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The Anatomy of Transnational Corruption The Anatomy of ...

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Proactive Investigative Tools<strong>The</strong> Voluntary DisclosureProgram (VDP)Allows participating firms to…• Voluntarily disclose information about theirmisconduct in Bank-financed or supportedprojects or contractsin exchange for…• No debarment• Confidentialityprovided that they…• Cease misconduct• Voluntarily and fully disclose informationabout Bank-related Misconduct for past 5years• Conduct an internal investigation• Implement a Compliance Program• Engage a Compliance Monitor (3 years)• Pay most costs associated withor face a 10-year debarment.30

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