africandevelopmentbankgroup an… · bank adopted a resolution creating the integrity and...

Integrity and Anti-Corruption2007-2008 Report

Integrity and Anti-Corruption DivisionOffice of the Auditor General

African Development Bank Group

integrity2List of acronyms

anti-corruptionList of acronyms

2007-2008 Report

integrity

The African Development Bank (AfDB) is thepremier development financial institution in

Africa. Established in 1964 as the regionalmultilateral development bank for Africa, the AfDBis owned by 53 African countries (referred to asRegional Member Countries or RMCs) and 24non-African countries from the Americas, Asia,and Europe. The AfDB’s purpose is to contributeto the sustainable economic development andsocial progress of African member countriesindividually and jointly.

The AfDB Group operations support both thepublic and the private sectors in RMCs. In additionto the African Development Bank, the AfDBGroup includes the African Development Fund(ADF) and the Nigeria Trust Fund (NTF).

The ADF was created in 1973 and beganoperations in 1974. It assists the AfDB in makingan increasingly effective contribution to the

economic and social development of RMCs andin promoting cooperation (including regional andsub-regional cooperation) and in expandinginternational trade. The ADF provides loans onconcessional terms to low-income RMCs forprojects and programs. It also provides grantsfor technical assistance including support forstudies and capacity-building activities.

The NTF is a special AfDB fund created in 1976by agreement between the Bank and the FederalRepublic of Nigeria to assist in the developmentefforts of low-income RMCs whose economicand social conditions and prospects requirefinancing on concessional terms.

Please visit the African

Development Bank website

at www.afdb.org

3

anti-corruptionAfricanDevelopment BankGroup

2007-2008 Report



2007-2008 Report

integrity

In November 2005, the Board of Directors of theBank adopted a resolution creating the Integrityand Anti-Corruption Division (then called the Anti-Corruption and Fraud Investigation Division) asthe sole investigative body for fraud andcorruption within the African Development Bank.The Division is mandated to promote integrity inthe use of Bank resources and investigatecorruption in Bank-financed activities. “Bank-financed activities” is broadly defined. It refers toall operations and internal administrative mattersfinanced by the Bank Group. The Division, whichis one of two divisions under the Office of theAuditor General, began its work in June 2006.

Since mid-2006, the Integrity and Anti-CorruptionDivision (IACD) has pursued a strategy ofdeliberate and steady growth with adherence tothe highest professional standards. The initial sixmonths of work were used primarily to establishan administrative framework for the IACD.Consequently, this first Report presents theIACD’s mandate, highlights its operations andmarks its accomplishments during the periodfrom January 2007 to December 2008. TheReport also provides a prospective or wayforward. Subsequent reports will be publishedannually.

IACD began full operations in accordance withits mandate, by setting up a secure Hotline toprovide complete confidentiality for complaintsreceived by email, fax or telephone, implementingthe Bank’s Whistleblower and ComplaintsHandling Policy, and developing, StandardOperating Procedures (SOPs) to guideinvestigations and procedures to ensure duediligence and procedural fairness during allphases of the investigation process, consistentwith staff rules and regulations. IACD’sinvestigators are held to the highest standardsof confidentiality, integrity and equity.

In addition to investigations, IACD fulfills itsmandate to reduce Bank vulnerability and to raiseconsciousness about corrupt and fraudulentpractices through workshops and seminars forBank staff, Field Offices and Regional MemberCountries.

Every new entity within an institution struggles tofind its place and IACD has had its share ofobstacles to overcome. With the unwaveringsupport of the Board of Directors, the Presidentof the Bank and Senior Management, IACD isbeing well prepared to tackle future challengesas well.

5

anti-corruptionForeword

2007-2008 Report



2007-2008 Report

integrity7

anti-corruptionTable of Contents

2007-2008 Report

9

999

10

13

131415151516

19

192020

23

Introduction

Establishment of the Integrity and Anti-Corruption Division IACD MandateStandard Operating ProceduresResources

IACD’s Holistic Approach: Investigations – Risk Reduction Awareness–Outreach

Investigative Process Statistics Where do cases come from? Risk Reduction Awareness-Raising Outreach and Training Efforts

The Way Forward

Activity Indicators for ProgressWorkloadStreamlining Integrity and Anti-Corruption Efforts into All Bank Activities

Synopsis of Selected Cases



2007-2008 Report

integrity

Establishment of the Integrity and Anti-Corruption Division

In November 2005, the Bank created the Integrityand Anti-Corruption Division (IACD, formerly theAnti-Corruption and Fraud Investigation Division)as the sole investigative body within the AfricanDevelopment Bank. IACD commencedoperational activities effectively in June 2006. TheDivision, which is headed by a Division Manager,is part of the Office of the Auditor General andreports directly to the Auditor General. TheIntegrity and Anti-Corruption Division (IACD)works collaboratively with the Internal AuditDivision, which also reports to the AuditorGeneral. Under the Board of Directors resolutionestablishing the Office of the Auditor General, theInternal Audit Division deals mainly withprogrammed verifications of financial statementsand the functioning of business processes; whilethe IACD conducts investigations to verify specificallegations of misconduct, fraud or corruption.

IACD Mandate

IACD’s overriding mandate is to undertakeunhindered investigations into allegations of fraud,corruption and misconduct within the Bank andBank-financed activities. IACD’s role is bothreactive and proactive. The investigative functionis responsive to allegations of corruption; butIACD is also proactive in preventing corruptionand fraud. In creating the IACD, the Bank’s Boardempowered it to:

• Manage and operate procedures andmechanisms for ensuring confidentiality of thehotline facility, protection of whistleblowers andanonymous reporting of corruption and fraudwithin the Bank and in activities financed bythe Bank in RMCs;

• Receive, screen and investigate allegations fromwhistle blowing on fraud, corruption andmalpractices or suspicions thereof, in the Bankand in activities financed by the Bank;

• Employ surveillance measures deemednecessary and reasonable for the furtheranceof investigations;

• Report regularly to the Auditor General on theallegations received, screened and theirinvestigation status;

• Undertake risk assessments on fraud andcorruption for the purposes of determining ifcontrols need to be implemented orstrengthened to reduce vulnerability, and todesign tests to help disclose the existence offraud, corruption or abuse;

• Conduct fraud and corruption awareness andpublicity in RMCs and relevant training of Bankemployees and external partners; and

• Recommend debarment and the imposition ofsanctions against individuals, firms andcompanies found to have engaged in corruptpractices.

Standard Operating Procedures

IACD’s Standard Operating Procedures (SOPs)ensure due diligence and procedural fairnessduring all phases of its investigations. Adheringto international norms and best practices, theSOPs provide a professional methodology forconducting thorough and expeditiousinvestigations, for recording, securing and storinginvestigative evidence, and for ensuring thatfindings and conclusions are adequatelycorroborated and documented.

In 2006, the International Financial Institutions(IFIs) harmonized key principles of their respectiveSOPs in the Uniform Framework for Preventingand Combating Fraud and Corruption, whichwas adopted by the heads of Asian DevelopmentBank, African Development Bank, EuropeanInvestment Bank, European Bank forReconstruction & Development, Inter-AmericanDevelopment Bank, International Monetary Fund,and World Bank during September that year.

9

anti-corruptionIntroduction

2007-2008 Report

integrity

Due Process Rights of Those Under Investigation

The SOPSs accord due process rightsto suspects in all IACD investigations,consistent with Bank rules andprocedures:

• presumption of innocence • confidentiality of identity• right to notice of charges at early

stage of an investigation• right to present exculpatory

evidence• right to extracts of final

investigation report • right of appeal to an

administrative tribunal

The SOPs articulate the due process rights ofsuspects consistent with the Bank’s staff rulesand regulations, and set a high bar for theconfidentiality, integrity and equity of investigatorsthroughout the investigative process. Identitiesof the whistleblowers are protected fromunauthorized disclosure. Subjects ofinvestigations are presumed innocent until provenotherwise and have rights to be notified ofcharges, present exculpatory evidence, receiveextracts of findings of the investigation, and ofappeal.

Resources

IACD’s state-of-the-art technology includescomputer forensic equipment, specializedsoftware and recording equipment which ensuresefficiency and reliability in the system. The Divisionalso uses a “Voice-over Internet Protocol” (VOIP)telephone network and a satellite link for thehotline. To safeguard the office and protect

confidential materials, IACD installed surveillanceequipment (CCTV) and a security system torestrict access.

Human resources include a skills mix of expertsin: procurement, law, forensic accounting,forensic auditing, fraud examination, computerforensics as well as hotline management. IACD’sManager supervises investigators, a computerforensic expert, a transcriber and support staff.Investigators work in both working languages ofthe Bank. 2009 will see a considerable increasein staff at the IACD.

10

11

anti-corruption



2007-2008 Report

integrity

Investigative Process

T he Division investigates allegationsconcerning fraud, corruption, and other

misconduct in Bank operations. The definitionsof fraudulent, corrupt, collusive and coercivepractices have been harmonized with other multi-lateral development banks. Misconduct, such asconflicts of interest, or abuse of authority, isspelled out in the Bank Staff Rules and in theBank’s Codes of Conduct.

Complaints are received through a securedhotline (email, phone or fax) or other commonmethods, and can be anonymous.

The Whistleblowing and Complaints Handling Policy

The Board of Directors approved acomprehensive Whistle Blowing andComplaints Handling Policy in January2007. The Whistle Blowing Policyprovides an avenue for Bankpersonnel and others who wish tomake confidential or anonymouscomplaints relating to corruption,fraud and other misconduct. ThePolicy provides full protection for Bankpersonnel against retaliation. In March2008, the Bank’s President issued aDirective on Whistle Blowing andComplaints Handling. The Directiveinforms Bank staff of the objectivesand responsibilities under the Policyas well as the protection availableagainst retaliation. The Bank’s Whistleblowing and Complaints HandlingPolicy has been acclaimed widely asa model Policy and has been givenhighest ratings by major non-governmental organizational (NGO)watchdogs.

Complaints are immediately registered in acustomized Case Management System whichgenerates a unique and permanent case number.

Complaints are then screened and evaluated:either they are then discarded (patently false orfrivolous), referred (to another Bank unit), directlywarrant the opening of an investigation (sufficientevidence to move forward), or need additionalscreening via a preliminary inquiry (PI).

Final investigative reports are sent by the AuditorGeneral to the President of the Bank. If IACDconcludes that “the preponderance of theevidence proved that the subject more likely thannot committed the act,” then the Auditor Generalmay recommend sanctions to the President.Sanctions range from personnel disciplinaryactions, such as separation, to debarment forcontractors and loan cancellation. In making adetermination concerning sanctions, thePresident may ask the advice of the AdvisoryCommittee on Corruption and Fraud, establishedby Board Resolution.

13Investigations

Risk Reduction

Awareness

Outreach

anti-corruptionIACD’s HolisticApproach

2007-2008 Report

integrity

Statistics

IACD conducted a number of investigations intofraud, corruption and staff misconduct within thereporting activity period. Of the 58 relevantcomplaints received, 25 cases were consideredsubstantive and of sufficient priority to warrantat least preliminary investigation. 11 cases werecompleted by the end of 2008 and the final

reports were submitted by the Office of theAuditor General to the President. Based on theinvestigative findings, Management took actionin all 11 cases. The action taken includeddisciplinary actions of dismissal for 12 Bank staff.

The table above gives a breakdown of complaintsreceived and processed by IACD during theActivity Period 2007-2008.

14

IACD Statistics 2007 2008

Description

A Total number of allegations received 174 215

B Allegations screened 174 215

C Frivolous / scam allegations 147 184

D Preliminary inquiries 15 10

E Number of cases closed after preliminary inquiry (and internal referral)

3 17

F Active investigations 7 7

G Cases investigated and closed 7 4

H Cases referred (externally) 0 0

Where do cases come from?

The intake of complaints is governed by theBank’s whistle blowing and complaints handlingpolicy. A review of the substantive complaints(not including so-called scam mails) received bythe IACD so far, shows that about 10% of all

complaints have reached IACD anonymously.The rest of the complaints were received fromboth internal as well as external interlocutors.Significantly, most of the complaints received byIACD have come through email communicationsto the investigations hotline or directly to staff ofthe Office of the Auditor General.

15

anti-corruption

Risk Reduction

In addition to the investigation function, theDivision safeguards Bank funds by taking thelead in prevention and protection: developingtools to enhance due diligence practices,assessing the risk of corruption, fraud and otherfinancial crimes to Bank operations; determiningwhat measures or institutional reforms are neededto close loopholes, and serving as a resource forlessons learned and best practices.

Awareness-Raising

IACD’s Awareness Campaign providesworkshops for Bank staff, the Bank’s field officesand the RMCs. The training promotes knowledgeand understanding of the Bank’s rules regardingethics, procurement integrity, and avenues forregistering complaints about corruption, fraudand misconduct. During the period under reviewIACD conducted awareness and sensitizationprograms for various departments in each of the

integrity

Bank’s complexes. IACD also conducted in-country sensitization workshops in two RMCsthat involved Bank-staff in field offices,government officials, project implementation units,and non-governmental organizations.

To enhance public awareness of the Bank’s anti-corruption strategy, IACD created a website aboutits activities, including the Whistleblower Policyand the investigative process. In addition, IACD’sonline forms allow direct electronic submissionsof complaints to IACD’s secured email server.IACD designed and printed brochures, compactdiscs, and posters in the working languages ofthe Bank to reach a wider audience.

Outreach and Training Efforts

Currently, IACD offers technical assistance on alimited basis to counterparts, such as state anti-corruption agencies, with which it may work jointlyon investigations in the field. IACD shares withlocal partners its experience and knowledge inareas such as: techniques in computer forensics,establishment and operation of sound whistleblowing mechanisms, standard operatingprocedures, case management systems,interviewing techniques and the securing ofevidence. Moreover, IACD staff systematicallyparticipate in the on-boarding orientation cyclefor new Bank staff.

16

17

anti-corruption



2007-2008 Report

integrity

T he Bank’s policy of zero tolerance forcorruption contributes to the aim of

realizing a stable, economically sound Africa.IACD, in collaboration with the Bank’sGovernance and Economic & FinancialManagement Department and theProcurement and Fiduciary ManagementDepartment, lead the Bank in combatingcorruption that impedes economic and socialprogress. Although great strides have beenmade, the Division will face many challenges

over the next few years as its work growswithin the Bank and in the field.

Activity Indicators for Progress

IACD has designed a roadmap to navigate theevolving challenges of combating corruption andfraud. The Key Performance Indicators (KPIs, seetable below) chart progress in each area of theDivision’s work: investigation, reducing Bankvulnerability, and raising awareness and training.

19

anti-corruptionThe Way Forward

2007-2008 Report

IACD KPI Unit Explanation

1 Number of awareness seminars Bank departments and or trainings delivered to RMC

2 Percentage of cases screened Based on the total of incoming pieces of informationin the reporting period

3 Cases investigated Cases which have entered preliminary inquiry or full investigation stage during the reporting period

4 Amount saved or lost Expresses the potential amount saved or lost

The roadmap was designed with dueconsideration of the increasing caseload, theincorporation of new staff, training needs,enhanced due diligence requirements, and theemerging fraud and corruption risks that comefrom decentralization, an expanded private sectorand infrastructure investments.

New Priorities, New Risks: Infrastructure, Private Sector Lending & Decentralization

The Bank’s current operationalpriorities pose numerous challengesto the Bank’s zero tolerance forcorruption policy: 1) concentration onbuilding African infrastructure, 2)bolstering the Bank’s Private Sectorlending – which has grown from UA278.5 million in 2006 to UA One Billionin 2007; and 3) decentralizing authorityfor loans to the Bank’s almost twenty-five Field Offices.

Financing for infrastructure projectsis complex and known to be

vulnerable to high-cost corruption.Vulnerable and affected projects haveincluded schools and hospitals thatwere improperly constructed, roadsthat did not reach their destination or

integrity

conform to specifications, telecom -mu nications programs that failed toreach the targeted communities, andsanitation projects that were nevercompleted despite huge investments.

The Bank has also embarked uponvigorous private sector activities byincreasing the Bank’s investment inprivate sector and Public-PrivatePartnerships. New and variedfinancing instruments bring risks notcommonly faced in the Public Sectorto date. These risks will require specialPrivate Sector due diligence measuresto prevent fraud and corruption. IACDwill respond by developing a strongcompliance program and duediligence systems for Private Sectoractivities.

As the Bank decentralizes, the numberof Field Offices will increase, and FieldOffice authority for local procurementand disbursement will rise to UA100,000 (equivalent to US$155,000);the risk of fraud and corruption is likelyto increase along with it. Closeproximity to and exposure of Bankpersonnel to contractors, suppliersand local government procurementofficials necessitate an affirmativeawareness program directed atintegrity in Bank projects.

Workload

A key challenge at this stage is the anticipatedcaseload volume, complexity and the length oftime needed to complete investigations. Drawingon the experience of sister MDBs after theestablishment of investigative functions, IACDexpects a major increase in complaints over thenext three to four years.

Streamlining Integrity and Anti-Corruption Efforts into All Bank Activities

More attention is being given to put integrity andanti-corruption issues at the center of all Bankactivities to maximize use of development funds.This is reflected in various Bank Groupinstruments including the revised Rules for theProcurement of Goods and Services; the new

General Conditions applicable to Bank and Fundloans, guarantees, and grants; the revisionsunderway to the Bank’s Staff Rules; the Bank’sStrategic Directions in Governance; the Boardapproved Anti-Money Laundering Strategy; andthe overall Bank’s Policy on Good Governance,which lists combating corruption as one of fivepillars for good governance. In 2008, onrecommendation of IACD to the President andthe Board of Directors, the Bank approved theestablishment of an independent Ethics Officercharged with providing independent andconfidential guidance and advice to Bankpersonnel on ethical matters. These efforts reflectthe Bank’s consistent stance of zero tolerancefor corruption in any of its activities and emphasison integrity.

20

21

anti-corruption



2007-2008 Report

integrity

Soliciting Kickback on a Bank-Funded Project

A number of irregularities were noted in themanagement of a project in a RMC and an

allegation of improper conduct by two Bank staffwas referred by the Internal Audit Division to IACD.The allegation specifically referred to receipt ofillicit payments from the Project’s staff to expeditedisbursements. Funds provided were allegedlyderived from the Project’s special account andconnected to a series of transactions whereProject officials made fraudulent claims on anactivity of the Project.

Sufficient evidence was established tosubstantiate the allegation that one of the Bankstaff members received illicit payments fromProject staff during the execution andmanagement of the Bank-financed project. Theconduct of the Bank staff fell short of theirprofessional duty to ensure the proper utilizationof funds. By their acts and omissions, the staffmembers failed to comply with their obligationsunder the Bank’s Staff rules.

OUTCOME: A report was submitted to thePresident. Management took appropriatedecision to dismiss the staff concerned. Totalproject loan from the Bank Group was UA 10million (approximately US$15 million) and thecontract from which kickbacks were obtainedwas UA 28,340 (US$ 42,510.00).

Fraudulent Education Benefit Claims

The allegations referred to false declarations madeby a Bank staff who declared his brother as hisson in order to benefit from the Bank’s educationgrants. The staff member also submitted forgeddocuments for two (2) of his declared dependentchildren.

IACD investigation substantiated the allegationthat the staff member made false declarations ofhis dependent children and also presented forgeddocuments in support of his relationship with thenamed children. The investigation showed furtherthat the staff claimed benefits from the Bank,based on those false declarations.

OUTCOME: A report was submitted to thePresident of the Bank. Management took specificaction to dismiss the concerned staff. The amountdefrauded was UA 76,848.01 (approximatelyUS$ 115,272.00).

Retaliation Against a Staff Member

A Bank staff reported through the IACDinvestigations’ hotline that he was being retaliatedagainst for reporting a suspicion of fraud orcorruption in Bank-financed projects. The staffhad disclosed to his immediate supervisor thathe had reported his suspicions of probablecorruption in three Bank-financed projects toIACD. The staff complained that subsequentlyadverse action was taken against him in four mainways by: (i) the downgrading of his PerformanceEvaluation; (ii) the compressing of his workloadon matters scheduled for Board presentationsuch that deliverables for the Board wereincreased: (iii) the cancellation of his missions;and (iv) a proposal to transfer him from amanagerial post.

The threshold inquiry involved determiningwhether a prima facie case had been established.IACD checked to determine whether fiveconditions for retaliation were present: (i) theComplainant made, or was in the process ofmaking, a communication about allegedfraudulent or corrupt practices to IACD; (ii)unfavorable personnel actions were taken orthreatened against the Complainant following thewhistle blowing; (iii) the management official(s)responsible for taking personnel action knewabout the whistle blowing; (iv) the whistle blowingwas an apparent contributing factor in thepersonnel action; and (v) the personnel actionoccurred within a period of time such that areasonable person could conclude the disclosurewas a contributing factor.

IACD found at least four out of the fiveconditions/criteria for determining prima facie theexistence of retaliation. Management was advisedof the prima facie case. Under the Whistle blowing

23

anti-corruptionSynopsis of Selected Cases

2007-2008 Report

integrity

& Complaints Handling Policy (“the Policy”) wherethere exists a prima facie case, Management hasthe burden of proof to show by clear andconvincing evidence that no retaliation againstthe Complainant occurred.

OUTCOME: IACD investigation concluded thatManagement showed by the required standardof proof that there was no Retaliation against thestaff member. Instead the matter related to inter-personnel conflicts and performance evaluation,which, under the Policy was excluded unless theperformance evaluation arose as Retaliationbecause someone complained about corruptionor fraud. IACD recommended use of theadministrative mechanism available to deal withperformance evaluation.

Soliciting Kickback From a Bank Supplier

IACD received a complaint from a whistleblowerfrom within the Bank of possible corruptionconcerning Bank internal procurement. The Bankstaff contacted the Supplier (local Supplier) tosolicit a commission on a contract entered bythe Supplier with the Bank.

The Bank staff denied soliciting a commission(kickback) on the contract. IACD obtained signedstatements from the Supplier’s personnel wherethey independently confirmed that the Bankemployee initiated telephone contacts andmeetings with them and solicited a commission(kickback) on the contract. IACD obtainedsupplementary evidence on the staff’smisconduct. The Supplier did not pay therequested commission (kickback), invoking asan explanation to the staff inability to pay becauseof cash problems at the end-of-year period.

IACD established sufficient evidence tosubstantiate the allegation that the Bank staffsolicited a commission (kickback) from theSupplier. This action is in violation of the Directiveon Bank Internal Procurement and incontravention of Staff Regulation 3.5 as well asthe Staff Code of Conduct.

OUTCOME: IACD submitted a report to thePresident. Management took immediate actionto dismiss the concerned staff.

Abusive Use of Bank Property

An investigation was initiated following informationfrom Bank staff that certain regular staff andcontracted short term staff (STS) were abusingtheir official telephone lines by calling specificlocal numbers and leaving the Bank phone linesopen for extended periods in return for freetelephone call units (airtime). Essentially, the longerthe line was left activated, the more airtime wouldbe credited. The investigation confirmed abusesto varying degrees by the concerned staff. Thetotal amount involved was TND 13,264.00

OUTCOME: A report was submitted to thePresident. Management took quick disciplinaryaction including dismissal of 8 staff involved.

24

How to Contact the Integrity

and Anti-Corruption Division

(IACD)

The AfDB protects the confidentiality ofcomplainants and accepts anonymousallegations.

To report allegations of staff misconduct orallegations of fraud or corruption within the Bankor in ADB-financed operations, you can contactIACD in a number of different ways by:

Telephone

You may telephone IACD at its secure number(216) 71 833 204. This is not a toll free number,and normal local or long distance telephonecharges will apply. The IACD has call backservices. If you wish to use our call back service,you can leave your telephone number includingthe country code and area code.

Only IACD staff can answer this telephone, oraccess the voice mailbox.

Facsimile (Fax)

You may send information to IACD’s securenumber (216) 71 833 224. This is not a toll freenumber, and normal local or long distancetelephone charges will apply.

E-mail

You may send an email to our secure email serverat [email protected].

In Person

You may visit us in person at the addressindicated below.

African Development Bank Temporary Relocation AgencyIntegrity and Anti-Corruption Division Office of the Auditor GeneralImmeuble EPI, Block C, 13th Floor1001 Rue de SyrieTunisTunisia

Mail

You may send correspondence marked“Confidential” to:

African Development Bank Temporary Relocation AgencyIntegrity and Anti-Corruption Division Office of the Auditor GeneralBP 3231002 Tunis-BelvedereTunisia

When reporting concerns, please provide asmuch information and details as possible. Includeat least the basic details of who, what, where,when, and how.

Contact persons for this report

Mr. Edward R. Ouko : Auditor GeneralMr. Seward M. Cooper : Division Manager

Integrity and Anti-Corruption Division Office of the Auditor GeneralAfrican Development Bank Temporary Relocation AgencyBP 3231002 Tunis-BelvedereTunisia

Acknowledgments

Design and LayoutAfrican Development BankExternal Relations and Communication UnitYattien-Amiguet L.

africandevelopmentbankgroup an… · bank adopted a resolution creating the integrity and...

Documents