Global Economic Crime Survey - PwC UK · current economic environment, based on the three...

Global Economic Crime Survey March 2010

Engineering and construction sector summary

PricewaterhouseCoopers 1Engineering and construction sector summary • March 2010

Introduction We are delighted to present our fourth Engineering and Construction (E&C) sector Global Economic Crime Survey. Our survey scrutinises fraud and associated integrity risks during a period in which most territories around the world experienced either a dramatic economic downturn or at the very least a significant slowdown. Against this backdrop, the survey investigates the root causes of economic crime and the way in which it affects businesses worldwide.

Economic crime is a truly global phenomenon. This year over 3,000 senior representatives from organisations across 54 countries completed our web based survey. The E&C sector was well represented, with 226 respondents spread across 43 countries. These responses were received from a cross section of management levels, from board members to managers, and their companies varied widely both in size and in ownership structure. Of the 226 E&C respondents, 36% came from listed companies, 62% from organisations trading in multiple countries and 62% from organisations with an employee base in excess of 200.

This year’s survey asked respondents to focus their responses specifically on their experiences over the last twelve months, with a view to developing an understanding of the fraud threats that emerge during an economic downturn. The responses suggest that the E&C sector continues to face the effects of the economic downturn, with 65% of respondents stating their organisations had experienced a decline in financial performance over the last twelve months. Many E&C respondents, nearly a quarter (24%), also reported they have been contending with economic crime during this period.

In addition to investigating the root causes of economic crime and the way in which it affects businesses within the E&C sector, this summary also examines the changing trends in economic crime within the E&C sector worldwide during a time of unprecedented economic and regulatory change. We hope that the findings will encourage business leaders within the E&C sector to review their companies’ anti-fraud policies and procedures, and to consider whether they are appropriate for the dynamic business environment.

Key findings of report:24% of E&C companies have •experienced economic crime in the last year;

more sophisticated frauds such as •accounting fraud and bribery and corruption are on the increase;

bribery and corruption is more •prevalent in the E&C sector than in the wider business world, 29% of those reporting crimes for the E&C sector versus 13% across all industries were impacted by it;

whilst the financial impact of •fraud was consistent with other sectors, employee morale is more damaged in the E&C sector than in other sectors;

over a third of E&C companies •had not performed a fraud risk assessment in the last twelve months and another third had not increased the frequency of those reviews; and

the significant majority (69%) of •reported economic crime in the E&C sector is committed from within organisations.


This may well be linked to the economic downturn. Current economic conditions may have exacerbated an existing trend. As can be seen in Figure 1, which shows a trend in reported frauds for the E&C sector, the percentage of those respondents reporting ‘accounting fraud’ has been steadily rising over time, increasing from 20% in 2007 to 38% in 2009. While asset misappropriation will continue to be a major concern for the E&C sector, fraudsters are also becoming more sophisticated and branching out into other types of economic crime.

Figure 1 highlights that the rate of ‘bribery and corruption’ for the E&C sector has

been on the upswing over time, increasing from 38% in 2007 to 47% in 2009. The bribery and corruption figure for the E&C sector (47% in 2009) was the largest of any sector and well above the average across all industries (27% in 2009) (see figure 2).

The E&C sector has a history of bribes being paid to those procuring or having influence over the procurement of construction works so as to either avoid competitive tendering, gain higher margins, or reduce tendering costs. Additionally, in the complex world of construction pricing and competitive tendering, there is often a lack of

Bribery and corruption – a perennial problem in the E&C sectorThe E&C sector has a number of characteristics which makes it particularly vulnerable to economic crime. These include projects with multiple contractual arrangements, often across geographic borders, use of agents and a heavy involvement with governments and state-owned organisations.

The industry has also under-invested in systems and preventative controls and lacked standardisation of process.

Asset misappropriation, accounting fraud, bribery and corruptionThe 2009 survey found that overall the three most common types of economic crimes experienced in the last twelve months in the E&C sector were asset misappropriation, accounting fraud and bribery and corruption.

Asset misappropriation has remained the most common economic crime in each of our surveys since 2003, and the E&C sector remains particularly vulnerable to this type of fraud. Given the nature of many engineering and construction projects, personnel often have remote and sometimes unsupervised access to valuable plant and materials. The misappropriation of these items remains a real problem for the industry, in spite of efforts to ‘chip’ or use tracking devices. In addition, the large quantities of materials used on many engineering and construction projects, combined with the difficulty in estimating accurately the quantity of materials required for construction, makes E&C organisations susceptible to over-ordering and subsequent re-selling of construction materials from site.

The prevalence of accounting fraud within the E&C sector has increased significantly since our last survey in 2007. This type of fraud includes accounting manipulations, fraudulent borrowing/raising of finance, fraudulent applications for credit and unauthorised transactions/rogue trading.

Figure 1: Trends in reported frauds for the E&C sector

Asset misappropriation

Accounting fraud

Bribery and corruption

% companies

4738

3820

6468

2007 2009

0 10 20 30 40 50 60 70 80

% respondents who experienced economic crimes

Figure 2: Reported frauds for the E&C sector versus all industries

Asset misappropriation

Accounting fraud

Bribery and corruption

IP infringement, includingtheft of data

Money laundering

Illegal insider trading

Espionage

Market fraud involving cartelscolluding to fix prices

Tax fraud

% reported frauds

6467

3838

4727

1515

412

64

63

63

95

E&C sector All industries

0 10 20 30 40 50 60 70 80

% respondents who experienced economic crimes


control over the procurement process. Sixty-two percent of E&C respondents stated their organisations had offices in more than one country; many of these offices fall into one or both categories. The consequential increase in fraud risk exposure needs to be appropriately managed.

The sector is typified by customised contracts, suffers from a lack of relevant cost benchmarks and continually faces challenges around the levels of governance expected and specified in relation to supply chain performance. The consequence is a wealth of opportunities for value leakage and waste. Owners, procurement agencies and funders need to press the sector for increased transparency of cost elements and enhanced management accountability within their conditions of contract, to remove the ability of suppliers to hide uneconomic costs as part of the overall construction costs. The sector needs ‘intelligent’ clients with integrity to lead this process of change in order to make the processes credible and transparent. We are seeing a trend emerging in certain sectors of the industry for project owners to seek additional specificity and transparency in contract commercial terms, despite the objections of contractors seeking to maintain flexibility in their contracting approach through more ambiguous commercial terms.

RegulationIn recent years there have been changes in attitudes towards bribery and corruption globally, resulting in increased regulatory enforcement. This trend is likely to continue as more territories introduce or strengthen anti-corruption legislation and/or strengthen enforcement in response to global pressures.

transparency in relation to risk pricing, overhead recovery, contingency allowances and profit margins. This lack of transparency, combined with the pressures of the competitive tendering process, make the construction industry particularly susceptible to corruption. The E&C sector has exposure to corruption risks through large-scale contracts, often for the public sector, frequently in the more lucrative emerging markets, and typically involving complex supply chains and increasingly cut-throat competition. Organisations in the E&C sector need to exercise a heightened awareness of this area as the consequences for organisations found guilty of corruption can be far reaching and long lasting.

Transparency International – the global anti-corruption organisation – publishes

annually ‘The Bribe Payers Index’, which in 2009 showed that construction companies are amongst the most likely to pay bribes when dealing with the public sector, ahead of the arms, defence, and oil and gas industries. Construction companies were also found to be the most likely to exert undue influence on governments’ policies, decisions and practices and, along with those in heavy engineering, were seen to be the most likely to bribe government officials.

The risk of bribery and corruption is present in most transactions and territories in which organisations operate. Of particular concern are dealings with government officials in emerging markets, where bribery and corruption can be more prevalent, and where the organisation uses sales agents, reducing internal

Bribery & corruptionA multinational company discovered it was paying overseas agents sales commissions of up to 50% of the sales value in some territories. It was unclear what services the agents were providing, whether they had the required expertise and whether their services were being provided at a fair market value. There were no anti-bribery provisions in the agency contracts that required the agents to conduct themselves in line with regulations, nor was there any provision for transparency and access to agents’ books.

Recommended remediation process:

Performed due diligence on overseas •agents and their services

Standardised agency agreements to •include anti-bribery representations and warranties

Monitored the performance of •overseas agents

Issued clear policy on what •constitutes unacceptable behaviour

Trained employees on the impact •of international anti-corruption regulation

Installed internal control procedures •requiring pre-authorisation for any commissions paid on third party agency agreements

E&C companies should consider:

Performing financial, technical and •operational due diligence on their business partners, personnel and contracts involved in a new-market expansion;

Issuing clear company policy •on what constitutes unacceptable behaviour, and enforcing the prescribed consequences;

Thoroughly (and annually) training •employees to address the impacts of international anti-corruption standards;

Reinforcing ethics and compliance •by top down communications and requirements for periodic written statements of compliance from key employees;

Performing random field tests/ •inspections to determine whether employees understand company compliance policy;

Streamlining and integrating •payment systems to make it easier to identify where, why and how much money is being spent; and

Regularly testing payment •systems and controls to assess the proper accounting of all project expenditures.

With many parts of the global economy flat or still in recession, pressure on governments to better control spending on public works is likely to continue. Coupled with the introduction of new industry regulation, this means that E&C companies face an increasingly competitive outlook.


Contributory factorsThe global economic downturn has significantly increased pressures on organisations and individuals to improve efficiency and reduce costs, creating more incentives and opportunities for fraudsters. Respondents to the survey were asked what they felt the most likely reason for greater risk of fraud was, in the current economic environment, based on the three components of the fraud triangle; opportunity, incentive and rationalisation.

The fraud triangle describes the interconnected conditions that act as harbingers to fraud: opportunity to commit fraud, incentive (or pressure) to commit fraud, and the ability of the perpetrator to rationalise the act.

Only 17% of respondents believe the increased risk of fraud is due to increased opportunities for fraud in the current economic environment, as costs are cut and gaps appear in control systems. This perspective suggests that the

‘ The belief is that competitors are paying bribes to win work. That this may be influencing behaviour is concerning and could create a downward spiral unless reisisted’Jonathan HookGlobal E&C leader

Figure 3: Fraud triangle

Attitude/Rationalisation

11%

!FRAUD RISK

Incentive or Pressure72%

Opportunity17%

% companies

E&C sector

Attitude/Rationalisation

14%

!FRAUD RISK

Incentive or Pressure68%

Opportunity18%

% companies

All industries

E&C sector could run the risk of reduced governance as a result of redundancies and streamlining. Relatively few respondents see increased opportunity as a serious issue. However, given the pressures of the economic downturn, many companies have downsized or abolished central procurement functions, and are now delegating responsibility for material ordering to site managers in a drive to reduce overheads and remain competitive. An individual site manager may consequently be responsible for all stages of procurement, from ordering through to certifying payment. Such changes do, in our view, increase the opportunity for fraud.

Far more respondents (72%) see increased pressure and incentives to commit fraud as the most likely reason for a greater risk of fraud within their organisation. Many organisations are indeed facing tough times, with 65% of respondents stating that their organisations had experienced a decline in financial performance over the last twelve months.

Survey respondents report that the two most important issues contributing to the increasing pressure and incentive to commit fraud in the current economic environment are; targets have become more difficult to achieve (50%) and fears over job loss (40%). These factors provide further insight into the significant increase in accounting fraud in the E&C sector that we noted earlier.

Of those respondents who cite increased pressures and incentives as the most likely reason for greater risk of fraud, a significantly higher proportion of E&C respondents attributed this to the belief that competitors are paying bribes to win


the E&C sector and in a low margin industry like construction, where there are high value contracts, the financial consequences may have had more impact on the overall financial health of those organisations and lost jobs. This is perhaps inevitable when considering the nature of the industry with a complex supply chain where owners rely heavily upon past experience and a track record of delivery on time and on budget. If there is a view that corruption is endemic in a sector, individuals may fear for their own reputations, or be uneasy about pressure to manipulate results or pursue unethical courses of action.

Perhaps even more striking is that 55% of E&C respondents found that the economic crimes experienced by their companies had a significant impact on

Figure 4: Factors contributing towards increased incentives/pressures to commit fraud

Financial targets more difficult to achieve

Fear of losing jobs

Desire to earn personal performance bonuses

For senior management to achievedesired financial results

Bonuses not paid this year

Maintain financial performance to ensurelenders do not cancel debt facilities

There is a belief that competitors arepaying bribes to win contracts

Others

% Incentives/pressures

5047

4037

2427

2925

2923

2618

2913

514


0 10 20 30 40 50

% respondents who believe increased incentives/pressures are the most likely reason for greater risk of economic crime in a downturn

contracts. Indeed, as governments cut back on capital spend, the pressure to achieve turnover targets, maintain profit margins and fill order books will only increase.

When compared with the average across other industry sectors, more than twice the number of respondents (29% versus 13%) from the E&C sector say that there is a belief that competitors are paying bribes. This stems from the historic prevalence of bribery within the sector which is continually reinforced with cases of corruption publicised on an increasingly regular basis.

Beyond the financial consequencesOf the E&C respondents that reported incidences of fraud over the last twelve months, eleven companies said that the direct financial impact of this exposure was more than US$500,000 and two others reported an impact of over US$5million. Perhaps more significantly, our survey revealed that E&C companies are proportionately more susceptible to the collateral damage caused by economic crime.

This is likely to reflect a tough environment for bidding on work and maybe an element of rationalisation by companies who have lost bids. However it also reflects some of the negative publicity the sector has received and shows that even within the industry, at a minimum, there is a serious perception problem with regards to instances of paying bribes to win work.

Reputation and business relationships are considered to be particularly vulnerable in

employee morale, compared with 32% in all industries (see figure 5). In addition to damaging employee morale, economic crime has long lasting impacts on business relationships and can lead to a complete erosion of trust. Success in the construction sector relies heavily on developing leadership skills, teamworking and the ability to sustain relationships with a variety of suppliers of goods and services. Therefore the impact of fraud on businesses within the sector can be significant.

The cost of collateral damage should be of real concern to organisations. Headlines about fraud within the sector affect not only the employees of the organisation; our survey results suggest there are further impacts on investors, suppliers, customers and potential recruits (see figure 5).


Figure 6: Detection methods for the E&C sector from 2009 and 2007 surveys

Internal audit

Fraud risk management

Suspicious transaction reporting

Corporate security

Rotation of personnel

Tip-off (internal)

Tip-off (external)

Whistle-blowing system

By accident

By law enforcement

Other detection methods

% reported frauds

2616

131

44

21

113

1623

615

98

99

40

165

2009 2007

0 5 10 15 20 25 30

% respondents who experienced economic crimes in the last 12 months for 2009; and in the last two years for 2007

Detection methodsThis year’s survey showed that the majority of frauds across all industries were detected by internal audit.

In the E&C sector, 26% of frauds reported were detected by internal audit in 2009 (see figure 6). This represents a significant increase from a level of 16% in 2007. In the E&C sector, economic crimes discovered by chance, through tip-offs or by accident, reduced from 47% in 2007 to 31% in 2009. This is a positive change for the sector and may highlight a greater awareness of the value of preventative measures.

Our survey also found that there was a correlation between the level of economic crime experienced and how often a risk assessment had been performed, with those that carried out regular fraud risk assessments reporting more fraud. Put another way, more

effort expended looking for fraud results in more fraud being found.

Within the E&C sector, 67% of respondents said that the frequency of conducting risk assessments had not changed compared to twelve months ago. More than a third, (35%) of E&C respondents have not performed a fraud risk assessment at all in the last twelve months.

Organisations need to be continually assessing fraud risks and the importance of addressing fraud risks needs to be conveyed from the top of an organisation. In addition, as construction projects tend to combine different companies and people within project teams, there is an increased need to review the threats and weaknesses in project management systems, especially when joint ventures are formed or new business relationships established.

Figure 5: Collateral damage

Employee morale

Business relationships

Reputation and brand

Relationships with regulators

Share prices

Impact of other areas

% all respondents

5532

3123

2919

1616

136

74


0 10 20 30 40 50 60

% respondents who experienced economic crimes in the last 12 months

A comprehensive fraud risk assessment should:

Identify the potential inherent fraud •risks and likely “gateways” to fraud.

Assess the likelihood and •significance of occurrence of the identified fraud risks.

Evaluate which people and •departments are most likely to commit fraud and identify the methods they are likely to use.

Identify and map existing preventive •and detective controls to the relevant fraud risks.

Evaluate whether relevant controls •and processes are effectively designed to address identified fraud risks

Identify and assess residual fraud •risks resulting from ineffective or non-existent controls.

Respond to residual fraud risks.•

Engineering and construction sector summary • March 2010 PricewaterhouseCoopers 7

Fraud in constructionA fast-growing contractor had sublet the construction of foundations for two tower blocks to a specialist subcontractor. Only when the tower blocks were nearly completed did they realise that the property was not constructed in line with expected standards. It came to light that the subcontractor had cut corners in constructing the majority of bored-piles supporting the towers to avoid large penalties for late-completion. The tower blocks needed to be completely demolished. The directors and staff of the subcontractor faced criminal prosecution for conspiracy to defraud. The main contractor’s business collapsed as a consequence of a massive damages claim against it in civil arbitration.

Measures that would have helped to prevent this type of fraud include:

Assessing the risks of subcontracting •decisions and assigning the appropriate levels of supervision

Undertaking due diligence on •subcontractors and employees

Considering the corporate and •personal incentives to defraud, including disproportionately large penalties for late completion

Considering the opportunities •to defraud, particularly in specialist work

months will be perpetrated by external parties. This highlights a gap between perception and reality which E&C organisations need to address. If organisations do not properly understand the risk of fraud inherent in their business, they will be unable to

develop adequate detective and preventative internal procedures.

The lack of awareness of fraud risk is also linked to a lack of awareness of the necessary investment and resources required to apply effective governance

Figure 8: Trends in the profile of internal fraudsters in E&C sector

Junior staff members

Middle management

Senior executives

% reported frauds

3452

4525

2123

2007 2009

0 10 20 30 40 50 60

% respondents who reported that an internal employee was the main perpetrator of fraud

Know your enemy E&C organisations that have suffered from economic crime report that a substantially higher level has been committed by internal fraudsters (69%) compared with the average of all industries (53%).

The survey also highlighted that the profile of the internal fraudster has changed. Economic crimes committed by middle managers have nearly doubled from a level of 25% in 2007 to 45% in 2009 (see figure 8). If we consider the fraud triangle discussed previously, this is perhaps unsurprising as it is middle managers that

would normally have the greatest opportunity to commit fraud within an organisation. They know what controls are operating within the business and know when effective authorisation of expenditure checks may not be carried out. This is also consistent with the trend towards more complex accounting manipulation and bribery and corruption frauds, rather than more straightforward asset misappropriation.

Despite this, there is a widely held belief amongst respondents in the E&C sector that the majority of economic crimes to be committed over the next twelve

Figure 7: Detection methods for the E&C sector in comparison with all industries surveyed

Internal audit

Fraud risk management

Suspicious transaction reporting

Corporate security

Rotation of personnel

Tip-off (internal)

Tip-off (external)

Whistle-blowing system

By accident

By law enforcement

Other detection methods

% reported frauds

2617

1314

45

25

115

1616

611

97

913

30

45


0 5 10 15 20 25 30

% respondents who experienced economic crimes in the last 12 months


‘ At a minimum, organisations should undertake an annual fraud risk assessment. Building an appropriate compliance framework won’t stop every instance of economic crime, but it will have an impact. It is also an important part of your defence and mitigation in the event of regulatory investigation’Jonathan HookGlobal E&C leader

over the management and delivery of large complex capital projects. There is a growing appreciation that a combination of leadership, people competency and strong management systems are required to deliver successful projects. In the E&C sector, cost-benefit analysis techniques of varying complexities are commonly used to guide decision making and the economic appraisal of options. However, the difficulty with fraud risk is the decision as to whether or not to undertake dedicated programmes of fraud risk assessment/identification. This stems from the difficulty associated with estimating the ‘true cost’ of fraud and it is therefore inherently difficult to assess whether it makes good economic sense to pursue a fraud assessment/identification programme.

ConclusionThe results of our survey show quite clearly that economic crime is real and is happening within the E&C sector, with significant consequence for those involved. A proactive approach to fraud risk management can protect your business from the effects of economic crime. There are signs that the E&C sector is beginning to utilise the tools available to mitigate fraud risk, with quantity of fraud detected by chance, through tip-offs or by accident, down 16%from 2007 (reduced from 47% in 2007 to 31% in 2009). Greater effort is, however, still needed as the industry remains heavily reliant on detection of economic crime through internal audit. The adoption of a pro-active, risk assessment, based approach to the management and detection of economic crime is therefore required.


TerminologyDue to the diverse descriptions of individual types of economic crime in countries’ legal statutes, we developed the following categories for the purposes of this survey. These descriptions were defined as such in our survey questionnaire.

Economic crime or fraud The intentional use of deceit to deprive another of money, property or a legal right.

Asset misappropriation (including embezzlement/deception by employees) The theft of assets (including monetary assets/cash or supplies and equipment) by directors, others in fiduciary positions or an employee for their own benefit.

Accounting fraudFinancial statements and/or other documents are altered or presented in such a way that they do not reflect the true value or financial activities of the organisation. This can involve accounting manipulations, fraudulent borrowings/raising of finance, fraudulent application for credit and unauthorised transactions/rogue trading.

Corruption and bribery (including racketeering and extortion)The unlawful use of an official position to gain an advantage in contravention of duty. This can involve the promise of an economic benefit or other favour, the use of intimidation or blackmail. It can also refer to the acceptance of such inducements.

Money launderingActions intended to legitimise the proceeds of crime by disguising their true origin.

IP infringement (including trademarks, patents, counterfeit products and services)This includes the illegal copying and/or distribution of fake goods in breach of patent or copyright, and the creation of false currency notes and coins with the intention of passing them off as genuine.

Illegal insider tradingIllegal insider trading refers generally to buying or selling a security, in breach of a fiduciary duty or other relationship of trust and confidence, while in possession of material, non-public information about the security. Insider trading violations may also include ‘tipping’ such information, securities trading by the person ‘tipped’, and securities trading by those who misappropriate such information.

EspionageEspionage is the act or practice of spying or of using spies to obtain secret information.

Financial performanceThis can be defined as measuring the results of an organisation’s policies and operations in monetary terms. These results are reflected in return on investment, return on assets and value added; typically, In the private sector, returns will be measured in terms of revenue; in the government/state-owned enterprises, returns will be measured in terms of service delivery.

Fraud risk assessmentFraud risk assessments are used to ascertain whether an organisation has undertaken an exercise to specifically consider:

(i) the fraud risks to which operations are exposed;

(ii) an assessment of the most threatening risks (i.e. evaluate risks for significance and likelihood of occurrence);

(iii) identification and evaluation of the controls (if any) that are in place to mitigate the key risks;

(iv) assessment of the general anti-fraud programmes and controls in an organisation; and

(v) actions to remedy any gaps in the controls.

Fraud triangleFraud triangle describes the interconnected conditions that act as harbingers to fraud: opportunity to commit fraud, incentive (or pressure) to commit fraud, and the ability of the perpetrator to rationalise the act.

Senior executiveThe senior executive (for example the CEO, Managing Director or Executive Director) is the main decision-maker in the organisation.

Note: In some cases percentages may not total 100% exactly as respondents were able to provide multiple answers.


Contacts

UK

Anthony Morgan (Forensic Services)[email protected]: +44 20 7213 4178

Roland Sonnenberg (Forensic Services)[email protected]: +44 (0) 20 780 45162

US

Kent Goetjen (US Engineering & Construction Leader)[email protected]: +1 (860) 241 7009

Stephen Lechner (Forensic Services)[email protected]: +1 (415) 498 6596

If you want to discuss the results of our survey and/or want to know what else your organisation should be doing to mitigate fraud risk. Please contact us.

Jonathan Hook (Global Engineering & Construction Leader)[email protected]: +44 (0)20 7804 4753

pwc.com/crimesurveyPricewaterhouseCoopers provides industry-focused assurance, tax and advisory services to build public trust and enhance value for our clients and their stakeholders. More than 163,000 people in 151 countries across our network share their thinking, experience and solutions to develop fresh perspectives and practical advice.

© 2010 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” and “PwC” refer to the network of member firms of PricewaterhouseCoopers International Limited (PwCIL). Each member firm is a separate legal entity and does not act as agent of PwCIL or any other member firm. PwCIL does not provide any services to clients. PwCIL is not responsible or liable for the acts or omissions of any of its member firms nor can it control the exercise of their professional judgment or bind them in any way. No member firm is responsible or liable for the acts or omissions of any other member firm nor can it control the exercise of another member firm’s professional judgment or bind another member firm or PwCIL in any way.

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