Republic of Tunisia

 Tunis West Sewerage Project

       Redacted Report




                  November 2018
                                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, or in any administrative, civil, or
criminal proceedings.

This Report is provided without prejudice to the privileges and immunities conferred on the
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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
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Background

The Tunis West Sewerage Project (the “Project”) in Tunisia was designed to improve the quality
of sanitation services in the Greater Tunis Area, to promote the reuse of treated wastewater in
irrigation on a sustainable basis and in significant quantities, and to enhance the performance of a
national public authority (the “Public Authority”) through financial and operational management
capacity building. The Project was financed by the International Bank for Reconstruction and
Development (“IBRD”).1 It closed in June 2015.

Company A was awarded, both individually and in joint venture arrangements, several Project-
financed contracts.

Allegations & Methodology

When issues arose in the performance of Company A’s contracts, the Public Authority attempted
to encash Company A’s performance guarantees. The alleged issuing entity (the “AIE”)
subsequently informed the Public Authority that the performance guarantees were not authentic
and that they had not been issued by the AIE. The Public Authority informed the World Bank of
this matter.

The World Bank’s Integrity Vice Presidency (“INT”) reviewed Project documents and statements
obtained from the Public Authority and the AIE.

Findings

        Evidence indicates that Company A submitted falsified performance guarantees with its
        bids for Project-financed contracts.

Company A submitted performance guarantees totaling more than US$ 3 million purportedly
issued by the AIE. However, in response to INT’s inquiries, the AIE informed INT that Company
A’s performance guarantees were not authentic and had not been issued by the AIE. The AIE
noted that Company A’s performance guarantees contained numerous anomalies inconsistent with
documentation issued by the AIE. Evidence also indicated that Company A’s performance
guarantees contained other signs of falsification, including grammatical and language mistakes.
Evidence suggests that the Public Authority’s inability to encash Company A’s falsified
performance guarantees exposed it to a potential loss exceeding US$3 million.

INT made several unsuccessful attempts to contact or meet with Company A’s representatives.

Corrective Actions

The World Bank has imposed the administrative sanction of debarment with conditional release
on Company A, extending to any affiliate it controls directly or indirectly.



1
  IBRD is one of the five institutions comprising the World Bank Group. The International Development Association
(IDA) and IBRD constitute the World Bank. Therefore, IBRD and the World Bank are used interchangeably
throughout this Report.
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