids and projects, the people acting as bid and project directors must:

- Ensure that risk assessments of bids and projects are carried out at an appropriate
level by the project managers
- Check that the quality of the risk assessment is adequate
- Ensure that effective control measures are implemented

Management must continuously bear in mind the following questions:

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- What kind of corporate culture do we want?

- What kind of conduct is ethical?
- What kind of conduct could damage or enhance the company’s reputation?
- What are the relevant and current laws, regulations and requirements?
- What grey areas should we avoid so as not to risk doing anything illegal or
unethical?

2.2 Employees, contractors and other third parties

All employees must familiarize themselves with and adhere to NORPLAN’s Ethical
guidelines 1 and our Anti-corruption handbook. People acting on behalf of NORPLAN,
including consultants and other third parties representing NORPLAN, must also accept
and adhere to our Ethical guidelines and must fill business partner qualifications
questionnaire and sign the business partner declaration.

Useful rules of thumb are:

Think TWICE if…

- you are dealing with family, friends or “old acquaintances”

- you are invited to bring your partner
- you are offered something for private use

STEER CLEAR of situations in which you…

- • offer the other party something of personal benefit

- receive something that you wouldn’t want your manager to know about
- are offered something for your personal use whilst you are involved in purchasing,
tendering or negotiating

1
The Ethical guidelines is included in the Human Resources Manual (HRM)

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- don’t actually know who the other party is, including its owners, board members
and management

REMEMBER that…

- the recipient may also have internal guidelines. You should try to find out what they
are, to avoid putting other people in a compromising position.
- public sector employees are usually subject to especially strict guidelines on what
they can accept. Avoid situations that can create misunderstandings.
- some benefits are taxable; would you want to receive a gift that you had to pay for?

Situations that are not explicitly mentioned in the guidelines, but which by their nature
might affect the independence of the employee, may easily arise. Such situations do
not exempt the employee of responsibility for their actions. A good rule of thumb is to
consult the relevant manager (line manager, project director or project manager), or
the Compliance Officer, when you are in doubt.

2.3 Particularly exposed employees, contractors and other third

parties

Some employees will be more exposed to the risk of corruption than others, due to
their roles and functions. This applies for example to employees who are in a position
to influence the financial decisions made by NORPLAN or other parties, who manage
financial resources or are responsible for contact with third parties and public officials.

Particularly vulnerable employees and functions include:

- Bid managers
- Bid directors
- Project managers
- Project directors
- Employees who are in contact with third parties
- Representatives working on projects in environments with a high risk of corruption

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People performing these functions must adhere to a number of requirements

described in this handbook, including documented control measures designed to
prevent and reduce the risk of NORPLAN being drawn into corruption. Managers are
responsible for ensuring that employees receive appropriate training to raise their
awareness and gain adequate understanding of corruption risks and how to deal with
them.

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MANAGING CORRUPTION RISK Approved by: E. Mushi Date: 21.12.18

3. MANAGING CORRUPTION RISK

In their day-to-day activities, NORPLAN’s representatives may find themselves in a
range of situations where there is a risk of corruption. The following guidelines are
designed to help them in those situations.

3.1 Gifts (goods, services and money)

UNACCEPTABLE
• Money (and other things
that can easily be converted
into money)
• Services such as work on
the recipient’s personal
property/ materials
supplied to his/ her home
• Gifts with conditions
attached
• Kickbacks to individuals
MUST BE CONSIDERED
CAREFULLY
• Personal gifts for birthdays
and other occasions
• Loyalty bonuses given
personally to employees as
part of an open loyalty
scheme (flights/hotels)
• “Competitions” and
“lotteries” with prizes that
could be considered gifts
• Tokens of gratitude
GENERALLY
FINE
• Gifts to the company on
important occasions
• Marketing gifts of
insignificant value
• Low-value gifts, such as
a bottle of wine, box of
chocolates, etc.
• Flowers after giving a
lecture

• Gifts that could affect a

tendering or negotiating
process

Particularly bear in mind:

• What is the purpose of the gift?
• Are you in a tendering or negotiating
process?
• Is the benefit personal – or for the
company?
• Is the recipient employed in the public or
private sector, and what rules is he/she
covered by?
• Is the gift being given secretly or openly?
Is it being sent to the recipient’s home or
to their place of work?

• Is something expected in return? • Is the gift being made to many people or

just one person?
• Significant or insignificant value?
• How often?

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• Are we allowed to give or receive a gift of

the same value as the one we are receiving
or giving?

• What is the recipient’s Code of Conduct?

3.2 Entertainment, experiences

(includes meals, hospitality, courses, customer events)

UNACCEPTABLE MUST BE CONSIDERED GENERALLY

• Expensive trips,
accommodation and events
that are not very relevant to
the employee’s work, and
are not paid for by his/her
own company
• Meals or events that might
influence a tendering or
negotiating process, or may
be perceived by others to
influence such processes
• Sexual services
CAREFULLY FINE
• Work-related events where • Working lunches or
the travel and/or dinners
accommodation is paid for
by someone else • Professional events
where the travel and
• Tickets to sporting or accommodation is paid
cultural events for by the participant’s
employer
• Expensive meals
• Partner invited as well
• Invitations to private
functions (private holiday
cottages, weddings, etc.)

Particularly bear in mind:

• What is the purpose of the invitation? • Is the recipient employed in the public or
private sector, and what rules is he/she
• Are you in a tendering or negotiating covered by?
process?
• Are several people or just one person
• Is the invitation being made to an individual invited?
or to the company?
• How often?
• Have you discussed who should participate?
• Who is paying for the travel and
• Is something expected in return? accommodation?

• Significant or insignificant value? • Is the professional content sufficiently

good and relevant?

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Particularly bear in mind:

• Are we allowed to give or receive an • Are you being invited totally openly?
invitation of the same value as the one we
are receiving or giving?

• What is the recipient’s Code of Conduct?

3.3 Reimbursing expenses of people who are not employees

(Incl.: Travel and accommodation, travelling expenses, etc.)

UNACCEPTABLE MUST BE CONSIDERED GENERALLY

CAREFULLY FINE
• Cash payments that are • Advances or cash • Moderate accommodation
not accounted for or payments (subject to
documented agreement and with • Shared transport (e.g.
expenses documented) minibus) over moderate
• Reimbursement of distances
expenses other than • Luxury accommodation
standard accommodation • Attending the host’s own
expenses included in the • Long distance travel, professional events
hotel bill expensive tickets (assuming that travel and
accommodation is paid for
• Reimbursement of • Reimbursing the expenses by employee’s own
personal expenses of public sector employees company)

• Reimbursing the expenses

of a partner

Particularly bear in mind:

- Why are we reimbursing these expenses/having these expenses reimbursed?

- Do they have a clear business purpose?
- Are the expenses relevant, and can they be documented?
- Can the company pay the bills instead of making an advance?
- Is reimbursement of expenses agreed with the company, not just with the individual
who is having his/her expenses covered?
- Are you in a tendering or negotiating process?
- Is the cost significant or insignificant?
- What says the recipient’s Code of Conduct?
- Which rules cover the recipient – is he/she employed in the public or private sector?

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4. TOOLS
NORPLAN has developed tools and procedures to help assess the risk of corruption
and to ensure satisfactory internal controls with respect to corruption risk. When
necessary, Compliance Officer can provide assistance with using these.

The following tools are available in the management system:

- Anti-corruption screening
- Corruption risk assessment
- List of control measures
- IDD – Integrity due diligence

4.1 Assessing corruption risk

All projects at NORPLAN must undergo a risk assessment for risk of corruption. For this
purpose, tools have been created that looks at various areas of risk to corruption
including the following:

- Suspicious bribery payments designed to gain business advantage

- Illegal payment facilitations to government officials including gifts, political
contributions etc.
- Conflict of interest, business partners involvements etc.

The list above is not exhaustive. Complete list can be found on the template used for
risk assessment. The template is also updated from time to time depending on
changed requirements/environment of operation.

If the screening concludes that the risk of corruption is acceptable (green), NORPLAN’s
standard procedures for project management, accounting, corruption and fraud
prevention etc. are considered sufficient. If the corruption risk is medium (yellow) or
high (red), various mitigation measures proposed aimed at lowering the level of risk to
the acceptable level. For each proposed action plan, target date for action and specific

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responsible staff are identified. The purpose of this is to come up with the list of
proposed solutions for the identified risks that are believed, if implemented, will lower
the risk to the acceptable level.

4.2 Control measures

Control measures cover both “hard” control measures (e.g. authorizations,
reconciliation, dual controls, access controls and passwords) and “soft” control
measures (e.g. competence, attitudes, culture, values).

Control measures used to identify, prevent, uncover and manage corruption risk
include (but are not limited to):

- The use of experienced staff with a track record of honesty and integrity
- Ethical guidelines that addresses the question of corruption
- Our Anti-corruption policy
- Procedures for assessing the risk of corruption in bids and projects
- Integrity due diligence of customers and third parties
- Contract clauses covering anti-corruption activities
- Self-declarations by third parties (partners, sub-contractors)
- Authorizations and budgets
- Discussing corruption at project and discipline meetings
- Including corruption as a separate item in project reporting
- Purchasing controls (reconciliation of orders, deliveries and amounts)
- Reconciling transactions against the contract
- Training, including dilemma training
- Procedures for establishing and reporting relationships and ownership interests (in
order to uncover conflicts of interest and grounds for disqualification)
- Whistleblowing channels

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4.3 Integrity due diligence (IDD)

Eighty percent (80%) of corruption cases globally are estimated to arise through the
actions of third parties. A corrupt customer or third party can expose NORPLAN or the
project to corruption, attempted corruption or the suspicion of corruption. Even if the
corruption is actually carried out by another party, it may result in loss of reputation
for NORPLAN and even criminal liability. Simply saying “we didn’t know” (about corrupt
practices by a third party) is not an acceptable answer. If you haven’t communicated
your attitudes and expectations or carried out any investigations – or if you cannot
document having done so – this may be interpreted as consciously “turning a blind
eye”. In other words, there is a duty to investigate who you are doing business with,
and to establish requirements for combating corruption.

It is therefore important for NORPLAN to carry out Integrity due diligence of its
customers and third parties, and to implement control measures to manage the
associated risk or corruption. These measures can include communicating our Ethical
guidelines and Anti-corruption handbook, including anti-corruption clauses in
contracts, obtaining self-declarations from third parties, providing training and
discussing anti-corruption activities as a separate topic in project meetings and reports.
You can never guarantee that an employee or third party won’t break contract clauses
or circumnavigate and manipulate internal guidelines, but the above measures will
reduce the risk of this happening and of NORPLAN being held responsible.

Integrity due diligence is performed in close collaboration with the Compliance

function, which keeps records of the customers and third parties who have been
investigated. IDD means assessing the other party’s integrity by obtaining information
about possible indicators of corruption – so-called “red flags”. The below information
is to be obtained from the partners and third parties.

Areas covered include:

- Name of owners, board members, managers and other key personnel and their
roles, past history, political appointments, networks and reputation
- Address

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- Bank account
- Role of party in project
- Turnover, capacity and qualifications
- The company’s past record, references and reputation

The IDD for customers and lead consultants will be confined to getting the particulars
for the owners/directors. These particulars will be used to assess their integrity in
relation to corruptions.

When assessing a project or an agreement of delivery of collaboration with a third

party:

CONSIDER...

- whether you know who is behind the company; who are the owners, board and
management?
- whether you know the company’s or person’s past record and reputation
- whether the company is registered in a country where there is openness and
transparency
- whether the company’s account number and address are registered in the same
country as the project or the company
- whether the company has clearly set out its attitudes and values in its own Ethical
guidelines, the contract, self-declarations or in other ways, and whether these are
reflected in management practice

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COMPLIANCE, THE ETHICS COMMITTEE
AND WHISTLEBLOWING Approved by: E. Mushi Date: 21.12.18

5. COMPLIANCE, THE ETHICS COMMITTEE

AND WHISTLEBLOWING
5.1 Compliance and the Ethics Committee
Compliance means adhering to relevant laws, rules and internal guidelines. At
NORPLAN, the Compliance function is responsible for managing the company’s Ethical
guidelines and Anti-corruption programme. The Compliance officer shall ensure that
NORPLAN’s anti-corruption programme promotes adherence to statutory
requirements and the Ethical guidelines, by adapting procedures and tools, providing
training, helping to assess corruption risk and ethical dilemmas, performing Integrity
due diligence, and carrying out supervision and monitoring. Due to the size of the
company, the management team will handle all ethical issues whereby such meetings
shall be chaired by the Compliance officer. Matters to be discussed in such meetings
include the Compliance function and issues relating to ethics, including anti-corruption
and compliance-related reports on misconduct (including whistleblowing).

In case of any questions about the anti-corruption programme, including the use of
tools, implementation of control measures, Integrity due diligence of third parties,
customer self-declarations and clarification of dilemmas, the Compliance function can
provide advice and assistance.

5.2 Reporting of possible misconduct

If you observe a possible breach of internal guidelines, including of the Anticorruption
Policy and related procedures, you should follow NORPLAN’s whistleblowing
procedures, which can be found in the management system.
Reports on possible misconduct can be sent to:

compliance@norplan.co.tz

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6. APPENDICES
6.1 Definitions
EMPLOYEE/COLLEAGUE A person who is a temporary or permanent member of staff
at NORPLAN. All board members are considered employees for the purpose of
NORPLAN’s Ethical guidelines, including the guidelines for anti-corruption.

ANTI-CORRUPTION PROGRAMME The company’s complete set of measures to

combat corruption and manage corruption risk in its own business. The programme is
based on the company’s Ethical guidelines and Anti-corruption handbook, and
includes procedures and tools for corruption risk assessments and Integrity due
diligence, as well as training, communication, monitoring and audits.

COMPLIANCE Refers to a company’s adherence to internal guidelines and regulatory

requirements.

COMPLIANCE OFFICER NORPLAN’s central Compliance function, who is responsible

for managing and implementing the NORPLAN’s Ethical guidelines and anti-corruption
programme4 2 , which includes ensuring that they comply with relevant laws and
regulations. Chairs the Management Ethics Committee.

THE MANAGEMENT ETHICS COMMITTEE An internal committee that helps to advise

the group management and Compliance Officer on ethical issues and to manage and
interpret the Ethical guidelines for use in practical dilemmas.

ETHICAL GUIDELINES NORPLAN’s internal guidelines on ethical conduct at both a

commercial and personal level. Covers both employees and hired consultants and is a
part of NORPLAN’s management system.

CONTROL MEASURES Mechanisms and measures for managing or eliminating risk.

Include both “hard” control measures (authorizations, access controls and passwords,

2
All employees are responsible for adhering to them

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reconciliation, etc.) and “soft” control measures (values, attitudes, expertise, culture,
incentive systems, etc.).

CUSTOMER Any “legal person” or entity that NORPLAN has a direct or indirect
contractual obligation to supply services to.

MANAGER An employee’s immediate superior.

POSSIBLE MISCONDUCT Situations that may be in breach of laws, regulations,

internal guidelines or what is generally considered proper and ethical conduct.

NEPOTISM Favoritism towards related parties.

RELATED PARTIES Family members, relatives and personal friends.

REPRESENTATIVE An employee, contractor or third party who represents NORPLAN

in its dealings with customers, the authorities or other third parties.

FACILITATION FEES/FACILITATION PAYMENTS: Payments intended to speed up or

ensure the delivery of products or services to which the individual or company is legally
entitled (e.g. administrative procedures, custom clearance, visas, passport controls, etc.).
Under Tanzania law, these payments are considered bribes.

THIRD PARTIES All legal persons or entities who sign an agreement to cooperate with
NORPLAN, deliver goods and/or services to NORPLAN, or act on behalf of NORPLAN.
Includes partners, suppliers, government bodies, contractors, agents, representatives
and intermediaries.

REPORTING OF POSSIBLE MISCONDUCT

Reporting concern about possible misconduct. This concern may be reported by

people both outside and at the company.

WHISTLEBLOWING

Reporting concern about serious misconduct, for example a violation of a law, rule,
regulation and/or direct threats to public interest, such as fraud, health and safety
violations, and corruption.

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6.2 References
External references:

- Tanzanian Law
- UK Bribery Act 2010
- UK Ministry of Justice: Guidelines on UK Bribery Act 2010
- The World Bank
- US Department of Justice: Foreign Corrupt Practices Act
- US Department of Justice: A Resource Guide to the U.S. Foreign Corrupt Practices
Act
- www.worldbank.org
- www.transparencyinternational.no

Internal references at NORPLAN:

- Ethical guidelines included in Human Resources Manual

- Anti-corruption handbook
- Code of Conduct
- Guidelines for Integrity due diligence

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