Tackling corruption overseas Contents

3DFID’s anti-corruption work

The need for a context-specific approach

68.Evidence to our inquiry has emphasised that there is no ‘one size fits all’ solution to corruption. Attempts to tackle it must be context-specific. Transparency International told us that, “addressing corruption always requires a country-specific approach, taking into account the general political and social context of the relevant country, particularly its political economy (i.e. an analysis of who benefits from corruption and who doesn’t)”.108 Christian Aid also emphasised that, “As corruption is different in different communities around the world, a case-by-case assessment is needed along with a degree of flexibility”.109 DFID told us this was also their approach, stating:

“DFID’s overall strategy to anti-corruption in partner countries is in line with recent evidence that makes it clear that there is no common template of actions for addressing corruption. Each country context is different, both in regard to the specific profile of problems and the opportunities available for tackling them.”110

69.The U4 Anti-Corruption Resource Centre told us that, “specific anti-corruption measures appear most effective when other contextual factors support them and when they are integrated in a broader package of reforms”.111 However, there is still limited evidence of ‘what works’ in these different country contexts. Aled Williams from U4 told us:

“There has been a lot of progress in recent years in the field of the challenges in measuring and characterising the different types of corruption that we see in different country contexts. However, this is still an evolving field where we must recognise that DFID is working in an environment where we still have limited understanding of the way that country contexts matter for anti-corruption outcomes.”112

Anti-Corruption Country Strategies

70.The Independent Commission for Aid Impact (ICAI) published a report in 2011, which was critical of DFID’s approach to tackling corruption. It called for more country-specific analysis of different types of corruption and the development of anti-corruption country strategies wherever there was a high risk of corruption.113 In response to this, in 2013, DFID published tailored anti-corruption country strategies for each of its priority countries. This country-specific approach has generally been welcomed, as Dr Marquette told us, “This is, in many ways, an excellent policy”.114 However, the strategies have also received criticism. Professor Heywood highlighted the difference in length and substance between the different country strategies; emphasising that whilst Mozambique’s strategy proposed specific interventions, Ghana and Rwanda’s strategies were “quite short and general”.115 He also raised the failure of the anti-corruption country strategies to “present any explicit theory of change (or reference DFID’s own commissioned review of 2012)”.116 This suggests that DFID is not making the best use of the research it has commissioned in its country-specific approaches.


71.Tackling corruption in countries where it is endemic takes a long time. Professor Mushtaq Khan of SOAS told us, “to achieve low levels of corruption throughout the developing countries DFID is working in will take time and concerted effort”. Phil Mason, Senior Anti-Corruption Adviser at DFID, concurred, stating: “All the academics and all our evidence show that changing a society around on corruption is a long-term effort”.117

72.DFID’s previous anti-corruption country strategies covered just three years (2013–2016).118 In oral evidence Professor Heywood told us, the “expectation that you can have an institutional fix that will have a real payoff in a three-to-five-year timeframe is pretty unrealistic”.119 In its 2014 report, ICAI recommended that the strategies must cover a ten to fifteen year period.120 Despite the weight of evidence, in its written submission to this inquiry DFID was clear that the new country strategies would only cover the next five years.121 Phil Mason told us:

“As an aid agency, programming in terms of our two or three-year time slice means we have to be realistic about what we can achieve. I don’t see any immediate, easy solution to suddenly being able to commit to a 20-year programme, for example, under the ways we have to work at the moment.”122

73.DFID’s evidence also stated clearly that the new strategies—to replace the previous country strategies that reached their three year completion date in January 2016—would be published in Spring 2016. The Government’s Progress Update on the UK Anti-Corruption Plan, published to coincide with the Anti-Corruption Summit in 2016, stated: “DFID has completed a review of its anti-corruption country strategies and has updated them to reflect how tackling corruption is fundamental to poverty reduction overseas and to strengthening our national security in the UK.”123 However, due to the significant delay in the publication of DFID’s Bilateral Aid Review (BAR), at the time of writing DFID’s anti-corruption country strategies had still not been published. Given the importance of tackling corruption, and the priority the Government has given to it, it is unacceptable that the new country strategies have still not been produced. DFID has given us some idea of what to expect, stating that the new strategies will “reflect a strengthened, more ambitious, approach […] The new strategies have an enhanced focus on how success is measured.”124 However, DFID has not told us when they will be released.

74.We welcome the introduction of DFID’s anti-corruption country strategies, following ICAI’s 2013 review. However, corruption is complex and deep-rooted and requires longer-term planning and commitment if it is to be addressed properly by DFID in the countries where it is working. The evidence presented to us strongly indicates that the five year plans proposed by the Government, although longer than the previous three year plans, are insufficient.

75.DFID’s future anti-corruption country strategies must cover a minimum timescale of ten years. Individual projects of three to five years may be undertaken as part of—but not in isolation from—a longer-term strategy. We understand the limitations presented by our five year political cycle in the UK and the need to monitor results and ensure value for money. However, this should not prevent an overarching country strategy from covering a ten year timescale. These strategies could retain enough flexibility to adapt to changing political and economic environments, and to allow for the kind of innovative and adaptive programming that is necessary to combat corruption, whilst ensuring a long-term financial and institutional commitment to tackling corruption in partner countries.

Other Government departments

76.Dr Heather Marquette highlighted the need for greater coherence between Government departments where they operate together in developing countries and, increasingly, where other government departments are spending ODA in developing countries. She told us:

“[…] there is need for country anti-corruption strategies to be whole of Government strategies. There is too much emphasis in this space on DFID: in any recipient country DFID is but one of many donors, but it is also only one of several HMG departments operating. While there has been a great deal of academic research on donors and anti-corruption, and several [two] ICAI reviews focused on DFID, we simply know too little about the role of the FCO, the MOD, BIS, DEFRA and so on when it comes to corruption and anti-corruption in developing countries. We know that foreign policy imperatives can undermine anti-corruption programming. But how often? Where? At what cost? For which trade-offs? At what cost (or boon) for development effectiveness? If we increasingly see aid as something delivered across HMG, and not just by DFID, then other Government departments need to be included in ICAI investigations and scrutinised more often by the International Development Committee. It is not good enough to shine the light on DFID alone when it is only one piece of a complex and moving puzzle.”125

The Bond Anti-Corruption Group called for similar action to ensure that, there was cross-departmental collaboration in DFID priority countries, and that DFID and the FCO were, “leveraging their diplomatic and financial influence” to encourage transparency and combat corruption. It also stated that, “DFID and the FCO should be collaborating with BIS [now the Department for Business, Energy and Industrial Strategy] and UKTI [now the Department for International Trade] to most effectively support British businesses operating in ODA target countries to identify, tackle, and prevent their engagement with corruption and, in particular, to mitigate its impact on people living in poverty and other marginalised groups.”126

77.DFID told us that they do work closely with other Government departments in countries such as Nigeria, where they state that, “the country strategy was a driver for greater joined-up working between different HMG departments and agencies, such as DFID, NCA [National Crime Agency], FCO and UKTI [UK Trade and Investment]. An anti-corruption working group meets regularly, and is currently collaborating on the design of an ambitious new corruption programme that links closely with the DFID-supported NCA unit that fights international corruption and bribery”.127 However, it is important that such collaboration is happening in all DFID priority countries, not just those—such as Nigeria—where anti-corruption measures are a high priority for both the Nigerian and UK governments.

78.In its submission DFID hints at a move towards a slightly different style of interventions in its new anti-corruption country strategies, which may take greater account of political economy and draw in other Government departments:

“These revised anti-corruption strategies will establish clear and ambitious anti-corruption expectations located in a broader, politically-oriented approach and articulate tactical choices on specific interventions that draw on all parts of HMG.”128

79.Other Government Departments (OGDs), aside from DFID and the FCO, are increasingly working in developing countries and using ODA to fund their activities. It is essential that the approach towards tackling corruption in any particular country is coordinated and coherent across all UK Government activity. We therefore welcome DFID’s commitment to producing enhanced anti-corruption country strategies which involve all Government departments. Given the increasing presence of OGDs in countries where DFID has bilateral programmes, it is essential that the Government’s approach is coordinated and coherent and that all officials are pulling in the same direction in their efforts to combat corruption.


80.There has been a significant delay in the publication of the new anti-corruption country strategies, caused by the overall delay in publication of the Bilateral Aid Review. Despite DFID’s evidence stating that the country strategies were being updated and “will be published in spring 2016”, to date they have still not been produced.129

81.We understand that political events, including the EU referendum and the Government reshuffle, have led to the delay in publication of the new anti-corruption country strategies. However, we are concerned that allowing domestic political changes to stall the release of important strategy documents for six months will have had an adverse effect on in-country programming, preventing country offices from progressing vital work.

82.DFID must publish its anti-corruption country strategies, alongside its overdue internal reviews and individual country plans, as a matter of urgency. Allowing vital policy documents to be stalled for so long is disappointing and risks hampering its efforts to tackle corruption in its priority countries, to the detriment of the countries it supports.

Research and learning

83.In comparison to other donors, DFID was described in evidence as, “a bit ahead of the pack […] in its sophistication of understanding” on corruption.130 However, the evidence still strongly suggests the need for further research, both on the nature of corruption in different contexts and the impact of donor interventions. This will help DFID establish ‘what works’ and enable it to formulate appropriate strategies to tackle corruption in its partner countries.

84.Evidence to the inquiry has suggested that donor interventions in anti-corruption have often been ineffective.131 However, there is a lack of solid evidence on why donor agencies are failing to achieve change on the ground.132 A review of evidence on donor interventions to curb corruption undertaken by U4 in 2012, had five key findings:

(1) For over half of the interventions examined, the findings of the evidence were mixed or even contested;

(2) For over half of the interventions, the evidence found was weak;

(3) Very little of the evidence comes from conflict-affected countries;

(4) Hardly any studies focused on the role of private sector actors driving corruption;

(5) There was little evidence on the interactions and interdependencies between different anticorruption interventions.133

These findings were corroborated in ICAI’s 2014 review into DFID’s Approach to Anti-Corruption and its Impact on the Poor which gave DFID a red rating for its learning in this area. It highlighted “that evidence of the effectiveness of anti-corruption interventions is weak in terms of quality and quantity”.134

85.DFID has in recent years, however, made considerable investments in research to investigate the contextual dynamics of corruption. An evidence paper entitled, ‘Why corruption matters: understanding causes, effects and how to address them’, was published by a team led by Alina Rocha Menocal in January 2015.135 In February 2015, DFID launched the £9.6 million Anti-Corruption Evidence (ACE) Programme to “deliver new, practical research on ‘what works’ to tackle corruption in developing countries”.136 DFID states that, “uptake of this new research by DFID and its partners will mean that anti-corruption initiatives are more effective and so corruption and leakage are measurably reduced. ACE will focus in 3–4 DFID priority countries drawn from a short list including Ghana, Uganda, Tanzania, Mozambique, Nigeria and Bangladesh.”137 The programme will consist of two components:

“A £3.6 million DFID-British Academy Anti-Corruption Research Partnership. The British Academy will design and let competitive research grants on testing ‘what works’ to reduce corruption.”

A New Anti-Corruption Research Partnership Consortium focussing on two themes: (i) the inter-dependencies between anti-corruption interventions and their impact on corruption; (ii) the private sector and economic growth.”138

There is also concern over the way in which research is then fed back into donor programming. Global Witness told us, “One of the biggest problems in current donor support for natural resource governance is that analysis of the context is either inadequate or ignored”.139

86.It is clear that more research is required to establish ‘what works’ when attempting to tackle corruption in partner countries. We therefore welcome DFID’s considerable recent investment in the Anti-Corruption Evidence (ACE) programme.

87.Alongside other donors engaging in anti-corruption work, DFID must allocate appropriate resources to establishing the effectiveness of its work in this area. Linking experience from country offices with its ongoing research will be crucial, as well as supporting new and innovative ways of working.

88.DFID has already invested in significant research into anti-corruption efforts. However, it must ensure that where research is being carried out, particularly but not exclusively where it is funded by DFID, its findings are being effectively fed back into the work it is conducting on the ground. DFID must ensure that it references relevant research and clearly shows the evidence base for the planned approach in each country when it publishes its new anti-corruption country strategies.

Fragile states

89.The new aid strategy commits to allocating 50% of DFID’s budget to fragile states and regions, an increase from its previous commitment of 30%.140 However, evidence suggests that the link between corruption and instability may not be well understood by policy makers and that anti-corruption efforts should be given higher priority.141.Written evidence from Professor Khan pointed out that, “while political corruption can have very damaging effects in many contexts, anti-corruption activities that threaten established patterns of resource capture can sometimes also contribute to further fragility”.142 Professor Heywood’s written submission stated:

“If we understand fragile states as those in which there are failings in political authority, in service entitlement (especially to the poor) and in legitimacy, then it is arguable that corruption is as much a consequence as a cause of such factors. […] the reality is that for many people in endemically corrupt or fragile states, corruption can in fact offer functionality in social, political and economic transactions where no better mechanisms exist. This is not to condone corruption, but to recognise that it can be seen, especially by those who live in fragile states, as a form of solution to resource allocation and access issues.143

90.U4’s evidence detailed a study that they had conducted with aid and development professionals working in fragile situations. They reported that, “All but two of our 23 respondents agreed that corruption control measures can cause damaging stress in fragile societies”.144 DFID’s evidence demonstrates understanding of this, as it states that, “Some forms of corruption are difficult to tackle in a conflict environment without fuelling more instability and violence”.145 This makes understanding the local context extremely important when considering ways to tackle corruption in fragile states and may mean that, under certain circumstances, it is not the best focus for aid agencies. DFID states that its anti-corruption efforts will be “integrated within wider stabilisation and governance efforts […] establishing an institutional and political framework within which longer-term state and peace-building processes can continue anti-corruption reforms”.146

91.DFID has committed to spending 50% of its budget in fragile states. In these countries, attempts to tackle corruption must be considered very carefully. Evidence to us has strongly suggested that anti-corruption efforts can have adverse effects in unstable situations. We welcome DFID’s understanding of these challenges and its approach to ground its work in broader state and peace-building processes. However, when DFID is committed to spending half of its budget on fragile states, this may limit the volume of anti-corruption work it is able to carry out.

Adaptive programming: thinking and working politically to combat corruption

92.Professor Heywood told us, there is growing consensus that, “we need to understand contextual factors much better, and that means recognising that corruption is inherently a political problem”.147 Dr Heather Marquette argued similarly:

“A growing body of evidence suggests that development programming that is politically savvy, ‘works with the grain’ of local political economy conditions and is led locally (rather than led by donors) is more likely to be effective than its opposite: aid that is insensitive or ignorant of the local political context; that imposes an external model, whether it fits or not; and that fights against the grain of the local political economy, whatever the motivation for doing so.”148

Gavin O’Hagan from Adam Smith International emphasised the need for DFID to allow for experimentation and adaption in its anti-corruption work:

“[…] with regards to anti-corruption work, the emerging evidence and literature is that a process of experimentation can be very important. There is no tried and trusted way. As the previous session was making clear, there is no one-size-fits-all either. It is incredibly important for implementers such as us in this space, or other actors, to be able to adapt and be flexible and to innovate.”149

93.Our Report on DFID’s programme in Nigeria, published in July 2016, cited DFID’s Facility for Oil Sector Transparency (FOSTER) as an example of good adaptive or ‘politically smart’ programming.150 According to ODI, the £14 million FOSTER project, “aims to understand the underlying political economy and incentive structures that can prevent the benefits of Nigeria’s natural resource wealth being shared more broadly. It tries to capitalise on and nurture appetite for reform, both within government and outside, by working opportunistically and strategically with government and civil society institutions and actors”.151 DFID’s State, Accountability and Voice Initiative (SAVI) in Nigeria has also received praise for, “delivering good results and illustrating a potential that could well be applied more widely”.152 In its written evidence, DFID suggests that it will be taking this politically smart programming forward in its new anti-corruption strategies. It stated that it will, “Base its anti-corruption activities on a robust and politically honest analysis of the power, interests and incentives of actors and groups”.153

94.We welcome DFID’s innovative approaches to thinking and working politically, which evidence suggests is vital when working to tackle corruption in its priority countries.

95.Thinking and working politically has proven to be a useful approach for DFID in Nigeria. DFID must ensure that lessons are being shared between country programmes, and that research in this new and innovative area is disseminated, to ensure that all in-country staff are equipped with the resources and information to start considering similar ways of working that are sensitive to the political context.

The challenges of a zero tolerance approach

96.As outlined in the introduction, our Report is addressing DFID’s approach to tackling corruption overseas, rather than looking directly at the ways in which DFID prevents corruption within its own aid programmes. On this, DFID’s evidence to the inquiry clearly states:

“It is important to state that DFID has a zero tolerance approach to corruption with regards to our own resources and programmes. DFID is committed to take all necessary steps to investigate allegations of misuse of DFID’s own funds and pursue sanctions available in each case, including dismissal, prosecution, suspension and cancellation of aid.”154

Understandably, there are significant sensitivities surrounding aid and corruption and this zero tolerance approach to corruption within the UK’s aid programmes is absolutely right.

97.Zero tolerance is an absolutely necessary approach providing a clear message that corruption will not be tolerated. Nevertheless, evidence we received indicated that a broad or simplistic implementation of zero tolerance is unlikely to be sufficient. Professor Mushtaq Khan told us that, “zero tolerance cannot mean that DFID should withdraw from a country as soon as any corruption is detected in any part of the administration of that country. This would prevent DFID from working in most developing countries, and in particular the most vulnerable countries where UK aid is most needed”.155 Christian Aid highlighted similar concerns.156 Evidence from Dr Heather Marquette expressed concern that, because of sensitivities, “it is difficult for the Government to even talk about aid and corruption, let alone have the grown up conversation many of us feel is important if we are to have an opportunity to think differently enough about how to design and implement more effective anti-corruption programming”.157 Professor Khan argued that in many of the countries where DFID works, corruption is endemic. He stated that, “Zero tolerance towards these entrenched societal forms of corruption must be a longer term goal that is achieved using ‘nuanced’ and targeted anti-corruption interventions.”158

Sector approaches

98.Sector approaches such as those made in extractive industries or defence industries can also be important and effective tool for DFID. Robert Barrington told us that, “sectoral approaches are a very good approach to take, because you can focus in on specific types of problem and specific numbers and types of actor”.159 Global Witness called for donors to do more to tackle corruption and said this would require “smart technical aid, clear benchmarks and consistent political pressure which are targeted at tackling grand corruption in key strategic countries and sectors”.160

Extractive industries

99.Work targeting the extractive industries is a sector approach with potentially significant and far reaching impact. According to the World Bank, non-renewable mineral resources play a dominant role in 81 countries, which together account for a quarter of the world’s GDP, half of the world’s population and nearly 70% of those in extreme poverty. Africa is home to about 30% of the world’s mineral reserves, 10% of the world’s oil, and 8% of the world’s natural gas.161 Frequently referred to as the ‘resource curse’, citizens living in resource-rich countries rarely receive the benefits of their country’s mineral wealth. As Transparency International told us, “Sierra Leone produced more than 400,000 carats of diamonds in 2010 […] Despite its mineral wealth, Sierra Leone is ranked among the least developed countries in the world in the UN’s Human Development Index.”162

100.Transparency International told us in its submission that, “Quality of governance is the major determinant of whether the extraction of minerals contributes to a country’s sustainable development”.163 In an attempt to improve governance and tackle corruption in the industry, international voluntary standards such as the Extractive Industries Transparency Initiative (EITI) have been established to “promote open and accountable management of natural resources”.164 EITI “seeks to strengthen government and company systems, inform public debate, and enhance trust. In each implementing country it is supported by a coalition of governments, companies and civil society working together.”165

101.Evidence from Global Witness claims that countries may get reputational benefits for signing up to the EITI but then fail to generate the data to scrutinise the industry in the country, and these initiatives can therefore be a distraction to real impact on corruption.166 It also highlights that these initiatives are only part of the picture and DFID should pair it with accountability mechanisms to ensure effective scrutiny.167 Transparency International’s evidence agrees that stronger accountability is required but sees a need for further transparency in the award of permits, licenses and contracts.168 Evidence from Adam Smith International emphasises that DFID should not shy away from improving the governance in the extractives sector because of political and reputational risk169 Shauna Leven from Global Witness told us, “There is also over-reliance on EITI as a technical mechanism. It does not come with as much political pressure as it could. Corruption is a technical issue but it is also a political issue and we need to take a holistic approach towards addressing it.”170


102.In our Report into UK implementation of the Sustainable Development Goals, we noted the potential to leverage the influence of the capital markets to encourage sustainable business practices.171 In evidence to this inquiry, the Royal United Services Institute (RUSI) argued that the influence of the capital markets—which has been steadily increasing for the past ten to fifteen years—could also be used to encourage other countries to strengthen their systems of governance and tackle corruption.172 In its submission, DFID admitted that, “In many developing countries where DFID works there are significant obstacles to changing the attitudes of governing elites”.173 RUSI highlights that countries—particularly emerging economies—are increasingly engaging in foreign currency borrowing and looking to encourage international investment. In this situation, a positive credit rating is important to attract investors and secure lower rates on borrowing.174

103.The submission states that, “A positive rating improvement can trigger a virtuous circle of lower borrowing costs, rising foreign investment, greater business with the global economy and thus greater national prosperity”.175 It highlights the importance of combating corruption in order to secure a positive rating:

“For governments seeking to borrow from international investors in the global capital markets, there is a clear economic benefit from presenting a profile that offers transparent governance, free from corruption”.176

104.A compelling business case that clearly shows the economic benefits of improving a country’s credit rating by improving governance and tackling corruption may encourage more of DFID’s partner governments to take action. Highlighting the link between transparent governance and anti-corruption measures, and increased investment and lower borrowing costs could encourage more governments to take action. We are pleased to hear that the Royal United Services Institute (RUSI) are already in discussions with DFID staff about how best to use this approach in its priority countries.


105.Our predecessor Committee published a Report on Parliamentary Strengthening in January 2015 which recommended the integration of parliaments into DFID’s work on anti-corruption. It stated:

“We recommend that DFID recognise the role of parliaments in its work on poverty reduction, human rights, equality, economic growth, security, transparency, accountability and anticorruption; in particular, include the role of the national Parliament in each of its country level anti-corruption strategies when it next revises them.”177

The Government’s response to the Report agreed with the recommendation and stated:

“Agree. We recognise parliaments can make an important contribution to combatting corruption and therefore to DFID’s work on anti-corruption in countries where we work. DFID’s country anti-corruption strategies will be updated in 2015. As part of that review, we will look for opportunities to reflect the potential role of parliaments for anti-corruption work, where appropriate and based on analysis of each country.”178

106.Evidence from Transparency International highlighted the importance of institutional capacity building to anti-corruption efforts:

“Particular emphasis should be placed on the development of oversight mechanisms. In any state where corruption is a major issue, a strong focus on building the capability of oversight institutions such as parliamentary committees, an Office of the Auditor General and a civil society able to exercise effective oversight of the funding and activities of institutions is vital.”179

In recent years, parliamentary committees in a number of developing countries have been instrumental in uncovering grand corruption, such as the Tanzanian Public Accounts Committee’s uncovering of the escrow scandal, which allegedly resulted in the theft of £76.5m from the country’s central bank.180 Such examples show the important part parliaments have to play in anti-corruption efforts.

107.As representatives and legislators, parliamentarians have a crucial role to play in exposing corruption and legislating against it and this is an area which is often neglected by DFID. Strengthening the capacity of parliaments and parliamentarians can only ever be part of a broader strategy to tackle corruption and the approach must be tailored to the context. However, it is important that DFID recognises the importance of legislatures and legislators in the fight against corruption and considers their role when designing each of its anti-corruption country strategies.

108.DFID must fulfil its commitment to include parliaments in its new anti-corruption country strategies, highlighting the role they will play in efforts to curb corrupt activities in its partner countries. We look forward to seeing this when the new anti-corruption country strategies are published.

Civil society

109.Professor Heywood cautioned that parliaments were only part of the answer, however, telling us: “Parliament is potentially a very important player in an anti-corruption strategy but it is one player”.181 Evidence has also highlighted the importance of DFID engaging with citizens and civil society in order to tackle corruption at the grassroots. VSO told us:

“Anti-corruption work is best led by the citizens and officials of the country themselves. By understanding the system and where there is movement for change, interventions can be effective and sustainable. Where that is in the system will depend on the country. This can be done in two ways—by supporting the people who are trying to make the change and by leveraging opportunities in a different part of the system that those people might find more difficult to change but where DFID and its partners have some influence. This requires working closely with a wide range of organisations, including civil society organisations and the private sector.”182

110.The Partnership for Transparency Fund also highlighted that tackling corruption “requires a free and well-supported civil society sector working in a relatively enabling environment”.183 Because of this, it expressed disappointment at the closure of DFID’s Governance and Transparency Fund (GTF) which aimed to support citizens to hold their governments to account.184 Although alternative support is available for such activities through country offices and other programmes (such as the Global Innovation Fund or Making Voices Count) it is argued that the GTF had clear advantages. These included the multi-country nature of the GTF programme, which allowed for learning across different environments, the ability to fund longer-term projects of up to five years, the strong partnerships fostered between NGOs from the Global North and Global South, and the ability for sub-grants to be awarded to smaller, local organisations which—it is argued—lowered DFID’s transaction costs.185


111.Protection of whistleblowers is essential, to ensure citizens, civil society and the media feel safe to expose corruption where it is found. Professor Indira Carr emphasised this in her written evidence to the inquiry:

“[…] it is important that civil society is free to voice concerns without fear […] protection of the media and whistleblowers is also important. There are instances where investigative journalists have been arrested or killed and informants harassed. In a climate of intimidation, regardless of the completeness of anti-corruption strategies, the approaches to tackling corruption are unlikely to succeed.”186

Professor Carr highlighted the need for DFID and the FCO to encourage partner governments to guarantee protections for whistleblowers. She alleged that, “Whistleblower protection has not been taken seriously by developing states. For instance, within Africa only Ghana and South Africa have whistleblower protection legislation.”187 During the inquiry concerns were also raised with us about the protections in place for whistleblowers bringing evidence of corruption to the attention of UK Government officials in other countries.

112.The Minister of State for International Development reinforced the importance of publically available data, stating that civil society would be empowered by “the production of the transparent data that will result from public registers of beneficial ownership, and the tax data—the other data that will be made public”.188 However, he also emphasised that the space for civil society to operate was closing in many of the countries they are working in.189 Phil Mason OBE, Senior Anti-Corruption Adviser, added that organisations such as Transparency International had raised concerns with them about their activists.190

113.Civil society has a vital role to play in anti-corruption efforts and the availability of data is essential to empower citizens to hold perpetrators to account. Civil society activists and journalists who may come forward as whistleblowers exposing incidences of corruption must also be protected, but there are concerns that in many countries the space for individuals and organisations to speak out is closing.

114.DFID and the FCO should work with governments in its priority countries to encourage greater protections for whistleblowers, including through legislation. The UK Government must also ensure that it has sufficient protections and mechanisms in place for whistleblowers that come to officials in overseas posts with evidence of corruption. The Government should lay out these processes clearly in its response to this Report.

115.DFID should also acknowledge that civil society has a vital role to play in anti-corruption efforts and outline how it will engage with local civil society actors in its forthcoming anti-corruption country strategies.

Measuring success

116.As it is very difficult to measure corruption, it is also very difficult to evaluate the success of anti-corruption interventions. For those implementing partners reporting into DFID, to whom results and value for money are quite rightly crucial, this presents a problem for work in this area where it could be argued that a certain element of ‘trial and error’ and allowance for failure is required. As Gareth O’Hagan from Adam Smith International told us:

“The systems that DFID has in place currently tend to be quite rigid, where there is a clearly designed programme of work with clearly defined results. That is very important because we need to demonstrate and achieve value for money and impact. We very much welcome that and like working with that. However, it is not suitable to all types of project and all types of intervention. Anti-corruption work and political economy work are very good examples of where it is not the best way to go about things.”191

117.Charles Kenny of the Center for Global Development told us, however, that, “While we struggle to measure or detect corruption, we can measure results”.192 He went on to say that:

“Development results are far harder to hide than is corruption. We can measure outputs and outcomes related to corruption like electricity transmission and distribution losses, road quality, test scores or indicators covering outcomes like do people with driving test pass know how to drive? Output measures are easier to compile with accuracy, and are likely to far better indicate reduction in the development impact of corruption and poor governance.”193

118.Professor Heywood criticised the lack of a monitoring and evaluation framework “against which to measure impact” in DFID’s anti-corruption country strategies.194 However, he also admitted that we cannot set expectations too high because of the difficulties in measuring success, due to the “very nature of corruption as a largely hidden activity” and—as highlighted earlier in the Report—the limits on being able to demonstrate any real impact over three years, which was “a wholly unrealistic time frame in which to identify clear impact”.195 He also told us:

“To assess progress, it is essential to develop specific, targeted and preferably quantifiable benchmarks against which to measure change (for instance, in regard to the operation of public financial management structures, procurement systems, oversight agencies, civil society initiatives, transparency and open data developments and so forth), rather than using generic measures such as national-level perceptions surveys. It is important to remain aware, however, that causality and attribution are fiendishly intractable problems to address.”196

119.The evidence suggests that measuring the success of anti-corruption programmes is immensely difficult as it is difficult both to measure results and to attribute results to any particular intervention.

120.As it is difficult to measure results, and there is still insufficient evidence to determine ‘what works’ in its anti-corruption interventions in its priority countries, DFID needs to ensure that it allows flexibility in its anti-corruption reporting frameworks to ensure that responses to corruption can be innovative and adaptable. Whilst it is crucial to ensure value for money, anti-corruption programmes involve inherent risk and the outcomes of the programme may not always be as expected. DFID must find ways to ensure it is monitoring progress, whilst not constraining programmes to a very specific set of results. DFID should include details of its monitoring frameworks in its new anti-corruption country strategies.

108 Transparency International and Transparency International UK (TCO0011) para 8.1

109 Christian Aid (TCO0013) para 3.2

110 DFID (TCO0025) para 31

111 U4 (TCO0008) para 3

113 ICAI, DFID’s Approach to Anti-Corruption (November, 2011) p. 1

114 Dr Heather Marquette (TCO0029) para 15

115 Professor Paul Heywood (TCO0004) para 7

116 Professor Paul Heywood (TCO0004) para 7

118 DFID, Anti-Corruption Strategies by Country, accessed 12 October 2016

121 DFID (TCO0025) para 51

124 DFID (TCO0025) para 51

125 Dr Heather Marquette (TC00029)

126 Bond Anti-Corruption Group (TCO0016) p. 2

127 DFID (TCO0025) para 46

128 DFID (TCO0025) para 52

129 DFID (TCO0025) para 51

131 Dr Heather Marquette (TCO0029) para 2; U4 (TCO0008) para 3

132 U4 (TCO0008) para 3

133 U4 Anti-Corruption Resource Centre, Mapping evidence gaps in anti-corruption (October 2012)

136 DFID Devtracker, Anti-Corruption Evidence Programme, accessed 12 October 2016

137 DFID Devtracker, Anti-Corruption Evidence Programme, accessed 12 October 2016

139 Global Witness (TCO0018) para 14

140 HM Treasury, UK Aid: tackling global challenges in the national interest, Cm 9163 (November 2015) para 3.8

141 Transparency International and Transparency International UK (TCO0011) para 9.1

142 Professor Mushtaq Khan (TCO0029)

143 Professor Paul Heywood (TCO0004) para 14

144 U4 (TCO0008) para 4.3

145 DFID (TCO0025) para 41

146 DFID (TCO0025) para 42

148 Dr Heather Marquette (TCO0029) para 5

150 International Development Committee, Second Report of Session 2016–17, DFID’s programme in Nigeria, HC 110

152 “Towards politically smart, locally led development in Africa”, David Booth, African Arguments, 23 October 2014

153 DFID (TCO0025) para 52

154 DFID (TCO0025) para 30

155 Dr Mushtaq Khan (TCO0030) p. 1

156 Christian Aid (TCO0013) para 3.4

157 Dr Heather Marquette (TCO0029) para 7

158 Dr Mushtaq Khan (TCO0030) p. 1

160 Global Witness (TCO0018) para 4

161 World Bank, Extractive Industries: Overview, accessed 12 October 2016

162 Transparency International and Transparency International UK (TCO0011) para 6.10

163 Transparency International and Transparency International UK (TCO0011) para 6.11

164 EITI, Who we are, accessed 12 October 2016

166 Global Witness (TCO0018) para 16

167 Global Witness (TCO0018) para 35

168 Transparency International UK (TCO0011) para 6.11 & 6.12

169 Adam Smith International (TCO0022)

170 Q20

171 International Development Committee, First Report of Session 2016–17, UK implementation of the Sustainable Development Goals, HC 103, para 36–41

172 RUSI (TCO0001)

173 DFID (TCO0025) p. 2

174 RUSI (TCO0001)

175 RUSI (TCO0001) para 10

176 RUSI (TCO0001) para 23

177 International Development Committee, Ninth Report of Session 2014–15, Parliamentary Strengthening, HC 704, para 17

178 International Development Committee, Ninth Special Report of Session 2014–15, Parliamentary Strengthening: Government Response to the Committee’s Ninth Report of Session 2014–15, HC 1125, p. 5

179 Transparency International and Transparency International UK (TCO0011) para 9.1.5

182 VSO (TCO0027) para 5

183 Partnership for Transparency Fund (TCO0021) p. 1

184 DFID, Guidance: Governance and Transparency Fund (GTF), accessed 12 October 2016

185 Partnership for Transparency Fund (TCO0021) para 7 & 8

186 Professor Indira Carr (TCO0009) para 23

187 Professor Indira Carr (TCO0009) para 24

192 Charles Kenny (TCO0020) para 17

193 Charles Kenny (TCO0020) para 17

194 Professor Paul Heywood (TCO0004)para 8

195 Professor Paul Heywood (TCO0004) para 8

196 Professor Paul Heywood (TCO0004) para 11

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18 October 2016