Mainstreaming Anti-Corruption in Development

UNDP Practice Note: Mainstreaming Anti-Corruption in Development
Mainstreaming Anti-Corruption in
Development
ANTI-CORRUPTION PRACTICE NOTE

December 2008
CONTENTS
ABBREVIATIONS AND ACRONYMS..................................................................................................... 2
EXECUTIVE SUMMARY .......................................................................................................................... 3
1. INTRODUCTION .................................................................................................................................... 4
2. UNDP’S NICHE AND POSSIBLE ENTRY POINTS ........................................................................... 6

2.1 BUILDING UPON PAST EXPERIENCES ..................................................................................................... 7
2.2 UNDP AND INTERNATIONAL LEGAL NORMS AND STANDARDS ............................................................. 8
2.2.1 UNCAC as a framework for UNDP anti-corruption activities .................................................... 8
2.2.2 UNDP’s comparative advantages in implementing UNCAC ....................................................... 9
2.2.3 Other international legal norms, standards and practices on anti-corruption ...........................11
3. OPERATIONAL IMPLICATIONS ......................................................................................................12
3.1 DESIGNING EFFECTIVE STRATEGIES .....................................................................................................12
3.1.1 Approaches and techniques ........................................................................................................12
3.1.2 Global, regional and country level strategies .............................................................................14
3.1.3 Mainstreaming anti-corruption into programmes and projects ..................................................15
3.1.4 Supporting anti-corruption institutions.......................................................................................16
3.1.5 Research and planning for programming ...................................................................................18
3.1.6 Identifying anti-corruption actors ...............................................................................................20
3.1.7 Building partnerships..................................................................................................................22
3.2 UNDP STRATEGIC AREAS OF INTERVENTION (PROGRAMMING ACTIVITIES) .........................................23
3.2.1 Increasing state/institutional capacity to respond to UNCAC and improve governance............23
3.2.2 Utilizing governance/anti-corruption assessment tools to inform policies .................................25
3.2.3 Strengthening media and civil society to provide anti-corruption oversight ..............................27
3.2.4 Improving harmonization and coordination of anti-corruption initiatives .................................28
3.2.5 Improving awareness and knowledge .........................................................................................29
3.3 LEADING BY EXAMPLE: STRENGTHENING INTERNAL ACCOUNTABILITY WITHIN UNDP ......................29
ANNEXES: (POLICIES, PRINCIPLES, KEY ACTORS, PARTNERS) ..............................................34
2
Abbreviations and acronyms

ACC - anti-corruption commission
ATI - accountability, transparency and integrity
CCA - Common Country Assessment
CO - country office
CoP - Community of Practice
CSO - civil society organization
DAC - Development Assistance Committee (of OECD)
DGG - Democratic Governance Group
DGTTF - Democratic Governance Thematic Trust Fund (UNDP)
IACC - International Anti-Corruption Conference
MDG - Millennium Development Goal
MoU - memorandum of understanding
NGO - non-governmental organization
OECD - Organization for Economic Cooperation and Development
PACT - Programme for Accountability and Transparency
TWG - thematic working group
UNCAC - United Nations Convention against Corruption
UNDAF - United Nations Development Assistance Framework
UNODC - United Nations Office on Drugs and Crime
UNDP - United Nations Development Programme
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EXECUTIVE SUMMARY
Corruption is found in rich and poor, developing and developed countries alike, albeit
in different forms and magnitude. Evidence confirms that corruption hurts the poor
disproportionately and hinders efforts to achieve the Millennium Development Goals
(MDGs) and human development by reducing access to social services and diverting
resources away from investments in infrastructure, institutions and social services.
Corruption also undermines democracy and the rule of law, leads to violations of
human rights, distorts markets, erodes quality of life and allows organized crime,
terrorism and other threats to human security to flourish.
The United Nations Development Programme (UNDP) has been involved in

accountability, transparency and integrity (ATI) programmes since the early 1990s,
through country office (CO) activities on accountability and transparency that were
later reinforced by the Programme for Accountability and Transparency (PACT). The
initiative was reinforced by UNDP’s corporate policy paper ‘Fighting Corruption to
Improve Governance’ (1998), which highlighted corruption as a development issue. In
2004, UNDP produced an Anti-Corruption Practice Note to clarify UNDP’s approach to
fighting corruption and give guidance on how to develop and integrate specific anti-
corruption measures into the wider development agenda.
As new norms and standards on anti-corruption evolved, it became necessary to

replace the 2004 Anti-Corruption Practice Note. Most notably, the entry into force of
the United Nations Convention against Corruption (UNCAC) on 14 December 2005
offered new challenges and opportunities for fighting corruption, leading UNDP to
review and ultimately refocus its anti-corruption priorities.
This Practice Note is organized in four parts. The first part sets out the case to fight
corruption by mapping out definitions, causes and consequences of corruption. The
second part discusses the role of UNDP in tackling corruption, taking into account the
organization’s experience and operational strengths in the context of UNCAC and other
international commitments, instruments, norms and standards. The third part
discusses operational implications for UNDP country, regional and global levels in
terms of strategic approaches and entry points. Finally, annexes provide guidance for
further reading.
The Practice Note clarifies that the main rationale for UNDP engagement on anti-
corruption is to further its mandates on poverty reduction, realization of the MDGs and
promoting sustainable development. It also reinforces two important facts: (i) UNDP
has been a leading provider of anti-corruption technical assistance within its
democratic governance portfolio, and (ii) the agency is in a unique position to engage
a broad range of national stakeholders in a holistic approach to fighting corruption.
The second fact is based on its wide country presence and support for nationally-led
programming processes, which is reflected also in United Nations Development
Assistance Frameworks (UNDAFs), Common Country Assessments (CCAs), and UNDP
Country Programmes.
The Practice Note provides guidelines to assist COs in programming areas such as: (i)
developing and implementing long- and short-term anti-corruption strategies, (ii)
mainstreaming anti-corruption activities into national programmes on service delivery,
(iii) developing the capacity of anti-corruption institutions, (iv) engaging in advocacy
and awareness-raising through civil society organizations and the media, (v)
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developing anti-corruption assessment tools and conducting anti-corruption surveys,
(vi) coordinating and harmonizing anti-corruption programmes, and vii) developing
knowledge tools.
1. Introduction
“Corruption undermines democracy and the rule of law. It leads to violations of human rights. It
erodes public trust in government. It can even kill—for example, when corrupt officials allow
medicines to be tampered with, or when they accept bribes that enable terrorist acts to take
place. […] It has adverse effects on the delivery of basic social services. It has a particularly
harmful impact on the poor. And it is a major obstacle to achieving our Millennium
Development Goals [emphasis added].”
—Ban Ki-Moon, United Nations Secretary-General, at the launch of the Stolen Asset Recovery
Initiative, 2007.
“Corruption hurts the poor disproportionately by diverting funds intended for development,
undermining a government's ability to provide basic services, feeding inequality and injustice,
and discouraging foreign investment and aid.”
—Kofi Annan, then-United Nations Secretary-General, in his statement on the adoption by

the General Assembly of the United Nations Convention against Corruption, 2003.
Regardless of the country context, evidence from across the globe confirms that
corruption hurts the poor disproportionately and hinders economic development,
reduces social services and diverts investment in infrastructure, institutions and social
services. Moreover, it fosters an anti-democratic environment characterized by
uncertainty, unpredictability and declining moral values and disrespect for
constitutional institutions and authority. Corruption, therefore, reflects a democracy,
human rights and governance deficit that negatively impacts on poverty and human
security.1
Since the mid-1990s, corruption has become a legitimate subject of international

interest and concern due to increased attention and focus from private sector
businesses, multilateral institutions, human rights organizations, regional security
blocs and international organizations. Many of them seek to contain corruption not
only for their own specific interests, but more broadly to avoid further erosion of
public institutions and exacerbation of poverty, to reduce threats to sustainable
development, and to avoid possible spillover effects to neighbouring countries.
UNDP recognizes that corruption is a threat to human development, which is a

development paradigm pursued by UNDP and is defined as “a process of enlarging
people’s choices”, which is achieved by expanding human capabilities.2
UNDP was one of the pioneer organizations in the early 1990s in developing
programmes to address and curb corruption. This, in some cases, implied shifting focus
from traditional (neutral) public administration reform concerns to confronting more
politically sensitive areas that are at the core of good governance. Since then,
improving ATI has been a rapidly growing area of assistance and UNDP has remained a
1
See UNDP Practice Note 2004, p. 1.
2
See, UNDP, Human Development Reports (http://hdr.undp.org/en/humandev/glossary/).
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leading provider of anti-corruption technical cooperation within its democratic
governance portfolio.
This Anti-Corruption Practice Note updates the 2004 edition and provides a hands-on
guide for COs to take newly installed normative frameworks in anti-corruption and
apply them in UNDP programming. At the time when the first practice note was
published, UNCAC had just been adopted, but had not yet entered into force. The
Convention ultimately came into force on 14 December 2005, bringing with it new
challenges and opportunities for fighting corruption. UNCAC and other international
norms and standards on anti-corruption made it necessary for UNDP to reflect and
refocus its anti-corruption priorities within its mandate of poverty reduction,
realization of the MDGs and promotion of sustainable development.
This Practice Note, prepared by the Democratic Governance Group (DGG), Bureau for
Development Policy (BDP) of UNDP builds on internal knowledge mapping from country
experiences, case studies, research on emerging issues and extensive peer review. It
draws on UNDP experiences and the expertise available throughout its network of 135
COs: the contents and focus of the Practice Note were informed by organization-wide
consultation through regional bureaux and centres, with valuable inputs from UNDP
staff on the ground. Additional inputs were provided by other experts and partners.
Similar efforts were made to obtain comments and suggestions upon completion of the
initial draft, which was circulated across UNDP’s governance network. Special
contributions were made by Phil Matsheza, Anga R. Timilsina, Harald Mathisen, Vera
Devine, Terence D. Jones and Pauline Tamesis.
This Practice Note is organized in four parts. The first part sets out the case to fight
corruption by mapping out definitions, causes and consequences of corruption. The
second part discusses the role of UNDP in tackling corruption, taking into account the
organization’s experience and operational strengths in the context of UNCAC and other
international commitments, instruments, norms and standards. The third part
discusses operational implications for UNDP country, regional and global levels in
terms of strategic approaches and entry points. Finally, annexes provide guidance for
further reading.
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2. UNDP’s niche and possible entry points
The notion of democratic governance is people-centred: it epitomizes the most

fundamental principle of democracy—that people should govern themselves through
the systems they choose through open and transparent participatory processes.
Democratic governance means that people have a say in the decisions that affect their
lives and that they can hold decision-makers accountable. It further entails that the
rules, institutions and practices that govern social interactions are inclusive and fair;
that women are equal partners with men in private and public spheres of life; that
people are free from discrimination based on race, ethnicity, class, gender or any
other similar factor; and that the needs of future generations are reflected in current
policies. It also means that economic and social policies are responsive to people’s
needs and their aspirations, that these policies aim at eradicating poverty and
expanding the choices that all people have in their lives, and that human rights and
fundamental freedoms are respected.3
UNDP views corruption as a governance deficit, a result of malfunctioning state

institutions due to poor governance. The Commission on Human Rights Resolution
2000/64 recognizes that the characteristics of good governance such as participation,
rule of law, transparency, responsiveness, consensus, equity, inclusiveness,
effectiveness and efficiency, and accountability are vital for promoting growth and
sustainable development. The Millennium Declaration also refers to good governance,
thereby linking it to the realization of the MDGs. This linkage stems from the fact that
ineffective institutions usually result in the greatest harm to those who are poor and
vulnerable, thereby obstructing human development.
The characteristics of good governance are also essential pillars of democratic

governance, which requires efficient institutions and an economic and political
environment that renders public services effective and makes economic growth
possible. At the same time, democratic governance for human development must also
be concerned with whether institutions and rules are fair and accountable, whether
they protect human rights and political freedoms, and whether all people have a say in
how they operate.4
UNDP considers democratic governance to be a core element of a democratic system,

but not necessarily synonymous with democracy per se. Thus, ‘democratic governance’
is more properly defined as a value and human rights–based concept that requires
making sustainable progress in human development.
UNDP has operationalized the concept of democratic governance in its strategic plan
for 2008–2011, which clarifies democratic governance as the process of creating and
sustaining an environment for inclusive and responsive political processes through
fostering inclusive participation; strengthening responsive institutions to ensure
accountability for meaningful results; and grounding internationally agreed norms and
principles by strengthening linkages between the normative work of the UN system and
its operational activities.
3
UNDP, Human Development Report 2002, p. 51.
4
UNDP, Democratic Governance Thematic Trust Fund Annual Report 2006 (New York: UNDP, 2006).
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2.1 Building upon past experiences
UNDP has for many years supported projects and activities that address the
fundamental, and often politically sensitive, elements of corruption, including its
social, economic and political consequences and its impact on key issues such as
poverty, the environment, human rights and gender.
Anti-corruption first became a major priority for UNDP in the mid-1990s, soon after it
placed greater priority on viewing corruption as the product of a governance deficit.
Most notably, in 1997 UNDP started to directly address corruption through projects and
programmes by developing the Programme for Accountability and Transparency
(PACT). That programme’s major focus has been on developing tools; strengthening
civil society engagement, research and development of knowledge products; and
supporting the establishment and strengthening of national oversight institutions. The
importance of ATI—accountability, transparency and integrity—was later backed by
UNDP’s corporate policy paper ‘Fighting Corruption to Improve Governance’ (published
in 1998), which highlighted the importance of addressing corruption as a development
phenomenon. While the emphasis initially was on awareness-raising activities, it
eventually shifted to providing technical advisory services to national governments,
coupled with the development of internally developed tools and methodologies. Since
then, improving ATI has been a rapidly growing area of anti-corruption assistance, and
UNDP has remained a leading provider of anti-corruption technical assistance within its
governance portfolio.
Box 1. Examples of projects from the ATI portfolio
UNDP Mongolia: Strengthening ethics and integrity in the health sector. The project
aimed to increase transparency and accountability of the Ministry of Health and
selected health institutions by identifying and addressing bottleneck areas. Initiated in
2007, it also sought to promote ethics and integrity of staff through open discussions,
training, a code of conduct and complaints handling. The project conducted a
perception survey on health sector corruption, produced a set of benchmarks for
transparency and accountability, and prepared a handbook on medical ethics.
UNDP Malaysia: Support to the 2004 National Integrity Plan of the Government of
Malaysia. The 18-month project, concluded in 2007, was a joint effort between the
UNDP country office and the Malaysian Institute of Integrity. The project contributed
to capacity-building and staff development in the Malaysian public administration
through implementation plans, the development and testing of a master training
programme, and the creation of a master training manual. A ‘guiding framework’ for a
National Integrity System within the Malaysian context was adopted after discussions
with stakeholders. The framework includes guidance, inter alia, on transparency in
public procurement, whistle-blower protection and monitoring of public officials.
UNDP Argentina. New management systems in public agencies. In 2007, UNDP

Argentina supported the development and implementation of new management
systems, administrative procedures and coordination mechanisms in various public
agencies, including the Ministry of Defence (properties, balanced scorecard and
learning management system unified) and the Ministry of Interior. Learning standards
were defined and implemented for the Federal Police and standard procedures were
developed for security budget formulation. The CO also supported the establishment
of digital information systems at the Ministry of Defence.
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2.2 UNDP and international legal norms and standards
2.2.1 UNCAC as a framework for UNDP anti-corruption activities
UNCAC recognizes the negative impact of corruption on sustainable development.

Although its substantive articles do not make explicit reference to sustainable
development, the Convention emphasizes and supports the principles of the rule of
law, ATI and human rights standards.
As of 5 December 2008, a total of 128 countries had ratified UNCAC, which provides an
additional entry point for UNDP’s anti-corruption programmes and projects. In
countries that have not yet ratified the Convention, UNDP as a member of the UN
family has an obvious role to play in advocating and promoting UNCAC and in
encouraging governments to sign, ratify and implement it.5
Box 2. Examples of past and ongoing UNDP projects and UNCAC provisions
UNDP Bangladesh. The programme Developing Civil Service Capacity for 21st
Century Administration (2005-06), through capacity assessments in selected
institutions and broader stakeholder consultation, prepared a strategy to support
capacity development for civil service reforms. Police Reform Programme (2005-09)
aimed at improving efficiency and effectiveness of the Bangladesh police. (Both these
projects are related to UNCAC Articles 7, 10.)
UNDP Angola. The Decentralization and Local Government (2004-07) project

focused on piloting decentralization and local governance in Angola through (i)
defining what would constitute stable, functional and fiscally prudent
intergovernmental relationships and experimenting in establishing these relationships,
(ii) promoting participatory democracy and (iii) developing human resources for
decentralization (UNCAC Articles 9, 10, 13).
UNDP Trinidad and Tobago. One UNDP project, Assistance to the Ministry of Public
Administration, supported the ministry’s efforts to achieve government priorities of,
inter alia, integrity, cost efficiency and effective service delivery. A second project,
Participatory Dialogue for Vision 2020, supported the Ministry of Planning and
Development’s efforts to introduce a participatory dialogue process involving the
wider population (UNCAC Articles 7, 9, 10).
5
For more information on UNCAC, see www.unodc.org/unodc/en/treaties/CAC/index.html.
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2.2.2 UNDP’s comparative advantages in implementing UNCAC
It is important to note that the United Nations Office on Drugs and Crime (UNODC)
houses the Secretariat to the Conference of State Parties to UNCAC and provides
support to various aspects of its implementation. UNDP, meanwhile, has country
presence in more than 135 nations, plays a coordination role among UN agencies in
many countries and has longstanding dialogue with governments through UNDAFs, CCAs
and other processes. In addition, UNDP’s role as an impartial facilitator and
coordinator has provided a comparative advantage to engage with various
stakeholders, including governments, civil society and the media. In the spirit of
delivering as ‘One UN’, coordination and cooperation among UN agencies should be
encouraged. In this context, a cooperation framework—in the form of a memorandum
of understanding (MoU)—between UNDP and UNODC recognizes that UNDP serves as
the coordinating arm of the UN and has a wider presence at the country level to
promote human development. The MoU also recognizes that UNODC has both
normative and technical assistance functions in relation to UNCAC. Given this
complementarity, this MoU seeks to enhance consistency, coherence and quality in the
delivery of technical cooperation in anti-corruption to Member States, in response to
national priorities. The agreement allows cooperation at regional and national levels
depending on the priorities of the country or region concerned. This is consistent with
‘One UN’ pilots that encourage joint UN activities such as (i) conducting joint training
programmes to develop capacity of COs and national counterparts, (ii) joint scoping
missions, and (iii) joint development of knowledge tools.
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Box 3. UNCAC articles and UNDP programme activities
UNCAC provides a framework for criminalization, asset recovery, international

cooperation, and prevention of corruption. A look at UNCAC requirements, as listed by
individual articles below, illustrates that they are already substantially part of the
objectives of day-to-day UNDP operations in the field, in particular in the area of
prevention.
Article 5 requires State Parties to carry out coordinated anti-corruption policies ‘that
promote the participation of society and reflect the principles of the rule of law,
proper management of public affairs and public property, integrity, transparency and
accountability’; State Parties are called to regularly assess the impact and adequacy
of these policies.
Article 6 calls on State Parties to assign the implementation and coordination of

preventive anti-corruption measures to an independent body or bodies.
Article 7 stipulates principles for the recruitment, retention and promotion of civil
servants, including the principles of efficiency, transparency and merit, as well
ensuring fair remuneration for civil servants.
Article 8 calls on State Parties to promote the introduction and implementation of

codes of conduct for public officials.
Article 9 stipulates the need for transparent public procurement and management of
public finances.
Article 10 requires State Parties to take measures to enhance the transparency of

public administration.
Article 12 calls on State Parties to implement measures to prevent corruption in the

private sector. Measures may include the promotion of codes of conduct for the
private sector, developing rules regulating conflict of interest and post-employment
regulations, ensuring transparency in regulatory policies, and introducing requirements
for the private sector to establish sound internal audit structures and to adhere to
accounting standards.
Article 13 requires State Parties to promote the participation of civil society in anti-
corruption efforts and calls on them to promote measures guaranteeing access to
information and transparency of decision-making processes, as well as transparency in
the work of institutions, including that of anti-corruption institutions or bodies.
Article 36 calls on State Parties ‘to ensure the existence of a body or bodies or
persons specialized in combating corruption through law enforcement’.
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2.2.3 Other international legal norms, standards and practices on anti-corruption
UNCAC is complemented by other regional conventions and instruments. While some of

these instruments might actually fall short of particular provisions set out in UNCAC,
they often have an established monitoring or peer review mechanism of good
governance and anti-corruption. Examples include the follow-up mechanism for the
Inter-American Convention against Corruption and the different anti-corruption
initiatives of the Organization of American States (OAS); the African Peer Review
Mechanism under the New Partnership for Africa’s Development (NEPAD); the Anti-
Corruption Committee under the SADC Protocol against Corruption; anti-corruption
initiatives carried out in the framework of the Asia-Pacific Economic Cooperation
(APEC); and regional bodies established as per Financial Action Task Force (FATF)
recommendations.
The 1999 OECD Convention on Combating Bribery of Foreign Public Officials in

International Business Transactions, the Paris Declaration on Aid Effectiveness and the
OECD/GovNet ‘Policy Paper and Principles on Anti-corruption’ all acknowledge the
importance of addressing the ‘supply’ side of corruption. This is based on the
recognition that the supply of bribes often originates from companies in a donor
country—and consequently action, including legal action, should be taken in the
country of origin.
UNDP supports these initiatives both in principle and at the operational level because
their implementation will work towards achieving global standards and sustainable
development. Where possible, implementation mechanisms of the regional
instruments and UNCAC should be able to address both instruments. For instance, both
UNCAC and the Inter-American Convention against Corruption require member states
to complete self-assessment checklists.
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3. Operational implications
UNDP’s strategic plan 2008–2011 aims at accelerating human development by

considering three key areas of democratic governance: inclusive participation,
accountable and responsive governing institutions, and democratic governance that is
grounded in international principles. To foster inclusive participation, the UNDP anti-
corruption service area focuses on, most notably, civil society, e-governance, electoral
systems and processes, political parties and independent media. To strengthen
governing institutions, UNDP focuses on promoting ATI among public institutions such
as parliament, the justice sector, public administration and local government
authorities. The anti-corruption service area also supports the strategic plan objective
of grounding democratic governance in international principles by supporting
implementation of UNCAC principles and the development of nationally owned
democratic governance/anti-corruption assessments.
3.1 Designing effective strategies
The development of effective anti-corruption strategies is highlighted in Article 5 of

UNCAC, which calls upon State Parties to develop and implement effective,
coordinated anti-corruption policies that promote the participation of civil society and
reflect the principles of rule of law, proper management of public affairs and public
property, integrity and transparency. The inclusion of such strong and clear language
reinforces the pivotal role of viable anti-corruption strategies in addressing the
problem.
An effective anti-corruption strategy requires a detailed understanding of a country’s

governance and political environment. There can never be a one-size-fits-all approach
to the corruption problem, mainly because of the historical, political, economic and
social differences among countries. The quality and effectiveness of anti-corruption
policies and programmes in a country rely on in-depth understanding of where, when,
why and how corruption occurs—and the factors that allow it to persist—in that
specific nation. There is general agreement on this, yet many countries continue to
copy standard models, often under strong donor pressure.
It is also imperative to accept that corruption is also a political problem that affects
(or is nurtured by) power relations. Many anti-corruption programmes fail because
they do not anticipate the nature, location, organization and strength of the
resistance to the reforms. Such resistance can come from either inside or outside the
bureaucracy (or from both sources). Effective programmes must include adequate
mechanisms to address all possible sources and types of resistance.
3.1.1 Approaches and techniques
Over the past decade, the approach of donors and international organizations to anti-
corruption policy has changed substantially. In the 1990s, technical assistance focused
on law enforcement and public administration reforms designed to enhance
transparency, reduce discretion and strengthen systems of oversight and control.
However, it became increasingly clear that such approaches were inadequate
(Svensson, 2005). Consequently, promoting ATI and improving ethics became a major
area of focus for institutional reforms in the public sector. As a result, anti-corruption
programmes increasingly shifted towards prevention, a development that
complements the traditional approach of pitching anti-corruption interventions to
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enforcement and control. This shift also reinforced the importance and relevance of
UNDP’s strategic approach.
However, some short-term anti-corruption strategies have proved to be unsustainable

in the long run in the absence of political will, adequate resources and clear national
strategies. For instance, legal impunity for those implicated by the media could
increase levels of public cynicism about the real political will to fight corruption.
Publicity not supported by action can also lead to scepticism if the public concludes
that officials implicated in corruption are being protected by the system.
One example is from the United Republic of Tanzania, where efforts to reform tax
administration in the second half of the 1990s through the creation of an autonomous
revenue agency ended up worsening perceptions of corruption and not leading to
sustainable revenue increases. The idea behind the reform was that by screening
existing staff to get rid of corrupt officials and raise salaries to a competitive level it
would be possible to reduce the incentives for people to take bribes. However,
corruption continued to thrive even with relatively high wages and good working
conditions. Corruption networks were in fact strengthened because the administrative
reforms led to the dismissal of many officers who were subsequently recruited to work
in the private sector as 'tax experts' because of their knowledge of the workings of the
tax system and their inside contacts. The strategy also had a negligible impact on tax
revenues: they rose steeply in the first year of the programme but then subsided due
to the increase in corruption.
Box 4. How to devise successful anti-corruption strategies
Interventions against corruption need to be centred on comprehensive initiatives at

the country level. This, however, calls for an approach that views corruption in the
context of the wider political economy of public sector governance in each country.
This stems from the growing recognition that corruption is invariably an outcome of
unresolved problems in national governance.
The following observation from the UN Anti-Corruption Toolkit (2004) is instructive:
‘[S]uccessful anti-corruption strategies must also generally be evidence-based,

dynamic, integrated and holistic. They must be able to accurately assess the problem
in advance, and from time to time as the strategy is implemented, able to create or
adapt strategic elements to respond to changing assessments; individual elements
must be integrated and coordinated with one another on an ongoing basis; and the
overall strategy must be sufficiently broad that essential elements of government and
society—including previously unaffected areas into which corrupt conduct is
displaced—are not left out.’
The challenge of addressing corruption in a comprehensive and holistic way carries the
obvious and very real risk of spreading resources too thinly. Therefore, what UNDP can
realistically achieve needs to be carefully assessed at the country level. Assessment
should take into account a number of considerations, including those mentioned in Box
5.
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Box 5. Sample pre-assessment questionnaire
1. Are the country’s needs already analyzed, budgeted for and prioritized in existing
key policy documents such as the Poverty Reduction Strategy Paper (PRSP), MDG
implementation and monitoring reports, or other relevant development
strategies?
2. What reforms is the government implementing, what is their relevance to
corruption, are preliminary outcomes available to build upon, and will there be
enough absorptive capacity to implement explicit anti-corruption projects?
3. How realistic are the prospects of strong domestic ownership of implicit or
explicit anti-corruption interventions?
4. What are the UNDP-specific experiences at the country level that should be built
upon?
5. Has a thorough mapping been undertaken of previous, ongoing and planned efforts
of the wider donor community? Are there efforts toward division of labour among
donors that might affect the programming and project design exercise?
6. Are there partners/donors that have taken the lead in cooperation/assistance
projects in certain sectors and thus should probably be left in the lead of these
sectors—such as the World Bank, which is traditionally engaged in reforming the
health and education sectors, but does not work with political parties?
7. What internal resources (staff, skills, knowledge) are available in the country
office to (i) design anti-corruption programmes, or (ii) re-shift/re-focus the
existing portfolio to add anti-corruption components and address anti-corruption
concerns?
8. What are the disbursement criteria for available funds—e.g., pressure to disburse
vs. multi-year availability?
For more on anti-corruption assessment, see CONTACT (Country Assessment in Accountability

and Transparency) Guidelines at www.undp.org/governance/docs/AC_guides_contact.htm.
3.1.2 Country, regional and global level strategies
Based on UNDP’s experience, the advantage of national strategies is that they are
easier to design and implement, by allocating national resources and identifying
implementing institutions. Another advantage is that media, civil society, professional
bodies, non-governmental organizations (NGOs), community-based organizations, and
political parties can increase ownership of, and demand for, anti-corruption
initiatives. Moreover, data collection and collation are easier at the country level from
logistical and political standpoints. It is also much simpler at a national level to
disaggregate data by gender, internal regions, sectors, levels, themes and institutions.
On the other hand, development of global and regional strategies could be effective in
situations where some countries fear that engaging in aggressive anti-corruption
activities on their own exposes them to negative perceptions; they may therefore
prefer a more regional approach. Moreover, for some practitioners, it may be safer to
engage in anti-corruption programming through regional forums in a country where the
government does not have the political will to combat corruption. For these reasons,
some countries have found it easier to ratify regional anti-corruption instruments than
develop national anti-corruption strategies. In addition, the regional forums can be
15
very useful in sharing knowledge and best practices as well as utilizing peer influence
to tackle the problem.
Global strategies could help improve policy and programme advisory services on anti-
corruption by creating an internal pool of experts through community of practice (CoP)
and networks. Members of this pool would then assist each other, reinforce
inter/intra-regional cooperation, and thereby facilitate South-South cooperation.
3.1.3 Mainstreaming anti-corruption into programmes and projects
UNDP’s strategic plan recognizes anti-corruption as one of the three international

principles and cross-cutting governance issues to be integrated into all UNDP practice
and programme areas—a process known as mainstreaming. At the country level, anti-
corruption can be mainstreamed into processes such as UNDAFs, CCAs, PRSPs, MDGs,
thematic working group (TWG) reports and other development processes. For instance,
UNDP has supported mainstreaming anti-corruption in training programmes for civil
servants in Bangladesh and in the MDG-9 document of Mongolia.
Mainstreaming of anti-corruption is most likely to be successful if it is closely

integrated in other key functional service areas of democratic governance, such as
local governance, public administrative reform and economic governance, access to
justice, parliamentary strengthening, electoral processes, independent media
development, e-governance, civic engagement (including political parties), and human
rights. By working in conjunction with these service areas, the anti-corruption service
area reinforces important governance principles such as ATI, rule of law, participation,
responsiveness and equality. This also helps reinforce human rights and democracy
while directly responding to corruption. (See section in Annex 5 titled ‘Programme
Partners’ for details on mainstreaming).
A number of challenges with regards to mainstreaming have been identified in recent

practitioners’ discussions and literature. The tension between mainstreaming on the
one hand, and the need to be strategic and focused on the other hand, has been
pointed out for some time. Another obvious challenge is that mainstreaming requires
awareness, resources and skills of staff on the ground. UNDP, through the Global
Thematic Programme on Anti-Corruption for Development Effectiveness (PACDE), is
making a conscious effort to raise staff skills and knowledge about corruption across
its operations (see Box 6). At the moment, the methodologies available are very
limited and do not provide adequate guidance to COs. Moreover, mainstreaming anti-
corruption in development processes could help prevent programmes without an ‘anti-
corruption’ label from being overly politicized, especially in situations where there is
limited political will.
16
Box 6. UNDP global programme on anti-corruption
In order to respond to the growing demand from UNDP COs and national
counterparts for technical cooperation in anti-corruption, the Democratic
Governance Group (DGG) of the Bureau for Development Policy (BDP) has
developed the UNDP global programme on anti-corruption titled Global Thematic
Programme on Anti-Corruption for Development Effectiveness (PACDE) 2008-11.
This programme aims to increase state/institutional capacity to engage more
effectively in reducing corruption to improve governance and sustainable
development. PACDE focuses both on inclusive participation (e.g., strengthening
media and civil society) and long-term systemic changes within and among public
institutions. It as also seeks to mainstream anti-corruption into UNDP’s existing
work.
3.1.4 Supporting anti-corruption institutions
The establishment of specialized anti-corruption agencies, institutions and bodies has,

for many years, been widely held to be one of the key solutions to tackling corruption
at the national level.6 To a great extent, this assumption was popularized by the
successful model of the Hong Kong Anti-Corruption Agency, established in 1974, which
had a dramatic impact on reducing corruption at the time. As a result, specialized
anti-corruption institutions have sprung up in many countries, often supported by the
international donor community.
UNDP supports establishing and strengthening anti-corruption institutions and is aware

that a number of challenges need to be highlighted and addressed when assisting
specialized anti-corruption bodies/agencies. Among the challenges are the following:
• Most governments establish anti-corruption agencies or bodies hurriedly in

reaction to a political emergency. For that reason, they often overlook and/or
underestimate the importance of making clear and well-informed decisions on
major critical policy issues such as:
1. institutional models (e.g., whether to create a new, stand-alone anti-
corruption agency or modify existing agencies; whether to focus primarily
on prevention, investigation or awareness-raising or try to do all such things
equally);
2. policies and capacity development efforts (e.g., responsibilities, mandates
and power, level of autonomy, and resources); and
3. rules of engagement (e.g., interaction, coordination and collaboration with
other agencies).
• Anti-corruption entities are often a technocratic answer to a political problem

(Smilov and Tisné 2004). Therefore, although political support is initially given,
it is often not sustained, thereby setting the conditions for the failure of such
agencies. Anti-corruption commissions have been most successful when they
have strong political backing at the highest level of government.
6
Articles 6 and 36 of UNCAC call for an independent anti-corruption body or bodies to be assigned the task of co-
coordinating preventive and educational anti-corruption activities and for an independent body dealing with the law-
enforcement aspect of corruption, respectively. However, both articles leave the option of which model to adopt to
the individual countries themselves.
17
• Anti-corruption commissions need to be thoroughly budgeted to ensure that
they have sufficient resources over the long term. Such exercises should
consider financial, human and technical resources equally.
• More attention must be given from the onset to the fact that commissions that
have investigative and law enforcement mandates are often perceived by
‘traditional’ agencies as interfering in their work; those agencies may therefore
withhold adequate cooperation. More importantly, qualified staff are often
drawn away from those other institutions, thereby leaving them under-staffed.
• Terms of reference of specialized anti-corruption agencies should be precisely

defined, and they should be governed by a comprehensive legal framework.
• There is a need for sound performance indicators of anti-corruption entities. At

the very least they should include monitoring methodology and indicators of
success.
• The issue of resources needs to be addressed upfront. Anti-corruption

commissions tend to put a heavy strain on already limited resources in country
administrations; as a rule, there are no surplus capacities to channel into a new
institution.
• The cost of failure is substantial. Public expectations are initially very high,
resulting in an increase in public cynicism that can undermine future anti-
corruption efforts. (See, for example, Doig et al, 2005.)
The institutional setting of the law enforcement system has been an important focus
of reform in many countries. A growing number of countries have established
centralized and specialized agencies explicitly entrusted with combating corruption
and taking over from other law enforcement agencies that were perceived to be too
much involved in corruption themselves.
Generally, the multiple agency approach is found in countries where bureaucratic

institutions are strong and functional, well-resourced and coordinated, such as
Canada, Japan, the United States, and many Western European countries. Similarly,
China, the Philippines, South Africa, and Viet Nam depend on multiple agencies to
curb corruption. But one of the major disadvantages of this approach is that it can
lead to the problems of duplication, lack of coordination and turf wars.
In any case, whether taking a single or a multiple agency approach, anti-corruption

institutions depend largely on good cooperation and communication with, and the
proper functioning of, other law enforcement agencies, especially the police, public
prosecutors and the courts.
It should be pointed out that although Hong Kong’s single institution model has been
copied by many countries (including Botswana and Singapore), its results have been
mixed. While independence continues to be cited as one of the main success factors,
experience from around the world actually suggests that ‘focused mandates’ is
probably as much a critical factor as the need for operational independence. The
agency needs to be strategic in defining its focus in a way that will maximize its
effectiveness. For example, the Independent Commission against Corruption (ICAC) in
the Australian state of New South Wales deals only with matters that have the
18
potential to expose significant and/or systemic corruption or which otherwise involves
matters of significant public interest. In Indonesia, meanwhile, the Corruption
Eradication Commission of Indonesia (KPK) investigates, indicts and prosecutes
corruption cases that involve law enforcement officers, government executives and
other public officers that have drawn the attention of the general public and /or
involve loss to the state of at least 1 billion rupiah (about $104,000 using the exchange
rate as of 6 October, 2008).
Instead of creating new institutions, a number of countries have opted to strengthen

existing institutions’ roles and capacities to fight corruption (e.g., South Africa). There
is a sufficient body of evidence to suggest that ‘specialization, expertise and even the
necessary degree of autonomy can be achieved by establishing dedicated units within
existing law-enforcement agencies’ (UNDP, Institutional Arrangements to Combat
Corruption, 2005).
Box 7. Case for and against specialized anti-corruption commissions and

agencies
Advantages:
• completely new institution enjoys a ‘fresh start’ and thus faster action is
achieved
• sends a signal that the government takes anti-corruption efforts seriously
• high degree of specialization, expertise and autonomy
• greater public credibility; political and legal accountability
• clarity in the assessment of its progress, successes and failures
Disadvantages:
• often a technocratic answer to a political problem
• greater administrative costs; cost of failure is substantial due to public
expectations
• isolation, barriers, rivalries with other existing agencies
• vulnerable to attempts to marginalize (e.g., by underfunding)
3.1.5 Research and planning for programming
Since causes, consequences and perceptions of corruption constantly change, there is

a great need for UNDP to continue supporting research and analysis of emerging
trends, phenomena and acts of corruption in partnership with research and academic
institutions.
Through research data and measurement of impact, UNDP, due to its experience as a
knowledge broker and its presence in more than 135 countries with its vibrant
knowledge networks and CoP, can make a valuable contribution to the understanding
of key issues where the current anti-corruption debate is based on inaccurate or
insufficient information and assumptions. For example, there is very little
disaggregated data available regarding how and to what extent corruption affects
women and men differently; or on the effect (if any) of anti-corruption programmes or
projects on reducing gender-related patterns of corruption. Likewise, the need to
target private sector actors through programmes and projects has now widely been
acknowledged. Further research is needed to understand the specific dynamics and
19
mechanisms of corruption involving the different types of businesses in different
countries. Finally, adequate research would likely be able to separate corruption from
mismanagement. That would be particularly useful in public sector service delivery,
where the two issues are often conflated in the public perception; but ultimately,
they require very different remedies.
Moreover, in order to achieve greater impact and improve UNDP anti-corruption

strategies in the future, technical studies should be commissioned to address the need
for any specific anti-corruption programme and evaluate the success of past
programmes. Technical studies should be readily accessible to practitioners. Even if
there are only limited resources for a study, UNDP staff should nevertheless collect
quantitative and qualitative data to the fullest extent possible. This raw data could
contribute significantly to an improvement of UNDP anti-corruption programming.
The creation and support of regional anti-corruption networks has been a popular
form of raising awareness about corruption. By bringing senior level officials and anti-
corruption practitioners together, these networks can be a catalyst for putting
corruption and relevant instruments on the political agendas of countries that might
otherwise be reluctant to publicly discuss the issue. If managed well, the networks can
benefit from healthy competition among peers. Finally, regional forums provide
opportunities for the promotion of information exchanges and mutual learning among
different countries.7
Box 8. A User’s Guide to Measuring Corruption
A User’s Guide to Measuring Corruption, jointly produced in 2008 by UNDP and

Global Integrity, is one of the first attempts to explore how best to use existing
tools to measure one of the major impediments to development: corruption. Based
on a review of the literature and bolstered by more than 30 original interviews
with experts in the field, A User’s Guide provides government, civil society and
development practitioners with ‘good practices’ in recognizing and measuring
corruption.
For more details see: www.undp.org/oslocentre/flagship/users_guide_measuring_corruption.html
Ultimately, the capacity to identify research needs and to use results in policy design
should be developed with national counterparts. UNDP urges partner countries to
make an honest and realistic assessment of why anti-corruption measures tend to fail.
Before providing support to new regulatory initiatives, strategy and policy documents,
the full potential of the provisions in place should be used, and measures should be
supported that advance their implementation and the monitoring of their impact.
7
Successful examples of regional anti-corruption networks include i) the Arab Regional Network, coordinated by UNDP
POGAR; ii) the Anti-Corruption Practitioners Network (ACPN), coordinated by the Bratislava Regional Centre; and iii)
the Caribbean Anti-Corruption Peer Support Network, coordinated in part by the UNDP Sub-Regional Office for
Barbados and the Eastern Caribbean (OECS).
20
3.1.6 Identifying anti-corruption actors
Government counterparts
Entry points for anti-corruption programming depend on identifying potential partners

in governments as well as the appropriate timing for engaging them. This depends on
the country context. Where there is little willingness to even talk about corruption at
the government level, it will be difficult to engage in explicit anti-corruption
activities. Choices might then be limited to less ‘controversial’ and less politicized
measures. However, there might be a champion of anti-corruption who could be a
catalyst for developing anti-corruption interventions. Moreover, during election
campaigns, candidates and political parties may want to ‘attach’ a good governance
tag to their campaigns, and this may create an opportunity for anti-corruption
programming when a new government is formed. For instance, in Pakistan, UNDP is
working with the Ombudsman’s Office, in Swaziland with the Anti-Corruption
Commission, and in Chile with the Comptroller General’s Office. In a number of other
countries, UNDP works with various government institutions such as prosecutor’s
offices, ministries, judiciary, police and public service commission as partners in the
fight against corruption.
Civil society
Civil society organizations8 can play a vital role in anti-corruption policy and
programme development and implementation as well as holding the public sector
accountable—especially in the social sector and service delivery. One strategy is to
have citizens’ oversight bodies that are involved in social audits9 and budget tracking,
and citizens’ committees organized in sectors such as education, health and the
environment. Civil society networks can also mobilize the population for zero
tolerance against corruption.
The first generation of anti-corruption programmes acknowledged the important role

of civil society in the fight against corruption. However, a number of crucial problems
have been highlighted in the literature, such as the fact that anti-corruption CSOs
often have internal governance and management problems. Others are not perceived
as truly legitimate; for example, some were established or began focusing on anti-
corruption not in response to corruption per se, but primarily because of international
donor interest in funding civil society anti-corruption activities (See, for example,
Tisné and Smilov, 2004; Bailey, 2003). But examples abound of successful civil society
engagement—these involve initiatives at both the very local level as well as
transnational movements, most notably Transparency International. Experience shows
that civil society can play a central role in monitoring corruption and improving the
delivery of public funds. For example, it has been very effective in monitoring public
funds for construction of schools and roads in Uganda and Indonesia (Reinikka and
Svensson, 2005; Ben Olken, 2007).
8
Article 13 of UNCAC provides that each State Party shall take appropriate measures, within its means and in
accordance with fundamental principles of its domestic law, to promote the active participation of individuals and
groups outside the public sector, such as civil society, non-governmental organizations and community-based
organizations, in the prevention of and the fight against corruption and to raise awareness on the existence, causes and
gravity of and the threat caused by corruption.
9
Social audits refer to oversights of public institution performance by citizenry.
21
Thus, civil society actors should be part of the explicit or implicit anti-corruption
portfolio, and the capacity of these groups should be supported specifically in
countries where other oversight (governmental, parliamentary) is weak. The objective
of civil society capacity-building should be, inter alia, to generate demand for
accountability and transparency from the general public. But civil society actors
should never be made the sole stakeholders focusing on the issue in a country. An
ongoing effort should be made, at country level, to be aware of (or ‘map’) what NGOs
are doing and what type of assistance might be required. Not all backing for NGOs has
to take the form of project funding—sometimes, adding UNDP’s voice of support can
boost an organization’s efforts at the official level.
Box 9. UNDP engagement with civil society
UNDP has a longstanding partnership with CSOs at the national, regional and
international levels. For example, UNDP in 2003 supported an independent research
organization to use the national human development report process of Burkina Faso to
research on corruption and use the findings to effectively advocate for more radical
reforms. Burkina Faso’s Human Development Report 2003 highlighted the adverse
effects of corruption on the implementation of the human development process, with
a particular focus on the fight against poverty. It aimed at informing people on the
consequences of corruption in terms of critical human development dimensions:
durability, equity, productivity and empowerment. The purpose was also to raise
debate among development actors and influence the implementation of policies to
reduce corruption in public affairs management.
Work with and support for civil society actors should also take into account that the
fight against corruption is, in most cases, politically charged, and thus can be
dangerous for NGOs. Supporting activities that are based on neutral methodologies—
for example, monitoring election campaigns—can therefore be one way to engage civil
society.
Media
In many countries where corruption is rampant, the demand side of anti-corruption

tends to be low. This can be attributed to citizens not used to enforcing their rights,
as well as a political environment where the mechanisms for democratic expression of
rights do not exist. In such contexts, the media can play two important roles, assuming
it is informed on causes, effects and magnitude of corruption as well as international
anti-corruption norms and standards: it can (i) expose acts of corruption; and (ii) raise
citizen awareness of the direct impact of corruption and weak integrity systems on the
economy and people’s lives. (It is important to remember too that the media can also
be corrupt; the sector therefore needs to be accountable and have oversight
mechanisms including a code of conduct for its members.)
Within this context, UNCAC Articles 10 and 13 recognize the importance of State
Parties to adopt procedures and regulations that allow citizens to obtain information
from the public sector. UNCAC recommends simplifying government procedures to
facilitate public access to information on decision-making processes and encourages
governments to publish information on risks of corruption in the public sector.
22
Private sector
Article 12 of UNCAC calls on State Parties to strengthen measures to prevent

corruption in the private sector. It also lists several possible ways to achieve that
overall goal, including the promotion of cooperation between law enforcement
agencies and private entities; the promotion of standards and procedures to enhance
integrity of private sector entities (e.g., codes of conduct); the introduction of post-
employment rules for former public officials; the introduction of sound internal
auditing; and strengthening of external auditing procedures. These are all potential
areas for cooperation and technical assistance to partner countries. This has been a
weak programming area for UNDP and notable examples are few.
The importance of involving the private sector—which is often involved in what is

called the ‘supply side’ of corruption—in anti-corruption efforts has been increasingly
acknowledged over the past years. The 1997 OECD Convention on Combating Bribery of
Foreign Public Officials in International Business Transactions was the first
international legal instrument addressing the issue. The Convention makes it an
offence for companies from OECD countries to bribe public officials in any country
where they conduct business.
More recently, in 2004, the UN Global Compact added a 10th principle on anti-
corruption: ‘Businesses should work against corruption in all its forms, including
extortion and bribery’. (The Compact is an initiative for businesses to comply, on a
voluntary basis, with principles in the areas of human rights, labour, and the
environment.)
3.1.7 Building partnerships
How to use UNCAC as a tool for furthering UNDP mandates requires close cooperation
across practices at the horizontal and vertical levels. The strategy should be to work
with a number of partnerships at different levels and different programme
components and with the global programmes and major activities of other democratic
governance areas such as human rights, local governance, economic governance,
gender, media, parliamentary strengthening and public administration reform.
Guided by the MoU between UNDP and UNODC, there is close partnership with UNODC
in a number of areas, particularly in capacity development, development of
knowledge tools, joint scoping missions and joint resource mobilization. UNDP will
continue its cooperation with OECD’s DAC/GovNet in joint assessments. It will enhance
cooperation with the World Bank, the International Monetary Fund (IMF), the Asian
Development Bank, the African Development Bank, GTZ (Deutsche Gesellschaft für
Technische Zusammenarbeit, the Government of Germany’s primary foreign aid
agency), the U4 Anti-Corruption Resource Centre, the New Partnership for Africa’s
Development (NEPAD) and other partners. Cooperation with CSOs, particularly to
enhance South-South cooperation, will also be one of the leading activities under
UNDP’s anti-corruption service area.
23
3.2 UNDP strategic areas of intervention (programming activities)
Building upon UNDP’s past experiences and taking into account the increased demand
for anti-corruption activities due to UNCAC and other international norms and
standards, strategic areas of UNDP intervention may be grouped in the following five
major categories:
• Increasing state/institutional capacity to respond to UNCAC and improve
governance;
• Strengthening the capacity of the media and civil society to provide anti-
corruption oversight;
• Utilizing governance/anti-corruption assessment tools to inform policies;
• Improving harmonization and coordination of anti-corruption initiatives; and
• Improving awareness and knowledge.
The activities under these five categories are presented in detail in Sections 3.2.1 to
3.2.5.
3.2.1 Increasing state/institutional capacity to respond to UNCAC and improve

governance
Effective implementation of anti-corruption measures largely depends on

state/institutional capacity to do so, including to implement UNCAC. Therefore, a key
potential goal for UNDP programming should be to increase state/institutional capacity
to reduce corruption. For example, UNDP CoP and national counterparts could be
trained in international anti-corruption standards, and anti-corruption technical
assistance and programming in the context of UNCAC.
UNCAC underlines the importance of adequate anti-corruption training in several

places. Article 7.1 (d) notes the need for ‘education and training programmes to
enable civil servants and, where appropriate, other non-elected public officials, to
meet the requirements for the correct, honourable and proper performance of public
functions and that provide them with specialized and appropriate training to enhance
their awareness of the risks of corruption inherent in the performance of their
functions’. Article 60 of the Convention is explicit in giving direction to the content of
training for personnel responsible for preventing and combating corruption initiatives,
such as prosecutors and the police.
It should be noted that even in the absence of UNCAC, a central part of UNDP
programming on anti-corruption has traditionally focused on supporting efficient,
responsive, transparent and accountable public administrations. This focus is based on
the realization that a strong administrative capacity offers much needed clarity and
coherence for the implementation of national priorities. UNDP’s Public Administration
Reform (PAR) programmes have been comprehensive and include process changes in
areas such as organizational structures, decentralization, personnel management,
public finance, results-based management and regulatory reform. As the first
comprehensive and global anti-corruption instrument, UNCAC has provided fresh
momentum for linking UNDP work on public administration with the implementation of
UNCAC norms and standards.
Experiences show that most anti-corruption training to date has been too general in
nature, and future efforts must be tailored according to the needs of a specific sector
24
(for example, public utilities), or certain high-risk processes in the public
administration (for example, public contracting and procurement). It is important to
note that training programmes must aim to transfer specific, concrete information,
and they must not be too generic or too brief. In addition, specialized training should
be provided by the partners to increase the impact of capacity-development efforts.
Coordinating with UNODC and other relevant partners, UNDP headquarters and
regional centres and COs can provide anti-corruption technical and advisory support
for national partners. The global and regional advisors could facilitate the
development of terms of reference (ToR) to guide anti-corruption assessment
processes, identify experts and stakeholders to be involved in the process and organize
missions. Stakeholders may include government officials, media, NGOs and UN
agencies. The assessment reports are useful in developing future proposals, strategies
and activities. Similarly, ongoing technical and advisory support could also be provided
to national counterparts to develop anti-corruption policies and strategies, establish
oversight institutions, and develop knowledge products.
Another important area of anti-corruption programming is developing methodologies

to incorporate anti-corruption principles in service delivery and activities of UNDP
TWGs. At the country level, a number of projects fall under TWGs, and these are the
projects that impact on the poor most.
As more and more countries move towards implementation of UNCAC, one of the basic
ways of identifying strength and weaknesses of state institutions, laws and regulations
is to conduct a gap analysis of State Parties’ legal and institutional frameworks and
national anti-corruption strategies.10
Box 10. Gap/compliance analyses with respect to implementing UNCAC
The main objective of gap/compliance analyses to implement UNCAC is to assist the

States seeking to ratify and implement UNCAC by ensuring legislative and institutional
compliance with UNCAC provisions. For example, Bangladesh and Indonesia have
conducted analyses to identify gaps between the provisions of UNCAC and their
existing legislation and institutional realities.
10
Article 60 of UNCAC provides areas for training and technical assistance, which can be utilized for developing anti-
corruption interventions.
25
3.2.2 Utilizing governance/anti-corruption assessment tools to inform policies
The UNDP approach to supporting country-led democratic governance and anti-

corruption assessments aims to strengthen the organization's broader agenda on
democratic governance with the assessments as a corporate output in the UNDP
strategic plan for 2008–2011.
Box 11. Examples of UNDP knowledge tools
Mapping of Corruption and Governance Measurement Tools in Sub-Saharan Africa.

UNDP conducted this mapping with Transparency International in 2007. It provides
guidance to the uses and limitations of 42 different international, national and local
tools for measuring corruption in 28 countries in sub-Saharan Africa. Online in PDF
format: www.undp.org/oslocentre/docs08/mapping_corruption_africa.pdf.
Tackling Corruption, Transforming Lives—Accelerating Human Development in Asia

and the Pacific (2008). This regional human development report shows why
eliminating corruption that plagues people’s daily lives must become a priority. It
recommends that cleaning up the police, health, education and environment sectors
be a top political priority in the Asia-Pacific region in order to loosen the stranglehold
of corruption on the lives of the poor. Online in PDF format:
www.undprcc.lk/ext/crhdr/Download.html.
Many current surveys on anti-corruption, such as those released annually by

Transparency International, are dominated by perceptions indices that rank countries.
UNDP takes a different approach, which is consistent with Resolution 1/1 of the first
Conference of States Parties (COSP) to UNCAC held in Jordan in 2006. The COSP
recommended that any review mechanism under UNCAC should not rank countries, but
rather provide opportunities to share good practices and challenges.
There is a clear need to develop local or domestic surveys and indicators that provide
more in-depth analysis of particular policy issues such as marginalized and vulnerable
groups. Country-specific and disaggregated indicators can help identify specific
institutions and practices that perpetuate unfair and sub-standard provision of services
to these groups. In order to use measurement tools for positive change, precise
knowledge of corruption is required that can be used beyond awareness-raising. For
example, information about the levels, forms, types, manifestations and location of
corrupt practices could be utilized to inform policy-making and build cooperative
partnerships with all stakeholders engaged in anti-corruption work at the national
level. Surveys to qualify and quantify corruption at selected country levels provide
independent, specific and reliable information to inform, trigger and monitor policy
change. The information gathered will contribute to various development processes,
including regional and national human development reports.
26
Box 12. UNDP support to governance assessment
Capacity development is always at the centre of the UNDP approach. The agency
emphasizes four key areas in its support for governance/anti-corruption assessment
tools:
1. promoting multi-stakeholder participation
2. aligning governance assessments with national development plans
3. promoting pro-poor and gender-sensitive governance assessments
4. strengthening evidence-based policy-making
Support to the governance, justice, law and order sector reform programme of
Kenya
In order to assess the second phase of the programme (anticipated to run until 2009),
which focuses on in-depth, inter-institutional reforms involving over 30 public
institutions, a National Integrated Household Baseline Survey Report involving over
12,000 Kenyans was conducted in 2006. The survey aimed to increase awareness that
specific targets could not be established for a number of ‘objectively verifiable
indicators’ due to the absence of empirical baseline information. The survey collected
data and observations on corruption, access to justice, safety and security, human
rights, and the perceived performance of government institutions. The findings will
form the basis for the assessment of the programme’s progress.
Assessing democracy in Mongolia
Mongolia embarked on a country-led governance assessment in 2003 using

International IDEA’s democracy assessment framework as the foundation for its
methodology. It adapted that framework to a national context with guidance provided
by UNDP (see www.idea.int/democracy/da_mongolia.cfm). Mongolia has established a
link between national democracy assessment and democratic interventions aimed at
consolidating democracy by linking an assessment and a plan of action. Mongolia’s
MDG-9 on human rights, democracy and anti-corruption has particularly benefited
from the development of democratic governance indicators (DGIs) and will in its turn
help institutionalize the application of DGIs in a government reporting mechanism,
including the zero tolerance of corruption target in MDG-9 (UNDP, 2006; Hulan, 2007).
UNDP support to governance assessment in Zambia
In response to multi-donor governance indicators that sometimes overlap and

contradict each other, UNDP is supporting Zambia to develop common indicators
applicable to different donors’ programmes and activities aiming to rationalize and
harmonize governance assessment by donors in Zambia, in line with the 2005 Paris
Declaration.
Another set of activities to inform policies is the production of diagnostic tools to

measure corruption. A report summarizing the available tools across the examined
countries and organised by type, coverage, purpose, source, methodology, and impact
would enable disaggregated data to serve as viable policy instruments for pro-poor and
gender development goals.
27
3.2.3 Strengthening media and civil society to provide anti-corruption oversight
Strengthening media and civil society to provide anti-corruption oversight has been a
major component of UNDP anti-corruption programming. UNDP should continue
involving civil society and media in awareness-raising, training civil society members
and journalists on anti-corruption, increasing civil society and media participation in
policy formulation and international representation, and supporting innovative
activities of CSOs and the media.
However, it is important to link anti-corruption awareness campaigns closely to a

policy issue and to provide the public with specific tools that it can use to report
instances of corruption, or to seek remedies. This could consist of, for example,
raising public awareness about the reform or adoption of a piece of legislation.
Awareness campaigns do create a momentum for reform: it should be carefully
assessed whether this momentum can be maintained over the medium or long term.11
It is crucial that awareness campaigns include activities on promoting the goals and
objectives of UNCAC and other relevant instruments.12
Box 13. Examples of UNDP support to media and civil society
UNDP support to the Peruvian Press Council (Consejo de la Prensa Peruana)
In February 2004, after several meetings on the role of the Peruvian press in the new
democratic context, UNDP and the Peruvian Press Council signed an agreement that
enabled UNDP to provide resources to the Information for Democracy project, through
which the Peruvian Press Council contributed significantly to the debate and drafting
of the Transparency and Access to Public Information law. The press council conducted
a year-long public education campaign for citizens’ right to public information that
was published weekly by its print media members. This collaboration has expanded
over the years, with the press council’s work relating to the defence and enhancement
of freedom of expression and of the press, the role and responsibility of the media in a
democratic society and the right to public information continuing to have positive
results both in Peru and the Latin American region.
Strengthening the capacity of media and CSOs in transparency advocacy in Yemen
In order to increase the momentum of anti-corruption efforts in Yemen, UNDP

supported a media project advocating for greater transparency through capacity
strengthening, networking, and promoting codes of conduct for journalists at the
national level. The project also aimed to promote the exchange of information on
corruption issues, methodologies to monitor public expenditure and awareness-raising
among NGOs.
11
Successful examples include an anti-corruption awareness campaign conducted in Bulgaria in 2000 that raised the
perception of corruption (Tisné and Smilov, 2004).
12
UNDP, together with Transparency International and the Institute for Security Studies of South Africa, is conducting
the Joint Convention Project for Africa. The project aims at building critical stakeholder support for the promotion and
implementation of UNCAC and the African Union Convention against Corruption. Guides and practical instruments have
been developed to raise awareness about the objectives of both conventions with civil society actors and national
legislators.
28
3.2.4 Improving harmonization and coordination of anti-corruption initiatives
In many developing countries, UNDP is uniquely positioned to play an important role in

various coordination mechanisms. As the chair of the resident coordination system,
which encompasses all organizations of the UN system dealing with operational
activities for development, UNDP should continue its coordinating role in
mainstreaming anti-corruption into processes such as UNDAFs and CCAs. Similarly,
UNDP’s specific role in many countries also provides an opportunity for enhancing
coordination and collaboration among major anti-corruption efforts.
Box 14. UNDP Afghanistan’s accountability and transparency project(ACT)
Responding to a request from the Afghan government for international donors to

support the development of a national anti-corruption strategy, UNDP in 2007 joined
forces with the UK Department for International Development (DFID), the Asian
Development Bank and the World Bank to conduct a number of sectoral and functional
analysis that will provide data to feed into the strategy. UNDP and DFID have funded
an in-depth analysis of vulnerabilities to corruption in the budget department, one of
the seven departments of the Ministry of Finance. The objective of that analysis is to
identify areas vulnerable to corruption and to create a tool that will facilitate the
assessment of progress made in addressing those problems.
Box 15. Institutional coordination: The case of UNDP Nicaragua
At the beginning of 2002, a group of like-minded donors decided to support the

Government of Nicaragua in its fight against corruption and appointed the Embassy of
Norway as leading agency of the basket fund. UNDP joined the anti-corruption fund,
which had an objective to increase transparency in public administration, reduce
corruption and strengthen public institutions in order to promote democratic
governance and economic growth. The initial partner institutions during the first phase
(2002–2005) were the Prosecutor General’s Office and the Ministry of Interior. During
the second phase (2005–2008), the national police, the Public Ministry and the Office
of Public Ethics were also involved. Total contributions to the fund rose from $293,000
in 2002 to $1.21 million at the end of the second phase in 2008.
The most visible results of the fund have been strengthened institutions and better
institutional coordination. Another important achievement has been the establishment
of Prosecutor General’s Offices nationwide in all districts of the country and the
creation of the Citizen Participation Office at the Prosecutor General's Office. The
third phase will be based on the implementation of the national anti-corruption
strategy, which is expected to begin in 2009. That strategy has been developed with a
high degree of ownership by various relevant national institutions.
At the global and regional levels, UNDP should continue its activities in building and
improving strategic coordination with other partners such as U4, OECD, Transparency
International and international financial institutions. The cooperation framework with
UNODC in particular promotes increased cooperation in scoping missions, backstopping
and delivery of technical assistance for capacity development. UNDP should also
encourage networks and cooperation with institutions from developing countries as
well as promoting South-South cooperation.
29
3.2.5 Improving awareness and knowledge
UNDP should continue its efforts to improve awareness and knowledge through
updating and developing information products (e.g., flyers, fact sheets and posters on
topical issues) and knowledge tools (guidelines, manuals, comparative experiences and
primers) on anti-corruption to support anti-corruption programming at the global,
regional and country levels. These products could be disseminated and best practices
could be shared in coordination with UNDP knowledge networks and the CoP.
3.3 Leading by example: Strengthening internal accountability within UNDP
The accountability system of UNDP is established by General Assembly resolution

26/88 and affirmed by resolution 59/250. It is reaffirmed by resolution 62/208 on the
Triennial Comprehensive Policy Review of the operational activities for development
within the UN system, which emphasizes the principle of national ownership. As per
that principle, operational activities are carried out in programme countries at their
request and in accordance with their own policies and priorities for development. The
UNDP accountability system is composed of (i) an accountability framework and (ii) an
oversight policy. The accountability framework underscores the commitment of UNDP
to results and risk-based performance management, as well as the shared values of
accountability and transparency. The oversight policy of UNDP includes the
organization of independent internal and external oversight to provide assurances to
the Executive Board and the Administrator that functional systems of internal controls
are in place, including evaluation of the policy framework, efficient utilization of
resources and adherence to professional and ethical standards in UNDP.
UNDP will continue to build on the progress made to strengthen accountability. It will
leverage relevant lessons learned from its own experience and those of other
international organizations to further enhance the UNDP accountability framework.13
Box 16. UNDP internal anti-corruption and accountability measures
1. UNDP Legal Framework for Addressing Non-compliance with UN Standards of

Conduct
2. UNDP Policy on Prevention of Workplace Harassment, Sexual Harassment and
Abuse of Authority
3. UNDP Accountability System, Internal Audit and Oversight (18 December 2007,
DP/2008/16)
4. Criminal accountability of United Nations officials and experts on mission, Note
by the UN Secretariat (A/62/329)
5. UNDP Programme and Operations Policies and Procedures
6. The Ethics Office tasked by the Secretary-General and the appointment in 2008
of the UNDP Ethics Advisor in ensuring the highest standards of integrity among
UN/UNDP staff members
The 2007 Global Accountability Report by One World Trust, a leading expert in the
field of global governance and accountability, ranked UNDP first among 30 of the
world's leading organizations from intergovernmental, non-governmental, and
13
UNDP accountability system DP/2008/16/Rev /1
30
corporate sectors assessed under four widely accepted dimensions of accountability:
transparency, participation, evaluation, and complaint and response mechanisms. This
ranking independently validates UNDP’s current work as the agency continues to
adhere to the best practices of accountability.14
Box 17. Summary of potential anti-corruption interventions

1. Interventions to increase state/institutional capacity to respond to UNCAC and
to improve governance:
• training UNDP field staff and national counterparts on anti-corruption and UNCAC
• providing anti-corruption technical and advisory support for national partners
• undertaking risk assessment and gap analysis (capacity assessment)
• providing advisory support toward the development of national anti-corruption
strategies, policies and work plans
• supporting the establishment and strengthening of oversight institutions
• developing methodologies for incorporating anti-corruption principles in service
delivery/activities of TWGs
2. Anti-corruption interventions to increase use of assessment tools to inform
policies at national level:
• producing diagnostic tools to measure corruption
• undertaking surveys to qualify and quantify corruption (by sector)
3. Interventions to strengthen capacity of the media and civil society to provide

oversight against corruption:
• training civil society and media
• increasing civil society and media participation in policy formulation and
international representation
• funding innovative activities of CSOs and the media
4. Interventions to improve harmonization and coordination of anti-corruption

initiatives:
• improving UN agency and donor coordination
• improving strategic coordination with other partners
5. Interventions to increase awareness and knowledge of anti-corruption norms,
standards and methodologies and their application:
• producing flyers, fact sheets and posters on topical issues
• producing guidelines, manuals, comparative experiences and primers
• enhancing knowledge management (sharing best practices using knowledge
networks)
14
One World Trust, 2007 Global Accountability Report: Accountability Profile. Online:
www.oneworldtrust.org/documents/UNDP,_accountability_profile.pdf (accessed 7 August 2008).
31
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UNDP Practice Note: Mainstreaming Anti-Corruption in Development 34
ANNEXES: (POLICIES, KEY ACTORS, PRINCIPLES, INSTRUMENTS, RESOURCES, PARTNERS)

Annex 1. Summary of main policies to prevent, restrict or combat corruption
Sphere Main policies/measures
Improving integrity of laws and the • Institutionalization, transparency, consultation and professionalism of legislative processes
legislative process • Screening draft laws for vulnerability to corruption
Criminal law enforcement • Criminalize corrupt acts
• Enable tracing, seizure, freezing and forfeiture of illicit earnings from corruption
• Restrict immunity from prosecution
• Strengthening and coordination of law enforcement bodies
• Witness protection
Conflict of interest, asset and income • Addressing conflicts of interests
declaration • Provisions on incompatibility, disclosure, exclusion from decision-making
• Require public officials to regularly declare assets
• Independent supervision and control
Other accountability mechanisms • Ombudsperson
Public administration/civil service • Effective management systems
• Systems of recruitment, hiring, retention, training, remuneration, promotion and retirement of civil
servants
• Application of administrative law: procedures, recourse and appeal
• Standards of conduct and codes of ethics
• Complaints mechanisms; and whistle-blower protection
Public finances, financial control and • Improving budget standards and processes
audit • Independent supreme audit institution (auditor and comptroller General Offices)
• Functionally independent internal control/audit
• Tax and customs revenue collection
Public procurement regulation • Public procurement law
• Independent oversight and systems of appeal
Transparency and access to information • Guaranteeing constitutional right of freedom of expression and association
• Ensuring passive and active access to information
• Media reform (e.g., public service broadcasting)
Political finance regulation • Political party and election campaign finance regulation
Public service provision • Holistic approach to public service reform (e.g., health and education)
Economic regulation • Effective competition policy; Transparent and proportionate business regulation
UNDP Practice Note: Anti-Corruption 35
Annex 2. Key actors in the fight against corruption
Key actor Role in combating corruption

Freely elected • Enacting legislation
parliament • Holding the executive accountable through regular public scrutiny
The Global Organization of Parliamentarians against Corruption is a good
network for legislators working against corruption; online:
www.parlcent.ca/gopac/index_e.php.
Central • Sound economic policies (actors: Ministry of Finance, Central Bank, etc.)
government • Political commitment to combating corruption
• Initiation of anti-corruption policies and sponsoring coalitions necessary
for their success
Local government • Establishing effective accountability and transparency mechanisms at the
interface between citizens and officials
An example of local accountability initiatives is the Seoul OPEN system that gives
citizens ability to track online the progress of their application for services;
online: http://english.seoul.go.kr/gover/initiatives/inti_open_system.htm.
Public • Can provide example to society of values of honesty, sincerity and
administration/civil integrity
service • Implementation of policies on guidance, management and control of
ethical conduct
On efforts to improve civil service ethics and integrity, visit UNPAN’s website:
www.unpan.org/EthicsWebSite/inc/ethicspg.htm.
Schools/Ministry of • Can educate youth on good governance values and encourage resistance
Education to corruption.
Listing of resources regarding education and training in ethics, online:
www.iipe.org/resourcedocs/training.html.
Law enforcement • Ensuring observance of the rule of law and protection of rights
and the judiciary • Enforcement of anti-corruption legislation
Anti-corruption Where effective, can
agency • help coordinate and formulate anti-corruption policy
• be responsible for prevention and awareness raising
• assist law enforcement where existing institutions inadequate
Examples: Lithuania Special Investigation Service (www.stt.lt/?lang=en), Hong
Kong Independent Commission against Corruption
www.icac.org.hk/eng/main/index.html, Central Vigilance Commission of India
http://cvc.nic.in.
Auditor General • Responsible for auditing government income and expenditure
• Prevents corruption by raising accountability in use of public funds
The work of the National Audit Office in the United Kingdom is a useful example;
online: www.nao.org.uk.
Ombudsperson • Receives and investigates allegations of mal-administration, including
issues of corruption—thereby providing another layer of accountability
and transparency
Public procurement • Provides independent oversight and control of the legality and efficiency
body of public procurement
Guidelines for procurement in developing countries can be found on the OECD
website; see the following (in PDF format):
Media Can play an important role in
Key actor Role in combating corruption
• holding public institutions and functionaries accountable
• increasing transparency
• exposing corruption
• building support for efforts to combat corruption
For good examples see Philippine Center for Investigative Journalism; online:
www.pcij.org.
Electoral • Supervises proper conduct of elections
commission • May supervise and control political party and electoral campaign finance
Non-governmental • Can play a crucial role in advocacy and awareness about corruption and
organizations anti-corruption policy
(NGOs) • Exerts pressure on government and the private sector for greater
transparency and accountability
• Independent monitoring of conduct and performance of institutions and
officials and of policy implementation
The most influential and well-known NGO working primarily on anti-corruption
issues is Transparency International; online: www.transparency.org.
Private sector Can be an important ally in fighting corruption by
• providing counterweight to government by helping to resist corrupt
practices
• lobbying in coalition for legislative and other reforms
• promoting sound and ethical business practices and corporate
accountability
Annex 3. Promoting accountability, transparency and integrity (ATI)
Accountability and transparency are indispensable pillars of democratic governance that

compel the state, private sector and civil society to focus on results, seek clear objectives,
develop effective strategies, and monitor and report on performance. Through public
accountability and transparency, governments (together with civil society and the private
sector) can achieve congruence among public policy, its implementation and the efficient
allocation of resources.
Accountability means holding individuals and organizations responsible for performance

measured as objectively as possible. Accountability exists when a power holder must explain
or justify his or her behaviour to another actor, and/or face the threat of sanctions.
Accountability has four main pillars:
1. Financial accountability is the obligation of anyone handling resources, public office or

any other position of trust, to report on the intended and actual use of the resources or of
the designated office. This includes ensuring transparency in the processes and procedures
to achieve that obligation.
2. Administrative accountability includes critical systems of control internal to the

government, which complements and ensures the proper functioning of checks and
balance supplied by the constitutional government and an engaged citizenry. These
include civil service standards and incentives, ethics codes, criminal penalties and
administrative review.
3. Political accountability, which fundamentally begins with free and transparent elections,
is an effective starting point for oversight. In an electoral democracy, people have a
regular, open method for sanctioning or rewarding those who hold positions of public
trust. Through periodic elections and control mechanisms, elected and appointed officials
are held accountable for their actions while holding public office. One mechanism that
can achieve more specific oversight is to have the three political branches (executive,
legislative and the judiciary) watch over each other—a system known in some countries as
checks and balances. In addition, separating the institution that raises and spends funds
from that which actually executes the spending decision helps ensure that the underlying
public interest is served.
4. Social accountability refers to situations when citizens have to bypass cumbersome or

compromised formal accountability systems in order to engage in policy-making,
budgeting, expenditure tracking, etc. Social accountability is thus a demand-driven
approach that relies on civic engagement and involves ordinary citizens and groups
exacting greater accountability for public actions and outcomes.
Transparency comprises all means of facilitating citizens’ access to information and their
understanding of decision-making mechanisms. Transparency is built on the free flow of
information: processes, institutions and information should be directly accessible to those
concerned, and enough information should be provided to understand and monitor them.
Public sector transparency begins with the clear application of standards and access to
information.
Integrity is a key element that completes the notion of accountability and transparency. It is
defined as incorruptibility, an unimpaired condition or soundness, and is synonymous with
honesty. In terms of public service, integrity requires that holders of public office should not
place themselves under financial and other obligation to outside individuals or organizations
that may influence them in the performance of their official duties. Integrity is not an end in
itself; rather, it is better viewed as a path leading to the effective delivery of the services
and performance of functions, which the public is entitled to receive from those who govern
them.
Since 1997, UNDP has been increasingly involved in ATI programmes as part of its efforts to
strengthen democratic governance. UNDP’s primary tool for this has been participating in the
Programme for Accountability and Transparency (PACT), an independent trust fund
established with assistance initially from the Governments of Denmark and the Netherlands,
and later on from Germany. PACT has focused on helping countries improve financial
management and accountability. CONTACT—the Country Assessment in Accountability and
Transparency—is a tool developed by PACT to assist governments in undertaking
comprehensive self-assessments of their public financial management systems.
Source: UNDP, Country Assessment in Accountability and Transparency (CONTACT) guidelines, 2002.
Annex 4. Regional and international instruments to fight corruption
Listed below are the major relevant international and regional treaties, agreements,
resolutions and other instruments that refer to corruption. These include both legally binding
obligations and some ‘soft law’ or normative instruments intended to serve as non-binding
standards.
United Nations
United Nations Convention against Corruption

www.unodc.org/unodc/crime_convention_corruption.html.
United Nations Convention against Transnational Organized Crime

www.unodc.org/pdf/crime/a_res_55/res5525e.pdf.
United Nations Declaration against Corruption and Bribery in International Commercial

Transactions
www.un.org/documents/ga/res/51/a51r191.htm.
UN Global Compact
www.unglobalcompact.org.
Africa
Southern African Development Community Protocol Against Corruption

www.sadc.int/english/documents/legal/protocols/corruption.php.
African Union Convention on Preventing and Combating Corruption

www.africa-
union.org/Official_documents/Treaties_%20Conventions_%20Protocols/Convention%20on%20C
ombating%20Corruption.pdf.
Economic Community of West African States Protocol on the Fight against Corruption
www.unodc.org/pdf/crime/corruption/compendium_e.pdf.
Excerpts from the Economic Community of West African States Protocol relating to the
Mechanism for Conflict Prevention, Management, Resolution, Peacekeeping and Security
www.unodc.org/pdf/crime/corruption/compendium_e.pdf.
Americas
Organization of American States (OAS) Inter-American Convention against Corruption

www.oas.org/juridico/english/Treaties/b-58.html.
Asia
ADB OECD Anti-Corruption Action Plan for Asia and the Pacific
www1.oecd.org/daf/ASIAcom/ActionPlan.htm.
Council of Europe
Civil Law Convention on Corruption

http://conventions.coe.int/Treaty/EN/Treaties/Html/174.htm.
Criminal Law Convention on Corruption

http://conventions.coe.int/treaty/en/Treaties/Html/173.htm.
Additional Protocol to the Criminal Law Convention on Corruption

http://conventions.coe.int/Treaty/EN/Treaties/Html/191.htm.
Model Code of Conduct for Public Officials

www.coe.int/t/dg1/greco/documents/Rec(2000)10_EN.pdf.
Recommendation 2003 (4) of the Committee of Ministers to member states on common rules
against corruption in the funding of political parties and electoral campaigns
https://wcd.coe.int/ViewDoc.jsp?id=2183&BackColorInternet=9999CC&BackColorIntranet=FFB
B55&BackColorLogged=FFAC75.
Resolution (99) 5 of the Committee of Ministers: Agreement Establishing the Group of

States against Corruption
http://conventions.coe.int/Treaty/EN/PartialAgr/Html/Greco9905.htm.
J. Resolution (97) 24 of the Committee of Ministers: Twenty Guiding Principles for the
Fight against Corruption
www.coe.int/t/dg1/greco/documents/Resolution(97)24_EN.pdf.
European Union
Convention on the Fight against Corruption involving Officials of the European Communities or
officials of Member States of the European Union
http://eur-
lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc=4
1997A0625(01)&model=guichett.
Convention on the Protection of the European Communities’ Financial Interests
http://eur-
Protocol to the Convention on the protection of the European Communities’ financial

interests
http://eur-
Second Protocol to the Convention on the protection of the European Communities’ financial
interests
http://eur-
Council of the European Union Framework decision on combating corruption in the private
sector
http://eur-lex.europa.eu/LexUriServ/site/en/oj/2003/l_192/l_19220030731en00540056.pdf.
Communication from the Commission to the Council, the European Parliament and the
European Economic and Social Committee On a comprehensive EU policy against corruption
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:52003DC0317:EN:NOT.
OECD
OECD Convention on Combating Bribery of Foreign Public Officials

www.oecd.org/oecd/pages/home/displaygeneral/0,3380,EN-document-88-nodirectorate-no-
no-7198-31,00.html.
Commentaries on the Convention on combating bribery of foreign public officials in

international business transactions; Revised Recommendation of the Council on Combating
Bribery in International Business Transactions; Recommendation of the Council on the Tax
Deductibility of Bribes to Foreign Public Officials
www.oecd.org/document/21/0,3343,en_2649_34859_2017813_1_1_1_1,00.html.
OECD Anti-Corruption Network Action Plan

DAC Revised Principles for Donor Action in Anti-Corruption

www.u4.no/pdf/?file=/document/literature/OECD-principles-on-fighting-corruption.pdf.
Annex 5. Resources and links to other useful resources
UN/UNDP resources
UNDP Anti-Corruption Practice Note 2004

www.undp.org/governance/docs/AC_PN_English.pdf.
UNDP Primer on Corruption and Development, 2008.
UNDP Anti-Corruption Guidance Note, 2008.
Mapping of Corruption and Governance Measurement Tools in Sub-Saharan Africa, 2007.
UNDP Users’ Guide to Measuring Corruption, 2008.
Source Book on Accountability, Transparency and Integrity (Module 10: Resources on ATI
provides a full list of references, web links and sources of information.)
UNDP Case Studies on Anti-Corruption (only available for internal audience from DGG
workspace).
UNDP Inventory of Anti-Corruption Projects (only available for internal audience from DGG
workspace).
CONTACT Country Assessment in Accountability and Transparency guidelines
www.undp.org/governance/contact_2001.htm.
Fighting Corruption to Improve Governance

www.undp.org/governance/docsaccount/fighting_corruption_to_improve_governance.pdf.
UNDP/OECD Integrity Improvement Initiatives in Developing Countries

http://magnet.undp.org/Docs/efa/corruption/Corrupti.htm.
Corruption and Good Governance (UNDP Discussion Paper)

http://magnet.undp.org/Docs/efa/corruption3/corruption3.htm.
UNDP Roundtable (2003), Fighting Corruption in Post Communist States: Where are we now?
Where do we go from here?
www.u4.no/document/showdoc.cfm?id=83.
Fighting Corruption in Post Communist States: Lessons from Practice

www.transparency.org.ru/CENTER/DOC/book04_eng.pdf.
UNDP PARAGON (Training Module on Public Service Ethics and Accountability)

http://unpan1.un.org/intradoc/groups/public/documents/eropa/unpan002651.pdf.
UN Public Administration Network (UNPAN)

www.unpan.org.
UNCICP (Centre for International Crime Prevention Anti-Corruption Tool Kit)

www.odccp.org/corruption_toolkit.html.
United Nations Crime and Justice Information Network

www.uncjin.org.
United Nations Centre for International Crime Prevention

www.undcp.org/odccp.
United Nations Interregional Crime & Justice Research Institute

www.unicri.it.
UN Educational, Scientific and Cultural Organization (UNESCO)

www.unesco.org/iiep/eng.
The U4 Anti-Corruption Resource Centre contains an outstanding overview of relevant

literature, websites, toolkits, glossary, FAQs, helpdesk answers and tailor-made
resources for practitioners on a series of themes. Online: www.u4.no.
Books and journal articles
USAID, 1999, A Handbook for Fighting Corruption.
World Bank, 2000, Anti-Corruption in Transition–A Contribution to the Policy Debate.
Noonan, John T., 2006, A Quick Look at the History of Bribes.
Asian Development Bank, 2000, Combating Corruption in Asian and Pacific Economies.
Klitgaard, Robert, 1988, Controlling Corruption.
Klitgaard, Robert et al., 2000, Corrupt Cities – A Practical Guide to Cure and Prevention.
Alatas, Syed Hussein, 1990, Corruption – Its Causes, Nature, and Function.
Phongpaichit, Pasuk and Piriyarangsan Sungsidh, 2005, Corruption and Democracy in Thailand.
Meijer, Martha and T.K. Oey, 2002, Stealing from the People: The Partnership for Governance
reform in Indonesia.
Transparency International, 2000, TI Source Book: Confronting Corruption: The Elements of A

National Integrity System.
Asian Development Bank, 2004, “Country Governance Assessment Report: Republic of

Indonesia”.
IDS, 1996, “Liberalization and the New Corruption” (IDS Bulletin, 1996).
Sardan, J. P. Olivier de, 1999, “A Moral Economy of Corruption in Africa”.
Websites
World Bank
World Bank Anti-corruption Web site

http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/EXTPUBLICSECTORANDGOVERNANCE/E
XTANTICORRUPTION/0,,menuPK:384461~pagePK:149018~piPK:149093~theSitePK:384455,00.ht
ml.
CFAA (Country Financial Accountability Assessments)

www1.worldbank.org/publicsector/pe/PEMworkshopJune22.ppt.
PER (Public expenditure review)
www1.worldbank.org/publicsector/pe/p1pers.htm.
Public expenditure management handbook

www1.worldbank.org/publicsector/pe/english.htm.
CPAR (Country Procurement Assessment Review)

www.worldbank.org/html/opr/procure/borrower.html.
IGR (Institutional and Governance Reviews)

www1.worldbank.org/publicsector/igrs.htm.
HIPC (Expenditure tracking exercise – with IMF)

www1.worldbank.org/publicsector/pe/tracking.htm.
New Empirical Tools for Anti-Corruption and Institutional Reform

www.worldbank.org/wbi/governance/guide.htm.
Country Analytic Work

www.countryanalyticwork.net.
International Monetary Fund
ROSC (Reports on Observance of Standards and Codes)

www.imf.org/external/np/rosc/rosc.asp.
IMF Manual on Fiscal Transparency

www.imf.org/external/np/fad/trans/manual/index.htm.
USAID
USAID 2005 Anti-corruption Strategy

www.usaid.gov/our_work/democracy_and_governance/publications/pdfs/ac_strategy_final.p
df.
USAID (Conducting a DG Assessment – a Framework for Strategy Development)

www.usaid.gov/democracy/techpubs/pnach305.pdf.
USAID Strategic Assessments

www.usaid.gov/democracy/center/sa.html.
USAID anti-corruption resources

www.usaid.gov/deomcracy/anticorruption.
OECD
The following pages from OECD’s web site contain useful and interesting information on
corruption-related issues:
• www.oecd.org/EN/document/0,,EN-document-0-nodirectorate-no-21-42047-
0,00.html.
• www.anti-corruptionnet.org.
• www.oecd.org/daf/nocorruption/index.htm.
• www.oecd.org/EN.
• www.oecd.org/fatf.
• www1.oecd.org/daf/nocorruptionweb/index.htm.
• www1.oecd.org/puma/ethics/index.htm.
CSOs, academia, media and other information sources
Anti-Corruption Gateway for Europe and Eurasia (http://nobribes.org)
BETA news agency, Clean Hands pages (www.beta.co.yu/korupcija/eng)
Center for International Private Enterprise (www.cipe.org/programs/corruption)
Colgate University, Corruption Bibliography (http://people/colgate.edu/mjohnston)
Committee to Protect Journalists (www.cpj.org)
Ethics Resource Center (www.ethics.org)
Freedom of Information Laws (http://home.online.no/~wkeim/foil.htm)
Freedom of Information portals (www.freedominfo.org and www.accessinitiative.org)
Global Access Project (Center for Public Integrity: www.publicintegrity.org)
Global Witness (Publish What You Pay Initiative, jointly with Transparency International,
Global Compact: www.globalwitness.org/campaigns/oil/publish_what_pay.html)
Human Rights Trust of Southern Africa (www.sahrit.org)
Paris Declaration (www.parisdeclaration.org)
Philippine Center for Investigative Journalism (www.pcij.org)
Respondanet (www.respondanet.com)
The Corruption List (www.corruptionlist.com)
The Corruption On-line Research and Information Centre (CORIS)

(www.transparency.org/coris)
The International Budget project (www.internationalbudget.org/index/htm)
The SEE Legal Development Initiative (www.seldi.net/anti_corruption.htm)
The Urban Governance Initiative (TUGI) (www.tugiapdip.net)
TIRI (www.tiri.org)
Transnational Crime and Corruption Center at American University
(www.american.edu/traccc)
Transparency International Source Book (www.transparency.org/sourcebook.index.html)
Transparency International: The Corruption Fighters Toolkit

(www.transparency.org/toolkits/index.html)
Other inter-governmental organizations
European Bank for Reconstruction and Development (EBRD) (www.ebrd.org)
EUROSAI (www.eurosai .org)
Extractive Industries Transparency Initiative (EITI) (www.eitransparency.org/)
GOPAC (Global Organization of Parliamentarians Against Corruption)

(www.parlcent.ca/gopac/index_e.php)
Group of States against Corruption (www.greco.coe.int)
Independent Journalism Foundation (www.ijf-cij.org)
International Chamber of Commerce (www.iccwbo.org/)
International Criminal Police Organization (ICPO-Interpol) (www.interpol.int)
Internet Centre for Corruption Research (at Goettingen University)

(www.gwdg.de/~uwvw/icr.htm)
Nathanson Centre for the Study of Organized Crime and Corruption

(www.yorku.ca/nathanson/Links/links.htm)
Open Society Institute, EU Accession Monitoring Programme (www.eumap.org)
OSCE (Organization for Security and Cooperation in Europe) (www.osce.org/eea)
Southern African Development Community Protocol against Corruption

(www.safac.org.zw/pages/SADCProtocol.htm)
Task Force on Organized Crime in the Baltic Sea Region

www.balticseataskforce.dk/Corruption/Corruption.htm
U4 Anti-Corruption Resource Centre (wwwU4.no)

Annex 6. Programme partners
Internal partners
UNDP bureaux Areas of cooperation/partnership
Regional bureaux • Mapping and development of anti-corruption diagnostic
tools
• Inputs to bureaux on project document and regional human
development reports
Regional centres • Training on anti-corruption
• Supporting regional communities of practice (CoP)
• Supporting regional initiatives such as anti-corruption
networks
BRSP • Resource mobilization and development of MoUs
BCPR • Corruption in post-conflict situations
UNDP practice areas Areas of cooperation/partnership
Environment and Energy • Corruption in service delivery such as water and energy
Group • Corruption and climate change
Poverty Group • Linkages between poverty and corruption
Capacity Development • Procurement capacity development related to service
Group delivery and public-private partnership
Gender Team • Primer on gender and corruption
DGG service areas Areas of cooperation/partnership
Elections • Corruption and election
Media • Training on investigative journalism
• Training on the role of media in fighting corruption
• Supporting access to information legislation
E-governance • Increased use of technology in service delivery and access
to information
Human rights • Development of primer in human rights and corruption
• Trainings on human rights and anti-corruption
Justice • Judicial Integrity
Knowledge management • Network analysis (in collaboration with DGP-Net)
• Anti-corruption knowledge mapping
• Quick survey
• E-discussions
• E-consultation (use of knowledge and information to fight
corruption)
Local government • Development of guidelines for integration of accountability
and anti-corruption initiatives in local governance
strengthening
Parliamentary • Training in parliamentary oversights
strengthening • Supporting anti-corruption capacity of GOPAC
Public administrative • Support institutions/legal/policy frameworks to promote
reforms and enforce ATI in public service
Oslo Governance Centre • Governance assessment
• Online training
• Governance of non-natural renewable resource
• Validation workshop on knowledge products
External partners
UN system Areas of cooperation
UNODC • Joint trainings
• Scoping missions
• Development of knowledge tools
• Coordination at the international level
UNICEF • Development of knowledge tools on corruption
and service sectors such as health and
education
UNIFEM • Primer on gender and corruption
UNECA • Strengthening anti-corruption commissions in
Africa
International organizations/institutions Areas of cooperation
OECD, DAC/GovNet • Joint assessment
• Coordination of anti-corruption initiatives
through the DAC anti-corruption task team
Transparency International • International anti-corruption commission
• Presents anti-corruption award
• Research and development of knowledge
products
U4 and GTZ • Research and knowledge products
World Bank; IMF; African Development • Regular consultations on policies and
Bank; Asian Development Bank programmes

Mainstreaming Anti-Corruption in Development

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UNDP Practice Note: Mainstreaming Anti-Corruption in Development

ANTI-CORRUPTION PRACTICE NOTE

EXECUTIVE SUMMARY .......................................................................................................................... 3

2. UNDP’S NICHE AND POSSIBLE ENTRY POINTS ........................................................................... 6

Abbreviations and acronyms

The United Nations Development Programme (UNDP) has been involved in

As new norms and standards on anti-corruption evolved, it became necessary to

—Kofi Annan, then-United Nations Secretary-General, in his statement on the adoption by

Since the mid-1990s, corruption has become a legitimate subject of international

UNDP recognizes that corruption is a threat to human development, which is a

2. UNDP’s niche and possible entry points

The notion of democratic governance is people-centred: it epitomizes the most

UNDP views corruption as a governance deficit, a result of malfunctioning state

The characteristics of good governance are also essential pillars of democratic

UNDP considers democratic governance to be a core element of a democratic system,

Box 1. Examples of projects from the ATI portfolio

UNDP Argentina. New management systems in public agencies. In 2007, UNDP

2.2 UNDP and international legal norms and standards

2.2.1 UNCAC as a framework for UNDP anti-corruption activities

UNCAC recognizes the negative impact of corruption on sustainable development.

UNDP Angola. The Decentralization and Local Government (2004-07) project

UNCAC provides a framework for criminalization, asset recovery, international

Article 6 calls on State Parties to assign the implementation and coordination of

Article 8 calls on State Parties to promote the introduction and implementation of

Article 10 requires State Parties to take measures to enhance the transparency of

Article 12 calls on State Parties to implement measures to prevent corruption in the

2.2.3 Other international legal norms, standards and practices on anti-corruption

UNCAC is complemented by other regional conventions and instruments. While some of

The 1999 OECD Convention on Combating Bribery of Foreign Public Officials in

UNDP’s strategic plan 2008–2011 aims at accelerating human development by

3.1 Designing effective strategies

The development of effective anti-corruption strategies is highlighted in Article 5 of

An effective anti-corruption strategy requires a detailed understanding of a country’s

3.1.1 Approaches and techniques

However, some short-term anti-corruption strategies have proved to be unsustainable

Box 4. How to devise successful anti-corruption strategies

Interventions against corruption need to be centred on comprehensive initiatives at

The following observation from the UN Anti-Corruption Toolkit (2004) is instructive:

‘[S]uccessful anti-corruption strategies must also generally be evidence-based,

Box 5. Sample pre-assessment questionnaire

For more on anti-corruption assessment, see CONTACT (Country Assessment in Accountability

3.1.2 Country, regional and global level strategies

3.1.3 Mainstreaming anti-corruption into programmes and projects

UNDP’s strategic plan recognizes anti-corruption as one of the three international

Mainstreaming of anti-corruption is most likely to be successful if it is closely

A number of challenges with regards to mainstreaming have been identified in recent

3.1.4 Supporting anti-corruption institutions

The establishment of specialized anti-corruption agencies, institutions and bodies has,

UNDP supports establishing and strengthening anti-corruption institutions and is aware

• Most governments establish anti-corruption agencies or bodies hurriedly in

• Anti-corruption entities are often a technocratic answer to a political problem

• Terms of reference of specialized anti-corruption agencies should be precisely

• There is a need for sound performance indicators of anti-corruption entities. At

• The issue of resources needs to be addressed upfront. Anti-corruption

Generally, the multiple agency approach is found in countries where bureaucratic

In any case, whether taking a single or a multiple agency approach, anti-corruption

Instead of creating new institutions, a number of countries have opted to strengthen

Box 7. Case for and against specialized anti-corruption commissions and

3.1.5 Research and planning for programming