The Caribbean Development Bank’s (CDB) Office of Integrity, Compliance and Accountability (ICA) is reflecting on “a significantly increased volume of intake and intensity of investigative traffic for ethics and integrity investigations”.

This is for the 2024 reporting period, a year in which the Barbados-based institution’s then President Dr Hyginus “Gene” Leon was sent on administrative leave and eventually departed.

The ICA did not link any of the reported matters to the Leon issue, nor mentioned it specifically, and also made it clear that all reports made to it by staff “do not necessarily lead to cases being opened”.

The CDB published the ICA’s Annual Report for 2024 on its website on January 26 and ICA head Dr Toussant Boyce said in the publication that the report “promotes transparency, in alignment with ICA’s board-approved mandate to operationalise and manage the Strategic Framework for Integrity, Compliance and Accountability of the CDB”.

ICA reports functionally to the CDB board of directors through the oversight and assurance committee and administratively to the CDB president.

Ethics cases

With the ICA’s five functions being institutional integrity, ethics, compliance, accountability and whistleblowing, the report said that in 2024 the entity “opened 13 new cases pursuant to complaints received through whistleblower channels, of which there were two new integrity cases, one accountability and ten new ethics cases”.

“This caseload was in addition to the one integrity case, one ethics case, and one accountability case carried over from 2023. The new cases opened throughout 2024, exceeded the four new cases opened by ICA during 2023,” it noted.

“The allegations in these cases include breach of the code of conduct; abuse of CDB’s assets, systems and operations; abuse of privileges and immunities; conflicts of interest; falsification of documents and records; social harm (sexual exploitation and abuse) and fraud”.

The report said that in 2024 the ICA also “received numerous consultations and pre-cases during in-person and virtual office visits from members of staff; received four new requests for assistance from the finance department; received 17 new requests for assistance and conducted enhanced due diligence exercises on individuals and entities, in accordance with ICA’s integrity due diligence toolkit”.

These 17 requests exceeding the 13 similar requests received in 2023.

The publication added that the ICA “received for review 171 conflicts of interest submissions with disclosures for resolution”.

“These 171 submissions were received through the conflicts of interest disclosure portal or by email and can be contrasted with the 72 submissions received in 2023,” it reported.

Conflict of interest

“Annually, each member of staff is required to disclose whether there is any actual, apparent or potential conflict of interest between their private interests and their official duties to CDB and to attest to human resources and administration department (HR&AD) that they have read and understood the code of conduct.

“Each submission is made digitally using a questionnaire through a conflicts of interest portal which helps CDB to detect, assess and resolve conflicts of interest.”

ICA explained that submissions that contain specific disclosures are resolved by ICA and HR&AD with the assistance of the member of staff who made the submission.

ICA also “conducted other investigative activities to assist the operations area, related mainly to suspicions of procurement-related integrity violations; assisted HR&AD with the resolution of an attempted cyber fraud; and assisted an external independent investigator with the conduct of a special investigation.

Possible report to ICA

The report said that “some staff visit ICA to seek advice and share concerns about a possible report to ICA but are not yet ready to make a full report or never wish to do so”.

“These are referred to as ‘consultations’ or ‘pre-cases.’ Some may expressly request ICA to not open or to delay opening a case or to open a case and then suspend it,” it stated.

Boyce said the report was written “to help ensure accessibility by diverse types of audiences ranging from the most seasoned development bankers to less sophisticated and curious stakeholders who interested in learning more about ICA and its work”. The report called 2024 “a year of major success for ICA and also significant challenges for CDB which required expertise, experience, agility, innovation, and patience”. “During the first half of the year, many of these challenges related to managing a spike in sensitive internal investigations, and other major related commitments with staff resource and time constraints,” it said.

“ICA has managed similar spikes in sensitive internal and external investigations before, however, 2024 had other unique complexities and organisational processes that placed extraordinary demands on ICA throughout the year.

“ICA also managed challenges related to misinformation among staff and the public about CDB’s whistleblower system and the conduct by ICA of internal investigations.”

The report said that “despite these challenges, ICA commenced corrective action to address information asymmetries and gaps through planning special targeted training in 2025 on the CDB whistleblower system for board of directors, training on internal investigations for staff and for the public during ICA outreach exercises”.

Looking ahead, the ICA stated: “ICA maintains a positive outlook for 2025 and beyond. ICA is confident that it will be able to continue to deliver on its strategy to prioritise prevention and deliver effectively on its broad mandate despite the challenges mentioned above.” (SC)