Keywords

For those with responsibility for delivering results in organisations, or for units inside organisations, corruption is just one issue among many they may face. Leaders must decide how their organisation can deal with corruption issues where they impact results, identify where they come across them and then take action. To do this, and especially to build a working environment which is effective at limiting corruption opportunities, requires systems and processes just like other management tasks. In other words, corruption is a management issue as much as, or more than, a political issue.

This is NOT how corruption is seen by most governments and businesses today. This matters because management accountability is the default way of making change inside organisations. It may be true that the corruption in question is also a governance issue, and/or a criminal issue, and/or a financial guardianship issue, and/or a political issue, but such framings do not lead easily to action. On the contrary, they can be easily and deliberately misconstrued in ways that lead to impressions of action rather than to substantive change.

An analogy with safety at work is instructive. Fifty years ago, safety was a ‘slogan’ issue for management—you would hear CEOs stating loudly how deeply they cared about safety, whilst not having the systems and processes in place that could prevent accidents and instil safe practices. Those CEOs sounded impressive, and indeed were often sincere, but the words were almost entirely empty of content because there was no management machinery to put that commitment into action. Nowadays safety management is very different. Safety and accidents are well recognised and quantified risk factors. Safety training is part of the professional competence of all staff, from top leaders to field staff. Besides general safety competence of all staff, there are specialist safety groups for the more technical safety issues. This is a model that can be followed.

Relevant Management Systems

There are several management systems and processes relevant to managing corruption risk in organisations.

Training and Education

The first is training and education of professional staff, so that they know about corruption risks in the same way that they know about health risks, safety risks and environmental risks. These risks are relevant to all professions: you can expect a construction engineer to be well versed in health, safety and environment risks related to construction even if they are not central to construction engineering. It is the same with doctors, with water engineers and indeed with most industries.

Few sectors yet have systematically institutionalised education on corruption risks in the same way as can be found in the health or safety or environment sectors, so in practice, responsible organisations organise in-house training or facilitate training by their staff using the support of professional training organisations. Such organisations have a whole series of anti-bribery training courses available, plus more specialised ones, for example for the legal sector. One such international training organisation is the U4 Anti-corruption Resource Centre (U4) that runs multiple training courses. At the time of writing (September 2023), these include courses on Anti-Corruption Basics, Corruption in the Justice Sector (3 weeks), Addressing corruption in the natural resource sector (4 weeks), Addressing corruption in the health sector (4 weeks), Corruption risk management (2 weeks), Essentials of Anti-Corruption: Development Programming (4 weeks). Many of the courses are available in languages besides English, such as Spanish and Arabic.

Monitoring and Compliance

The second block of relevant management processes is the monitoring capabilities of the organisation: compliance processes, supervision units, internal and external audit processes, together with specialist investigative capabilities. One good public-private sector example of such capabilities is the Global Fund in the health sector (Pyman 2020), which has a risk assessment team, a fraud and corruption investigation team, and a global ethics team, all at or reporting to Board level. Board risks are listed as in-country supply chain risks, programme quality risks, strategic data quality risks, grant-related fraud and fiduciary risks, procurement risks, accounting and financial reporting risks, grant oversight and compliance risks, quality of health products risk and foreign exchange risks. The Global Fund has a substantive policy to combat fraud and corruption, first elaborated in 2017, and has developed a clear set of responsibilities between the different monitoring entities (see Global Fund 2017; Pyman 2020).

A good public sector example is in the Polish military in the defence sector (Wnuk 2008), where they set up a semi-separate unit within the military with the specific job of monitoring all procurement for corruption risk (see box below).

Example

Defence sector—Poland

At a time when it was recognised that there was considerable corruption within the Polish military and defence forces, the Polish Ministry of Defence (MoD) team identified eight high-risk corruption areas: defence procurement, R&D projects, development projects, disposal of surplus property, conscript procedures, lack of meritocracy in appointments and promotions, and defence investments. The ministry decided to focus on just one aspect of one problem: bribery involving top officials in high-value defence procurements. The chosen solution was a preventive monitoring reform measure, in which the minister established a small but full-time task force of four people inside the MoD with the remit to review and reject tenders and technical specifications where there was a suspicion of bias. This was a low-profile reform, but with a chance of success because the defence minister was supportive of greater integrity as one way of improving the reputation of Polish defence forces in NATO. The reform was largely successful, and the task force has been an established feature of the MoD for more than ten years (see Wnuk 2008; Pyman 2023).

Information and Communication Systems

The manner in which organisations—both private and public—manage information and communicate with their customers and with citizens can have an impact on corruption, in both a positive and a negative way. Encouraging feedback systems can also help to highlight issues as well as close loops. Citizens, through feedback and engagement, can help improve performance in a sector; they can also support implementation and sustainability of the reforms and changes needed.

Specialist Expertise Group In-house

Whilst corruption, in general, is a risk factor within the responsibility of a line manager or director, there needs to be a source of specialist expertise for the trickier issues. In the same way that a corporation may have a specialist environmental group that can advise line managers on environmental matters, the same is also true of corruption concerns. There are all sorts of possible names for such a group. It might be called an ‘Integrity Unit’. In police forces, it is sometimes called ‘Internal Affairs’. In the Polish defence sector example quoted above, the unit in the Polish MOD is called the Anti-Corruption Procedures Bureau. Or it might sit within the audit department of an organisation.

Clarity of responsibility also forms part of the systems picture. Line managers within an organisation are expected to have overall responsibility for their product, service or outputs, and this includes direct responsibility for corruption issues that might be affecting the performance of their specific department or area within the organisation.

Leadership

The final and most important system/process is leadership. To pursue the ‘safety’ analogy noted above, in any good, safety-conscious organisation the current status of safety matters will be on the leadership agendas at all levels through the organisation. Often, it will be the first item on the daily and weekly operations agendas. It will be the first item for discussion at the monthly senior management meeting. It will be at or near the top of every annual Board meeting agenda.

If an issue never makes it onto the agenda at each leadership level, then it is evident that the issue is not considered relevant or important. Most organisations, public and private, still fail this test in respect of corruption.

In some organisations, the leadership may label the agenda item ‘Integrity Issues’ rather than corruption issues. One of us (Pyman) spent almost a decade working with NATO and NATO staff in developing and seeding thinking about corruption and integrity into NATO forces, especially in building the knowledge of military planners and forces on how to respond to endemic corruption in an operational environment. The senior NATO civilian leading this effort had an apt phrase that she employed throughout the NATO organisations:

We need to get to the point where building integrity and reducing the risk of corruption are embedded into NATO processes—planning cycles, staff assessments, policy reviews, operational planning, procurement—so that it becomes part of the organisation’s DNA.Footnote 1

Declarations of Commitment

Many organisations commit publicly to acting with integrity and without corruption, even though such statements are quickly seen to be empty if they lack the ‘machinery’ inside the organisation to address issues as they arise. At a sectoral level, many professions require a formal commitment to act with integrity and to speak up about corruption as a condition of membership. At an individual level, some jobs have a similar clause in their employment contracts. Many governments have such clauses within national regulations for individuals in public sector roles.

Do make yourself familiar with what the organisational, contractual and individual commitments related to integrity and anti-corruption are in your organisation/ministry or area of work. Sometimes it can be a good hook for connecting your colleagues into a more formal anti-corruption stance and for building a better shared understanding of corruption and anti-corruption obligations.

In the private sector, there has been an increase in companies that talk publicly about their commitments against corruption, such as the Partnering Against Corruption Initiative (PACI) hosted by the World Economic Forum (2021a); it is also the case that the number of Chief Integrity Officers is rapidly growing (World Economic Forum 2021b). Something similar has been happening with public sector organisations as well (see, e.g. World Bank 2023). But, as noted above, such obligations mean little without effective management systems in place.

When Talking About Corruption, Language Matters

One of the aspects that make corruption as a topic hard to explore within an organisation is that everyone has a different idea of what it is. Part of the reason is a lack of coverage of the topic in the education, professional training and certification that everyone needs to go through, either in the organisation or earlier. But there is also a more fundamental reason, connected with the fact that every profession, from dancing to telecommunications, has its own language, both technical and cultural. Evolved over time and absorbed into the culture of the profession, that language serves the useful function of enabling people within the profession to know exactly what their technical words mean, to understand and be able to use the jargon. In academic research, the term ‘epistemic communities’—professional networks with authoritative and policy-relevant expertise using specific language—describes how transnational actors influence and operate (Cross 2013), and how they function in sectors such as health (Scott et al. 2018).

This language specificity extends to words such as corruption. In a political context, the term is likely to mean ‘purchase of political influence’. Inside the construction sector it will mostly mean ‘procurement wrongdoing’. In humanitarian aid and development contexts, it usually means failure to safeguard donor funds.

Language also serves the purpose of including or excluding people from a professional community. If those who are examining the corruption problem are from within the same profession, and thereby speaking the same peer-group language, then they will start off already being more-or-less accepted by their peers.

Discussion of corruption inside an organisation thus needs to work with the grain of the professional language, the shared cultural reference point, to be accepted. For example, in the health sector, corruption is mostly spoken of as a ‘risk factor’; conversely, within the defence sector in Saudi Arabia, the accepted phrase to use for corruption is ‘integrity issues’. The aim is not so much to create a defined set of terms as to build a shared understanding of collective experience and knowledge. The ultimate objective is for the whole organisation to share a common understanding of corruption—where it matters, how it matters—and how the organisation can respond to it. Thus, we recommend that you develop the language of curbing corruption in your organisation within the culture of your sector, working with the grain of the professions involved, a process of co-developing that helps to build a shared understanding. Once this process is well on its way, then the organisation will be more able to get on with addressing related issues without external impetus.

Sometimes language is employed not for the purpose of clarity but to dissemble, and this also happens with corruption. We have seen this most often when corruption is referred to as a ‘governance issue’. Historically, this came about through the influence of the World Bank, which was keen around the mid-1990s to act against corruption, but their charter did not support such action: it was seen as being hostile to many of the nations who comprised the Bank’s membership. The way that World Bank management got round that was to frame corruption as a governance issue. Since then, this language has spread, and the definition of ‘governance’ in public policy and development circles has got broader.Footnote 2 The unintended consequence is that for people in leadership and management roles in organisations—for whom the term ‘governance’ is usually limited to the formality of corporate control, as wielded by boards of directors, legal counsel, financial controllers and auditors—corruption problems become equated with financial issues or audit issues. As a result, those in management and functional leadership roles feel justified in leaving the corruption issue to the accountants, the lawyers and the auditors. Of course, there are corporate control issues in relation to corruption (see, e.g. Rose-Ackerman and Palifka 2016; Rothstein and Varraich 2017), but to frame governance as the locus of the problem and the solution, rather than the operational and functional performance of the organisation, is potentially to bypass a large proportion of the leadership cadre from assuming responsibility for remedial action.

Discussing corruption and bringing it into accepted language inside the organisation does not mean that we are acknowledging or admitting that we are corrupt. It means the opposite. Corruption thrives on remaining hidden and unspoken about, so bringing it out into the open is a positive step towards anti-corruption. If your organisation has rarely or never previously examined the effect of corruption in reducing performance, you may get this question a lot: giving an unambiguous response is an important task of leadership, demonstrating that the subject is henceforth discussable.

By contrast, this also does not mean talking publicly about any and all corruption issues. All organisations have problems to solve, and they have to make their own judgements of when to work through an issue privately and when to make it public. This applies to corruption issues as much as it applies to any other issues.

Language also matters in building support for change, particularly whether to use ‘corruption’ or ‘integrity’ as the lead concept. ‘Integrity’ has the advantage of a positive connotation, often key for political buy-in, which also makes it easier to avoid the merely legal and criminal perspectives many actors have in the anti-corruption world. However, we need to avoid the trap of simply rebranding anti-corruption measures as pro-integrity ones: the genuine promotion of integrity entails a much broader frame of reference than just the absence of corruption (Heywood and Kirby 2020). We discuss this further in Chap. 6, where taking a corruption or an integrity focus forms part of the broad framing of a reform strategy.

Like All Risk Factors, Context Matters

Corruption resembles most other management-type problems in that there is always a history and a context as to why things are the way they are. The history may be unappealing—a staff member or director decided to help themselves to more than they were entitled; or it may have arisen from unwelcome but irresistible pressure, such as from a powerful person in the environment; or it may be fully understandable—staff have devised a clever but seemingly corrupt solution that fixes an otherwise intractable problem. The history may point to corruption only within your organisation, or corruption between your organisation and others (suppliers, politicians, etc.), or corruption wholly forced upon your organisation by a third party. Similarly, there are all sorts of different contexts—political, social, competitive, cultural. In other words, no judgement of the situation makes sense until you understand, at least to some degree, how and why the situation came about. There are many situations in the health sector, for example, where seemingly corrupt processes have evolved as the only ways to get essential supplies to patients.

Corruption is a problem in any setting, as much in advanced economies as in developing countries. This can be clearly seen in the construction sector, for instance. In the UK, half of a sample of 701 UK construction professionals claimed corruption is common throughout the British construction industry (CIOB 2013). Or in South Korea, where sub-standard materials were used in the construction boom of the 1980s and 1990s (resulting in the collapse of the Sampoong department store in Seoul), or in housing projects in New York City, Japan or Canada (see Wells 2015).

Is This Really My Responsibility?

Early in 2022 we conducted some research on corruption and corruption reform in the water sector (Martinez Rossignol et al. 2022a, 2022b), looking in particular at the management and distribution of the world’s supply of water, such as the unregulated diversions in watersheds. We asked a cross-section of those who have devoted their professional careers to managing the world’s water supply what they were doing to combat corruption in the sector. Interviewees included engineers in water utilities in the USA, Mexico and elsewhere; environmental lawyers; geographers; geologists; ocean economy investors; ecosystem scientists; natural resources managers; plus water anti-corruption practitioners and journalists too. What we found was that the interviewees were uncomfortable even talking about corruption.

We heard several explanations, such as worries about the vastness of corruption as a concept, the absence of professional anti-corruption training for water professionals, and that the subject was almost never included on professional agendas, not even as a topic of conversation. Our interviewees also questioned the limits of their personal and professional responsibilities. They asked, ‘Do we have a responsibility in relation to corruption, whatever its impact on water performance outcomes?’ There was an instinctive response that preventing or tackling corruption was not part of the job of a water professional.

Our interviewees did recognise, despite their discomfort, the importance of professionals becoming more attuned to corruption issues, such as by being specific about the corruption risks and the beneficial effects of responsible public sharing of water data. Similarly, they did recognise the need for adaptive, resilient community building, a by-product of which is likely to be limiting corruption. They recognised the role of the technicians, engineers and scientists to produce reliable, complete, unbiased data. But there was pushback against the idea that professionals held some responsibility for improving water performance by speaking up about corruption, or by exploring ways to prevent corruption, or by solving those issues that could be addressed.

We, the authors of this book, have encountered such reactions repeatedly from people we have engaged with on corruption reform over the past 20 years.

  • Some were politicians, in government and in opposition, needing to propose and implement anti-corruption initiatives within their sphere of responsibility, but doubtful about what they could achieve.

  • Many were public officials, within government or in related agencies, where corruption was constraining their capacity to deliver, wondering how they could be more effective, and with lower political risk, but not at risk to their jobs.

  • Some were the leaders of professional bodies and associations, knowing the corruption problems their sector faced and uncomfortable about being required by their membership to remain silent on the subject.

  • Many were private sector executives, seeing multiple ways in which corruption was hurting their operations, but nervous of dealing with a subject they perceived their leadership as being conflicted about.

The ‘not my job’ mentality of working professionals is, we believe, one reason why corruption has been able to flourish so easily—corruption always benefits from silence and people looking the other way. It may also be a reason why limited progress has been made against corruption in the last 30 years. Though there are many communities of people who work diligently on addressing corruption—such as anti-corruption agencies, auditors, civil society groups, ethics and compliance officers in companies, national and multilateral aid agencies, researchers—none of these hold positions of responsibility in the organisations and institutions at the core of daily working life. The many people in the category we are focusing on have responsibility for the operation of the individual structures and functions through which our lives operate. Because the job of professionals in such organisations is to deliver performance—products, policies, services—and if that performance is constrained, then it is their duty to examine the constraints and make the trade-offs of whether and how to remove those constraints. Corruption is simply one such risk factor.

A readiness to examine corruption issues and to address them thus should thus be part of the role of professionals in organisations. Not a core role—at least we all hope not—but one skill among the many others that a professional should have to ensure they can perform effectively. Indeed, anti-corruption work is complementary to other efforts towards improving an organisation’s performance.