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Interpreting the UK Government’s Anti-Corruption Plan

Written by Robert Barrington on Thursday, 18 December 2014

The Government has today published its first ever Anti-Corruption Plan, with 66 Actions in a 60-page document.  Such plans are only as good as the political will and resources behind them: so how does it all stack up?


The Government has today published its first ever Anti-Corruption Plan, with 66 Actions in a 60-page document.  Such plans are only as good as the political will and resources behind them: so how does it all stack up?

We should be in no doubt: this is a ground-breaking document for the UK.  It recognises the threat that corruption poses to the UK’s society and economy, shifting the long-standing narrative of the UK establishment that corruption happens overseas but not here in the UK.  It’s the first time there has been such a plan, and so of course it has weaknesses.  There is a nagging doubt about political will, implementation, and the possibility of it being undermined by turf wars.  But credit must go to those involved, from the Prime Minister to the civil servants, for a substantial and important step forward in the UK’s fight against corruption.  The UK should feel slightly prouder of itself this morning.

Let’s start with the good news.  It’s a good plan, and in places first class.  It is particularly strong on the framing and context-setting – gathering phrases and ideas that have been in miscellaneous speeches and publications over the past 2-3 years and putting them into a more coherent strategy.  The Plan shows a good overall understanding of the problem of corruption and of the impact that it can have.  It draws widely on research and thinking from several government departments, law enforcement agencies, resources-resources-business and civil society.  

And now the less good news.  The Plan was due for launch in June, when it was apparently ready; and was then postponed until ‘before the end of the year’; and has now been left to almost the last possible date, just as we enter a long holiday period and then go straight into the pre-election period.  This would not matter except that such plans only ever work if there is political will behind them and if it is someone’s priority.  The government is sending out very mixed messages.  The post of Anti-Corruption Champion was left vacant for four months this year.  It is talking about abolishing the Serious Fraud Office, the only law enforcement body in the UK that has corruption as one of its top two priorities. And only this week, the Audit Commission’s renowned Counter-Fraud unit was suddenly closed down, and not transferred to another body as had been planned.

Yet set against this sorry picture of prevarication and inter-agency turf wars is the fact that this Government has said more about corruption than any UK government in living memory.  The Prime Minister has won huge respect on the international stage for his support for transparency, open governance, and new Sustainable Development Goal on governance.  This is the Government that signed the UK up to the Extractive Industries Transparency Initiative, has resisted pressure from a powerful minority of dinosaurs in industry to weaken the Bribery Act and has committed to creating a public register of company ownership.

This is mixed messaging at its most confusing.  Looking at the Plan itself, here’s a quick analysis of some strengths and weaknesses – TI will be publishing a more detailed critique in due course:

Five Strengths

The Plan recognises some of the key structural problems – such as lack of coordination, lack of data, lack of public and institutional awareness – and sets out how they will be addressed.

It is wide-ranging: encompassing many areas from local government, to defence, to sport, police, politics and overseas aid.  That correctly recognises the wide-ranging threat from corruption.

Good, joined-up thinking. A past problem has been that tackling corruption has been the job of everyone and the priority of no-one.  The Plan announces a new inter-ministerial group and a dedicated support unit in the Cabinet Office.  It acknowledges the links between international and domestic corruption.  

Inclusivity.  The Plan rightly recognises that government can’t deliver this by itself – it needs help from trade and professional bodies, resources-resources-business and civil society.  A challenge for trade and professional bodies will be for them to commit to and enforce the highest ethical standards, and not the lowest common denominators of their membership.

Acknowledging the UK’s international role.  This is not just in increasing global standards and in international development – both strong areas in the plan; it’s also in the critical role for the UK in global money laundering and asset recovery, and the objective of ‘denying a safe haven to the proceeds of corruption’.  There is even a warning shot to the Overseas territories, for too long the UK’s Achilles heel on corruption (sections 7.23-7.28).

Four Weaknesses

Imprecision – some of the actions are embarrassingly vague such as a commitment to ‘consider what further steps are required’ (Action 23) and ‘examine the case for a new offence’ (Action 35).

Patchy on some of the key areas – such as prisons (one of the big problem institutions for corruption, but with one very weak action (Action 14) and no sense of a strategy), parliament (clearly a very difficult area for a government plan as Parliament is self-governing – recognises the problem but proposes generally poor solutions including citing the laughably bad Lobbying Act (section 4.28), and ignoring much of the good work of the Committee on Standards in Public Life) and sport (great to have it in, but focuses on match-fixing (Actions 30-32) not sports governance – ironic when more column inches and public outrage on corruption are directed at FIFA than any other area of corruption).

Assumptions.  Some of the departments asked to contribute have rather flattered themselves.  Do we really believe that ‘Prison staff are well trained’ on corruption (section 4.9) – not according to our 2011 report; and that the big threat on corruption in defence is dastardly foreign companies gaining contracts at the expense of responsible British contractors?

Private sector.  It’s light in this area, at times not sufficiently acknowledging that the private sector is part of the problem, and not simply a delivery partner for the solution.  This is a particular problem when public services are contracted out to or delivered by private sector companies operating to different standards of integrity.

Some key questions arising from the Plan are these:

  1. Action 17 – risk assessment.  The Ministry of Justice Guidance to the Bribery Act suggests this is the foundation of an anti-corruption procedure for a company, and it is equally the right starting point for public bodies.  The Plan does not specify which departments or agencies will be asked to undertake a risk assessment, how they will be selected, whether this will be voluntary or obligatory, and what if any details would be published.  What will happen?
  2. Sustainability.  The Plan contains actions going through to April 2016.  What we don’t know is which parties are committed to the Plan after the May 2015 general election.  What guarantee or commitment is there that the new Cabinet Office unit will be continued?  Is this a one-off plan or will there be others?
  3. Accountability.  The Plan is vague on this, noting that the Champion reports to Parliament but in an unspecified manner.  Will the Government commit to delivering an annual report to Parliament (possibly a specified Parliamentary Committee?) on progress against the Plan?

​TI has written elsewhere about threats to the SFO and the separate plan – which we support in principle – to consolidate different anti-corruption law enforcement units within the NCA.  It is difficult to read the sub-text in the Plan in phrases such as ‘the Government will review the enforcement response to bribery and corruption more broadly’.  If that means trying to abolish the SFO through the back door – well, read the criticism that has been heaped on this idea by the legal profession, prosecutors from other countries and civil society.

Finally, a word on defence, in which the Plan specifically mentions that the MoD will ‘respond to Transparency International recommendations’.  We have in our TI-UK chapter a global Defence & Security team, who are the acknowledged world experts in corruption and the defence sector.  Here’s their view of the Plan:

  1. The steps included in the plan lack the breadth we would like to see. There are individual defence actions  that are positive—improving whistleblowing policies, conducting an assessment of corruption risks across the MOD, and providing awareness-raising sessions for new MOD recruits. The plan also recognises the threat corruption poses to stability worldwide. 
  2. The government does not address the potentially corrupting role of UK arms sales abroad, which is a significant shortcoming. This issue should be addressed by BIS, the FCO, the MOD, and DFID. At particular risk are  government-to-government deals, such as the “SANGCOM” deal with Saudi Arabia currently under investigation by the SFO.
  3. The plan also does not mention the preparation of UK troops for military operations abroad in respect of corruption threats, which has been brought to the fore by Iraq and Afghanistan.

Of course, we look forward to seeing the MoD’s response to our recommendations in March.​

While looking at the strengths and weaknesses, let’s not forget that tackling corruption is not easy.  It is usually a secret and insidious crime, whose victims are unaware of the cause of the impacts they suffer, and is sometimes perpetrated and defended by the most respectable-looking people with huge resources at their disposal.  Once it takes hold, it is very hard to root out.  Many countries have tried and failed.  But Britain already has a track record of success – a transformative couple of decades in the nineteenth century saw the country changed from one in which you could bribe a judge to win a lawsuit and buy a seat in Parliament into a country with strong public and private institutions that recognised the value of probity and integrity.  This has come under threat in recent years.

The Government is right to act now before it is too late; it has not shied away from the challenge, and this Plan is an excellent starting point.  We give it a qualified welcome: good plan, political will yet to be proven.



Read 4470 times Last modified on Wednesday, 11 November 2015 10:07

Robert Barrington

Robert is TI-UK's Executive Director. You can view his full bio here, and tweet him @TIukED.

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