Inside how Pula Consultants defrauds government
Pula Consultants have been fingered in an elaborate scheme that has been defrauding the government using personnel who were rejected as non-qualified.
Pula Consultants - a company awarded the Mmankgodi-Tloaneng-Gabane Link Road tender for direct procurement of engineering design services have been claiming for staffing personnel that were non-compliant.
So far, about P1, 162,000.00 has been paid to the consultant, who is yet to refund the government. It is said that the Director of Technical Services, Kaboyamodimo Raitoko, in the Ministry of Water and Human Settlement, has been aware of these fraudulent activities by the Pula Consultants, but he turned a blind eye until his juniors forced him to act.
They also advised that Pula Consultants be reported to the relevant authorities, but that has not happened.
Pula Consultants Director, Carthage Matlhaga, has not reimbursed the government the funds he obtained fraudulently. These fraudulent activities committed by Pula Consultants are contained in a letter signed by Raitoko, dated June 13, 2025, which is said to have been backdated, addressed to the Director of Pula Consultants, Carthage Matlhaga, regarding Tender Reference No.
POU/MLWA/PMO/Direct Procurement of Engineering Design Services For Mmankgodi-Tloaneng-Gabane Link Road/0205/21052024.
This was apparently about Matlhaga's correspondence dated June 2, 2025, and the meeting held between the employer, the Ministry of Water and Human Settlement, and Matlhaga on the same date.
'The employer has noted that four of your staff members have been inadvertently included in your current Tax Invoice Certificate No.12,' Raitoko wrote.
Raitoko said Agang Raphapha was proposed as a replacement by Pula Consultants to the employer on November 11, 2024. The employer was then informed on February 6, 2025, that Raphapha had resigned with immediate effect.
'Your office then proposed Mr Boitshwarelo Nkile as a replacement Quantity Surveyor/Measurement Engineer.
The employer reviewed your submission and subsequently responded on the 19th March with letter Ref DTS 11/4/63 II (46) that the proposed replacement does not meet the contract requirements.
The employer has noted that despite this non-compliance, the consultant has claimed the remuneration amounts for the Quantity Surveyor/Measurement Engineer (Mr B. Nkile) for four months totalling P520, 000.00.
Raitoko then listed four tax invoice certificates, No. 09 from February 2025 with the amount of P130,000.00, until tax invoice certificate No. 12 of May 2025. Each of the four tax invoice certificates costs P130,000.00.
'On the 12th March 2025, the employer was informed by your office, by letter of Ref PC/99191/DTS/gk/040-2025, that Mr Tlhabanelo Mapuland, the Soils/Materials Engineer, has resigned and was serving one month's notice effective from 1st March 2025 to 31st March 2025.
Your office then proposed Mr Tefo Kgabo as a replacement Soils/Materials Engineer. The employer reviewed your submission and subsequently responded on the 19th March 2025, with letter of Red DTS 11/4/63 II (46), that the proposed replacement does not meet the contract requirements,' Raitoko said.
Despite this non-compliance, the employer has, however, noted that the consultant has claimed the remuneration amounts for Soils/Materials Engineer (Kgabo) for April and May, totalling P280,000.00.
In another correspondence submitted by Matlhaga on March 12, 2025, the Department of Technical Services was informed that Tefo Kgabo is on a six-month contract as a project planner ending on April 30, 2025.
'The employer has noted that the consultant has claimed the remuneration amounts from the Project Planner (Mr T. Kgabo) for the month of May for amount P125,000.00.'
During the June 2, 2025, meeting, the employer was informed that the Surveyor David Kealeboga had been missing since March 2025.
'The employer notes that your office continued to bill for this service for the months of March, April, and May, totalling P237,000.00,' Raitoko said.
Each invoice certificate from No. 10 of March, amounting to P79,000.00 until the last tax invoice certificate No. 12 of May 2025, was tabulated in the correspondence.
Raitoko further highlighted that the aforementioned personnel are resourced (rent, utilities, etc) by the project through the construction contract.
'Despite the consultant's non-compliance, the employer is incurring monthly costs for resourcing these personnel.
The employer would like to caution your office that the employer intends to recover these incurred costs from Pula Consultants (PTY) Ltd.'
Interestingly, in his response to the Botswana Guardian questionnaire, Raitoko did not see actions of Pula Consultants as fraud, and he even understated the amount paid to the consultant.
'I am aware that the consultant did put up a staff claim that he used at site; however, it will be misleading to state that staff were non-existent.
I would like to state that the consultant submitted staff that was compliant to the Tender Document, and in the process, they left work for greener pastures. Then consultant proposed replacement staff in line with the set procedure.
I should hasten to state that the proposed staff did not meet the requirements of the “ITT” and a recommendation for rejection was forwarded to the Ministry for adjudication.
Meanwhile, the consultant was contractually notified in writing that his proposed staff does not meet the specification and has been forwarded to the Accounting Officer for decision-making.
While still waiting for response, the consultant used his proposed replacement staff supported from head office,' Raitoko said.
Asked about how much had been misappropriated from this project, he said he did not agree that there was misappropriation since action was taken immediately.
'I became aware that the interim payment certificate was claiming for staff that was not approved. I should state that the consultant claimed for a couple of months since there were difficulties with regards to transfer of funds from Ministry of Infrastructure to Ministry of Water and Human Settlement. The amount involved cumulatively amounts to P688,000.00'.
'In my view, I do not consider this to be fraud, especially that when I became aware, I right away notified the consultant in writing that the payment will be recovered in their next payment certificate.
Since this is an interim payment, it is always corrected in the next IPC, of which the consultant has been notified accordingly that he should reimburse the government accordingly.'
Raitoko denied that he turned a blind eye to the turn of events as alleged, saying the moment he became aware, he straight away issued the consultant with notice as per the contract to recover the due amount.
'The consultant is expected to reimburse Government without fail in the next payment certificate since the project is still ongoing.'
He added that as part of contract management, immediately he recognised the overpayment, he informed the affected party of his observation and caused him to regularise the anomaly.
'The matter had not yet reached the level which needs escalation because I need to act as per the contract and escalate if the matter is beyond my control.'
He denied any involvement in any fraudulent activities. Matlhaga has not responded to enquiries sent last week.