Nigeria
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A data-driven strategy for anti-corruption Collective Action: Lessons from Nigeria
In last week’s interview on how Collective Action has cut corruption in Nigerian ports, Cecilia Müller Torbrand of the Maritime Anti-Corruption Network and Soji Apampa of the Convention on Business Integrity explained their data-driven approach and the measurable impact it has had. In the second part of the interview, Cecilia and Soji offer lessons for anti-corruption practitioners seeking to implement a robust data and impact strategy in their own initiatives. What are your top 5 tips for collecting data on corruption? Data on corruption is never perfect, but it is essential to start somewhere. The MACN’s anonymous incident reporting system, which allows maritime players to report incidents of corruption demands in port operations anonymously, has been critical to our data collection strategy over the years. Based on our experience developing the system, we believe the following lessons have been key to our platform’s success: Develop an easy and simple-to-use system to encourage front-line staff to report. Define, explain, and communicate the system's objectives to meet the expectations of all stakeholders, including national governments who may receive future reports. Define what the solution looks like and translate that into data points. Strongly consider anonymity of reporting to build trust in the reporting system itself. Ensure good data governance. How do you manage the data? Since the launch of MACN’s anonymous incident reporting system, the Network’s membership and scope of operations have grown significantly. This growth has brought with it an increased adoption of MACN’s anonymous incident reporting. Today, MACN has collected over 54,000 incident reports worldwide and continues to see momentum in corruption data collection. We constantly seek ways to make our data more useful, accurate and actionable. In 2021, with external support from the Danish Ministry of Foreign Affairs, MACN worked on optimising and improving its incident reporting functionalities and developed a robust data visualisation capability. In addition, MACN progressed with the development of the Global Port Integrity Platform GPIP – the world’s first platform to measure and compare integrity in ports worldwide. GPIP will draw upon MACN’s anonymous incident data as well as other data sources to capture and display integrity risks at the port and operational levels. What data does the HelpDesk collect and what do you do with it? In Nigeria, MACN was looking for a way to track the effectiveness and impact of our Collective Action programme. We focused on three main areas: Transparency of operating procedures Consistency of their application Impact of this on the predictability of port call duration a function of cost One key factor in port call delays was the inconsistent application of standard operating procedures by many officials. MACN conducted an annual survey of operations departments and ship captains on their experiences at Nigerian ports and terminals to provide a measure of annual improvement in the operating environment. Through this, we noted the major challenge of understanding and tracking complaints being filed by vessel captains with the Nigerian authorities and tracking the resolution process. At this stage, only the government could access data on actual complaints. It had decided such information was ‘secret’ and could not be shared without high-level clearance. Assessing the operational situation, we saw there were several defined steps involved in clearing a vessel through port. These include being checked and cleared for health risks, undergoing inspections and seeking clearance to depart. Corrupt demands could occur during several of these procedural stages. Rather than relying solely on anonymous incident reporting in the aftermath of a vessel entering Nigerian waters, we believed there was enormous potential in the real-time tracking of clearance progress and addressing any procedural issues as they occurred. If there were any issues, they could be lodged in the government complaints system and tracked from the response to the resolution. This process led to the creation of the MACN Nigeria HelpDesk. With the establishment of the HelpDesk, we progressed from receiving anonymous data to actionable data. A key moment came when the government system went down. All stakeholders had only our HelpDesk to rely on, demonstrating the system’s added value as an important extension to official channels. How did you get captains and companies to use the HelpDesk? Empowering and building trust in the private sector have been key for the work in Nigeria. There was initial reluctance to use the HelpDesk as MACN had previously promoted anonymous reporting. The operation of the HelpDesk meant issues could not be resolved anonymously. The changes being implemented in partnership with the Government of Nigeria were highlighted at MACN member meetings over the course of two years, but members were initially skeptical. A turning point came when a member had a problem at an offshore terminal. They tried to resolve it on their own and did not succeed. Then someone remembered the “crazy” guy at an MACN meeting who claimed things were changing Soji Apampa in this case and the member decided to “give it a shot”. The company informed MACN and CBi about the issue and we escalated the matter through the new channels established by the government. Within 48 hours the vessel was permitted to sail. The company had another issue not long after that. It used the HelpDesk immediately, and it was resolved within 24 hours. Captains in that fleet then started spreading this news by word of mouth within their company and to the wider seafaring community. The masters, crews and company never experienced any backlash, even though the reports were no longer anonymous. MACN streamlined and promoted the processes of using the HelpDesk amongst members, and uptake increased, especially because of the growing number of success stories. MACN also offered online meetings and other forms of support for companies to ensure captains were well briefed and knew what to do when sailing to Nigeria’s waters. What was the reaction to your Outstanding Achievement Award from the Basel Institute? We believed what was emerging from the Collective Action project in Nigeria was unique, and we wanted to showcase this as much as possible. MACN and CBi received the award, but we wanted to ensure that the government and stakeholders locally also received well-deserved recognition. We believed it was important to hand the award over to the Nigerian Vice-President, whose strategic interventions since 2015 in response to our requests for intervention accelerated our progress with each case of involvement. When we eventually presented the award to the Vice-President of Nigeria, the communication of the award trended on social media and was very widely reported in the media. We also used the meeting with the Vice-President to provide direct feedback on what he could further do to make the changes sustainable and the project even more impactful. What’s next? MACN and CBi have ambitious plans to expand our work in West Africa and continue to build on the learnings from Nigeria. We still have work to do in Nigeria, and our efforts will continue, especially as elections take place in February and March 2023. We must maintain the momentum and results from this 10-year journey. Learn more See part 1 of this interview: Cutting corruption in Nigerian ports: data, impact and Collective Action Find out more about the Anti-Corruption Collective Action Awards and how to nominate your initiative in 2023.
Cutting corruption in Nigerian ports: data, impact and Collective Action
The Maritime Anti-Corruption Network MACN delivers leading examples of Collective Action against corruption around the world and Nigeria is one of its flagship success stories. In collaboration with the Convention on Business Integrity CBi , the initiative has kept seafarers calling at Nigerian ports safe from corrupt demands since 2019. Their installation of the world’s first real-time incident reporting tool and connected HelpDesk has significantly reduced corrupt demands and earned them the Basel Institute’s 2022 Collective Action Award in the category of Outstanding Achievement. In the first instalment of a two-part interview, Cecilia Müller Torbrand, CEO of MACN, and Soji Apampa, Co-Founder and CEO of CBi, offer their insights into how a data-driven approach has contributed to the initiative’s success in reducing corruption in Nigerian ports. Part 2 offers lessons for anti-corruption practitioners seeking to implement a robust data and impact strategy in their own initiatives. Briefly, what was the problem? MACN identified Nigeria as one of the most challenging countries in which to do maritime business. Corrupt demands posed a major risk to member companies, their ships and seafarers, who faced extortion, harassment and threats of violence. Regulations and procedures in ports and terminals lacked detail and consistency, which gave authorities and individual official representatives wide discretionary powers. And the impact of MACN’s initiative in Nigeria? By developing a results-based approach with measurable outcomes, our initiative has empowered the private sector and reduced the risk and associated costs to vessels and companies. In 2020/2021, the number of corruption incidents reported through MACN’s anonymous incident reporting system dropped. Usage of MACN’s national HelpDesk and the Nigerian Shippers Council reporting platform has increased. Before the HelpDesk operation, case resolution where companies formally challenge officials’ reports against vessels and crew took up to 7–10 days. In 2021, MACN reported an average case resolution time of 1–4 hours. For a shipowner, the operational costs staying in port, delayed ships, processing paperwork have therefore been reduced from approximately USD 150,000 to USD 20,000 per port call. What factors contributed to the success? Three elements were and remain critical: Strong political will to drive change: Strategic alignment of the initiative with political priorities, coupled with a critical mass of actors and sustained engagement with high-level contacts that could make change happen Methodical situational assessment and a well-planned intervention, starting with a corruption risk assessment pushing for incremental change around ‘what is possible’ rather than a big-bang approach. Negotiation of direct and immediate consequences for non-compliance. Tell us about your data-driven approach Corruption, by its very nature, is difficult to measure and quantify. MACN’s anonymous incident reporting system seeks to address that challenge by inviting maritime players to submit anonymous reports of actual corrupt demands they have faced during port operations. The most significant outcomes of the reporting system, based on feedback from MACN Member businesses, Collective Action partners and other stakeholders, are as follows: The ability to reduce risk and strengthen company compliance programmes increases with better knowledge of the operating environment. The power of an escalation channel – by reporting on illicit demands, we have created transparency on the industry's challenges, which is the first step to building a solution. Increased transparency encourages the industry at large to take necessary preventative actions and to provide better-prepared operational support. The data can be used as a “door opener” for constructive dialogue between the private and public sectors. How do you define impact? We defined impact from the perspective of the primary beneficiaries: businesses in the Maritime Anti-Corruption Network. What counts for them is the predictability of time and therefore cost of clearing vessels through Nigeria’s ports and terminals. This predictability is a function of pre-known therefore transparent standard operating procedures. Vessel captains are consistently asked to comply with these procedures. They expect that, regardless of what port or terminal they were visiting and regardless of what official they came into contact with, the rules would be applied the same way. These operational parameters formed the basis for data collection and the development of an index to track performance. How did data help to convince the government? We engaged early on with the government to establish a framework on how reported incidents could be addressed in a joint effort. Initially, data on the challenges was limited. But it was still enough to convince the government on the importance of working with the private sector to improve trade efficiency in Nigeria. Since then, we have worked in collaboration with the government. It may be a challenging task at times as this is truly a multi-stakeholder effort. But Collective Action is the only way to create sustainable change in the fight against corruption. Learn more Find out more about the Anti-Corruption Collective Action Awards and how to nominate your initiative in 2023. See more guidance on evaluating the impact and effectiveness of Collective Action. Read part 2 of the interview next week.
How to enhance integrity during crises: lessons from behavioural science
The following summary reflects key messages emerging from the Harnessing the intangible: enhancing integrity during crises Knowledge Partner session on 25 March 2021 at the 2021 OECD Global Anti-Corruption & Integrity Forum. Hosted by the Basel Institute and moderated by Claudia Baez Camargo, Head of Public Governance, the event explored how practitioners could tailor approaches to strengthen integrity during an emergency response to counter recurrent social norms and informal practices. The panel incorporated a wide range of perspectives from health, anti-corruption and behavioural research, featuring Dina Balabanova and Eleanor Hutchinson of the London School of Hygiene and Tropical Medicine, David Jackson of the U4 Anti-Corruption Resource Centre, and Ruth Persian of The Behavioural Insights Team. Why aren’t traditional approaches to tackling corruption and promoting integrity working? A key takeaway from the session is that mainstream anti-corruption interventions focusing on accountability, transparency and law enforcement measures have not been as effective as we would like in combatting corruption. Could this be because we don’t make enough effort to understand the local context, social networks and power dynamics in the target countries as well as individual actors’ experience and motivation? A growing body of evidence suggests so. For example, recent research carried out in Nigeria by the London School of Hygiene & Tropical Medicine reveals that the causes of absenteeism among Nigerian health workers are much more complex than one might expect. They encompass economic pressures, structural inefficacies and managerial/organisational dynamics, with the research also emphasising that these are shaped by sociocultural factors and political relationships. Without a more nuanced analysis of how and why people behave as they do and the context in which they make decisions, laws and rules alone are unlikely to change the drivers of corrupt behaviour. Initiatives are increasingly focusing on improving health system governance, but thinking about the “upstream” social and political factors is essential. Exploring social norms can offer insights into the drivers of unethical/corrupt decision-making. For instance, the Basel Institute’s current research project in Tanzania under the GI-ACE programme shines a spotlight on, among other things, social norms related to returning favours or serving family members first. Health workers are put under pressure to make special concessions to their kinship or those who offer gifts. If people follow these informal rules, merely changing or strengthening laws or rules will not get rid of the underlying drivers of corruption or violations of integrity. The message is clear: when designing interventions, it is critical to first understand the context, including what social norms are at play and which behavioural and structural barriers to behaviour change the different actors face. Are we less rational than we think – and even worse in a crisis? Traditional economic thinking has assumed that human beings are rational agents acting according to an analytical, cost/benefit analysis. In his best-selling book, Thinking, Fast and Slow , Daniel Kahneman referred to this as slow “System 2” thinking. In contrast, System 1 thinking is fast and automatic, and more susceptible to environmental influences and biases than we think. However, policies and systems are often designed with only System 2 in mind. Furthermore, in situations where decision-makers act under a lot of pressure and stress – as is the cases in crises – evidence shows that System 1 is most likely to take over when making decisions. This has to be taken into account when designing interventions. In the context of the Covid-19 pandemic, interventions could support medical staff and policy makers by simplifying how information is displayed and framed. For instance, a study showed how changing how prescription instructions are framed can lead a significant reduction in prescription errors in UK’s National Health Service NHS . It seems likely that this finding can be generalised: by providing information at the right time and an easily accessible format and by simplifying decision-making, people working under a lot of stress are supported to take the right course of action. Do crises amplify integrity issues? Or is “crisis” mode quite normal? The pandemic has merely exacerbated the fact that health systems around the world are in a constant state of crisis, with regular shortages and understaffing. This generates different pressures on staff workers, with a direct link to integrity issues. One issue relates to the political economy of a country. For instance, sanctioning health workers for corrupt behaviour if they enjoy political protection may lead to severe consequences – like job losses – for head of departments. An intervention that does not take this into account would do more harm than good. Gendered norms and expectations also drive behaviour. In the case of absenteeism among Nigerian health workers mentioned above, for example, female nurses are often expected to juggle their shifts with family care and contribution to the household economy e.g. farming . Merely changing rules or management without understanding people’s behaviour and the expectations they face in a complex system will not yield the expected results. As for political power, understanding how social and family networks are structured and operate is key to designing effective anti-corruption interventions. Harnessing behavioural insights to drive change A solid political economy analysis will help build understanding among anti-corruption practitioners – but what should they do with that understanding? The next step is to understand how to use these insights into different networks to design more effective interventions. This is the idea behind another GI-ACE project led by the Basel Institute on Harnessing Informality: Designing Anti-Corruption Network Interventions and Strategic Use of Legal Instruments. To continue with the example of absenteeism among health workers, individuals who are negatively affected by this more working hours, more pressure due to the added activities related to the Covid-19 responses may be more likely to support an intervention to address the issue. So, clearly identifying networks of allies with a reason to support a change in favour of integrity should be an essential step of any intervention. How social norms affect behaviour – for better or for worse Another interesting point raised during the session was how we all belong to different reference groups which form part of our identity. Social norms stem from these reference groups and influence our behaviours in different ways. We follow descriptive norms because they relate to common behaviour, whereas we respect injunctive norms because we think that others think these behaviours are socially appropriate. For example, assisting our family materially because we think that others perceive this as the right thing to do. These last norms generate social pressure as we are scared by the social sanctions we would incur by violating them. Social norms become particularly salient during crises when, as mentioned above, System 1 thinking is likely to take over in stressful situations where actors need to make fast decisions under a lot of pressure. Rather than changing social norms, perhaps the objective in the Covid-19 crisis and more generally should therefore be relieve individuals from the pressures generated by the norms. Norms of elites need careful consideration. Cases of decision-makers violating social distancing norms may make it permissible to violate health guidelines in the eyes of the public. However, research shows that trend-setters – i.e. people within groups leading by example by adopting virtuous behaviours associated with social norms like respecting social distancing – play an equally important role in changing undesirable behaviours associated with social norms. Revealing information about these virtuous behaviours within reference groups can incentivise others to change their own behaviour vis-à-vis a social norm. Another option that requires careful consideration and handling – and a deep understanding of political economy, behaviours and norms – is for governments to publicly condemn corrupt behaviour using normative interventions, for example naming and shaming individuals who violated covid-19 regulations. Can social norms be changed? So: relieving individuals from the pressures generated by social norms is one avenue for intervention. Another common form of intervention aims to correct people’s incorrect perceptions of social norms. More drastically, perhaps some norms need to change in order to form the basis of a stronger, healthier and more resilient society. Is this possible? The short answer that emerged at the session is yes. Three elements must be present: People need a reason to change. People must trust each other. A mechanism must be in place to let change occur e.g. a civic space . This implies that changing social norms to encourage integrity is a collective effort. It is also an immensely challenging one – but nonetheless essential if we wish to enhance integrity during crises as well as during “business as usual”. Learn more Read more about our Public Governance team’s research on social norms and related factors here. Learn more about the UK-funded Anti-Corruption Evidence ACE programme and its two components: SOAS-ACE led by SOAS University of London and GI-ACE led by Global Integrity . Read a publication on the London School of Hygiene & Tropical Medicine LSHTM website by Dr Dina Balabanova LSHTM , Professor Obinna Onwujekwe University of Nigeria and Dr Eric Umar University of Malawi on Understanding and eliminating health sector corruption impeding UHC at district level in Nigeria and Malawi: institutions, individuals and incentives. Watch a video recording of the session on YouTube.
What is an Ethically Aware Supplier – and how does it support business integrity in Africa?
Local certification is emerging as an interesting way for large companies and their supply chains to help address compliance and due diligence issues that can be a barrier to business. A recent Basel Institute working paper showed how local certification programmes developed with a Collective Action approach can help: SMEs to develop and demonstrate robust anti-corruption compliance procedures; ease due diligence for large companies seeking suppliers in local markets; raise standards of integrity across a market or geographical area. The Ethically Aware Supplier Induction EASI programme of The Ethics Institute in South Africa, first developed as a project of the Siemens Integrity Initiative, harnesses this innovative approach. Its expansion into other African countries under a recent grant of the UK Business Integrity Initiative Challenge Fund shows how agile and flexible Collective Action can be – even when working in very different and challenging contexts, and in the face of a global pandemic. Kris Dobie, Manager – Organisational Ethics at The Ethics Institute, gives an insight into the project below: What is the idea behind EASI? Multinational companies want to do business with suppliers that are committed to operating with integrity and that actively manage their corruption risks. This is partly to manage their own legal and reputational risks. From a big-picture point of view, this can have a positive consequence in developing markets: by insisting on high standards of anti-corruption compliance through their supply chains, multinationals can become an important driver of good governance. But in practice, SMEs need support and training. Who better to support SMEs in their compliance journey than their larger customers? What exactly is EASI? EASI helps companies that want to train their suppliers by providing an online interactive short course in business ethics. The aim is to make participants aware of key ethical issues that are relevant to their companies. It is based on the principles of the UN Global Compact and the content is benchmarked against the supplier codes of conduct of several large companies. Members of the senior management of SMEs – with influence over the companies’ business ethics and operations – can complete the course on behalf of their businesses. If they pass the assessment, we certify the company as “ethically aware”. This emphasises their knowledge and awareness of integrity issues relevant to their company and of the main ethical requirements of multinational enterprises. We don’t certify the company itself as ethical. You can find out about the course on the EASI website or watch this two-minute YouTube video: Where do the large companies come in? Ideally, this foundational online training is combined with a live group session where suppliers and representatives of the larger companies come together for a structured discussion on some of the key topics. We find that significant additional learning – on all sides – takes place here. Many of the compliance officers, procurement specialists and internal auditors who have taken part in these discussions tell us how eye-opening it is to learn of the realities faced by their suppliers. Rolling out EASI throughout supply chains Our strategy involved large organisations taking charge of rolling out the EASI programme throughout their supply chains. We started close to home, with the Coalition for Ethical Operations. This is a private sector-led Collective Action initiative that The Ethics Institute facilitates. Its members, who are multinational companies, commit to promoting ethical business across Sub-Saharan Africa and to training their suppliers. We also partnered with the UN Global Compact local networks in Kenya and Ghana. When the pandemic hit and travel became impossible, we managed to free up funding to partner with the UN Global Compact network in Nigeria, as well as the Addis Ababa Chamber of Commerce in Ethiopia. What adaptations did you make to address covid-19? The meetings went online, of course, and sadly webinars replaced business breakfasts and face-to-face engagements. This was rather challenging to facilitate. Group discussions in person foster trust, whereas building a relationship between strangers on a video call is not quite the same. Attendance and attention were also lower online. Nevertheless, we enrolled 34 multinationals and 82 individuals in the EASI programme across those four countries, and have certified a similar number of SMEs so far. How did you promote the programme despite the pandemic restrictions? We believe that business networks are key to reaching more companies, large and small. After all, they are about business getting together to collectively raise the bar. This is why it has been fantastic to partner with the UN Global Compact networks and with the Addis Chamber. Companies that engage in the EASI programme clearly see its value. One large telecoms company is currently rolling out the EASI programme to subsidiaries and operating companies across its group. If a couple more in this sector follow, EASI will become a form of industry standard. And that’s when tangible change will really occur. Improving together There are however a number of issues we are still grappling with. The feedback we get tells us that this is a really good product, but it still needs to be marketed to take off internationally – and anti-corruption practitioners are not necessarily marketers. We want to strike the balance between making the programme accessible to as many companies as possible, while ensuring they value it properly. Dealing with "products" as an ethics non-profit organisation has proven to be a healthy learning curve. These are issues that I know many fellow practitioners are grappling with in their contexts, as they seek to attract a critical mass of companies to their initiatives. Learning from and supporting each other, such as at the recent peer learning workshops hosted by the Basel Institute or the roundtables as part of their wider certification project, are crucial. We also thank the Siemens Integrity Initiative and UK Business Integrity Initiative for their support in making this idea become a reality for ourselves and hundreds of companies across Southern Africa. \ \ \ About The Ethics Institute The Ethics Institute is an independent public institute with the vision of ‘Building an ethically responsible society’. They pursue this vision by working with organisations in the public and private sectors where they offer a range of services related to organisational ethics, including training, assessments and advisory services. See www.tei.org.za About the UK Business Integrity Initiative and Challenge Fund The UK's Business Integrity Initiative Challenge Fund was launched to support innovative, business-focused, Collective Action initiatives aiming at reducing corruption or promoting human rights to improve the investment climate in emerging markets and developing countries. IMC Worldwide has been working closely with the UK Foreign, Commonwealth and Development Office FCDO as the Business Integrity Initiative Challenge Fund Manager. Find out more. About the Siemens Integrity Initiative The Siemens Integrity Initiative promotes projects around the world that seek to combat corruption and fraud, supporting educational and training programmes as well as Collective Action, which is building alliances against corruption in a joint effort between business and institutions to establish clean markets and ensure fair competition. See siemens.com/collective-action.
Ten-country Advanced Operational Analysis training offers chance to reflect on the effectiveness of AML systems
Twenty anti-corruption investigators and financial intelligence analysts from 10 African countries completed an intensive Advanced Operational Analysis course last week hosted by the Commonwealth Africa Anti-Corruption Centre CAACC . Delivered online by our International Centre for Asset Recovery ICAR training team, the workshop blended eLearning modules with live video sessions in which the participants worked together to solve a simulated corruption case. Enhancing mutual understanding The participants came from anti-corruption agencies and Financial Intelligence Units FIUs in Botswana, South Africa, Nigeria, Sierra Leone, Kenya, Namibia, Mauritius, Zambia and Lesotho. As usual in ICAR training programmes, the multi-agency approach helped participants to better understand each other’s needs and roles. FIU analysts were encouraged to tailor their intelligence products to the needs of investigators in law enforcement agencies. In turn, investigators learnt how an FIU operates by taking the Operational Analysis eLearning module and solving the simulated case. By the end of the week, participants fully understood the value of breaking silos down, of exchanging information and coordinating their actions, nationally and regionally. Reflecting on FATF mutual evaluations The training was also an opportunity for the participants to reflect on the lessons learnt from the recent Financial Action Task Force FATF evaluations of Mauritius, Zambia and Botswana. These three countries have undergone an FATF fourth-round evaluation, which covers the effectiveness of national systems to combat money laundering and terrorist financing and not merely technical compliance with FATF Recommendations. The Basel AML Index, which assesses the risk of money laundering and terrorist financing around the world, has consistently noted that countries typically fall down the rankings when assessed with the new methodology. The participants together looked at ways to enhance effectiveness in the use of financial intelligence for money laundering investigations, as well as in investigations, prosecutions and the confiscation of assets. Impact and collaboration This impact-driven training aimed to provide participants with skills that are directly applicable in their daily work. We were happy to receive participants’ comments including “it touched on similarities of the case I am currently investigating” and “the financial analysis will improve the presentation of my case”. One participant commented that the training will “help me in investigating suspicious transaction reports that I recently received”. The Basel Institute has a long-standing relationship with the Botswana-based CAACC and has conducted previous workshops in 2017 and 2020. See our article about the 2020 workshop on Financial Investigations and Asset Recovery for more information about the CAACC and our fruitful collaboration. ICAR training in multiple languages To find out more about ICAR training programmes, please download our latest brochure in English, Spanish, French or Portuguese: English: Training programmes – Financial investigations and asset recovery Español: Programas de capacitación – Investigaciones financieras y recuperación de activos Français : Programmes de formation – Enquêtes financières et recouvrement d’avoirs Português: Programas de formação – Investigações financeiras e recuperação de activos
Publications
Engaging the private sector in Collective Action against corruption: A practical guide for anti-corruption agencies in Africa
This guidance seeks to capture and explore the innovative approaches that African governments have developed to address the demand and supply sides of corruption more effectively and sustainably. It is designed to help government institutions, in particular national anti-corruption agencies, engage with the private sector more effectively to prevent corruption.
The document highlights good practices identified through interviews, desk research and a 2021 Southern African Development Community (SADC) training on “Emerging anti-corruption issues and private-sector engagement for SADC anti-corruption agencies”.
Africa offers many examples of innovative, unique and context-sensitive approaches to engage the private sector in anti-corruption efforts. Ghana’s National Anti-Corruption Action Plan, for instance, offers an award scheme and is looking into providing tax benefits to companies that enforce anti-corruption measures and demonstrate leadership in the fight against corruption. Other agencies and governments in the region, such as Morocco, are currently discussing implementing a reward system for compliant companies that can be considered when companies bid for public tenders.
These examples demonstrate how African governments proactively seek to tackle corruption and collaborate with the private sector.
From the initiatives captured, three common strategic approaches can be identified to underpin effective and impactful engagement:
- Raising awareness, guiding and working with the private sector to more effectively address corruption risks.
- Identifying and providing incentives to companies investing in their compliance programmes.
- Demonstrating leadership by actively participating in Collective Action and public-private partnerships.
This document is a follow-up of a practical global guide published in July 2022 and was produced with the support of the Siemens Integrity Initiative.
It is freely shareable under a Creative Commons CC BY-NC-ND 4.0 licence. Please credit the Basel Institute on Governance.
Nigeria Collective Action: MACN Impact Report
Nigeria is one of the most challenging countries to do business in as requests for cash and in-kind payments are very common. Many government agencies frequently make corrupt demands during port calls related to alleged irregularities of documentation (e.g. yellow fever certificates, crew contracts) or operations (e.g. ballast water discharge documentation, onboard practice in general).
When practices are challenged, threats of heavy delays are common. One of the main challenges faced by shipping companies is the officials’ wide individual discretionary powers. This leads to unpredictable interpretation of laws, making it difficult to prepare for port calls and governmental actions.
Promoting Anti-Corruption Collective Action through Global Compact Local Networks
This guide helps businesses to learn more about the UN Global Compact Collection Action Project in partnership with five Global Compact Local Networks in Brazil, Japan, Kenya, Nigeria and Egypt.
It also aims to help improve anti-corruption practices within their individual organizations and to engage other businesses, governments and civil society in anti-corruption Collective Action.
Collective Action on Corruption in Nigeria: A Social Norms Approach to Connecting Society and Institutions
That corruption is a destructive and complex practice is openly acknowledged in Nigeria, yet it remains ubiquitous in the functioning of society and economic life. The consequences of corruption for the country and its people are, moreover, indisputable. Acts of diversion of federal and state revenue, business and investment capital, and foreign aid, as well as the personal incomes of Nigerian citizens, contribute to a hollowing out of the country’s public institutions and the degradation of basic services. All the same, corruption is perhaps the least well understood of the country’s challenges.
It has been estimated that close to $400 billion was stolen from Nigeria’s public accounts from 1960 to 1999, and that between 2005 and 2014 some $182 billion was lost through illicit financial flows from the country. This stolen common wealth in effect represents the investment gap in building and equipping modern hospitals to reduce Nigeria’s exceptionally high maternal mortality rates – estimated at two out of every 10 global maternal deaths in 2015; expanding and upgrading an education system that is currently failing millions of children; and procuring vaccinations to prevent regular outbreaks of preventable diseases.
Corruption tends to foster more corruption, perpetuating and entrenching social injustice in daily life. Such an environment weakens societal values of fairness, honesty, integrity and common citizenship, as the impunity of dishonest practices and abuses of power or position steadily erode citizens’ sense of moral responsibility to follow the rules in the interests of wider society.
Returning Stolen Assets - Learning from past practice
Before the adoption of UNCAC, there was no policy or international legal framework guiding the disposal and monitoring of repatriated assets. As a result, there were no globally accepted rules to follow when repatriating confiscated assets to requesting countries.
Even after the adoption of UNCAC, global practice regarding the disposal of repatriated assets remains unclear. Indeed Article 57 (5) of UNCAC does not provide clear guidance in relation to the final disposal of confiscated assets.
The selected case studies in Peru, Nigeria, Kazakhstan and Angola explore the proactive and innovative practice of Switzerland in the past decade in recovering, repatriating and monitoring stolen assets.
These four cases, which are different from various aspects, in particular the types of the mechanism of monitoring, are insightful and yield some important lessons. The lessons drawn in the respective cases highlight the successes achieved as well as some challenges encountered. The Swiss experience has influenced reflection on existing policies and legislation regarding the disposal and monitoring of repatriated assets, including in the context of the introduction by the Federal Council of the Restitution of Illicit Assets Act (RIAA 2011) and, in May 2013, the opening of a consultation procedure on the draft of a new federal act on the freezing and restitution of potentates’ assets.
This selection of case studies has been drafted as background document to the two-day workshop on Returning Stolen Assets, organised by the Basel Institute on Governance’s International Centre for Asset Recovery (ICAR) in collaboration with the Directorate for Public International Law of the Swiss Federal Department of Foreign Affairs (FDFA/DPIL) in October 2013 in Küsnacht/Zürich, Switzerland.