Towards a common standard for development agencies’ integrity systems
An eventual OECD integrity guideline for development agencies should emphasise communication around ethics regimes and control systems, assessment and management of corruption risks, and moving towards joint responses in donors’ integrity systems.
Corruption is for most development activities an ongoing and tenacious operating condition. While there are some resources available, development agencies do not yet have a truly shared framework for guiding their efforts to thwart corruption in their projects.
Building Donor’s Integrity Systems, a recently published report by Liz Hart, co-funded by U4 Anti-Corruption Resource Centre and the OECD, presents the initial findings of a project to map development agency integrity practices and policies.
The report will serve as background material for a possible OECD guideline or standard for development cooperation integrity. Twenty-five development agencies´ survey responses and in-depth interviews in nine countries formed the basis of the report.
Identifying integrity system components
Survey respondents broadly endorsed the following areas as making up an integrity framework for agencies and their staff:
- Internal ethics policies, assistance/advisory function, and training/awareness raising
- Reporting mechanisms
Concerning the interface with grantees, contractors and partner governments, respondents identified critical elements of an integrity framework covering:
- Aid transparency
- Anti-corruption strategy or policy
- Control and enforcement
- Risk analysis and management
- Joint responses to corruption
What should an OECD integrity guideline include?
Most agencies have mechanisms to address the above areas. Strengthening communications appeared as an emergent issue in relation to widespread integrity functions, such as internal ethics and reporting systems and control mechanisms.
Donors need to improve communications around ethics regimes and corruption reporting channels, to demystify potentially intimidating mechanisms such as whistleblowing or seeking advice regarding ethics or suspicions of corruption. The same applies to the process and outcomes when they investigate suspected wrongdoings. If trust is to be built around these processes, donor agency staff should know and understand them.
Agencies consistently implement controls via procurement rules and auditing. Most also implement investigation, sanctioning and information sharing. However, these practices are difficult to harmonise, particularly due to differences in national legal regimes.
Assessing corruption risks and translating such assessment into operational mitigation measures is a major challenge. Most agencies perform corruption risk analyses, but a gap remains between country-level assessments and detailed due diligence reviews. Agencies face the complex tasks of moving from assessment into activity design or project management approaches (specific mitigation measures), and of integrating these analyses into their formal control mechanisms (inspections, internal audits, etc.).
The report also finds some momentum for promoting joint donor responses to corruption problems. Despite well known barriers to coordinating actions, respondents broadly endorsed this goal.
Staff welcome flexible anti-corruption guideline
While the prospective integrity guideline would primarily be aimed at development agencies in OECD member countries, it could also become a resource for the broader development community. Ultimately, the usefulness of such an instrument would depend on the agencies’ capacity to adapt their own policies and evaluative frameworks.
The report confirms that potential users would welcome a guideline and underlines the need to be careful in its design. It should provide a framework that is both comprehensive and flexible in its application. Any integrity framework should also be sensitive to limitations regarding its applicability under humanitarian emergencies and conflict settings, the coordination challenges imposed by conflicting legal and administrative systems, and its potential reach if based only on the experience of OECD countries.
U4 Brief. Francesco De Simone and Nils Taxell. 2014. Donors and “zero tolerance for corruption”: From principle to practice.
U4 Brief. Maja de Vibe and Nils Taxell. 2014. Collective donor responses: Barking or biting?
U4 Brief. Nils Taxell and Liz Hart. 2013. Donor anti-corruption strategies: Learning from implementation.
U4 Issue. Jesper Johnsøn, Nils Taxell and Dominik Zaum. 2012. Mapping evidence gaps in anti-corruption: Assessing the state of the operationally relevant evidence on donors’ actions and approaches to reducing corruption.
U4 Anti-Corruption Resource Centre (theme). Corruption and Aid
Published: 14 October 2015.
Image: Dave Bleasdale on Flickr.