News 08th Oct 2020

Untangling the Gordian Knot? The UK’s promising start in measuring the progress of its anti-corruption efforts

Matt Jenkins

Research and Knowledge Manager

Matt is a Research and Knowledge Manager at Transparency International. He operates the Anti-Corruption Helpdesk, where he specialises in donor agencies’ anti-corruption interventions. He also leads the research component of Transparency International’s SDG engagement, developing and testing bespoke governance indicators as well as coordinating data collection by TI’s network of national chapters. In addition, Matt has produced an e-learning course on tackling corruption across the SDG framework in association with the University of Leiden. Previously, he worked for the European Commission and several think tanks in Berlin and Hyderabad.

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The UK recently released its second annual update to the 2017-2022 Anti-Corruption Strategy, publication first having been delayed by the 2019 general election and then by COVID-19.

There is much to digest across the six areas of review, which range from insider threat to international finance, public procurement, international collaboration and more. For a quick recap of the Strategy’s broad strengths and weaknesses, I highly recommend a concise overview from a previous Transparency International UK blog.

In this post, I’ll be focusing on a novel feature of this annual update: a dashboard of indicators intended to provide a picture of the UK’s progress towards the Strategy’s three long-term outcomes:

  • reduced threat to UK national security;
  • increased prosperity at home and abroad; and
  • enhanced public confidence in domestic and international institutions.

Before going any further, I should come clean. I work for the Anti-Corruption Helpdesk, run by the Transparency International Secretariat in conjunction with the U4 Anti-Corruption Resource Centre. We were approached last year by the UK’s Joint Anti-Corruption Unit (JACU) with a request to identify indicators that could be used to develop a monitoring framework to assess the UK’s performance in areas prioritised by the Strategy. After we provided them with a background paper presenting a menu of options, JACU held a broader consultation with other government departments and civil society groups before finalising their selection.

Not all our suggestions were taken on board. Nonetheless, it is encouraging to see that the UK is keen to go further than just publishing the government’s own appraisal of its progress in implementing the activities foreseen in the Strategy (see the Commitment tracker in Annex B). Indeed, the indicators listed in Annex A help to provide a more rounded view at the outcome level by way of reference to third party measurements.

While any attempt to link the Strategy to such indicators must (and does) come with a host of caveats cautioning against implied causation, this is an admirable effort at consolidating and baselining a wide range of relevant governance assessments. JACU has generally selected indicators for which data is regularly collected and scores are available dating back several years, noting that “many factors […] can influence these measures but we can use them to monitor patterns and trends over the life time of the Strategy.”

Having said that, parts of the accompanying text that seek to interpret changes in score arguably read too much into relatively small year-on-year changes. I would instead encourage users of the dashboard not to fixate on these fluctuations but rather to step back and consider the bigger picture as an agenda for action. In which policy areas is the UK performing comparatively well on anti-corruption? Conversely, where the UK should prioritise its anti-corruption efforts?


Merits of the conceptual approach

Particularly welcome is the so-called “indicator basket” approach adopted. The Strategy update provides five baskets of around half a dozen indicators each, which can be broken down into two distinct tiers.

First, a specific basket has been developed for each of the three outcome areas: security, prosperity and trust. These three baskets are primarily composed of specific, disaggregated indicators drawn from a wide range of governance datasets, which bear a clear conceptual link to the given outcome area and are thus at least somewhat sensitive to targeted policy interventions.

Second, there are two additional indicators baskets that provide a picture at a higher level of abstraction, one focused on the robustness of anti-corruption safeguards such as transparency and stakeholder engagement, the other looking at global composite corruption indices. In other words, the former is about the risk of corruption, the latter about the (perceived) incidence of corruption. While the scores in these two baskets are unlikely to change dramatically during the lifecycle of the Strategy, these indices nonetheless provide a useful illustrative impression of how the UK is performing relative to other countries in terms of controlling corruption.

The basket approach is a pragmatic response to the fact that, as the Strategy notes, governance and corruption are complex, multi-dimensional phenomena. All indicators have weaknesses, and a single indicator is not sufficient to obtain a comprehensive understanding of the state of affairs and to identify possible points of intervention. The basket approach has the advantage that it can include a number of complementary indicators that draw on a variety of both objective and subjective types of data, including experiential and perceptions-based datasets, expert assessments, administrative data and where available citizen-generated data. The approach taken by JACU thus allows it to generate a more comprehensive picture based on the views and experiences of experts and citizens, while mitigating the risks of making decisions based on misleading data.


The missing piece of the puzzle: administrative data

Perhaps the key disappointment with the dashboard of indicators is the lack of administrative data included. The one real exception is the “number of corruption-related offences reported to the police”, which relies on data collated by the Office for National Statistics.

Of course, administrative data has its own limitations. Its utility depends on the impartiality of law enforcement agencies and the courts, the record-keeping and monitoring capacities of public bodies, and consistency in the use of statistical definitions across subnational units (different police forces, regional administrations and so on).

Administrative data is nonetheless a vital complement to other types of data. It has the advantage of being relatively straightforward to track over time and can be useful to identify areas of concern in institutional setups and procedures, thereby helping to prioritise reforms or other anti-corruption measures.

Future rounds of the update would do well to prioritise efforts to systematically collect and report relevant administrative data in line with the Strategy’s commitments 7.3 Improve how corruption is reported in national crime recording and 7.5 Improve the quality and breadth of relevant anti-corruption related open data releases by government.

A starting point could be to include indicators drawing on statistics of corruption cases, such as:

  • the number of investigations under relevant legislation such as the UK Bribery Act;
  • the number of serious and organised crime disruptions related to bribery and corruption;
  • the number of successful convictions;
  • the number of unsuccessful prosecutions (and reasons for failure);
  • the number and value of fines handed out.  

Admittedly, some of these figures may not be readily available given the difficulties in accurately recording administrative information mentioned above.

Nonetheless, while the update notes that in the longer term the ambition is to “utilise information from across Government and law enforcement to collect administrative data”, there are already a number of existing datasets that could have been referred to. The 2018 FATF Mutual Evaluation Report, for instance, notes that UK authorities launch around 7,900 investigations and 2,000 prosecutions annually, and achieve 1,400 convictions for money laundering each year. Further data could be drawn from the Crown Prosecution Service and the police, and other watchdogs, such as the Independent Office for Police Conduct or even the NHS Counter Fraud Authority, may generate other relevant data.


The need for a more expansive view of corruption

In fact, beyond figures on corruption cases captured in law enforcement statistics, there is also great potential for the UK to systematically report on “softer” forms of corruption and misconduct that typically result in administrative penalties. This could include breaches of codes of conduct, noncompliance with lobbying regulations, failure to declare or report interests and assets accurately, illicit acceptance of gifts and hospitality, and so on.

Here, relevant existing data sources may include reports by the Independent Advisor on Ministerial Interests, the Propriety and Ethics team and Advisory Committee on Business Appointments (ACoBA) or statistics of complaints received by Parliamentary Commissioner for Standards and Standards Committees.

The speaks to a more fundamental need to understand that corruption is not only about bribery and embezzlement, but also encompasses a range of behaviours such as nepotism, cronyism, as well as the unethical exploitation of conflicts of interest, the revolving door between regulators and the private sector, undue influence over policymaking, cash for access and so on. Given the furore surrounding the Westferry Printworks scandal, it may be surprising to outside observers that issues relating to money in politics are noticeably absent from the indicators.

These types of behaviour, and the headlines they generate, potentially already influence a number of indicators included in the dashboard, particularly citizen trust in institutions and the business community’s confidence in the impartiality of the public sector. Complementing these perception-based measures with administrative data would allow for the triangulation of different data sources to verify whether they point to the same trends.


Capturing progress at home and abroad

The formulation of each of the UK’s three primary outcomes makes it clear they all have both a domestic and an international aspect:

  1. Reduced threat to UK national security, including from instability caused by corruption overseas.
  2. Increased prosperity at home and abroad, including for UK businesses.
  3. Enhanced public confidence in our domestic and international institutions.

The international angle is something that we at the Helpdesk wrangled with when considering which indicators could be useful, and I’m sure JACU has too. Any attempt to measure the UK’s contribution towards global (anti-)corruption is likely to encounter the attribution problem. Isolating the impact of UK action overseas – be this aid, trade or diplomatic – from other background activity in other countries is extremely challenging.

It is thus not surprising that the UK indicator dashboard focuses primarily on the domestic aspect, though reference to the FATF Mutual Evaluations, the Financial Secrecy Index and Transparency International’s own Exporting Corruption report relate to aspects of transnational corruption over which the UK can exercise direct influence, such as active enforcement of the OECD Anti-Bribery Convention.

Nonetheless, there is perhaps potential in future to develop additional indicators that touch on the role of the UK in broader transnational forms of corruption. For instance, input indicators could be designed to measure the level of resourcing provided to law enforcement agencies to work on international corruption cases. For example, a specific indicator could be funding and staff for the National Crime Agency’s International Corruption Unit and the Serious Fraud Office.

A matching output indicator might refer to the number of Unexplained Wealth Orders or Account Freezing Orders secured against suspected corrupt assets and accounts, the number of charges brought against suspects of foreign bribery, money laundering and so on. Finally, outcome indicators could be developed that count the number of successful prosecutions for international corruption cases or the amount of assets frozen and accountably repatriated to victims.

Again, this data may in many cases already be available. The UK’s 2018 FATF Mutual Evaluation notes that between 2014 and 2018, the UK restrained £1.3 billion and recovered £1 billion using the Proceeds of Crime Act, civil recovery and agency-specific disgorgement mechanisms. In addition, HMRC recovered a further £3.4 billion between 2016 and 2018 using its tax powers. Therefore, it should be possible to review how much of these totals relate to corruption, domestically or globally.

Another element of transnational corruption over which the UK exercises some considerable influence is in relation to its Crown Dependencies and Overseas Territories (CDOTs), which have not been included in the Financial Secrecy Index score provided in the indicator dashboard. There has been some notable progress in recent years, with most of the key financial centres in these jurisdictions (except the British Virgin Islands) committing to introducing open beneficial ownership registers. However, the Tax Justice Network notes that three of the four methodological options to combine the secrecy scores of the UK and its CDOTs “result in the UK and its satellite network of secrecy jurisdictions top[ping] the FSI by a large margin.”


Final thoughts

Attempts at measuring corruption usually elicit strong reactions. There are certainly some omissions in the dashboard and readers may think that additional indicators would have merited inclusion. Indicators from the Hansard Society’s Audit of Political Engagement, for example, provide a useful (and somewhat more sceptical) view about the British public’s trust in political institutions.  

Yet the document is candid about the limitations of the dashboard and JACU rightly points out that the purpose is not to be exhaustive. Rather, the purpose of the exercise is to select a broad range of different measures that bear some conceptual coherence to the goals of the Strategy and provide an indication of the general direction of travel.

Conceivably, an approach that draws on a variety of data providers will on occasion offer conflicting impressions about whether the UK is making progress. It certainly demands a careful and nuanced interpretation of what the data is telling us, yet this is surely preferable to overreliance on a couple of global composite indicators stubbornly insensitive to policy change.

In the words of a recent publication on governance indicators, it is to be hoped that this dashboard approach encourages policymakers to go beyond simply seeking to “game” the system to attain better scores in international rankings to instead “grasp the complexity of governance and policy-making” and link “problem diagnosis with potential solutions.”



Annex: provisional list of potential sources of administrative data


Additional administrative data could be drawn, among other sources, from the following:

  1. Convictions of a Misconduct in Public Office common law offence (note the Law Commission’s review and initial recommendations regarding reform of this offence) or an offence under Section 1(1) of the Criminal Law Act 1977 (conspiracy to commit misconduct in public office)
  2. Convictions relating to embezzlement under the Fraud Act 2006, Theft Act 1968, or common law offences of conspiracy to defraud or cheating the public revenue
  3. Breaches of the House of Commons/Lords code of conduct
  4. Breaches of the Ministerial Code
  5. Convictions under Section 10 of the Parliamentary Standards Act 2009
  6. Convictions under the Honours (Prevention of Abuses) Act 1925
  7. Convictions of bribery or treating under the Representation of the People Act 1983 (RPA 1983) (note the Law Commission’s views on the treating offence and the need for reform)
  8. Breaches of standards under the Localism Act 2011 (England only)
  9. Breaches of the Civil Service Management Code (in particular offences regarding gifts and hospitality)
  10. Findings of Serious Corruption in the police
  11. Convictions of corrupt or improper misuse of police powers and privileges (Section 26 Criminal Justice and Courts Act 2015)
  12. Convictions under Section 77 of The Freedom of Information Act 2000 (FOIA) (excl. Scotland) for altering records with intent to prevent disclosure