Investigating Prohibited Conduct
The European Investment Bank Group (EIB Group) has a zero tolerance of Prohibited Conduct whether occurring in connection with projects and activities financed by the EIB Group or perpetrated by its own staff. The EIB Group consists of the European Investment Bank (EIB or the Bank) and the European Investment Fund (EIF).
The Fraud Investigations Division is an independent office within the EIB Group and is the sole office mandated to investigate Prohibited Conduct within EIB Group.
Prohibited Conduct includes fraud, corruption, collusion, coercion, obstruction, money laundering and financing of terrorism affecting the EIB Group’s operations and activities.
The Fraud Investigations Division aims to protect the EIB Group’s finances and reputation through six core activities:
- Assessment and, where necessary, investigation of allegations
- Policy work aiming at ensuring the existence of a robust anti-fraud policy framework at the EIB Group and incorporating the lessons learned from the investigations into policies and practices
- Proactive Integrity Reviews (PIRs) to identify actual fraud or potential vulnerabilities
- Fraud awareness training for all EIB Group staff
- Raising awareness of Prohibited Conduct-related issues in the public and private sectors
- Analysis and information gathering to support the above five activities
The EIB Group encourages everyone to report promptly to the Fraud Investigations Division suspicions of Prohibited Conduct in EIB Group-financed operations or activities. Investigations are primarily triggered by reporting of suspicions. External reports from parties or persons involved in EIB Group projects and activities are therefore of important value for the EIB Group.
EIB Group staff members have an obligation to report any suspicion of Prohibited Conduct immediately after becoming aware of the matter. For this purpose, the EIB has developed a Whistleblowing Policy applying to all staff members and service providers, allowing them to fulfil their duty to report wrongdoings.
The key reference documents are the EIB’s Anti-Fraud Policy, the EIF’s Anti-Fraud Policy and the Procedures for the Conduct of Investigations. These documents are based on the Uniform Framework agreement reached by the International Financial Institutions (IFI) Anti-Corruption Task Force in September 2006, which harmonises the definitions of fraud and corruption and investigative procedures across the IFIs.
The Bank also developed an exclusion framework which aims at enhancing the Bank’s ability to fight Prohibited Conduct by enforcing the prohibitions contained in the EIB’s Anti-Fraud Policy.
Furthermore, the Bank’s ethical, professional and business approach is supported by Codes of Conduct, a Guide to Procurement, internal policies and rules including conditions and clauses contained in the EIB Group's finance contracts and relies on European and International standards.