INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
I.
INTRODUCTION AND SUMMARY
Both Resolution 986 and the Iraq-UN MOU provided for the appointment by the SecretaryGeneral of independent agents to inspect the oil exported from Iraq and the humanitarian goods
entering Iraq. The oil inspections were to occur at the loading facilities for Iraqi oil exports in
Ceyhan, Turkey, and at the Mina al-Bakr offshore terminal in the Persian Gulf, and such
inspections were required to include both “quality and quantity verification.” The inspection of
humanitarian imports was intended to confirm the delivery of the shipments to Iraq and to occur
“at relevant Iraqi entry points, custom areas or other locations” chosen by the United Nations in
consultation with Iraq where defined inspection functions could be performed. Specifically, the
inspection agents were to “compare the appropriate documentation, such as bills of lading, other
shipping documents or cargo manifests, and the documents issued by the 661 Committee, against
goods actually arriving in Iraq.” The inspection agents were permitted “to perform duties
necessary for such confirmation, including: quantity inspection by weight or count, quality
inspection including visual inspection, sampling and, when necessary, laboratory testing.”782
Significantly, the inspections of oil and humanitarian goods were commercial in nature, designed
merely to ensure that oil exports and humanitarian goods imported under the Programme
conformed to contracts approved by the United Nations. There was no provision in Resolution
986 or the Iraq-UN MOU for the Programme’s inspection contractors to interdict or report
smuggling of oil and goods that were not financed under the Programme.
On August 16, 1996, the United Nations awarded the Programme’s oil inspection contract to a
Dutch company, Saybolt Eastern Hemisphere BV (“Saybolt”). On August 23, 1996, it awarded
the humanitarian goods inspection contract to a British firm, Lloyd’s Register Inspection Ltd.
(“Lloyd’s”). In December 1998, the United Nations selected a Swiss company, Cotecna
Inspection S.A. (“Cotecna”), to replace Lloyd’s after the contract was put up again for re-bid.
Cotecna served until the Programme’s end in 2003. Earlier Committee reports reviewed the
circumstances surrounding the selection of these independent inspection agents, and specifically
whether the procurements complied with United Nations regulations, were conducted in a fair and
transparent manner, and were free from improper or illicit influence.783
The Committee has not undertaken a full-scale performance review of all aspects of these
contractors’ activities. Such a review has not been possible because of time and resource
limitations and because, as detailed below, Saybolt has declined to provide timely cooperation.
Where relevant, internal audits conducted by the United Nations Office of Internal Oversight
Services (“OIOS”) are noted. The Committee has focused its efforts on allegations of significant
wrongdoing and, in particular, allegations in the nature of corruption as opposed to instances of
782
S/RES/986, paras. 6, 8(a)(iii) (Apr. 14, 1995); Iraq-UN MOU, paras. 18, 25-28, 31, and Annex II, para.
4.
783
“First Interim Report,” pp. 85-119; “Second Interim Report,” pp. 3-80; “Programme Management
Report,” vol. III, pp. 195-277.
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 463 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
deficient performance. In cases in which allegations have been fully investigated but not
substantiated, the Committee does not recite the nature of these allegations.
Part II of this Chapter reviews Saybolt, with particular attention to the improper conduct of Peter
Boks, then Saybolt’s managing director, in recommending to the Iraqi Minister of Oil an
allocation of oil for a private Dutch company that was a client of Saybolt. Part III reviews the
conduct of Lloyd’s during the first two years of the Programme. Part IV reviews the conduct of
Cotecna during the Programme’s later years, including a brief review of payments made by
Cotecna to Michael Wilson and an official of a United Nations specialized agency, the World
Intellectual Property Organization, shortly after Cotecna obtained its inspection contract with the
United Nations.
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 464 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
II.
SAYBOLT
The objective of the initial contract between the United Nations and Saybolt was the monitoring
of the export of petroleum and petroleum products from Iraq. Specifically, Saybolt was obligated
to provide qualified inspectors to perform this monitoring and report on its results. In addition, in
a contract executed in June 2000, Saybolt was further charged with monitoring of oil spare parts
and the state of the oil infrastructure within Iraq, and to report upon the results of that
monitoring.784
Saybolt has disclosed documents in response to the Committee’s request and has allowed
interviews of some of its senior management. However, it has declined more recently to allow
the Committee to interview its field inspectors and inspection supervisors. According to Saybolt,
it was “not in a position to accommodate the [Committee’s] pending request for interviews with
up to ten current company employees,” because it had “reached the financial limits of its
cooperation.” As a result, the Committee’s investigators were able to interview only two Saybolt
inspectors (who no longer worked for Saybolt). Because the interview of those who conducted
Saybolt’s inspection work is essential to evaluating Saybolt’s performance, Saybolt’s decision to
limit its cooperation has impeded the Committee’s ability to assess the company’s
performance.785
Notwithstanding the limits placed by Saybolt on its cooperation, the Committee has reviewed
extensive documentation produced by Saybolt, documentation created by Saybolt during the
Programme within United Nations records, and an audit by OIOS of OIP’s management of the
Saybolt contract.786
The OIOS audit focused on OIP’s management of the Saybolt contract, taking note as well of
some deficiencies of Saybolt in executing the contract. Specifically, the audit found that OIP had
failed to implement sufficient controls to verify some of Saybolt’s charges, and it identified
instances in which Saybolt overcharged OIP and/or OIP overpaid Saybolt. In addition, the audit
784
UN Contract, PTD/127/0065-96 (Aug. 16, 1996); UN Contract, PD/CO114/00 (June 6, 2000); Peter
Boks interview (Aug. 11, 2005).
785
Saybolt letter to the Committee (May 10, 2005). In assessing Saybolt’s claim of financial distress, the
Committee notes that Saybolt earned in excess of $31 million from its contracts with the Programme.
Accounting entries posted to the Programme accounting ledgers (1997-2003). The Committee interviewed
an inspector who worked for Cotecna but who also used to work for Saybolt; this interview was arranged
without Saybolt’s assistance. Gordon Schoeman interview (May 1, 2005) (former inspector who worked
for Saybolt from January 2001 until March 2003 and who stated his view that Saybolt did a satisfactory job
in monitoring oil exports). The Committee also interviewed former Saybolt inspector Armando Carlos
Costa Oliveira; this interview, as discussed below, was solely with respect to allegations that he accepted a
bribe to allow smuggling of oil from the Mina al-Bakr terminal. Armando Carlos Costa Oliveira interview
(May 14, 2005).
786
OIOS, “Audit of the Management of the Oil Inspection Services Contract,” AF2001/30/6 (July 3, 2002).
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 465 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
noted that OIP did not exercise its contractual prerogative to review and approve candidates for
inspector positions. OIOS made recommendations relating to these issues, many of which OIP
accepted. OIOS did not render findings with regard to the adequacy of the inspections
undertaken by Saybolt, and its findings did not suggest fraud or corruption on the part of Saybolt
management or staff.787
Apart from performance issues raised in the OIOS audit, the Committee’s review of Saybolt
inspection reports does not suggest that Saybolt systematically failed to meet its contractual
obligations; however, this review is of limited value without interviews of the inspectors who
prepared the reports. The Committee is not aware of major complaints by OIP or United Nations
member states about Saybolt’s performance. Nevertheless, although the available evidence does
not suggest pervasive corruption or mismanagement by Saybolt, two highly significant instances
have emerged of improper conduct by Saybolt officials. These are discussed below.
A. BRIBERY OF ARMANDO CARLOS COSTA OLIVEIRA
In May and August 2001, Trafigura Beheer N.V. and Ibex Energy France engaged in a scheme
with the Iraqi Ministry of Oil to “top off” an oil tanker, the T/T Essex, at the Mina al-Bakr
terminal. The “top off” was possible because of a bribe paid by the Ministry of Oil to Saybolt’s
supervising inspector—Armando Carlos Costa Oliveira—to permit loading of oil in excess of
what the United Nations contract allowed. This conduct is fully described in Chapter 2 of this
Report, and Saybolt does not dispute the Committee’s conclusion that Mr. Oliveira accepted a
bribe. The Committee does not have evidence that Mr. Oliveira’s corrupt conduct involved other
employees or management of Saybolt.788
B. REQUEST FOR OIL ALLOCATION BY PETER BOKS
According to oil allocation tables disclosed by SOMO to the Committee, SOMO allocated oil to a
Dutch company, Petroplus International Ltd. (“Petroplus”), upon nomination of Petroplus by
Peter Boks, a senior Saybolt executive. As set forth below, although Mr. Boks initially denied
having recommended Petroplus for an allocation, he later admitted making this request.
Mr. Boks worked as a consultant for Petroplus in 1995, before taking a position with Saybolt in
April 1996 as a business development manager. Soon after he joined Saybolt, he prepared
Saybolt’s successful bid to win the oil inspection contract. In 1999, Mr. Boks became a
managing director of Saybolt and then chief executive officer in 2000. Petroplus was a private
client of Saybolt. Apart from Saybolt’s work for the United Nations under the Programme, it also
787
Ibid.
788
Saybolt letter to the Committee (Oct. 20, 2005).
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 466 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
furnished private commercial inspection services for Petroplus relating to non-Programme
transactions.789
Petroplus first sought to purchase oil from Iraq under the Programme in 1998 when a Petroplus
executive, Aernout Boot, contacted SOMO but did not obtain a response. In December 1999,
SOMO invited Petroplus to visit Baghdad for a meeting. When interviewed, Mr. Boot stated that
he attended a meeting with another Petroplus executive, Nicholas Moriarty. They learned that
Petroplus had been allocated 1.5 million barrels of crude oil for Phase VII. Petroplus executed a
contract, and the oil was lifted. For the next Programme phase, Petroplus once again received
and lifted an allocation of 1.5 million barrels of crude oil. Petroplus received two more
allocations in Programme Phases X and XI but, according to Mr. Boot, did not purchase the oil
because of the advent of SOMO’s oil surcharge requirement.790
SOMO records reflect that Mr. Boks and Saybolt were associated with the award of allocations to
Petroplus. SOMO allocation records identify the Petroplus allocations as a “special request,” and,
for each of the allocations, there is a notation in either the draft and/or final version of the
allocation table linking the allocation to Saybolt or Peter Boks or both.791
For Petroplus’s first allocation, SOMO’s draft allocation list identifies Petroplus as a “Special
Request” and notes: “New request (6) million nominated by Mr. Peter Boks-Saybolt Co.”792
789
Peter Boks interviews (Nov. 2, 2004 and Aug. 11, 2005); Aernout Boot interview (June 1, 2005). Mr.
Boot was hired by Petroplus in 1998 and was responsible principally for business development in the
Middle East. Ibid.
790
Ibid.; Peter Boks interview (Nov. 2, 2004); Nicholas Moriarty interview (May 24, 2005); SOMO sales
contracts, nos. M/07/56 (Dec. 21, 1999), M/08/78 (June 28, 2000). Mr. Moriarty was hired by Petroplus in
the mid-1990s and was its most knowledgeable employee concerning crude oil. Nicholas Moriarty
interview (June 2, 2005).
791
Iraq official interview; SOMO oil allocation tables for Phase VII (Dec. 13 and 17, 1999), Phase VIII
(May 26 and June 1 and 14, 2000) Phase X (Aug. 4, 2001), Phase XI (Dec. 1, 2001) (each translated from
Arabic).
792
SOMO oil allocation tables for Phase VII (Dec. 13, 1999) (translated from Arabic).
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 467 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
50- The Netherlands
1.5
- 0.5%
1.5
- 0.5%
A- Regular requests
New request (6) million
nominated by Mr. Peter
Boks- Saybolt Co.
B- Special Request –
Petroplus
Figure: SOMO oil allocation tables for Phase VII (Dec. 13, 1999) (translated from Arabic) (excerpt).
A later and final version of the allocation table no longer referenced Mr. Boks by name, but
stated: “Mr. Petroplus,” under which there was a handwritten notation: “Saybolt.”793
33- The Netherlands
A- Regular requests
1.5
-
0.5%
1.5
-
0.5%
B- Special Request –
Mr. Petroplus
[handwritten Saybolt]
Figure: SOMO oil allocation tables for Phase VII (Dec. 17, 1999) (translated from Arabic) (excerpt).
Similarly, in each of the listings for the next three allocations to Petroplus, a reference appeared
to Saybolt. The recipient of the allocation given to Petroplus was listed as “*Petroplus/Saybolt,”
and the final listings for the last two allocations referred to “Saybolt,” without any mention of
793
SOMO allocation tables for Phase VII (Dec. 17, 1999) (translated from Arabic).
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 468 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
Petroplus. As one Iraqi official advised the Committee, Ministry of Oil officials considered
Saybolt to be the recipient of the allocations and Petroplus to be lifting the oil for Saybolt.794
When interviewed, Petroplus executives denied that Saybolt or Mr. Boks assisted Petroplus in
obtaining its oil allocations. Mr. Boot and Marcel van Poecke, Petroplus’s Managing Director
who served as its Chief Executive Officer during the relevant time period, suggested that Iraq
made the award to curry favor with the Netherlands in recognition of its political ascendancy
within the European Union and its seat on the Security Council. Mr. van Poecke also credited the
“hard work” of Mr. Boot and Mr. Moriarty. Mr. van Poecke stressed that Petroplus would not
have needed the assistance of an inspection company to obtain oil allocations from Iraq.795
According to Mr. Boot, although he had told Mr. Boks about Petroplus’s interest in purchasing
oil from Iraq, he did not request or receive active assistance from Mr. Boks or anyone else at
Saybolt in establishing contact with SOMO. When asked to explain why Saybolt’s name
appeared on SOMO’s oil allocation list with Petroplus’s allocations, he claimed that it was
because Saybolt permitted Petroplus to use Saybolt’s facilities to relay their communications to
SOMO. Specifically, Petroplus faxed its communications to Saybolt’s facilities in Baghdad, and
a Saybolt staff member passed the documents to the appropriate person within SOMO. Mr. Boot
stated that this arrangement was instituted through his request to Mr. Boks.796
To the same effect, when initially interviewed about the appearance of his name on SOMO’s
allocation table, Mr. Boks suggested that it was because Petroplus forwarded its correspondence
to SOMO through Saybolt’s office in Baghdad. In a later interview, Mr. Boks stated that he had
no knowledge about oil allocations in connection with Saybolt.797
When the Committee re-interviewed Mr. Boks on this issue for a third time, however, he stated
that he met with a SOMO official in December 1999 who asked him if he knew a Dutch company
that was interested in purchasing oil. Mr. Boks named Petroplus. At the same time, he twice
denied discussing Petroplus with Iraqi Oil Minister Amer Rashid, with whom he had met in
Baghdad at that time to discuss the “oil spare parts” program. At that point in the interview, Mr.
Boks was presented for the first time with a version of the SOMO oil allocation list identifying
his name and stating: “New request (6) million nominated by Mr. Peter Boks – Saybolt Co.” Mr.
Boks then admitted that he discussed Petroplus with the Oil Minister after he had first met with a
SOMO official. According to Mr. Boks, the issue of oil allocations was “briefly discussed” when
Mr. Rashid asked Mr. Boks if he knew of “a Dutch company that was interested in oil
allocations”; Mr. Boks then informed him of Petroplus’s interest. Mr. Boks stated that the Oil
794
SOMO oil allocation tables for Phase VIII (May 26 and June 1 and 14, 2000) Phase X (Aug. 4, 2001),
Phase XI (Dec. 1, 2001) (each translated from Arabic); Iraq official interview.
795
Aernout Boot interview (June 1, 2005); Marcel van Poecke interview (June 28, 2005).
796
Aernout Boot interview (June 1, 2005).
797
Peter Boks interviews (Nov. 2, 2004 and Mar. 14, 2005).
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 469 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
Minister instructed him to tell Petroplus to write a “letter of introduction” to SOMO to enable
Petroplus to become an “off-taker.”798
According to Mr. Boks, when he returned to the Netherlands, he spoke with Mr. van Poecke to
advise him that he recommended Petroplus to the Oil Minister for an oil allocation. He suggested
that Mr. van Poecke write a letter to SOMO according to the Oil Minister’s instructions. Mr. van
Poecke said that “it fits Petroplus well to hear that,” and “we are going to pursue this.” Mr. Boks
stated that he later learned from Petroplus that it had signed a contract to buy Iraqi oil; however,
Mr. Boks could not recall whether anyone at Petroplus ever thanked him for his help. He further
stated that Petroplus never sought his assistance for securing its subsequent oil allocations or
obtaining larger oil allocations. Mr. Boks apologized for failing to advise the Committee earlier
of his intercession on Petroplus’ behalf and stated that he was embarrassed that Saybolt’s name
had appeared on the allocation list.799
According to Mr. Boks, he did not derive any financial benefit from his recommendation of
Petroplus. The Committee does not have evidence that he received a financial benefit. Nor does
the Committee have evidence that Mr. Boks compromised the performance of his or Saybolt’s
duties as a result of the allocation that he recommended to the Oil Minister. 800
Nevertheless, Mr. Boks’s assistance to Petroplus posed a serious conflict of interest with respect
to his obligations to the United Nations. He was in a position to exercise significant influence
over Iraq’s oil exports and production in his capacity as a senior executive of the sole company
charged with monitoring exports of oil and imports of equipment for Iraq’s oil infrastructure.
Saybolt’s contract with the United Nations required that its employees perform their obligations
“in accordance with the highest professional standards” and “conform to the highest standards of
moral and ethical conduct.”801 By seeking from the Government of Iraq a financial benefit for a
798
Peter Boks interview (Aug. 11, 2005). An Iraqi official with knowledge of the oil allocation process has
separately advised the Committee that the allocation for Petroplus came about after a meeting between Oil
Minister Rashid and Mr. Boks. Iraq official interview. By contrast, former Oil Minister Rashid has
acknowledged meeting with Mr. Boks but could not confirm that Mr. Boks asked him for an oil allocation;
and he had no knowledge of “a connection” between Saybolt and Petroplus. Amer Rashid interview (Oct.
29, 2004).
799
Peter Boks interview (Aug. 11, 2005).
800
Ibid. The Committee has reviewed financial records produced by Petroplus and found no evidence to
suggest that Mr. Boks received payment from Petroplus for his recommendation. Committee note-to-file
(Oct. 12, 2005). In August 2005, the Committee made a request to legal counsel for Mr. Boks that Mr.
Boks produce his personal bank records. There was no definitive response to this request until October 14,
2005, when Mr. Boks’s legal counsel offered for the first time to produce these records. Because of the
delay in this response, the Committee declined this offer because it would not be possible to review the
records and conduct any follow-up investigation necessitated by that review in time for presentation in this
Report. Committee note-to-file (Oct. 17, 2005).
801
UN Contract, PTD/127/0065-96, paras. 4.4, 5.3 (Aug. 18, 1996); UN Contract, PD/CO114/00, paras.
3.6, 4.3 (June 6, 2000).
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 470 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
Saybolt client, Mr. Boks effectively indebted himself to the Government of Iraq, thereby
compromising his and Saybolt’s position of independence and integrity in carrying out its oil
inspection functions on behalf of the United Nations.
In addition, Mr. Boks was not forthright when interviewed by Committee investigators. Nor was
Mr. van Poecke forthright when he denied intercession by Saybolt or Mr. Boks in his company’s
favor. Mr. van Poecke’s version of events is inconsistent with Mr. Boks’s admission that he
spoke directly to Mr. van Poecke about his conversation with the Oil Minister. Although Mr.
Boot also denied intercession by Saybolt in Petroplus’s favor, there is no evidence that he spoke
to Mr. Boks about this matter.
After being apprised of the Committee’s anticipated findings, Saybolt submitted a letter (attached
as an Annex to this Chapter of the Report) that sets forth Saybolt’s reasons for declining to allow
the interview of its inspectors. These reasons are unconvincing, especially in light of the fact that
Saybolt does not contest that one of its inspectors corruptly took part in an illegal “top off”
scheme. Nor has Saybolt demonstrated that it was not a conflict of interest and abuse of Mr.
Boks’s position as a Saybolt executive for him to assist Petroplus in obtaining oil from the
Government of Iraq. Moreover, the Committee’s investigative records do not support Saybolt’s
claim that Mr. Boks was at all times accurate and truthful to the Committee with respect to his
intercession on Petroplus’s behalf.802
After being apprised of the Committee’s anticipated findings, Mr. van Poecke and Mr. Boot,
through counsel, appeared before the Committee and argued that they had no recollection of
conversations with Mr. Boks on the issue of his recommendation of Petroplus to the Ministry of
Oil. They conceded, however, that they received their oil allocations only after Mr. Boks
suggested to them that they should seek to purchase oil from SOMO because the political climate
had changed to favor a Dutch company. However, as described above, Mr. Boks told Committee
investigators that he had informed Mr. van Poecke of his meeting with Oil Minister Rashid, and it
is most plausible to believe that he would have taken the opportunity to advise a Saybolt client of
the potential benefit that he secured.803
802
Saybolt letter to the Committee (Oct. 20, 2005).
803
Committee meeting with Marcel Van Poecke and Aernout Boot (Oct. 24, 2005).
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 471 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
III. LLOYD’S
On August 30, 1996, Lloyd’s signed its initial contract under the Programme. That contract was
extended several times through January 1999. By the terms of the contract and its extensions,
Lloyd’s was required to provide personnel who would confirm the importation of humanitarian
goods into Iraq. Specifically, Lloyd’s agents were to compare the appropriate documentation,
including bills of lading, other shipping documents, or cargo manifests, and the documents issued
by the 661 Committee, against the goods actually arriving in Iraq. In doing this comparison,
Lloyd’s was to conduct both a quantity and quality inspection, which would include not only a
visual inspection, but also sampling and laboratory testing, when necessary. If the inspected
shipment was in order, Lloyd’s agents would indicate their confirmation of the goods’ arrival on a
copy of the 661 Committee’s letter, as well as on a copy of the invoice, and would notify the
Secretary-General of the confirmation. Based upon this confirmation, the United Nations would
pay the supplier. The contract did not obligate Lloyd’s to examine or report with reference to
smuggled goods (i.e., those imported outside of the Programme).804
The Committee has conducted a limited review of the performance of Lloyd’s. This has included
the review of United Nations and Lloyd’s documentation relating to the inspections, interviews of
former inspectors, and the review of an OIOS audit of OIP’s management of the contract with
Lloyd’s. Preliminarily, the Committee notes that during the course of the Programme, there were
no major complaints by the United Nations or its member states about the performance of Lloyd’s
or requests that its services be terminated for deficient performance. Many of the former
inspectors who were interviewed expressed frustration regarding some impediments encountered
in performing their duties. These included understaffing, lack of necessary technical expertise,
lack of necessary equipment, and lack of independence from OIP. Moreover, several inspectors
noted that smuggling was widespread and that they were not mandated to take any action with
regard to it.805
The OIOS audit of OIP’s handling of the Lloyd’s contract, as did its audit relating to the Saybolt
contract, mainly focused on administrative issues such as staffing irregularities, deficiencies in
the renegotiation of contract renewals, and OIP’s failure to ensure that Lloyd’s invoices were
based on sufficient documentation which possibly resulted in instances of overcharging. The
audit did note several instances of what it described as “deficiencies in the contractor’s
804
“First Interim Report,” p. 16; “Programme Management Report,” vol. III, pp. 27-28; UN Contract,
PTD/127/0085-96 (Aug. 30, 1996).
805
Zeljko Kalincevic interviews (May 4 and June 13, 2005); Milan Radenovic interview (May 12, 2005);
Carlo de Hennin interviews (May 10 and Oct. 6, 2005); Goran Ciric interview (May 3, 2005); Jean Azouri
interview (Oct. 3, 2005); Howard Earnshaw interview (Oct. 14, 2004); Russ Kemp interview (Oct. 13,
2004); Warwick Preston interview (June 13, 2005). Several of the interviewed inspectors worked for both
Lloyd’s and Cotecna and, in general, they did not distinguish between the two companies when relating
their observations concerning these impediments. Zeljko Kalincevic interviews (May 4 and June 13,
2005); Milan Radenovic interview (May 12, 2005); Carlo de Hennin interviews (May 10 and Oct. 6, 2005);
Goran Ciric interview (May 3, 2005); Jean Azouri interview (Oct. 3, 2005).
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 472 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
performance,” which included lack of independent verification of bulk cargo, lack of independent
testing of medicines and vaccines, and inordinate delays in obtaining the results of samples that
were taken. The audit did not describe these problems as pervasive, nor did it make any findings
of fraud or corruption relating to Lloyd’s and its execution of the inspection contract.806
In short, the Committee’s limited review has not determined that Lloyd’s systematically failed to
comply with its contract with the United Nations. Nor has this review disclosed corruption or
fraud committed by Lloyd’s or its employees.
806
OIOS, “Report on a Contract for the Supply of Inspection Agents in Iraq under the Oil for Food
Programme,” AP1998/17 (July 21, 1999).
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 473 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
IV.
COTECNA
Cotecna’s responsibilities under its contract with the United Nations corresponded with those
contained in the Lloyd’s contract. Like Lloyd’s, Cotecna was to provide a commercial inspection
designed merely to confirm the receipt of items.807 Section A discusses the Committee’s review
of Cotecna’s contract performance. Section B reviews two additional matters concerning
Cotecna, for which the Committee recommends further inquiry by OIOS.
A. CONTRACT PERFORMANCE
The Committee has conducted a limited review of Cotecna’s performance pursuant to its contract
with the United Nations. In this regard, Committee investigators have reviewed Cotecna and
United Nations documents relating to the inspection of humanitarian goods, including forty-eight
volumes of “chron” files maintained at Cotecna’s headquarters as well as seventy-one boxes of
documents that Cotecna made available for review. In addition, Committee investigators have
interviewed nine persons who worked as Cotecna inspectors during the Programme and reviewed
an OIOS audit report regarding OIP’s management of the Cotecna contract. As was the case with
Saybolt and Lloyd’s, during the course of the Programme, there were no major complaints by the
United Nations or its member states about Cotecna’s performance or requests that its services be
terminated for deficient performance.808
The interviewed inspectors, some of whom had worked also for Lloyd’s, complained of various
impediments to the performance of their duties, such as faulty equipment, insufficient staffing,
and lack of independence from OIP. In addition, some inspectors also reported their frustration
that they were not mandated to address what they stated were very obvious instances of
smuggling.809
807
UN Contract, PD/CON/324/98 (Dec. 31, 1998).
808
Zeljko Kalincevic interview (May 4, 2005); Hamid Araie interview (May 10, 2005); Milan Radenovic
(May 12, 2005); Emil Valasuteanu interview (May 6, 2005); Gordon Schoeman interview (May 1, 2005);
Carlo de Hennin interviews (May 10 and Oct. 6, 2005); Goran Ciric interview (May 3, 2005); Jean Azouri
interview (Oct. 3, 2005), Arthur Ventham interview (Sept. 22, 2005); OIOS, “Management of the Contract
for the Provision for Independent Inspection Agents in Iraq,” AF2002/23/1 (Apr. 8, 2003).
809
Zeljko Kalincevic interview (May 4, 2005); Hamid Araie interview (May 10, 2005); Milan Radenovic
(May 12, 2005); Emil Valasuteanu interview (May 6, 2005); Gordon Schoeman interview (May 1, 2005);
Carlo de Hennin interviews (May 10 and Oct. 6, 2005); Goran Ciric interview (May 3, 2005); Jean Azouri
interview (Oct. 3, 2005); Arthur Ventham interview (Sept. 22, 2005). When interviewed, Jean Azouri, who
worked as an inspector for both Lloyd’s and Cotecna, stated that OIP made the ultimate decisions
concerning the authentication of humanitarian goods under the Programme. Jean Azouri interview (Oct. 3,
2005).
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 474 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
One former Cotecna inspector, Arthur Ventham, testified before the United States Senate
Permanent Subcommittee on Investigations. In his testimony, Mr. Ventham opined that Cotecna
was not performing adequately its function under the contract and did not conform to the best
practices in the industry. He testified that Cotecna was badly managed; did not provide adequate
training to inspectors; and did not have a performance management or appraisal system. He also
complained that Cotecna management was unwilling to listen to others—even if more
knowledgeable and experienced—and that some of the team leaders were not performing their
duties. He stated that it was common knowledge that smuggling was occurring, but that the
United Nations did nothing to counteract it. When interviewed, Mr. Ventham reiterated similar
complaints—though he noted that he was unaware of any instance in which a Cotecna inspector
received or was offered a bribe.810
The OIOS audit focused mainly on administrative issues, such as staffing being below what was
required by the contract, the amending of the contract to include additional costs prior to the start
of services, the increasing of costs during the contract, OIP’s failure to assess the economic
benefits of different methods of determining contract costs, and OIP’s failure adequately to verify
Cotecna’s attendance records. The audit did not report any deficiencies in Cotecna’s inspections,
and it did not report on instances of fraud or corruption.811
In short, the Committee’s limited review has not determined that Cotecna systematically failed to
comply with its contract with the United Nations. Nor has the review disclosed pervasive
corruption or fraud committed by Cotecna or its employees with respect to Cotecna’s provision of
inspection services under the contract.
B. REVIEW OF ADDITIONAL ALLEGATIONS
The Committee has also conducted a review but without reaching a conclusion concerning two
additional circumstances involving activities of Cotecna. The Committee recommends that these
matters be the subject of further review by OIOS.
1. Tugboat Authentication
During its review of Cotecna’s performance, the Committee initiated a review of the
circumstances surrounding Cotecna’s decision to authenticate the arrival of two tug boats, worth
in excess of seven million dollars, that were claimed to have been delivered several days before
the invasion of Iraq in March 2003. Due to time and resource limitations, that review has not
been completed. Based on the information received and Cotecna's response to this information,
the Committee does not reach a conclusion concerning the adequacy of authentication.
810
Arthur Ventham statement to the United States Senate, Permanent Subcommittee on Investigations
(Feb. 17, 2005); Arthur Ventham interview (Sept. 22, 2005).
811
OIOS, “Management of the Contract for the Provision for Independent Inspection Agents in Iraq,”
AF2002/23/1 (Apr. 8, 2003).
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 475 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
Therefore, the Committee will forward the information it has collected concerning this matter to
OIOS for further consideration.
Cotecna has submitted a letter (attached as an Appendix to this Chapter of the Report) defending
its decision to authenticate the tug boats. The Committee is aware of additional information not
discussed in Cotecna’s letter and will forward this letter and the additional information to OIOS.
Cotecna’s letter also sets forth its position that the payments to two bank accounts, as discussed
below, were not related to Cotecna’s selection by the United Nations as an inspection contractor
for the Programme.812
2. Concurrent Payments to Michael Wilson and WIPO Official
During its investigation into Cotecna’s selection as the inspection contractor for the Programme,
the Committee identified two identical transfers of $135,000 which Cotecna, through a related
business entity, Cotecna International Ltd., made on March 3, 1999 to two accounts held at the
Mees Pierson Bank in Geneva, Switzerland. As described below, one of the accounts was
controlled by a senior official of a United Nations specialized agency; the other was controlled by
Michael Wilson, a Cotecna executive with close ties to Kojo Annan. A portion of these funds
was disbursed two years later from Mr. Wilson’s account to another account for the apparent
benefit of Kojo Annan.813
The first account was held in the name of Prazino Technologies Inc. (“the Prazino account”) and
listed Khamis Suedi, who at the time was the Director, Office of Strategic Planning & Policy
Development in the World Intellectual Property Organization (“WIPO”), a United Nations
specialized agency, as its sole owner and signatory.814 The second account was held in the name
of Kynaston Worldwide Ltd. (“the Kynaston account”) and listed Michael Wilson as its sole
812
Cotecna letter to the Committee (Oct. 18, 2005).
813
Mees Pierson Bank record, Kynaston Worldwide Ltd. corporate account, account opening contract and
credit and debit advices (1998-2001); Mees Pierson Bank record, Prazino Technologies Inc. corporate
account, account opening contract and credit advices (1998-2001); WIPO Human Resources e-mail to the
Committee (Oct. 20, 2005). There was a $25 bank fee associated with each of the $135,000 transfers. As a
result, each account was credited only $134,975 for the transaction. Mees Pierson Bank record, Kynaston
Worldwide Ltd. corporate account, credit advice (Mar. 3, 1999); Mees Pierson Bank record, Prazino
Technologies Inc. corporate account, credit advice (Mar. 3, 1999).
814
Mees Pierson Bank record, Prazino Technologies Inc. corporate account, account opening contract;
WIPO record, Khamis J. Suedi curriculum vitae (included as an attachment to “WIPO Coordination
Meeting, Fiftieth (17th Extraordinary) Session, Geneva, September 2 and 3, 2003”); WIPO organizational
chart (July 2004); WIPO, Press Release PR/2003/352, “Member States Approve Appointment of Top
Management Team” (Sept. 3, 2003), http://www.wipo.int/wilma/pressinfo-en/200309/msg00000.html.
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 476 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
owner and signatory. The Prazino and Kynaston accounts were both opened on December 9,
1998, and an initial deposit of $5,000 was made into each account on January 29, 1999.815
A review of the Prazino and Kynaston accounts reflects that, from 1999 through 2001, there were
substantial deposits to both accounts from various corporate entities, including some that
provided services to WIPO in connection with a renovation of its headquarters in Geneva.
During this same time period, there was a substantial flow of funds from the Kynaston account to
the Prazino account. Also, on May 23, 2001—more than two years after Cotecna’s initial
payment of $135,000—CHF20,000 were wired from the Kynaston account to another account in
the name of Vevey Sport, with a description: “Vevey Sport, Attn R. Frey, for the benefit of Mr.
Annan.” Vevey Sport is an entity in which Kojo Annan had invested funds.816
Cotecna has informed the Committee that its two payments of $135,000 had no relationship to the
Programme or it bids for the Programme inspection contract. Rather, according to Cotecna, the
payments constituted a “success fee” paid to Abdallah Suedi, whom Cotecna identified as a
consultant and “former ambassador of Tanzania,” for assisting Cotecna in obtaining an inspection
contract with the Government of Tanzania. Cotecna stated that it was introduced to Abdallah
Suedi and Khamis Suedi by Mr. Wilson who had told Cotecna that it would need their assistance
to win the contract with the Government of Tanzania. It is unclear what relationship there is
between Abdallah Suedi and Khamis Suedi. Cotecna signed a contract with the Government of
Tanzania on January 15, 1999 to provide pre-shipment inspection services. Cotecna provided
Committee investigators with certain information in support of this explanation and the
circumstances under which the deposits were made, but said that there was no written agreement
concerning the payment of the success fees. According to Cotecna, Mr. Wilson stated that
Abdallah Suedi should receive the entire “success fee” because he had done all the work to obtain
the contract and that Abdallah Suedi wanted the payment to be made into the two Mees Pierson
accounts.817
815
Mees Pierson Bank record, Kynaston Worldwide Ltd. corporate account, account opening contract and
credit advices (Jan. 1999); Mees Pierson Bank record, Prazino Technologies Inc. corporate account,
account opening contract and credit advices (Jan. 1999); WIPO Human Resources e-mail to the Committee
(Oct. 20, 2005). Mr. Wilson’s status as a Cotecna executive and his role in obtaining the humanitarian
goods inspection contract was the subject of previous Committee reports. “Second Interim Report,” pp. 380; “Programme Management Report,” vol. III, pp. 195-277.
816
Mees Pierson Bank record, Kynaston Worldwide Ltd. corporate account, credit and debit advices (19992001); Mees Pierson Bank record, Prazino Technologies Inc. corporate account, credit advices (19992001); Ralph Isenneger interview (Mar. 4, 2005); see “Second Interim Report,” p. 68. Mr. Isenegger is an
attorney who has represented Kojo Annan with regard to several matters since meeting him in 1999. Both
Mr. Isenneger and Kojo Annan invested money in Vevey Sport, a junior football team. Ralph Isenneger
interview (March 4, 2005).
817
Cotecna letter to the Committee (Oct. 6, 2005); Cotecna press release (Jan. 18, 1999) (announcing the
signing of the contract); Committee meeting with Cotecna (Oct. 18, 2005).
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 477 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
Mr. Wilson was asked about the Cotecna payment to the Kynaston account. He confirmed his
receipt of these funds and said that the funds could have involved other Cotecna contracts. Mr.
Wilson added that he could not remember more about the transaction. When asked about the
Prazino account, he stated that he had “done business with that company.” Mr. Wilson said that
he could not answer questions about the $135,000 deposit into the Prazino account and suggested
that the Committee speak to Cotecna or Prazino, also noting that these questions were “outside
the scope of the [Committee].”818
The Committee has been unable to locate Khamis or Abdallah Suedi. According to a lawyer for
WIPO, however, Khamis Suedi informed WIPO officials that he had received CHF325,000 from
Michael Wilson. Khamis Suedi claimed that the receipt of these funds was not improper because
it involved a private business venture regarding some hotels in Tanzania for which he had
received verbal permission from the WIPO Director-General (who is now deceased). Although
WIPO conducted an internal evaluation of the procurement process for its headquarters
renovation, it did not make a finding concerning the activities of Khamis Suedi.819
Based on the available evidence, the Committee cannot conclude that the payments by Cotecna to
the Kynaston and Prazino accounts related to Cotecna’s inspection contract under the
Programme, and it can draw no conclusions about the other transactions noted herein.
Accordingly, the Committee will refer the information it has collected to the appropriate
investigative authorities and recommends that WIPO obtain the investigative assistance of OIOS
concerning this matter. pter Five. Chapter Five.
818
Michael Wilson interview (Sept. 5, 2005).
819
Edward Kwakwa interviews (Oct. 11 and 13-14, 2005); WIPO, “Approve Appointment of Top
Management Team” (Sept. 3, 2003), http://www.wipo.int/wilma/pressinfo-en/200309/msg00000.html; see
also WIPO record, Khamis J. Suedi curriculum vitae (included as an attachment to “WIPO Coordination
Meeting, Fiftieth (17th Extraordinary) Session, Geneva, September 2 and 3, 2003”). Mr. Kwakwa is
WIPO’s legal counsel. Edward Kwakwa interviews (Oct. 11 and 13-14, 2005).
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 478 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
V.
RESPONSES OF INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 479 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
A. RESPONSE OF COTECNA SA
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 480 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 481 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 482 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 483 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 484 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 485 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 486 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 487 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 488 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 489 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 490 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 491 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
B. RESPONSE OF SAYBOLT INTERNATIONAL B.V.
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 492 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 493 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 494 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 495 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 496 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 497 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 498 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 499 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 500 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 501 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 502 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 503 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 504 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 505 OF 623
INDEPENDENT INQUIRY COMMITTEE INTO THE UNITED NATIONS OIL-FOR-FOOD PROGRAMME
REPORT ON PROGRAMME MANIPULATION
CHAPTER FIVE
THE INSPECTION COMPANIES
This page is intentionally left blank
REPORT ON PROGRAMME MANIPULATION–OCTOBER 27, 2005
PAGE 506 OF 623