Split Contracts at a Regional Education Directorate

The scheme is contract splitting to avoid the XOF 10 million tender threshold, likely combined with bid rigging or supplier collusion. Red flags: 28 purchase orders all between XOF 8.6 million and 9.8 million, just under the threshold; three suppliers sharing a phone number and bank branch; one supplier registered 14 months earlier with XOF 100,000 capital; delivery receipts for nine orders signed by the same storekeeper on the same date although orders were six weeks apart; the procurement officer prepared all three quotes; and no tender was held. The near-threshold clustering is the strongest indicator because it is statistically unlikely if needs were genuine and independent. Shared contact details and a thinly capitalized new supplier suggest the companies may not compete. The same-date delivery receipts suggest falsified delivery evidence. This is not merely poor paperwork; it is a procurement fraud scheme with a concealment layer. The examiner should treat the directorate files as the primary evidence and avoid alerting suppliers before preserving records.

Run threshold-clustering analysis: plot purchase-order amounts and count how many fall within 5% to 15% below XOF 10 million. Compare with prior years and other directorates. Test supplier concentration, shared addresses, phones, bank accounts, and directors. Check incorporation dates and capital against contract size. Sequence purchase orders and invoices for gaps and duplicate numbers. Compare delivery dates, receipt signatures, and storekeeper handwriting. Price-test furniture against market quotes or other regions. Calculate the total value of split contracts and identify any payments for undelivered goods by visiting schools or requesting photos and inventory. Interview the storekeeper and school directors, not only the procurement officer. Quantify potential loss as the amount above fair market price plus payments for undelivered items, not the entire contract value unless nothing was delivered. Document tests and keep a reproducible workbook, because the auditor general may review it.

The root cause is a threshold that can be gamed and a procurement officer who controls requisition, quotes, and documentation. Priority: require aggregation of annual demand and prohibit splitting; any requirement likely to exceed XOF 10 million in a year must go to tender regardless of how it is phased. Then: separate requisition, quotation, approval, and receipt functions; use a supplier registry with beneficial-ownership disclosure and cross-checks for shared phones and addresses; rotate procurement staff; independently verify delivery by a second officer or school director; publish awards; and monitor near-threshold amounts monthly. The directorate should also keep a centralized contract register and use data analytics to flag amounts just below the threshold. Prevention must be supported by a whistleblower channel and consequences, because the officer explanation that he helped suppliers is itself a control red flag. The auditor general review should be treated as an opportunity to show corrective action, not concealed.