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How stronger borders can create smarter corruption: lessons from one of Europe's most strategic border crossings
When Bulgaria joined the European Union in 2007, many believed it would lead to more secure, transparent and less corrupt borders. New regulations, infrastructure modernisation and digitalised customs procedures all followed. European standards and money arrived together. Yet corruption did not disappear at the Kapitan Andreevo border checkpoint, the main land crossing between Bulgaria and Türkiye and one of the busiest gateways between Europe and Asia. Instead, it evolved. This is the central finding of a recent article by the Prevention, Research and Innovation team of the Basel Institute on Governance – Dr Jacopo Costa, Dr Claudia Baez Camargo, Noémi Jäger and Dr Saba Kassa – published in the Journal of Illicit Trade, Financial Crime, and Compliance . The article examines how criminal networks, smugglers, businesses and corrupt officials adapted to Bulgaria’s EU integration. It illustrates how corruption behaves like an adaptive ecosystem: when regulations and border control technologies change, corruption changes with them. A border built for opportunity – legal and illegal Border spaces concentrate discretionary power in the hands of customs officers, border guards, inspectors and regulators, while bringing together also traders, transport companies, migrants, smugglers, criminal groups and political actors. Kapitan Andreevo is a particularly instructive case due to its strategic location, with thousands of trucks, travellers and goods passing through the border checkpoint daily. Before Bulgaria’s EU accession, corruption at the checkpoint was already deeply embedded. The 1990s brought economic crisis, shortages of consumer goods, weak state capacity and rapidly expanding informal markets. Smuggling became a profitable survival strategy. Border officials could be bribed to overlook undeclared goods, counterfeit products and tax evasion. Duty-free shops in the "no man's land" between Bulgaria and Türkiye became hubs for smuggling cigarettes, alcohol and petroleum products. Corruption operated at multiple levels: everyday exchanges between traders, drivers and officials, often based on long-standing personal relationships, at the lower level connections between politicians, senior civil servants, business elites and organised crime at the higher level. Smuggling routes required political protection. Profits flowed upward through patronage systems. EU accession changed the rules of the game Bulgaria’s EU accession radically transformed the legal and institutional environment. The country had to align its customs regulations, VAT rules, excise tax systems, phytosanitary standards and border procedures with EU standards – a gradual process requiring significant investment. The reforms affected almost every aspect of border governance. Customs procedures became increasingly digitalised. New systems such as the VAT Information Exchange System VIES and the Excise Movement and Control System EMCS improved cross-border monitoring. Phytosanitary and veterinary inspections became stricter. Migration controls tightened through alignment with Schengen rules and access to systems like the Schengen Information System SIS and international databases of stolen documents and vehicles. Meanwhile, new border control technologies – X-ray machines, scanners, thermal cameras and risk-analysis tools – expanded the state’s capacity to detect illicit activity. From a policy perspective, this appeared to be a modernisation success story. But criminal systems rarely remain static when the environment changes. Corruption did not decline – it adapted The most striking finding is that stronger controls often increase the strategic value of corruption. After EU accession, crossing the border illegally became more difficult, risky and expensive. Corruption became necessary not only to speed up procedures but to bypass sophisticated control and regulatory systems. In other words, modernisation transformed the function of corruption: Criminal actors began targeting specialised procedures, such as food safety inspections, VAT systems, automated license plate recognition, laboratory testing and digital customs controls. VAT fraud and the manipulation of digital systems VAT fraud illustrates this adaptation clearly. Within the EU, exports are often subject to a VAT rate of 0 zero percent, which means companies can reclaim any VAT they have already paid domestically. Criminal actors exploited this through "carousel fraud" schemes involving fictitious transactions chains. At Kapitan Andreevo border checkpoint, for example, corruption allegedly enabled traders to manipulate customs procedures. One method involved corrupt officials manually entering fake truck registrations into customs systems to simulate border crossings, enabling fraudulent VAT refunds for exports that never occurred. Even more revealing was the manipulation of automated license plate recognition: corrupt actors reportedly disabled automated recognition and manually entered altered plates using Cyrillic characters resembling Latin letters, allowing smugglers to bypass alerts and inspections. This illustrates a pattern seen in many modern corruption systems: digitalisation does not automatically eliminate corruption. Instead, corruption turns towards the technological systems themselves. Food safety, privatisation and rent-seeking EU food safety and phytosanitary regulations created new bottlenecks and forms of discretionary authority. The research describes two recurring manipulation strategies: selective sampling during inspections, where officials took samples only from "clean" sections of shipments; and falsification of laboratory tests to certify unsafe products as compliant. These risks increased after some border functions were outsourced to private companies. At Kapitan Andreevo, food testing, parking operations and vehicle disinfection were privatised. This reform, intended to increase efficiency, allegedly created new opportunities for rent extraction. The controversy surrounding Eurolab 2011, which reportedly obtained monopolistic control over food safety testing under questionable legal arrangements became emblematic of these tensions. The broader implication: privatisation of public functions does not necessarily reduce corruption risks. It can shift them into hybrid public-private arrangements where accountability is weaker and oversight is more fragmented. The rise of “routinised” corruption The study highlights the increased organisation of corruption itself. Today, no single official can independently guarantee a smuggling route. Procedures involve multiple agencies, overlapping inspections and layered oversight. As a result, corruption evolved towards collective coordination. Customs officers, border guards, supervisors, intermediaries and sometimes political actors participate in networks where bribes are pooled and redistributed. These schemes resemble coordinated organisational systems with revenue-sharing mechanisms, internal hierarchies and protection structures rather than isolated rogue actors. This reflects an important conceptual change: border corruption can function as an embedded institutional ecosystem sustained through cooperation, mutual dependence and political protection. Drug trafficking: when corruption becomes too risky Interestingly, corruption is not always the preferred strategy. In drug trafficking, for example, the risks are dramatically higher. Border officials caught facilitating drug trafficking could face severe criminal penalties, including organised crime charges and lengthy prison sentences. As a result, traffickers increasingly invest in sophisticated concealment methods. One example is the "twin trucks" strategy: several nearly identical trucks carrying similar cargo cross the border simultaneously during heavy traffic, with only one of them containing drugs. Since inspection capacity is limited, the probability is high that the "clean" trucks are checked while the drug shipment passes undetected. This shows that corruption and criminality do not always go hand in hand. Sometimes, stronger anti-corruption measures push criminals towards deception and concealment rather than bribery. The bigger lesson: criminal systems are adaptive The case study of the Kapitan Andreevo border crossing is not just about Bulgaria. Policymakers often assume that more technology, controls and regulation will automatically reduce corruption and illicit trade. But criminal systems and corruption adapt. Informal networks reorganise around the vulnerabilities created by reforms. Every regulatory innovation creates new incentives, bottlenecks and opportunities for exploitation. This does not mean reforms are useless. Many EU measures have clearly strengthened border management. However, reforms must be designed with an understanding of adaptive behaviour. Otherwise, states risk producing unintended consequences: stronger incentives for bribery, use of alternative trafficking routes, technological manipulation, new forms of collusion or opaque privatisation structures. I and my co-authors argue for a more integrated approach that combines anti-corruption and anti-crime strategies. We also emphasise the importance of anticipatory governance and foresight-oriented policymaking that try to predict how illicit actors will respond to institutional changes before reforms are implemented. This may be the most important lesson from Kapitan Andreevo. Borders are not static lines defended by static institutions against static threats. They are evolving ecosystems where states, markets, technologies and criminal actors constantly adapt to one another. Learn more Access the full article, “The Evolution of Corruption and Crimes at Kapitan Andreevo Border Checkpoint: The Impact of EU Accession”. Read our Quick Guide 38 to border corruption for a short introduction. Read our Working Paper 58, “Corruption as a facilitator of drug trafficking in the port of Rotterdam” for a related analysis.
Four major developments in the fight against corruption through Collective Action
What are the four biggest developments in anti-corruption Collective Action in the last years? And what are some examples of these around the world? Gemma Aiolfi spoke on these topics to delegates at a Members Meeting of Etik ve İtibar Derneği TEİD – the Turkish Ethics and Reputation Society. TEİD is an inspiring cross-sectoral Collective Action initiative that has been working tirelessly since 2010 to promote business ethics in Turkey. Read her speech below or view it on here on YouTube. If you have any questions about Collective Action or want more details on any of these initiatives, please don’t hesitate to browse the B20 Collective Action Hub resource centre. You can get in touch with our team via our Helpdesk, a free advice service on anti-corruption Collective Action to promote fair business. Thank you for the invitation to speak at this important milestone event for the ethics and reputation society. May I congratulate you all on the commitment and engagement you all bring to addressing integrity and corruption related challenges. I’ve been asked to talk about examples of anti-corruption Collective Action initiatives from around the world. Before doing so I just wanted to mention four developments that are incentivising companies to engage in anti-corruption Collective Action. 1 Revised OECD Recommendation includes Collective Action for the first time The first is the revised OECD Recommendation published by the member countries of the Anti-Bribery Convention at the end of 2021. Among the new measures to reinforce efforts to prevent, detect and investigate foreign bribery, Collective Action is included for the first time. Member countries have to: “consider fostering, facilitating, engaging, or participating in anti-bribery collective action initiatives with private and public sector representatives, as well as civil society organisations, aiming to address foreign bribery and bribe solicitation.” This Recommendation will be part of the country monitoring process that the 44 member countries of the OECD Convention undergo on an ongoing basis. Quite simply, this means that governments will be asked to explain what they have done to foster, facilitate, engage or participate in Collective Action. So there is an international standard that is now encouraging the public and private sectors to get active and participate in Collective Action. 2 Collective Action becomes a key part of ESG and non-financial reporting Secondly, there is rapidly growing interest in corporate non-financial reporting, where companies explain how they address environmental, social and governance ESG issues. The largest organisation that publishes such information is the Global Reporting Initiative or GRI. GRI’s reporting standard on anti-corruption asks companies to describe whether they participate in Collective Action to combat corruption, including: the company’s strategy for its Collective Action activities; a list of the initiatives in which the organisation participates; a description of the main commitments of these initiatives. 3 Companies find synergies in human rights and anti-corruption Thirdly, there’s an increasing recognition in the convergences or overlaps between how companies are addressing human rights and corruption. These topics have much in common and are linked, but they also have important differences: Using Collective Action to share knowledge and experiences is a practical approach that some companies are already using given the new laws on human rights in order to keep up with these new developments. 4 Governments explore ways to engage with the private sector through Collective Action Fourthly, the Network of Corruption Prevention Authorities NCPA brings together government organisations from all over the world, many of which are responsible for drafting their national anti-corruption strategies. These strategies call on the private sector to prevent corruption. These authorities are now exchanging on their experiences and different ideas on how to engage with the private sector, including through Collective Action. Those are some of the developments in mainstreaming Collective Action. Let’s now take a look at some of the inspiring examples of Collective Action for companies. Collective Action in action – examples from around the world ------------------------------------------------------------ Measuring the effectiveness of anti-corruption compliance A question often asked by investors and boards is: How can you measure whether an anti-corruption compliance programme is really effective? This was a question posed by the one of the world’s largest investors – the Norwegian Sovereign Wealth fund manager – to a group of pharmaceutical companies. Together, they formed a Collective Action initiative to agree on key performance indicators to identify what an effective anti-bribery and corruption programme means in practice. The output was a set of indicators for companies to report on publicly. So far, two companies from the eight that participated in the Collective Action have published information about the quantitative and qualitative indicators of the effectiveness of their anti-corruption compliance programmes. This is probably the start of a discussion to identify more indicators of what is effective. This initiative is an example of how Collective Action can break new ground. It was the first to be inspired by an investor, and also to address a new area that is useful to companies. It may inspire other industry sectors to develop improvements to these basic indicators. Transforming beneficial ownership transparency in extractives industries The second example is the joint project of two major global Collective Action initiatives. Open Ownership and the Extractive Industries Transparency Initiative EITI are partnering to develop and deliver a new global programme called Opening Extractives. Opening Extractives aims to stimulate a real transformation in beneficial ownership transparency in the extractives industry. This will involve governments, companies and civil society publicly revealing the ultimate beneficial owners of their supply chain companies, and partners of the companies that engage in mineral and mining industries. This Collective Action could be a game changer in a sector that has long been associated with corruption risks, including kleptocracy and state capture. It's an exciting development because it brings together two well established collective action initiatives to tackle a really complex and political issue. We’ll have to see how it develops. Sharing compliance expertise between private firms and state-owned enterprises Compliance without Borders is a mentoring programme between state-owned enterprises and the private sector that was developed by the B20 and the OECD. It has been piloted in the last few months, and could be a great way for state-owned enterprises to benefit from experienced compliance officers in the private sector sharing their experience and expertise for free. At the same time, the private-sector compliance officers learn about the challenges of having to implement a compliance programme in a state-owned organisation. Developing industry-tailored anti-corruption guidance for high-risk industries The Natural Resource Governance Institute NRGI is a non-profit organisation that seeks to improve countries’ governance of their natural resources, with a focus on the oil and gas industry. Over a two-year period, the NRGI conducted a detailed desk review and analysis of corruption cases involving state-owned enterprises and their oil and gas corporate partners. They identified recurrent corruption issues and reviewed existing best practices in corruption prevention. Then they brought together, in a series of consultations, 15 of the largest oil companies plus state-owned enterprises and civil society stakeholders. The aim was to develop a new and tailored set of guidance that recommends measures that companies in the oil, gas and mining sectors should adopt to reduce corruption risks when partnering with state-owned enterprises. The Guidance also recommends measures SOEs can take to strengthen their anticorruption safeguards. The Collective Action entailed interviews with over 110 individuals and 50 companies from NGOs, companies, financial institutions, universities and a core group of 18 companies through closed-door workshops. The guidance breaks new ground for three reasons: It focuses on the business interactions between companies and state-owned enterprises – not on everything. For example, it does not cover gifts and entertainment because there’s already lots of guidance on that topic. It mixes basic and ambitious measures. Some can be implemented already, while others will take longer. It prioritises the public interest in the producing countries, rather than the company’s interest which is often the focus of compliance guidance. This means higher disclosure levels even if the entities are not legally obliged to do so, and stopping serious forms of corruption like kleptocracy where possible. This guidance could provide inspiration to other countries. There are SOEs everywhere in the world and many present similar risks to this industry sector. So the Collective Action methodology that the NRGI used could be applied in other sectors, other countries and to other corruption-related challenges.
Talking from experience – an interview with Tayfun Zaman
In an interview with Tayfun Zaman, Secretary General at TEID , Ethics and Reputation Society, and Founder and Director of Turkish Integrity Center of Excellence, Mr Zaman talks about his own professional experience of launching and participating in a Collective Action initiative for custom brokers in Turkey. This article first appeared this summer in the Basel Institute Institute on Governance Annual Report 2014. Can you please tell us about TEID, the Ethics and Reputation Society of Turkey? ------------------------------------------------------------------------------------------------------- The Ethics and Reputation Society – TEID, was established in May 2010. TEID’s main mission is to make business ethics the very basis of companies’ written culture in Turkey. It is also our aim to act as a reference centre in integrity risk management in Turkey. In this context, TEID establishes partnerships and affiliations with some of the most respected NGO s in the field, such as the Basel Institute on Governance. TEID currently has more than 100 corporate members, whose total revenues exceed 13% of Turkish GDP and who collectively employ approximately 200,000 people. TEID has initiated a Collective Action amongst customs brokers in Turkey.Could you tell us more about the background of this initiative? ---------------------------------------------------------------------------------------------------------------------------------------- TEID, in partnership with five local associations of customs brokers in Turkey Istanbul, Izmir, Bursa, Mersin and Ankara has prepared Customs Brokerage Ethics Standards governing business ethics and integrity risk management in customs-associated transactions and relations. At the unveiling of the initiative in 2013, 250 Turkish customs brokers signed the declaration of integrity. What are the main goals and operating procedures of the Customs Brokerage Ethics Standards? ------------------------------------------------------------------------------------------- The initiative seeks to combat corruption and integrity related barriers in customs operation with a holistic approach, through the partnership of NGO s, and both the public and private sectors. First, we try to address and manage the relationship between customs brokers and the customer in order to better manage integrity risks on behalf of the customer. Secondly, we promote fair competition in all business relationships involving customs brokers and their customers. Finally, the Customs Brokerage Ethics Standards includes commitments for combatting corruption in connection with interactions between customs brokers and public officials. Why have you chosen a Collective Action approach over another methodology and why do you think that Collective Action was the most promising one in view of the challenges that you were seeking to address? ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ As the private sector can play a part in the corruption problem in customs, it can also be a significant part of the solution. An adherence to standards of integrity and ethics by customs brokers in their business could thus be considered as an initial key step. A comprehensive Collective Action approach can further strengthen and support a successful integrity programme of individual customs brokers, increasing an individual company’s impact by making fair business practices more common and elevating individual action of vulnerable individual players such as small and medium sized enterprises, which compose the majority of customs brokerage operations in Turkey. Thus, this gives customs brokers a very important part in reducing corruption in customs through their role as agents of the private sector. In June 2014, the ICCA hosted an international conference on anti-corruption Collective Action, where you delivered an excellent presentation. Could you please share with us some of your thoughts and experiences on the event? --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- It was indeed a pleasure to take part in this important conference. I believe that it was a very productive event for me and for all of the participants, providing a unique opportunity to exchange with Collective Action practitioners from business, government, academia and civil society. The variety of topics and methodologies analysed in the presentations and discussions helped underscore effective methods and the value of Collective Action in the fight against corruption. It was an honour to discuss some of the successful examples, practical advice and lessons learned about collective action drawing from our recent experience in Turkey. Turkey is currently the host nation for the G20/B20, with a B20 Task Force devoted to Anti-Corruption. What will be B20 Turkey’s approach to anti-corruption? ------------------------------------------------------------------------------------------------------------------------------------------------------------- The B20 and G20 this year are focused heavily on implementation, and thus B20 Turkey will build upon recommendations and action plans of the 2014 B20 Anti-corruption Working in ACWG in Australia and the G20 ACWG. For example, one B20 Australia Recommendation calls for endorsement of the G8 core principles on transparency of ownership and control of companies and legal arrangements. G20 leaders answered positively to this recommendation, and thus B20 Turkey will focus on this as an area for implementation in 2015, with actions to be further detailed and carried out over the course of the year. In addition, B20 Turkey’s approach for 2015 will also contain an important Collective Action component, again in relation to the area of customs brokerage. That is a very topical idea, in light of your experience in this field. What are your recommendations to B20 with regard to Collective Action in customs brokerage? ------------------------------------------------------------------------------------------------------------------------------------------------------------------- Model a collective action tool-kit to be used by the local associations of customs brokers in all G20 Countries to promote and facilitate parallel collective action initiatives Prepare a customs-focused integrity guideline equipped by sector specific risk definitions, regulations and solutions Create sector specific tuning based on the integrity barriers defined by a TEID / OECD Survey Conduct a corruption focused survey in Turkey to identify corruption risks and barriers in customs operations Create and publish a “case for change” showing the return on investment for customs agencies of each G20 country that combats corruption Compile an online repository of innovative uses of technology and analytics, apps, data platforms, case studies in mitigating corruption risk at customs in G20 countries Monitor adoption and effectiveness of new technologies in customs in five pilot G20 countries. You have recently founded and lead the Turkish Integrity Centre of Excellence TICE . What are the aims of this institution and how do you see it further promoting business integrity and Collective Action? ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- We have established TICE in 2014 with the mission of levelling the playing field, by including and engaging the private sector in the fight against corruption, based on the recognition that businesses seldom have appropriate expertise to implement internationally developed anti-corruption and good governance guidelines and standards. Also, it was noted that the assessment of how companies improve their practical implementation of these standards is difficult due to the lack of coherent data regarding socio-economic effects of corruption on leading sectors of the local economy. Further, especially smaller companies, whilst they might have defined some sort of ethical standards, often do not have a compliance program through which they integrate those standards into their written corporate culture and into their corporate practice. Consequently business ethics remain a soft skill for the companies rather than a value and an asset to be measured, reported and effectively managed. The vision of TICE is to create a cultural change in the Turkish private sector to address this problem. To this end, TICE amongst others is dedicated to training compliance officers who will effectively manage integrity risks for their companies. Collective Action will play a very important role in this cultural change.
Participation in 5th International Ethics Summit in Istanbul
The Basel Institute supported the 5th International Ethics Summit ‘Understanding Today, Inspiring Tomorrow’, hosted by the Turkish organisation TEID in Istanbul on 17 June 2015. The conference was dedicated to discussing how concepts such as responsible citizenship, sustainable production, innovation, ethics and reputation can be integrated into a successful company alongside making profits for shareholders. Some 250 interested participants from the private and public sectors joined this discussion led by leading Turkish and international officials and business leaders. Gemma Aiolfi, Head of Corporate Governance, Compliance & Collective Action at the Basel Institute, spoke at the conference on creating positive incentives for companies to implement comprehensive anti-corruption risk prevention programmes, and about Collective Action as an innovative tool to implement ethical business conduct in exposed sectors.
Unity makes strength
As the problems created by corruption affect society as a whole, everyone would benefit from its eradication. Unfortunately, however, perceptions of corruption may not always align with this view which is why it is of utmost importance to raise awareness of corruption by way of education and training, and greater knowledge of the consequences of corruption may enable its elimination. That being said, corruption cannot be tackled alone, and the concept of Collective Action could ensure that businesses have the opportunity to use the power of unity to make a difference. What is Collective Action? -------------------------- As its name suggests, Collective Action is the idea that everyone should join forces and act together in the fight against corruption. Within this concept lies the belief that not only the government should be responsible for anti-corruption matters, but that everyone should come together to take initiatives. Moreover, this method for fighting corruption is founded on the principle that vulnerable stakeholders might not be capable of fighting corruption on their own, but once they unite with a common goal, they may get one step closer to eliminating corruption. All in all, Collective Action gives businesses the opportunity to come closer to demonstrate their compliance and commitment to fighting corruption. The implementation of Collective Action is especially important in regions deemed to be exposed to high-risk of corruption. This is because emerging markets seem to suffer from generally inadequate or unenforced anti-corruption legislation and consequently, engaging in Collective Action would be more effective to overcome corruption risks. In the case of Turkey, existing legislation is quite extensive and thus provides adequate tools to combat corruption in theory. However, the issue lies more with their enforcement, an aspect that deserves more attention when fighting against corruption. The World Bank illustrates four types of Collective Action: i anti-corruption declaration, ii principle based initiatives, iii integrity packs and iv certifying business coalitions. That being said, any collaboration to fight corruption shall amount to Collective Action. Perception and awareness of corruption -------------------------------------- TUSIAD, the Turkish Industry and Business Association, an independent, non-governmental organisation aiming to promote public welfare, undertook a project to find out what the business perception of corruption is, with the aim to create awareness on corruption and discuss policy recommendations. In the framework of this project, TUSIAD interviewed many businesses, of which about half were directly integrated with global business, and conducted a survey, enabling a closer understanding of the perception of corruption. Based on the outcome of the TUSIAD project, one may conclude that perception and awareness of corruption in Turkey is still problematic. Worryingly, 26% of the 801 respondents of the study conducted perceive corruption as quite frequent and 10% as extremely frequent and 27% of the 801 respondents perceive corruption in quite large scale and 10% as extremely large. The surveyed companies were also divided into small, medium and large enterprises, showing the differences in perception between them. According to the results, small companies perceive corruption to be extremely frequent by 15% and quite frequent by 30%. The perception of frequency on part of medium companies is of 7% perceiving it as extremely frequent and 22% as quite frequent, and large companies perceive corruption as extremely frequent by 2% and quite frequent by 26%. Concerning the perception as to the magnitude of corruption, small companies perceive corruption to be extremely large by 16 % and quite large by 31%, while medium companies perceive it as extremely large by 6 % and quite large by 22% and large companies as extremely large by 2 % and quite large by 26%. This shows that larger companies have a tendency of lower perception of frequency and scale, perhaps due to the existence of more articulate corporate policies and control mechanisms. Moreover, a total of 39% say that they believe corruption is increasing and 46% affirm that it will keep rising in the future. However, most of the respondents do not consider corruption as a problem. Even more worryingly, 37% of the respondents who said they do not perceive corruption as a problem also stated that corruption will increase. When read together the two following results demonstrate the problem with corruption perceptions: the construction sector perceived the highest rate of corruption, with 55% perceiving it as frequent and 56% in large scale. However, it was noted that, despite the perception that corruption was frequent and in large scale, the construction sector does not perceive corruption to be problematic. An important point to note is that the business community seems confused as to what constitutes an act of corruption. It is unclear to many where they must draw the line, and they are thus sometimes unable to figure out what would or would not be deemed corruption. The survey contained examples of different types of actions, asking the participants whether they perceived them as corruption or not. This part of the survey proved that there is a pressing need to raise awareness in order to ensure that the businesses know what constitutes compliance. In the most worrying example, while a majority found that offering advantage to public officials to procure an irregular service absolutely constitutes corruption, a considerable percentage chose to answer that this ‘ can be considered’ corruption, illustrating their uncertainty as to the matter. Following the same line of thought, it has come to light that some people give bribes with the perception that this is a good deed. This illustrates once again to what extent confusion in the minds of stakeholders’ causes corruption to persist. Moreover, 46% of the businesses taken into consideration for this study did not have a code of ethics or a corporate policy. When there are no such guiding principles and policies, this creates an environment of lack of education on the matter and lack of structure and framework to fight corruption. Moreover, similarly to stakeholders not being able to distinguish between what does or does not constitute a bribe, stakeholders are also mostly unaware whether other participants have engaged in corrupt behaviour. This is caused by the secrecy of such behaviour and is influenced by the confusion as regards to what constitutes corruption. This environment of information asymmetry feeds corruption and enables it to persist. This is an aspect within the fight against corruption where companies can take concrete steps, by informing and training their employees and implementing adequate mechanisms. Adopting compliance programs or anti-corruption programs within private companies would help achieve great progress in the fight against corruption and it would create awareness on the matter among stakeholders which would help tackle the issue of reporting corruption. According to the survey, 60% of the participants have affirmed that they would not report corruption, even if they were aware of it. When asked why they would not do so, their answer in 30% of the cases was based on the lack of a reporting mechanism. It is of paramount importance to make sure that training and compliance mechanisms are enforced, to enable reporting of corruption. Companies should communicate the message that reporting corruption is a duty towards the company, and thus give the opportunity to identify, sanction and ultimately eradicate corruption. Consequently, the project, among others, comes to the conclusion that the fight against corruption should be a united one, namely through Collective Action. This way, collective action can help overcome corruption by changing the general perceptions, making compliance the norm, raising awareness among the participants and isolating bad participants. Collective Action can be beneficial in the fight against corruption as it can take place on every level and stage, and any type of declaration or monitoring action which would eliminate information asymmetry and bring parties together would be deemed a Collective Action. Collective Action, especially coming from the business sphere, brings hope in changing the corrupt behaviour and perceptions in place. Companies setting the tone, implementing effective monitoring mechanisms and compliance programs, while sticking together and isolating the wrongdoers could be one of the most effective ways to overcome the problem of perception, and changing behaviour for the better. The TUSIAD survey also inquired whether participants thought Collective Action would be of benefit in Turkey. To that end, 66% to 77% of respondents believe that the use of Collective Action could in fact prevent corruption or at least increase awareness in the field. However, 54% of the participants expressed concerns on whether the Collective Action is legally binding and on the existence of monitoring mechanisms and sanctions. This is actually a general criticism towards Collective Action, as one could argue that if one is not obeying the law, one would not keep promises made to other parties either. In that sense, it seems like Collective Action would progress significantly better through monitoring initiatives. Moreover, it can be suggested that Collective Action should not be left up to the private sector completely, and civil society organisations could take the lead in gathering the public and private sector to achieve more effective results. NGOs and civil societies ------------------------ Occurring in the private sector, Collective Action would require competitors to trust each other and share sensitive information, an aspect that could hinder Collective Action to be established easily. To ensure that this tool remains effective, facilitator institutions, such as civil society organisations or NGOs must take action, making it possible for concerned parties to unite. Moreover, such organisations, creating the opportunity to fight collectively will increase the impact and credibility. The role of such facilitators is to bring stakeholders together and provide a neutral platform, to share and provide advice on the best-practices and to nominate external monitors or auditors. The unity created by such organisations will provide the whole matter with strength and importance. Participants will keep in mind a common intention, as opposed to trying to further only their personal benefits, and thus work towards achieving a common goal. Taking each personal capacity and uniting them as a whole will not only help achieve the group’s objectives with each participant making a contribution, but will also help influence other stakeholders. The more people are part of a Collective Action, adhering to rules of anti-corruption and conducting clean businesses, the more this becomes the norm and stakeholders will find themselves obliged to act accordingly, not only for the sake of clean business, but also for the sake of retraining their market share and competitiveness. The importance of unity is famously reflected in the saying of Aristotle ‘the whole is greater than the sum of parts’. NGOs and civil society organisations would benefit from Collective Action in the areas of improved access to essential resources such as healthcare and education, higher quality of products and services, increased trust and confidence in business, consistent and fair enforcement regulation and greater traction for their objective of more transparent environment and more attention to corrupt practices as well as better social development when and where the financial resources are invested in social projects instead of corrupt acts and bribery. Moreover in a general manner, Collective Action tends to be more successful if conducted by a neutral supporter. In conclusion, one of the targets in the fight against corruption should be to achieve adequate education, awareness and the correct perception on matters of corruption, enabled by Collective Action and the collaboration of NGOs with the stakeholders. These initiatives will be most effective if conducted as a united force, fighting against corruption hand in hand. Gönenç Gürkaynak is Managing Partner, and Ç. Olgu Kama a Partner at the Turkish law firm ELIG, Attorneys-at-Law, where Tahnee Türker is Associate.