Formal Complaint and Request for Full Forensic Audit and Investigation into Alleged Procurement Irregularities, Conflicts of Interest, and Breaches of Engineering Standards in Public Works Contracts

To: The Permanent Secretary 

Ministry of Public Works 

Co-operative Republic of Guyana 

And To: The Chairperson 

Public Procurement Commission 

Co-operative Republic of Guyana 

Subject: Formal Complaint and Request for Full Forensic Audit and Investigation into Alleged Procurement Irregularities, Conflicts of Interest, and Breaches of Engineering Standards in Public Works Contracts 

Dear Sir/Madam, 

 I write in a formal capacity to lodge a complaint of a serious and urgent nature concerning allegations of systemic irregularities in the award, administration, execution, and oversight of public works contracts under the purview of the Ministry of Public Works. 

 The matters raised herein are grounded in information received from multiple sources and are further supported by direct correspondence previously issued seeking clarification from parties identified as being connected to the projects in question. Given the gravity of the allegations, the potential breaches of procurement law, and the implications for public accountability, we hereby formally request the immediate initiation of a comprehensive, independent, and forensic audit into the matters outlined below.

• Allegations of Improper Award of Contracts and Lack of Qualification 

It is alleged that contracts valued at approximately G$1.5 billion, relating in part to works in C-field Sophia, Georgetown, were awarded to entities identified as Delta and RIM Construction. Serious concerns arise regarding: 

1. The recent incorporation of the entity known as Delta, reportedly established within the past one to one-and-a-half years; 
2. The absence of demonstrable technical experience or performance history, raising questions as to whether the entity satisfied statutory prequalification requirements; 3. The apparent award of high-value contracts to entities lacking a proven track record, thereby potentially contravening principles of fairness, transparency, and value for money as enshrined in Guyana’s procurement framework. 

• Allegations of Undisclosed Interests and Beneficial Ownership 

Information received suggests that: 

1. Mr. Dale Ibbott may have beneficial or controlling interests in multiple contracting entities, including Delta and RIM Construction; 
2. Questions also arise regarding the involvement of Ms. Tammy Ibbott, and whether she holds any directorship, ownership, or proxy interest in companies executing the works; 3. Concerns exist that material interests may not have been properly disclosed, thereby undermining procurement integrity requirements. 

These matters require urgent verification through a forensic examination of corporate records, beneficial ownership disclosures, and procurement filings. 

• Allegations of Conflict of Interest Involving Public Officials 

Of particular concern are allegations that individuals employed within the Ministry of Public Works, including engineers identified as Mr. Nickesh Pargoo (also referenced as Nickesh Mangru) and Mr. Kevin Samad, may have: 

1. Participated directly or indirectly in contracting or subcontracting arrangements relating to projects they are tasked to supervise or oversee; 
2. Maintained business, professional, or personal relationships with contracting entities; 3. Exercised supervisory authority over works in which they may have a financial or indirect interest.

If substantiated, such conduct would constitute a serious conflict of interest, potentially amounting to misconduct in public office and violations of procurement and public service regulations. 

• Allegations of Improper Subcontracting Practices 

It is further alleged that: 

1. Contracts awarded to primary contractors were subcontracted—formally or informally—to third parties, including smaller contractors; 
2. Such subcontracting arrangements may not have been disclosed to or approved by the relevant contracting authority, as required under procurement regulations; 3. The layering of subcontracting arrangements has resulted in reduced accountability, diminished quality control, and potential financial irregularities. 

As such, we believe a full audit is required to determine: 

1. The extent and legality of subcontracting arrangements; 
2. Whether procurement rules governing subcontracting were adhered to; 3. The identities, qualifications, and compliance status of all subcontractors involved. 

. 

• Allegations Concerning Mobilisation Advances and Financial Management There are also credible claims that: 

1. Mobilisation advances in the vicinity of G$500 million were disbursed upfront; 2. There is insufficient transparency regarding the utilisation, accounting, and justification of these funds; 
2. Project execution appears to be lagging behind schedule, raising questions as to whether funds were properly applied to mobilisation and project delivery. 

These matters necessitate a forensic financial audit, including tracing of disbursements, verification of expenditures, and assessment of compliance with contractual payment conditions. 

• Allegations of Systemic Preferential Allocation of Contracts

It has been asserted that: 

1. A limited group of approximately five contractors are consistently and disproportionately awarded contracts across multiple regions, including the East Coast Demerara corridor; 2. Competing contractors have reportedly been excluded from access to opportunities, raising concerns about fairness, competition, and possible collusion; 
2. Contracts continue to be awarded to the same cluster of entities over successive periods without transparent justification. 

Such allegations point to the possibility of bid rigging, collusive practices, or administrative bias, all of which fall squarely within the oversight mandate of the Public Procurement Commission. 

• Allegations of Breaches of Engineering and Construction Standards 

Of grave concern are reports that: 

1. Specified construction standards, including concrete strengths (e.g., 5,500 PSI), are not being adhered to; 
2. Actual works may be executed using substandard materials, including significantly lower PSI concrete mixes; 
3. Mandatory testing protocols, including cube testing, are allegedly not being conducted; 4. Oversight mechanisms appear compromised, particularly where supervising engineers may themselves be conflicted. 

If accurate, such practices would pose serious risks to public safety, infrastructure integrity, and long-term economic loss, and may constitute professional negligence or fraud. 

The cumulative effect of the allegations suggests a breakdown in independent supervision and certification of works; Maintenance and availability of testing records and quality assurance documentation; Clear delineation of roles and responsibilities within the project oversight structure. 

Relief Sought 

In light of the foregoing, we respectfully but firmly request that: 

1. A full-scale, independent forensic audit be commissioned into all contracts associated with the entities and individuals referenced herein;

The audit encompass: 

Procurement processes and contract awards; Corporate ownership and beneficial interest disclosures; Financial disbursements and utilisation of public funds; Subcontracting arrangements; Engineering compliance and quality assurance records; The Public Procurement Commission exercise its constitutional mandate to investigate potential breaches of procurement laws, including unfair or discriminatory practices; The Ministry of Public Works immediately review and, where necessary, suspend ongoing works pending the outcome of investigations; Appropriate disciplinary, civil, or criminal proceedings be initiated where wrongdoing is established. 

The scale, consistency, and seriousness of the allegations warrant nothing short of a thorough, transparent, and independent investigation. 

We trust that your offices will treat this matter with the urgency and seriousness it demands. 

Yours faithfully, 

Francis Bailey 

General Secretary, VPAC 

CC: Mr. Dale Ibbott 

Mr. Kevin Samad 

Ms. Tammy Ibbott 

Mr. Nickesh Pargoo