NIB expects its staff, members of governing bodies and other stakeholders to adhere to the highest level of integrity and ethical standards. To pursue these goals, the Bank has adopted a zero tolerance attitude towards fraud and corruption in all of its operations and activities. The Bank has also established codes of conduct of its staff, Board of Directors and President and members of the Control Committee.
A major review of the Bank’s compliance integrity and anti-corruption framework was undertaken in 2015. In its meeting on 4 February 2016 the Board of Directors approved three new policies, namely the Compliance, Integrity and Anti-corruption Policy, the Investigation and Enforcement Policy and the Speaking-up and Whistleblowing Policy. These policies replace the old Compliance Policy, the Resolution on Fighting Corruption and the Rules of Procedures of the Committee on Fighting Corruption. The major changes include the establishment of a Sanctions Panel and an appeals function for external fraud and corruption cases. NIB’s anti-corruption efforts are based on the Uniform Framework for Preventing and Combating Fraud and Corruption, which was agreed upon by the major international financial institutions in 2006.
The Office of the Chief Compliance Officer (OCCO) is responsible for the investigations of prohibited practices (including fraud and corruption), misconduct and complaints related to non-compliance with the Bank’s polices. Moreover, OCCO oversees and coordinates matters relating to integrity and reputational risks and regularly provides advice and guidance to the Bank’s management and Board of Directors on how to address integrity and reputational risks in new and ongoing lending operations. OCCO is headed by the Chief Compliance Officer who reports directly to the President and has unrestricted access to the chairpersons of the Board of Directors and the Control Committee.
In terms of prevention, NIB puts particular emphasis on knowing its customers and training its staff well to avoid the Bank becoming involved with unethical borrowers and projects in which corruption, money laundering, terrorist financing or tax evasion could take place. All new clients are screened thoroughly in the Bank’s integrity due diligence processes.
The Bank’s Counsel of Fighting Corruption is set up to enhance the awareness of the Bank’s ethical values as well as integrity and corruption risks among the Bank’s staff and stakeholders. Members of the Counsel may also assist OCCO in certain investigations of allegations of fraud and corruption. The Committee is chaired by the Chief Compliance Officer and shall have between six and ten members from different departments of the Bank.
No allegations of corruption involving the Bank’s personnel were reported in 2015. Three new external cases of corruption involving borrowers from NIB member countries were registered. These cases are currently under investigation by OCCO and two members of the Counsel of Fighting Corruption, in consultations with national enforcement agencies and co-financing partners. OCCO has also followed up with national enforcement agencies and prosecutors on fraud and corruption cases for which NIB’s own investigations were concluded in 2013 and 2014.