Absence of Past Misconduct and Significant Loss Sample Clauses

Absence of Past Misconduct and Significant Loss. 61. The Respondent puts forward the absence of past misconduct and the fact that there have been no significant losses caused to WCOS and to the Bank Group by the mistakes and the fact that the Respondent has no prior history of Sanctionable Practices. In a recent decision17, the Sanctions Appeals Board held that the absence of harm to the project is not a ground for mitigation, but a neutral fact. This is also true for the absence of past 16 Exhibit SG8 – Employment termination letter 17 SAB decision 7 at para 85 misconduct. The World Bank Sanctions Board has repeatedly held that, while a record of past Sanctionable misconduct may merit treatment as an aggravating factor; its absence is considered a neutral fact18. Therefore, the Sanctions Appeals Board declines to apply any mitigating credit on this basis.
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