Mongolia - Netherlands-Mongolia Trust Fund for Environmental Reform Project - Redacted Report - March 2020

Jul 19, 2026

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Redacted March 2020 report summarizes an administrative inquiry by the World Bank Group Integrity Vice Presidency (INT) into allegations of corrupt, fraudulent, collusive, and/or coercive practices in a World Bank-supported environmental reform grant in Mongolia. The investigation evaluates whether anti-corruption framework requirements were violated, based on project documentation and statements obtained from the contractor. Evidence finds the contractor failed to disclose a co-owner’s direct role as a PIU staff member involved in implementation and supervision.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages5

Reading Time13 min

AccessFree to download

Background

Allegations

Methodology

Findings

Corrective Action

Public Disclosure Authorized Public Disclosure Authorized Mongolia Netherlands-Mongolia Trust Fund for Environmental Reform Project Redacted Report March 2020 Statement of Use and Limitations This Report was prepared by the World Bank Group (the “WBG”) Integrity Vice Presidency (“INT”) . It provides the findings of an INT administrative inquiry (the“Investigation”) into allegations of corrupt, fraudulent, collusive, and/or coercive practices, as defined by the WBG for purposes of its own policies, rules and procedures (the “WBG’s Framework regarding Anti-corruption”), in relation to the WBG-supported activities. The purpose of the Investigation was to allow the WBG to determine if the WBG’s Framework regarding Anti-corruption has been violated. This Report is being shared to ensure that its recipients are aware of the results of the INT Investigation. However, in view of the specific and limited purpose of the Investigation underlying this Report, this Report should not be used as the sole basis for initiating any administrative, criminal, or civil proceedings. Moreover, this Report should not be cited or otherwise referred to in the course of any investigation, in any investigation reports, orin any administrative, civil, or criminal proceedings. This Report is provided without prejudice to the privileges and immunities conferred on the institutions comprising the WBG and their officers and employees by their respective constituent documents and any other applicable sources of law. The WBG reserves the right to invoke its privileges and immunities, including at any time during the course of an investigation or a subsequent judicial, administrative or other proceeding pursued in connection with this matter. The WBG’s privileges and immunities cannot be waived without the prior express written authorization ofthe WBG. Background The International Development Association (“IDA”), acting as administrator of grant funds provided by the Netherlands, and the government of Mongolia signed a Grant Agreement. The purpose of the grant was to fund the second phase of the Netherlands-Mongolia Trust Fund for Environmental Reform Project (the “Project”) in Mongolia. The Project aimed to assist the government of Mongolia to strengthen its environmental governance strategy and advance its environment and natural resources agenda. The Project closed in December 2011. In 2008, the Project Implementing Unit (“PIU”) conducted a selection process for a consultancy contract (the “Contract”). Company A submitted its proposal and was awarded the Contract. Allegations The World Bank Group Integrity Vice Presidency (“INT”) received a complaint, alleging an undisclosed conflict of interest, with one of Company A’s co-owners also working as a PIU staff member throughout Contract selection and implementation. Methodology INT’s investigation consisted of, among other things, a review of Project documents, as well as documents and statements obtained from Company A. Findings Evidence indicates that Company A failed to disclose that its co-owner was a PIUstaff member who was directly involved in the implementation of the Contract. The World Bank’s Guidelines: Selection and Employment of Consultants under IBRD Loans and IDA Credits & Grants by World Bank Borrowers (the “Consultant Guidelines”), which applied to the Contract, required that consultants provide professional, objective, and impartial advice, and at all times hold the client’s interest paramount. The Consultant Guidelines also prohibited the hiring of consultants that have a business or family relationship with a member of the project implementing agency’s staff who were directly or indirectly involved in any part of: (i) the preparation of the contract’s terms of reference; (ii) the selection process for the contract; or (iii) supervision of the contract. Such consultants may not be awarded a contract, unless the conflict stemming from this relationship has b

FAQs

What was the purpose of the INT administrative inquiry in this report?

The inquiry aimed to determine whether the World Bank Group’s anti-corruption framework was violated in relation to World Bank-supported activities under the project.

What conflict of interest allegation was investigated?

A complaint alleged an undisclosed conflict of interest because one co-owner of Company A also worked as a PIU staff member during contract selection and implementation.

What corrective actions were imposed after the findings?

The World Bank imposed debarment with conditional release on Company A and on Co-owner B (and entities they control). Co-owner A was not sanctioned because the World Bank does not sanction employees of its member governments.

Jul 19, 2026

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