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JunHe Assists a Large Chinese Company in Completing its Integrity Compliance Program for the World Bank Group


A Chinese construction giant retained JunHe’s consultancy services for an integrity compliance program that had been requested by the World Bank Group (“WBG”). The company and its subsidiaries had been sanctioned previously by the WBG with debarment for a few months and a conditional release of the debarment was sought. 

JunHe assisted the company to establish an integrity compliance program in both Chinese and English in line with the WBG standards, and according to the Settlement Agreement as well as the WBG Integrity Compliance Guidelines. It then helped the company undertake risk assessments and compliance reviews to address the compliance issues. JunHe’s team also carried out several integrity compliance training sessions for the company’s staff members including senior management and the compliance officers, and finally assisted the company and its subsidiaries to effectively implement the integrity compliance program in line with international standards.

JunHe assisted the company to actively cooperate with the Independent Integrity Compliance Monitor (“Monitor”) appointed by the WBG. During several site visits by the Monitor, JunHe, on behalf of the company, presented the integrity compliance efforts taken by the company. It thoroughly substantiated the practical accomplishments made by the company in line with the integrity compliance guidelines, and made well-founded explanations related to the hardship experienced  by the company during the implementation of some of the integrity compliance systems.

During the implementation of the integrity compliance program, JunHe advised the company in finding a balance between observing the guidelines and  consideration for the complex environment in implementing the integrity compliance program. JunHe also gave cost-efficient recommendations regarding implementation  in order to minimise the workload for the company and maximise the compliance results. 

JunHe also assisted the company in investigations on several WBG-funded projects by the independent investigator group retained by the WBG (“Investigators”). During these investigations, JunHe sorted and reviewed thousands of project documents and participated in the almost 20 rounds of investigation interviews of the company’s employees. It also successfully responded to instructions made by the Investigators regarding Chinese laws and regulations.

JunHe assisted the company in overcoming the difficulties caused by the pandemic by presenting their work online. The company was released from the sanctions according to the original timeline set by the Settlement Agreement, and successfully avoided delays. With almost three years of effort, JunHe helped arrange the integrity compliance program for the company and, as a result, it succeeded in establishing and implementing an effective integrity compliance program to the satisfaction of the WBG. WBG spoke highly of these achievements and the case has been recognized as a model of comprehensive compliance management by the industry, which has enhanced the international creditability and brand image of the company.

This is another example in which JunHe has assisted a Chinese company to complete a comprehensive compliance program, duly respond to an investigation and to finally be released from sanctions. It again demonstrates JunHe’s in-depth understanding of the rules of multilateral development banks (“MDBs”) as well as the abundant experience of JunHe’s team in implementing localized integrity compliance programs in line with international standards. JunHe team’s MDB sanction-related legal services have set the standard for the Chinese legal industry, showing the solid market position of JunHe in MDB-related practice.

This project was done in collaboration with Hughes Hubbard & Reed LLP and Kobre & Kim LLP.

JunHe is the only Chinese law firm to be admitted as a member of Lex Mundi and Multilaw, two international networks of independent law firms. JunHe and selected top law firms in major European and Asian jurisdictions are “best friends.” Through these connections, we provide high quality legal services to clients doing business throughout the world.