“Bottom Up” Corruption Prevention
“Bottom Up” Corruption Prevention
Jennifer Widner and Tristan Dreisbach
The challenge of where to target ‘bottom up’ approaches
Reducing opportunities for public servants to go astray is one important element of corruption control. Streamlining procedures to limit temptation, creating a few robust checks at critical points, and setting out clear standards are all important elements of this approach. The question is where to vest this activity.
Because different government functions give rise to distinct risks, no one size fits all. Decentralizing the design of prevention programs therefore makes sense. A bottom up approach enables each agency to create and modify procedures in ways appropriately tailored to its activities, and to learn from one another’s successes and failures. But this step is not so easy to accomplish. Civil servants may lack the time and know-how to undertake the work required, and those who already benefit from corrupt practices may deliberately set the bar low, rendering prevention ineffective. Further, senior agency officials may be reluctant to accept responsibility because they lack enforcement authority or fear enforcing new policies will over-stretch limited capacity.
Mauritius and Indonesia are two countries currently experimenting with “bottom-up”, decentralized corruption prevention initiatives. Both already had powerful anti-corruption commissions in place when they started, but also realized that preventive measures could not be completely top-down.
Mauritius: shifting the responsibility for revising anti-corruption practices
Mauritian citizens worried openly during the early 2000s about corruption in government. Surveys revealed that civil servants often took advantage of archaic procedures, offering to reduce delay in return for cash. In 2009, Anil Kumar Ujoodha, director general of the government’s Independent Commission Against Corruption (ICAC), introduced a new prevention program, based on a strategy that shifted responsibility for the revision of practices to government agencies and their employees.
For Ujoodha, this approach had three main advantages. First, it would help build ownership. Second, it would allow adaptation to the diversity of government practices: some parts of government handled large procurements or issued licenses, for example, whereas others had little day-to-day interaction with residents and businesses and made few large purchases. Third, since ICAC lacked adequate capacity to develop ministry-specific recommendations by itself, the strategy enabled Ujoodha to make the most of the resources on hand.
Under Ujoodha’s initiative, each ICAC prevention officer took responsibility for assisting about five agencies. The officers guided agencies through setting up an anticorruption committee, assessing institution-specific corruption risks, developing solutions, and monitoring implementation. The first step was to create an anticorruption policy using an ICAC template, reflecting existing provisions in the civil service guide. The committee then identified practices that risked violating these standards, redesigned practices, and made expectations clear.
Clarifying the subtler aspects of conflict of interest was crucial. Civil servants had a general sense of right and wrong, but there were gray areas of interactions with friends, family, or other personal relationships. “That was one of the major priorities,” Ujoodha said. “Conflict of interest in a small country is very important. We have to make sure it is clear.” Each agency was to clarify its conflict-of-interest policy and provide explicit guidance for staff members.
The presence of ICAC prevention officers at quarterly anticorruption committee meetings made it possible for the commission to keep a close watch on progress. But informal contact between ICAC officers and the agencies was crucial for making progress. Frequent and informal contact enabled ICAC officers to identify potential problems early. If an institution appeared slow in meeting its obligations, ICAC leaders asked the head of the civil service to write a letter asking that officials prioritize compliance with their commitments under the Public Sector Anti-Corruption Framework. To assess effectiveness, ICAC monitored complaints, commissioned public opinion surveys, and used internal audits.
The main unanticipated obstacle was staff turnover. When the chair of an anticorruption committee left the position, a new chair had to learn the details of the framework and getting up to speed on the agency’s policies and commitments was time-consuming.
The decentralized corruption prevention strategy gradually reduced low-level corruption (it did not address campaign finance, money laundering, or drug trafficking). By December 2016, ICAC reported that 73 public agencies had established anticorruption committees: 55 of them had established anticorruption policies, 44 had begun the corruption risk management process. Together they introduced 383 measures to address corruption risks.
Indonesia: cooperative decentralization
Indonesia also experimented with a decentralized approach. With support from top-level officials, in 2010, Indonesia planning agency official Diani Sadiawati acquired a mandate to expand the government’s corruption prevention program.
Sadiawati worked closely with the president’s delivery unit. She lacked both the political power to dictate the agendas of other government institutions, and the in-depth knowledge of the corruption challenges each office faced. Therefore, she decided to take a cooperative approach, sitting down with representatives from each office selected for participation to identify issues and agree on a mix of projects. Some would be straightforward and easy to implement, while others would be challenging.
Sadiawati’s team recognized that implementation was worthless without a reliable system for monitoring progress. They created an online system that enabled agencies to upload evidence of progress toward specific goals and required each office head to appoint one employee as the go-to contact. Quarterly progress reports helped flag implementation problems.
However, the secretariat struggled to secure meaningful commitments across agencies. In 2013-14, Sadiawati sought an outside assessment of the secretariat’s work and asked civil society leaders to evaluate implementation. The report was largely negative. Although the agencies included in the program had met 88% of their targets, civil society observers said the program had not treated many of the root problems. Despite Sadiawati’s efforts to move beyond business as usual, the action plans were seen as lacking ambition. Also, government employees’ awareness of the strategy and the action plans was insufficient.
After Joko Widodo became Indonesia’s president, his advisers worked with Sadiawati to reduce the number of action items each year, as it was hard to make progress on so many items at once. The new president also prioritized some critical areas, including revenue collection, procurement, import/export controls, and resource extraction. The process grew less collaborative or “bottom up” as it became more focused.
Nonetheless, Sadiawati’s program achieved some notable successes, including redesign of a corruption-prone procedure for obtaining passports, improvements to the standard operating procedures for police investigations, and a finance ministry-led project to gather and share information at Indonesia’s ports electronically, making it more difficult to import or export illegal commodities.
Lessons learned
Lessons learned: 1) Bottom-up strategies still require strong partnerships with anti-corruption officials with know-how and the skill to facilitate collaboration. Regular face-to-face engagement appears to generate greater progress than requiring agencies to log actions and outcomes electronically or in paper reports. 2) Bottom-up approaches may make more rapid progress in smaller countries where agency leaders know one another and may be more subject to peer pressure. 3) Clear linkage to an organization with enforcement capacity—and/or support of senior leadership–is important to trigger serious action.
Jennifer Widner is Professor of Politics and International Affairs and Director of a research program on institution building and institutional reform called Innovations for Successful Societies.
Tristan Dreisbach is a Senior Research Specialist at Innovations for Successful Societies.
For more information see the Innovations for Successful Societies case studies Tackling Corruption from the Bottom Up: Decentralized Graft Prevention in Mauritius, 2009-2016 and Heading Off Corruption: Indonesia Acts to Meet UN Standards, 2010-2016. These case studies are part of a series sponsored by the British Academy/UK Department for International Development Anti-Corruption Evidence Programme.