Economic and Political Studies

ISSN: (Print) (Online) Journal homepage: https://www.tandfonline.com/loi/reps20

Whistleblowing behaviours and anti-corruption

approaches in public administration in Kenya

Gedion Onyango

To cite this article: Gedion Onyango (2020): Whistleblowing behaviours and anti-corruption
approaches in public administration in Kenya, Economic and Political Studies, DOI:
10.1080/20954816.2020.1800263

To link to this article: https://doi.org/10.1080/20954816.2020.1800263

Published online: 07 Aug 2020.

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ECONOMIC AND POLITICAL STUDIES
https://doi.org/10.1080/20954816.2020.1800263

RESEARCH ARTICLE

Whistleblowing behaviours and anti-corruption

approaches in public administration in Kenya
Gedion Onyango
Department of Political Science and Public Administration, University of Nairobi, Nairobi, Kenya

ABSTRACT ARTICLE HISTORY

This article demonstrates that whistleblowing often receives little Received 18 February 2019
attention in public administration due to ambivalence regarding Accepted 17 December 2019
administrative roles held by public administrators, the fluid scalar
KEYWORDS
chain and horizontal linkages, and competitive and intricate pub-
Administrative culture;
lic, organisational and private interests. Drawing on comparative ethical climate; public
analysis to elucidate the broader scope of anti-corruption reforms integrity; corruption; public
and whistleblowing in public administration, the article explores accountability
the influence of the administrative culture on the relationship
between whistleblowing behaviours and implementation of anti-
corruption reforms in public administration in Kenya. It illustrates
how bureaucratic oversight mechanisms such as internal auditing
procedures and ethical guidelines tend to underperform where
administrative environments largely feature autocratic bureau-
cratic authority, parochial management styles and centralised
decision-making processes. Despite the functional specialty of
public institutions, these cultural composites potentially elicit
administrative behaviours that generally make whistleblowing
anti-organisational, anti-social and an outright illegality in public
administration. The absence of whistleblowing legislation or weak
whistleblowing laws exacerbate these conditions. Whistleblowing
becomes even more complex at the local-state level as social net-
works and working groups tend to be strengthened by the col-
lectivist associational culture in public administration.
Consequently, non-performance of anti-corruption reforms were
found to stem from the collective chastisement of whistleblowing
practices in public organisations in Kenya. Furthermore, institu-
tional deficits typical in local-state administration seemingly made
it riskier for potential whistleblowers to come forth, mainly
attendant to loose and inconsistent legislation on corruption.
Therefore, to enhance whistleblowing, there is a need to insulate
potential whistleblowers from legal retaliation, including cultural
retaliations that come in forms of emotional and profes-
sional ‘attacks’.

CONTACT Gedion Onyango [email protected] Department of Political Science and Public Administration,
University of Nairobi, Nairobi, Kenya
ß 2020 Economic and Political Studies
2 G. ONYANGO

Introduction
This article stems from general efforts to discern public integrity and ethics in public
administration, particularly in the context of the global south. Using a case study of
anti-corruption structures and whistleblowing behaviours in public administration in
Kenya, the paper endeavours to draw implications that will arouse broader interest for
scholars in public administration and public accountability. In so doing, whistleblowing
is understood as ‘disclosures by organisation members of matters of “public interest”
[or institutional interest] – that is, suspected or alleged wrongdoing that affects more
than the personal or private interests of the person making the disclosure’ (Brown
2008, xxi). Conversely, anti-corruption approaches or strategies refer to both institu-
tional and extra-institutional processes and initiatives targeted at addressing and con-
trolling corrupt practices and behaviours, and moderating systems within bureaucratic
and societal contexts. As much as these anti-corruption efforts focus on the conduct of
public officials, they have also been designed to stimulate anti-corruption behaviours
within the environments of public bureaucracies. This is to enhance citizen oversight
and to transform generalised societal norms and cultures, which may otherwise ration-
alise or normalise corruption in public administration.
It is commonplace that anti-corruption reforms come with the establishment of
institutions and the formulation of public norms and values. Institutions such as anti-
corruption bureaus, an Ombudsman, and oversight committees that are mandated to
enforce the adoption of and compliance with ethical guidelines, conduct training, col-
laborate cross-institutionally and perform community sensitisation provide some illus-
trations. Some of these anti-corruption approaches may explicitly direct and encourage
whistleblowing, while others may present ambiguity, leaving individual public entities
to draft their own policies on whistleblowing (Onyango 2017). Whistleblowing behav-
iours can either be externally channelled, i.e. to oversight agencies, or internally chan-
nelled, i.e. to utilise internal bureaucratic oversight mechanisms and chain-of-
command to disclose witnessed misconduct (Near and Miceli 1996). In linking whistle-
blowing behaviours and anti-corruption strategies, this article sets off by first identify-
ing gaps in whistleblowing in public administration. In so doing, it addresses, albeit
hypothetically, compliance and public integrity problems in the global south, where
anti-corruption reforms have become (or may be) primary public accountability
reforms in public bureaucracies. Despite such efforts, however, existing studies on anti-
corruption reforms reveal sporadic or temporal successes and permeating failures in
most countries in the region (Persson, Rothstein, and Teorell 2013).
Such policy or reform outcomes have often been tied to the problem of behavioural
discrepancies in public administration. Analyses of the problem of behavioural discrep-
ancies between norms and values in public administration have commonly revolved
around cultural variables (Jamil, Askvik, and Hossain 2013). African public bureauc-
racies are confronted with insurmountable challenges, which arguably emanate from
the effects of their cultural contexts on the functioning of public institutions (political
or administrative). Rational biased analyses commonly argue that these institutions are
largely reliant on communal rather than rational institutional logics, leading to the nor-
malising of waywardness in public institutions (Odhiambo-Mbai 2003; Olivier de
Sardan 2013; Hyden 2013). In other words, these cultural structures curtail effective
 ECONOMIC AND POLITICAL STUDIES 3

bureaucratic processes and erode oversight and controls at all levels of government
(Olivier de Sardan 2013). Therefore, understanding the attendant intricate socio-polit-
ical and economic synergies is relevant in understanding public ethics and in the ana-
lysis of corruption and problems of trust in the global south and Africa in particular.
The focus on whistleblowing behaviours as a composite of anti-corruption reforms
in local governments emanates from the fact that public sector reforms often sought in
response to the problems of accountability and ethics in local governments commonly
complicate rather than reduce problems of public accountability and responsiveness in
public administration (Carroll 1989; Grigorescu 2008). Local government reforms fre-
quently come with disruptive consequences and unsettledness in the form of loose
accountability and overlaps at the local-state level and between local-state political and
administrative units (Onyango 2020a). Additionally, there are correspondingly loose
relations between central government institutions, mainly the Ombudsman and anti-
corruption agencies, as well as central regulatory ministries with local government
structures (Treisman 2002). Therefore, it is without a doubt that in these contexts, and
given the steadiness by which some of these public sector reforms (e.g. inter-govern-
mental models) have been adopted in sub-Saharan Africa in the last decades, greater
threats to anti-corruption reforms in public administration have unexpectedly arisen
(Therkildsen 2001). Inter-governmental models have created unintended institutional
blind spots that have mostly consolidated and empowered intricate political citizenry
and identity group factions at the local-state level across Africa, and Kenya, in particu-
lar (D’Arcy and Cornell 2016). Also, it has featured an increased politicisation of
accountability reforms and deficits in organisational discipline in general, thereby nega-
tively influencing the enforcement of anti-corruption legislation (Onyango 2019b).
Furthermore, instrumental and cultural complexities and institutional hybridity that
come with these reforms broaden the accountability gaps or weaken political and
administrative controls and oversight mechanisms in public administration
(Grigorescu 2008). As such, local government structures typically take time to enhance
administrative efficacies needed for functional anti-corruption mechanisms in public
administration.
This article argues that in such anarchical circumstances of reform outputs on public
accountability, whistleblowing behaviours can become critical in controlling corrupt
behaviours in public administration. However, this is largely contingent on modalities
of prevailing administrative culture. That is to say, since whistleblowing is largely
behavioural, it relies less on conformity with formal processes, bureaucratic rules and/
or oversight controls in public administration and instead draws more on personal
traits, levels of organisational citizenry, individual motivations and the integrity of con-
cerned public administrators (Miceli and Near 1994; Van Wart 1996; Cho and Song
2015). Conversely, bureaucratic rules and controls that are central to the objectives of
anti-corruption reforms often become easily entangled or overshadowed by institu-
tional complexities and politics in public administration, especially at the local-state
level, hence slowing down the promotion of whistleblowing behaviours. At the same
time, whistleblowing behaviours do not need to be latched onto efficient administrative
structures to take place. All it takes to is to simply blow the whistle as a demonstration
instead of goodwill and a concern for integrity by administrators who witnessed a
4 G. ONYANGO

malpractice (Gelfand, Lim, and Raver 2004; Hwang et al. 2008). Pillay et al. (2018, 187)
contend that the ‘imperative, for “principled disclosure of wrongdoing,” which is some-
times considered as an act of loyalty [ … ] to the organisation and in the public interest,
contributes to an effective whistle-blowing culture’. However, several findings show
that whistleblowing not only takes a lot of courage from the potential whistleblowers to
come forth but it also involves different layers of interpretations and motivations that
consequently complicates the whole practice, including the formal and informal proc-
esses of addressing the wrongdeed.
The literature on whistleblowing in public administration in developing regions,
particularly in Africa, is limited despite increased demands for research and legislation
against the prevailing public disobedience and despite the implementation of rather
apposite public sector reforms (Schuppan 2009; Onyango 2018b). Public administra-
tion has apparently done little to understand ethical decision making on whistleblow-
ing behaviours as anti-corruption mechanisms have become central features in modern
public administration over the years. Similarly, general issues that seem to characterise
whistleblowing practices in public administration commonly stem from ambivalence in
the conception of administrative roles in matters of bureaucratic oversight in public
organisations, the fluid scalar chain and loose horizontal linkages. In addition, public
administration is animated by conflicting due processes, dissonant organisational just-
ice systems, competitive and intricate public-private and organisational interests. Either
way, these characteristics of public administration have been found to complicate
enforcement of ethical guidelines and proactive actions on whistleblowing (Zipparo
1998; Brown 2008; Pillay et al. 2018).
Taking cues from this trend while seeking to address the growing interest in discern-
ing the interfaces between whistleblowing and anti-corruption reforms and processes
in public administration across the globe, this article adopts a cultural approach –
administrative culture – to explore the correlation between whistleblowing behaviours
and anti-corruption reforms in the context of Kenyan public service. It is mainly pre-
sumed that the primary impediment to the effective functioning of anti-corruption
efforts in the public administration of unconsolidated democracies such as Kenya is the
lack of effective whistleblowing mechanisms. Extant studies on whistleblowing in sub-
Saharan Africa are bound within structural explanations that focus on legislation on
whistleblowing, while ignoring microscopic facets that reside in the behavioural or
informal dimensions of public administration. In the present discussion, I demonstrate
that insofar as common anti-corruption narratives in developing countries fail to
strengthen whistleblowing behaviours as key institutionalisation repertoires of anti-cor-
ruption structures, related accountability reforms are more likely to fail. The studies on
whistleblowing concur that the absence of a whistleblowing culture curtails the devel-
opment of an ethical climate that enhances the self-regulation and individual-responsi-
bility of public administrators (Zipparo 1998; Bowman and Knox 2008).
The approaches by most of these studies underscore the need for effective bureau-
cratisation of whistleblowing such as by enacting adequate legislation and promoting
formalised behavioural variables, i.e. codes of conduct for ethics and integrity in public
organisations (Dorasamy and Pillay 2011). Proponents of this line of thought argue
that unambiguous administrative legislation and related whistleblowing agencies can
 ECONOMIC AND POLITICAL STUDIES 5

reinforce bureaucratic ethos and the ethical climate needed to institutionalise whistle-
blowing behaviours in public administration (Zipparo 1998; Kaptein 2011; Dorasamy
and Pillay 2011). The absence of this legislation and these agencies exposes whistle-
blowers to organisational and cultural backlash, namely, retaliatory responses and vic-
timisation, commonly associated with whistleblowing (Zipparo 1998). The
administrative culture on whistleblowing in the public bureaucracies of Africa in gen-
eral and Kenya in particular is, in essence, understudied. However, the utility of admin-
istrative culture in this article and corresponding ethnographical data on
whistleblowing and anti-corruption practices generally elicit analytical rather than
empirical generalisation of administrative contexts in developing countries. The
Kenyan case therefore serves as a method rather than as a theory.

Cultural framing of whistleblowing: the utility of administrative culture

Sharma (2002) conceptualises administrative culture as multipronged and multifaceted
concept with no universal definition (also cf. Jamil, Askvik, and Hossain 2013).
According to Sharma (2002, 65), administrative culture involves ‘how administrator
acts or behaves vis-a-vis other administrative objects or actors or individuals of the
society in administrative capacity’. Thus, administrative culture explains synergic rela-
tionships emanating from environmental or ecological and behavioural composites of
administration. First, administrative culture involves components of social entity
because administration largely entails social relationships and networks. Second, it can
be viewed as a function of social norms of groups because administration entails differ-
ent interests, both societal and political. Third, it is a function of social institutions and
a subculture of socio-cultural systems (Sharma 2002). This comes with the promotion
of social structures such as power relations, caste systems and beliefs. As such, adminis-
trative culture is an elaborate form of organisational culture, consisting of a set of for-
mal and informal governance norms, traditions, and practices taken-for-granted that
have spanned over time in the organisational lifecycle, thereby, replicable across gov-
ernmental and sometimes non-governmental organisations in a particular society
(Peters 1990; Jamil 2002; Onyango 2019b).
In describing bureaucratic discrepancies, Olivier de Sardan (2013) uses the term
‘practical norms’ to loosely refer to such norms, traditions, beliefs and practices in pub-
lic bureaucracies. Administrative culture is an embodiment of a complex mix of polit-
ical culture, organisational culture, historical and institutional factors, standard
administrative norms and socio-structural composites in public administration. As
such, it is multidimensional and entails a layer of normative references or institutional
logics that shape and influence dominant perceptions, gatekeepers, attitudes, practices,
processes, underlying assumptions, and power relations in public administration
(Jamil, Askvik, and Hossain 2013). As it pertains to public sector reforms, administra-
tive culture is most likely to elicit continuity despite a pursuit of change in public
bureaucracies (Jamil 2002). For instance, the perpetuity of corruption, despite anti-cor-
ruption reforms in developing countries, strongly corresponds to problems of adminis-
trative culture in public organisations. Haque and Mohammad (2013) note that
dimensions of administrative culture in Bangladeshi public administration in the form
6 G. ONYANGO

of large power distance or adherence to hierarchy (i.e. autocratic administrative cul-

ture), centralisation of administrative processes, abuse of discretionary power, nurtur-
ing tadbir and sycophancy, correspond to the perpetuity of corruption despite targeted
reforms. Similar observations are made by Blundo and Olivier de Sardan (2006) in the
case of public bureaucracies in West Africa, which they found to host dimensions of
administrative culture analogous to an extensive hierarchy, privilegism and kinship
structures that, in the end, threaten the efficacy of anti-corruption reforms. According
to Onyango (2018a), administrative culture, especially ethnic identity and bureaucratic
autocracy in public administration, is bound to hinder individual innovation and inter-
agency communication, which can otherwise enhance implementation of accountability
reforms in public administration.
Concisely, the study of administrative culture presents a behavioural approach that
explains how things are done instead of how they should be done in public administra-
tion (Jamil, Askvik, and Hossain 2013). It defines the scope of action and ethical deci-
sion-making processes emanating from either the logic of consequences, i.e. compliance
with legal-rational principles, or the logic of appropriatenesss, i.e. based on past experi-
ences subject to cognitive and normative components. March and Olsen (2009, 478),
define the logic of appropriateness as the ‘relationship between action and rules, along
with the elements of slippage in executing rules, the dynamics of rules, and the stand-
ards of appropriateness’. This illustrates the transcendence of informal processes over
bureaucratised rules and controls that may assist in identifying cultural variables for
whistleblowing in public administration. Merton (1940) argues that these cultural func-
tions are objects of emotionalised disapproval or approval that may enlighten relational
dimensions of ethical decision making in public bureaucracies. However, they also
interact with bureaucratic processes for effective whistleblowing practices i.e. adminis-
trative culture can either promote or hinder whistleblowing efforts, including some of
its characteristics that may otherwise seem rationally noxious. Administrative culture,
therefore determines the general leeway of action on matters of corruption and anti-
corruption behaviours both within and between units, departments and ministries in
public administration. Still, apposite bureaucratic mechanisms and professional milieu
are needed to foster the institutionalisation of whistleblowing behaviours (Lavena 2016;
Zipparo 1998).

Whistleblowing as a function of administrative culture

Linkages of whistleblowing between culture and ethical behaviours in organisations
have often revolved around unpacking the complexity of the actions or inactions on
organisational wrongdoing (Kaptein 2011; Dyne, Ang, and Botero 2003; Brinsfield
2013). Studies have either looked into how accountability initiatives can foster internal
whistleblowing behaviours (e.g. Cho and Song 2015) or why organisational members
generally respond to malpractices in the way they do (e.g. Brief and Motowidlo 1986;
Lavena 2016). The pursuit of public integrity has also been focussed on organisational
processes and strategies for creating ethical culture. Yet, the deepening of ethical cul-
ture in public administration has mostly come with designing or redesigning necessary
bureaucratic initiatives to foster compliance and whistleblowing behaviours (Dorasamy
 ECONOMIC AND POLITICAL STUDIES 7

and Pillay 2011). Consequently, whistleblowing mechanisms should integrate key

anti-corruption strategies such as developing a ‘personal code of ethics, using hotlines,
having an ethics committee, engaging in periodic ethics training and doing an annual
ethics audit’ (Perks and Smith 2008, 15). These strategies should align public adminis-
trators with legal, professional and organisational ethics hence improving their per-
sonal ethical decisions, leading to improved internal whistleblowing processes (Van
Wart 1996).
Anti-corruption initiatives draw on the fact that positive attitudes and behaviours
on whistleblowing ‘can cause substantial changes and facilitate reforms in governmen-
tal organisations; [save] people’s lives as well as billions of taxpayer dollars’ (Cho and
Song 2015, 451). Again, whistleblowing should enhance auditing mechanisms in public
organisations (Alleyne, Hudaib, and Pike 2013). As such, both cultural and institutional
components of administration stimulate a collative whistleblowing culture that should
correspond to an improved ethical climate in public administration. Dimensions of
administrative culture, especially power distance and hierarchical orientation, define
the nature of the organisational leadership and the relationship between managers and
their subordinates (Haque and Mohammad 2013). For example, a high possibility of
retaliation by the management against whistleblowers discourages whistleblowing
behaviours in public organisations (Zipparo 1998; Onyango 2017). Tsahuridu and
Vandekerckhove (2008, 107) contend that legislation and policies on whistleblowing
may ‘either aim to enable individual responsibility and moral autonomy at work, or
they aim to protect organisations by allowing them to control employees and make
them liable for ethics at work’. This illustrates that whistleblowing may be interpreted
as a lack of organisational discipline or may become an anti-organisational and anti-
social behaviour, especially when corresponding legislation and procedures are ambigu-
ous in public bureaucracies.
The correlation between administrative culture and organisational leadership
and structures on accountability is complex. This is partly because organisational
culture itself is as intricate, inconsistent, multilayered and multidimensional as its
relationship with the effectiveness of accountability designs in public administra-
tion. That is, whistleblowing is contingent on factors that are not analogous to
dominant ways of doing things in an organisation – individual motivations, values
and different interpersonal relationships with groups outside the organisation
(Gelfand, Lim, and Raver 2004; Lavena 2016). This implies that there is a knotty
relationship between organisational design, culture and environment with respect
to ethical decision making. Kaptein (2011) contends that the management’s pos-
ition on ethical or unethical behaviours greatly influences levels of value-congru-
ency in an organisation.
Executive managers can either ease institutional overlaps on whistleblowing or
exploit these gaps for personal and organisational interests (Zipparo 1998; Onyango
2019b). Taylor and Curtis (2013) find that 106 senior-level auditors in the United
States were influenced by power distance and organisational policy on how they
responded to wrongdoing in their departments. Auditors can very easily blow the whis-
tle on their peers but hardly on their superiors, especially ‘when prior organisational
response is strong than when it is weak’ (Taylor and Curtis 2013, 21). Thus,
8 G. ONYANGO

whistleblowers seem to consider whistleblowing outcomes before deciding to blow the

whistle (Near and Miceli 1996). Actually, whistleblowing aftermaths may range from
perceived (or actual) retaliatory actions by management to unanticipated effects on
organisational interests and the perceptions of superiors and co-workers (Perks and
Smith 2008; Alleyne, Hudaib, and Pike 2013). Near and Miceli (1996) simplify these
determinants of whistleblowing into two categories: (i) Situational characteristics, i.e.
quality of evidence, supervisor’s support and ethical climate as judged by whistleblow-
ing mechanisms or legislation. (ii) Personality characteristics, i.e. job situation and
moral behaviour. In retrospect, whistleblowing is explicitly influenced by a mix of cul-
tural, structural and environmental facets of public administration leading to intricate
administrative motivations to blow the whistle. I argue that such intricacies can be bet-
ter discerned within the multidimensional and richly context-specific framework pro-
vided by administrative culture.

Anti-corruption strategies and whistleblowing in Kenyan public administration

Despite several sets of anti-corruption strategies and legislation, and despite being one
of the few administrative contexts in Africa where anti-corruption strategies seem to be
appositely integrated and contextualised in public bureaucracies (EACC 2013–2018),
public administration in Kenya is riddled by some of the worst forms of corruption in
the world (Persson, Rothstein, and Teorell 2013). And to deal with problems of public
accountability, mainly, corruption, Kenya is currently implementing structural devolu-
tion reforms for effective participatory, responsive and responsible governing processes.
Therefore, as a case study, Kenya presents an accountability paradox and a unique
context for investigating the interface between whistleblowing behaviours and anti-
corruption mechanisms in developing economies. Moreover, even though whistleblow-
ing in public administration in Kenya is understudied, there are surveys and periodical
statutory reports that illustrate instances of whistleblowing in public administration.
These reports, however, stress that whistleblowing by public administrators is occa-
sional, uncertain and in most cases anonymised. Oftentimes, this is linked to difficul-
ties involved in enacting effective disciplinary processes in Kenya (Onyango 2019b).
The key strategies for operationalising anti-corruption efforts in public administra-
tion in Kenya are embedded in the Anti-Corruption and Economic Crimes Act of 2003
(ACECA), the Public Officer Ethics Act of 2003 (POEA), The Bribery Act of 2015, the
Public Service Integrity Programme (PSIP) and other legislation. Although Kenya is yet
to develop specific legislation on whistleblowing, the existing legal framework is suffi-
cient for handling whistleblowing incidents. These are cross-cutting mandates within
different institutions, including the Commission for Administrative Justice (the
Ombudsman), the Ethics and Anti-corruption Commission (EACC) and other over-
sight institutions. Still, these present critical administrative burdens that frustrate
potential whistleblowers who need to be knowledgeable about anti-corruption strat-
egies, specific legislation, procedures and institutions with respect to particular illicit
practices. However, this has not been the case. Most public administrators seem to
have difficulties in understanding or are not even aware of the POEA and the ACECA,
 ECONOMIC AND POLITICAL STUDIES 9

including distinguishing the functions of the EACC and those of the Ombudsman
(EACC 2015; Onyango 2019a).
The mainstream of anti-corruption strategies in Kenyan public institutions integra-
tes the PSIP framework and other public accountability legislation. For instance,
through the PSIP’s Performance Contracting, government departments identify five
key indicators for implementing anti-corruption strategies in public entities as follows.

Strategy 1: developing institutional anti-corruption policies

Under this indicator all public institutions are expected to draft institutional-specific
anti-corruption policies. Such a policy should entail a statement that recognises anti-
corruption as a risk and acknowledges its occurrence in the institution. This is sup-
posed to create awareness of existing gaps that may cause corrupt behaviours.
Additionally, there should be a statement confirming the responsibility of the manage-
ment, the staff and stakeholders when it comes to addressing corrupt behaviours. This
involves a summary of anti-corruption practices in the institution as a guide to its staff,
such as corrupt practices in the concerned institution, composition of the corruption
prevention committee members, its objectives and operations, the procedures of
reporting corrupt practices internally and externally, confidentiality of information
provided, and the identity and protection of whistleblowers. However, among other
key challenges with the formulation of institutionally specific anti-corruption policies
is the problem of principal-agent on oversight structures (e.g. Persson, Rothstein, and
Teorell 2013; Onyango 2020b).

Strategy 2: forming corruption prevention/integrity committees

All public institutions are expected to operationalise corruption prevention or integrity
committees, as stipulated in the PSIP framework. These committees are supposed to
plan and coordinate all anti-corruption strategies by setting up corruption prevention
priorities in their institutions. They are required to integrate anti-corruption strategies
such as enhancing components of the POEA or ethical guidelines, receiving, reviewing
and documenting all incidences of corruption, monitoring corruption trends and eval-
uating the impacts of existing anti-corruption initiatives. They are also required to
write recommendations on the appropriate courses of action, especially by making
referrals to concerned agencies, in addition to championing anti-corruption initiatives
within the institution. To remain active, these committees are required to meet every
three months with clear records of minutes for effective supervision by the EACC.

Strategy 3: developing a corruption prevention plan

The corruption prevention plan (CPP) ‘must incorporate clearly set SMART (i.e.
Specific, Measurable, Assignable, Realistic and Time-bound) objectives and targets to be
met. This includes, activities and sub activities to be implemented, desired outputs/out-
comes to be achieved, clear and subjectively verifiable indicators for monitoring pro-
gress and evaluating results, clear responsibilities for implementation and resource
requirements’ (EACC 2007, 4). The CPP should carry out corruption risk assessments,
identify blind spots in systems, procedures and practices and recommend ways of
countering such deficiencies. Most importantly, the CPP is supposed to conduct its
10 G. ONYANGO

institution’s Corruption Risk Assessments to understand possibilities of exposure,

opportunities and discretionary powers that may curtail existing controls and favour
corruption. As such, the CPP should also identify persons and allocate timelines for
implementing anti-corruption strategies.

Strategy 4: developing specific codes of conduct

In line with the POEA, all public institutions are required to draft specific codes of
conduct. This should contextualise abstractions of the POEA to regulate unique dimen-
sions of some professional fields in public administration. The formulated ethical code
is binding to the Board of Directors of concerned institutions, the management and
staff. However, the POEA still remains the main point of reference.

Strategy 5: appointing and training integrity assurance officers

Despite their contexts of operation, public institutions are required to train Integrity
Assurance Officers (IAOs). IAOs are expected to offer technical assistance to the man-
agement and assist in the implementation of the PSIP. They are supposed to liaise with
the EACC and relevant ministries, e.g. the Ministry of State for Public Service, to con-
duct sensitisation programmes for the staff. In other words, IAOs should be at the fore-
front in promoting an ethical climate for whistleblowing behaviours in public
organisations (EACC 2007).
By design and default, the PSIP can hardly escape the principal-agent problems on
oversight structures in public bureaucracies, the inevitability of conflicting inter-organ-
isational relations between the centralised oversight institutions and local government
oversight mechanisms, and the problems of bureaucratic identity and political citizenry
in governmental organisations at all levels. Its emphasis on a stewardship approach to
the integration of the PSIP presumes particular levels of ethical awareness and concerns
among public and political administrators who would, therefore, commit to the realisa-
tion of anti-corruption norms. However, evidence of administrative behaviours and
accountability in Kenya indicate a problematic culture animated by intricate political
characteristics that limit bureaucratically biased approaches like the stewardship
approach (Odhiambo-Mbai 2003).
In fact, despite the above-mentioned integrative strategies for the PSIP in Kenya,
studies, especially by the EACC and the Commission for Administrative Justice (CAJ),
indicate prevailing whistleblowing deficits in all sectors of government. Such factors as
ignorance of procedures (50.5%), fear of victimisation (21.7%), inaction after whistle-
blowing both internally and externally (20.9%) and inadequate proof of allegations
have been identified as the key impediments to whistleblowing in Kenya (EACC 2015,
14–15). EACC (2015) also finds that only 5.3% of people who witnessed corruption
blew the whistle as opposed to 94.7% who resorted to silence. However, in 2013, whis-
tleblowing enabled the EACC to handle 26% of bribery cases and 25% of abuse of
office; besides, embezzlement of public funds accounted for 18%, irregular public pro-
curement 8% and fraudulent acquisition and disposal of public property accounted to
10% (EACC 2013).
Again, evidence shows that whistleblowing behaviours in Kenya are common on
malpractices by low- and mid-level administrators as opposed to those on senior public
 ECONOMIC AND POLITICAL STUDIES 11

managers (Onyango 2017). The hierarchical positioning and role specialisation of pub-
lic administrators, therefore, influence patterns of whistleblowing in Kenya and poten-
tially determine the viability or performance of external mechanisms in the public
sector. Yet this ubiquitous nature of whistleblowing behaviours is also quite evident as
incidences in Kenya generally underscore that contingencies such as fear of victimisa-
tion, inaction on malpractice, lack of confidence in accountability mechanisms and
ignorance of related procedures and processes are key determinants of whistleblowing
behaviours in most bureaucratic contexts (Miceli and Near 2002; Kaptein 2011). As
such, it is not unusual that difficulties with creating effective whistleblowing mecha-
nisms in Kenya are as much related to bureaucratisation and rationalisation deficits, as
they are with complex informal processes and culture in public administration. In fact,
this may explain why whistleblowing insufficiently discloses some of the most bureau-
cratically protracted malpractices related to public procurement in Kenya. For example,
in Kenya reports by the Auditor General point out that misappropriation of public
funds at both central and local governments mostly stem from the weak and covert
public procurement procedures. The same alludes to a problematic administrative cul-
ture that seemingly facilitates rather than condemns corrupt behaviours in Kenya. This
administrative culture is reportedly biased towards bureaucratic autocracy and ethnic
solidarity, parochial bureaucratic identities, personalised administrative processes and
politicised administrative relations (Odhiambo-Mbai 2003; Onyango 2019b).

Methodology
This study draws from both primary and secondary qualitative data collected between
January 2015 and May 2016 in three county governments in Kenya. Primary data
involve in-depth interviews, informal conversations and administration of question-
naires to purposefully and randomly selected departmental and middle-level county
administrators in Migori, Kisumu and Nairobi counties of Kenya. Migori and Kisumu
counties are selected because of their proximity to the researcher and resource limita-
tion. They also present viable contexts for testing variations in administrative culture
between rather consolidated complex administrative structures of Kisumu County
(which was until 2013 the provincial headquarters of the Migori district) and adminis-
trative structures of Migori County. Nairobi County is the headquarters of the CAJ,
EACC and Transparency International-Kenya. Due to the very centralised administra-
tive structure, some information is only found at the headquarters of the CAJ and
EACC located in Nairobi, including the permission to interview the staff of these insti-
tutions in their regional offices. Interviews are conducted with specific departmental
heads and unit leaders of oversight agencies. The unit and departmental heads in the
concerned oversight agencies are formally referred by the management of the agencies
upon granting the researcher the permission to interview the staff.
A total of 77 respondents, aged between 35 to late 50s, participate in the study. In-
depth and face-to-face interviews involve 28 mid-level and senior public officials,
including the staff of oversight institutions. Both structured and unstructured interview
guidelines are used. Most of these interviews last for at least an hour. The remaining
respondents answer unstructured questionnaires, which are administered with the help
12 G. ONYANGO

of two research assistants in Kisumu and Migori counties. These respondents sign
research consent forms before interviews and filling in the questionnaires. These forms
clearly stipulate the research topic and objectives and confidential information on
security of their identities.
Oversight agencies visited include the EACC, CAJ and Transparency International-
Kenya (TI-Kenya). Referral sampling is instrumental in accessing and creating rapport
with county administrators and oversight staff. Unwilling participants, who happen to
have been purposefully selected because of their role-specialisation, recommend other
colleagues whom they consider more knowledgeable on the issues of anti-corruption
strategies and related mechanisms in the public sector. In addition, documentary ana-
lysis is used to complement primary data. This is conducted in a continuous process
and involves analysis of survey data, media and audit reports, as well as periodical
reports by oversight institutions. Data analysis involved coding, data condensation,
schematisation and categorisation within adopted conceptual dimensions and struc-
tures of decision-making on anti-corruption behaviours and accountability mecha-
nisms in public administration.

Findings and analysis

The role of hierarchy and internal control mechanisms in
whistleblowing intentions
Questions on the utility of external anti-corruption mechanisms or external agencies in
whistleblowing may arise when internal processes are ineffective and untrustworthy.
However, whistleblowing is indicative of the failure of internal mechanisms and the
chain of command. This justifies the relevance of external whistleblowing. Also, struc-
tures for public accountability are likely to be loose and uncertain to encourage internal
whistleblowing. That is, the bureaucratic power is unequally distributed within public
institutions, resulting in unpredictability with respect to organisational action on whis-
tleblowing and against corruption. By design, anti-corruption strategies in Kenya, and
by extension whistleblowing mechanisms, underscore the role of internal mechanisms,
where employees, especially executives, are required to enforce ethical standards.
Therefore, unless otherwise indicated, whistleblowing remains an internal affair.
It has been established that the variance in the ethical climate across public institu-
tions in Kenya is primarily based on two factors. The first is found to be the depart-
mentally specific organisational culture, where internal composites, mainly
departmental social cohesion and leadership, influence direction and set priorities on
compliance with ethical guidelines as entailed in anti-corruption strategies. The quality
of the leadership on ethical matters is found to positively correlate to the effectiveness
of internal and external oversight structures. That is to say, the departmental leaders
patterned or directed collaborative activities and effectiveness, either fostering or con-
straining institutionalisation and internalisation of the codes of conduct, the creation
of anti-corruption committees and the appointment of Integrity Assurance Officers.
The second is the function specialisation of departments and directorates. Departments
like internal auditing and other regulatory agencies are obligated to pose an ethical
standing because it is their core business and lifeline, lest they become irrelevant and
 ECONOMIC AND POLITICAL STUDIES 13

illegitimate. These two variables – departmental leadership and organisational special-

isation – explain the varied prevalence of corruption across different departments and,
in turn, determine varied patterns and responses on whistleblowing in the public sec-
tor. Likewise, these variables explain why anti-corruption reforms, with respect to their
institutionalisation processes, perform relatively better in one ministry or directorate
than in another. This is the case despite the prevalence of a generic administrative cul-
ture (mainly collectivism or kinship) and an emphasis on bureaucratic processes for
whistleblowing that result in poor performance and high likelihood of inaction on
whistleblowing by the majority of departmental heads, therefore having little chance of
receiving moral support from colleagues.
Conversely, this study confirms that organisational leadership and culture may mod-
erate negative repercussions of ethnic enclaves, bureaucratic centralisation and privile-
gism on anti-corruption and whistleblowing behaviours. For example, besides the fact
that whistleblowing has a greater relationship with the personality of the bureaucrat
than with conformity to the rules, environments allowing such personalities to remain
active correspond to the way administrative executives utilise internal bureaucratic
oversight mechanisms. How these managers vertically relay and interact with their
supervisors on matters of public accountability in their departments either encourage
or discourage whistleblowing behaviours. So, whistleblowing is directly related to per-
sonal and organisational characteristics, with respect to the interests and intentions of
departmental leaders and accountability champions such as IAOs and
internal auditors.
However, the quality of the organisational leadership and the role-specialisation of
public organisations have a negative relationship with external whistleblowing tenden-
cies. That is, the degree of interpersonal trust, organisational bureaucratic-identity and
effective communication between the management and subordinates tend to resonate
with prevailing leadership styles; this elicits either departmental cohesiveness or
employee conflicts – jealousy, competition, malice, and so forth – within an organisa-
tion. Organisational cohesiveness set preferences for the interpersonal approach and
internal resolution of ‘conflicts’ over other channels, including on matters of adminis-
trative wrongdoing such as corruption; also, cognisant of their public image, internal
auditors prefer internal reporting mechanisms over external oversight agencies.
Therefore, positive dimensions of organisational culture such as employee cohesive-
ness, interpersonal trust and effective communication between management and
employees promote internal organisational environments where potential whistle-
blowers could utilise internal mechanisms and the chain of command to blow the whis-
tle. In fact, the interplay of the above factors and possibilities of whistleblowing were
alluded to by an administrator, who stated that:
In our department there is clear established chain of command, therefore misconduct
are basically reported by the officer in-charge of a section. It may not be easy for a
junior staff to report his boss unless it is something very serious. The department has
code of regulations that is strictly followed while handling misconduct. Therefore, action
to be taken to an officer involved on the same are clearly explained and must be
followed strictly (Cited from author’s interview data, 20 April 2015).
14 G. ONYANGO

Therefore, as put by Dyne, Ang, and Botero (2003, 1359), ‘[ … ] the key feature that
differentiates silence and voice is not the presence or absence of speaking up, but the
actor’s motivation to withhold versus express ideas, information, and opinions about
work related improvements.’ In departments with ethical leadership, anti-corruption
strategies were relatively institutionalised and communicated to employees. However,
the communication and training on anti-corruption strategies is confined to high-rank-
ing public officials. Thus, the degree to which the staff is knowledgeable of existing
anti-corruption strategies and related whistleblowing procedures is contingent on their
rank and the leadership style in a particular department.
From the above statements, and many others, it is clear that administrators consider
how whistleblowing could impact them as individuals and their co-workers rather than
being concerned about the pursuit of compliance and ethics in the local government.
As a consequence, even within seemingly ethical organisational environments, whistle-
blowing could become anti-social and anti-organisational, that is, against the spirit of
teamwork. Furthermore, the quality of the institutional leadership in a particular min-
istry does not necessarily lead to an improved ethical climate when it comes to external
whistleblowing behaviours. That is, there is a problematic relationship between positive
whistleblowing behaviours and the performance of government institutions, mainly
arising from jurisdictional constraints and factors related to the core business of the
department, which are beyond concerns of anti-corruption and public accountability.
The relationship between the vertical and horizontal tolerance of corruption in
Kenyan public administration largely depends on how administrative executives gener-
ally approach issues of maladministration. Verhezen (2010) argues that managerial
position psychologically aligns administrators with either resorting to silence or blow-
ing the whistle. In departments where whistleblowing is perceptively prohibited and
where employees think that the management tolerates corruption, they resort to
silence. Managers in such departments are withdrawn from the implementation of
anti-corruption initiatives in their departments. As a result, a top-down spiral effect of
corruption and an acquiescent culture towards whistleblowing in the studied public
sector tend to favour unethical organisational leadership. Negative psychological
responses to whistleblowing arise from efforts by the county administration and legisla-
tive assemblies to control damage. However, this involves disciplining ‘soft targets’ or
low to mid-level cadre administrators instead of executive culprits. It was reported that
this causes an apprehensive general response to whistleblowers due to the fear of retali-
ation and victimisation.
This study also establishes that, for the sake of their public image and based on their
autonomous corporate status, county governments prefer internal over external whis-
tleblowing mechanisms. Departmental matters, including incidences of corruption, are
generally handled internally prior to involving the EACC and other relevant oversight
institutions. However, internal whistleblowing as an ‘unwritten rule’ is explicitly rooted
in the administrative culture. Actually, the stewardship approach of anti-corruption
reforms means that, by design and default, accountability reforms have enhanced
organisational enclaves instead of openness to external whistleblowing mechanisms.
Consequently, employees are under strict instructions and sensitised to utilise internal
solutions to suspected malpractice. From both the respondents and accessed internal
 ECONOMIC AND POLITICAL STUDIES 15

memos, administrators are required to first engage the chain of command and relevant
internal mechanisms before resorting to external avenues on corruption. The use of
internal channels like internal auditing or human resource departments is considerably
more legitimate than external mechanisms for internal whistleblowing in public
administration.
In line with Tsahuridu and Vandekerckhove’s (2008) observation, organisational
emphasis on internal mechanisms in Kenya makes administrators more liable than
responsible for preventing malpractices in public organisations. That said, managerial
retaliation or disciplinary action cannot necessarily be initiated against the whistle-
blower. Rather, retaliatory responses may take stock of the previous personal imperfec-
tions or capitalise on grey areas to ‘punish’ the whistleblower. Thus, the common
administrative culture in the studied contexts put more emphasis on complying with
the hierarchy than on building an ethical culture. As such, whistleblowing as an anti-
corruption behaviour is challenging, even for ethical administrative executives to effect.
No wonder the normalisation of corrupt behaviours has prevailed over the enforce-
ment of anti-corruption strategies and ethical decision-making processes in county
governments in Kenya (D’Arcy and Cornell 2016; Onyango 2018b).

Bureaucratic autocracy, anti-corruption strategies and whistleblowing

The emphasis on the utility of bureaucratic hierarchy in Kenyan public administration on
all matters of public accountability does not mean the existence of strict compliance to
bureaucratic practices. Rather, it stems from a culture of previlegism that, alternatively,
takes stock of the colonial heritage of administration in Kenya. The big man syndrome
often associated with political absolutism and abuse of power in African states is prevalent
in the way administrative executives behave with relation to bureaucratic structures and
execute bureaucratic power (e.g. Hyden 2013). The lifeline of Kenya’s political system has
actually resided largely with the bureaucracy, which has, subsequently, been reduced to a
tool of political influence and control. This politics-administration linkage creates a bur-
eaucracy mostly influenced by an autocratic political culture. Political and administrative
executives at the local government, as well as the level of national bureaucracy have cre-
ated a bureaucratic system to serve their influence and interests. This has been the pri-
mary source of the constraints for anti-corruption strategies and whistleblowing
intentions in public bureaucracies in Kenya (e.g. Onyango 2020b).
As a consequence, the ethical climate at the local government level is largely linked
to the bureaucratic personality of county executive officers but not to the bureaucratic
processes, namely, ethical guidelines. For example, an administrator in a study con-
ducted by the EACC in Nakuru County stated that they:
[ … .] are afraid to report corruption cases because they are threatened by County
government. They are threatened in many ways, e.g. being denied budgetary allocations
such as bursary allocation of 3 [million] per ward. Governor asks for Ksh. 200,000 kick
back from each ward. No one has an idea what the money is for. For example, 4 million
shillings for renovations of a sub-County hospital but kickback of Ksh. 400,000 to go
back to governors account. There is bid rigging of County tenders e.g. in roads.
Governor’s company together with Member of County assembly and ward
administrators are the ones that win. There is challenge of improving laws to curb
16 G. ONYANGO

corruption because few members of County assembly are used by governors to thwart
such efforts. Budget is underutilised but projects are not undertaken (EACC 2015, 55).
In addition, internal administrative environments define the extent to which exter-
nal accountability institutions access information on corruption and other related
administrative ills in county government departments. Thus, even after a whistleblow-
ing incidence, internal oversight institutions are constrained by the influence of gover-
nors, a situation that is exacerbated by the ambiguity and the fluid nature of
bureaucratic processes. Senior county executives and political representatives patronise
internal oversight mechanisms and county government public service boards. This is
partly illustrated as follows:
Auditing is not treated as an independent department. We are still under the governor
and we are using his logistics. I want to say that we should improve on this so that we
have completely different board where I control my own finances because it is me who
knows how auditing is very important [ … ] being under the director of administration
means anything that we require we have to go through him as the one monitoring our
budget. I want to monitor my own budget in order to ensure that there is that activity
of independence (cited from one of the auditors in my interview data, 6 May 2015).
These statements interrogate the autonomy and effectiveness of anti-corruption
committees in county governments, and the extent to which potential whistleblowers
could be protected or victimised by the county administration. Public bureaucracies in
Kenya tend to be more of closed cultural orientation than open-cultural systems with
respect to whistleblowing (Hofstede 1980). Like administrators, public institutions are
closed, suspicious and secretive towards non-members. Senior administrators enjoy
high levels of formal and informal privileges, whereas their subordinates feel disem-
powered and lack of control over their administrative decisions. With such a closed
cultural orientation and a bureaucratic autocracy, whistleblowing intentions are lim-
ited. In retrospect, effective communication between departments and agencies is verti-
cally and horizontally constrained by over-centralisation and over-personalisation of
bureaucratic processes in the implementation of anti-corruption initiatives.
In consequence, whistleblowing is riskier because of its intolerance by management
and co-workers alike. The autocratic administrative culture also makes it difficult to
control conflict of interest, especially that of senior administrative executives. Besides,
internal mechanisms and, to some extent, external agencies are not appositely designed
to effectively hold governors accountable on matters of corruption and implementation
of anti-corruption strategies. That said, there are parochial interpretations of ethical
decision making that exaggerate the mismatch between bureaucratic and social identi-
ties on ethical matters. This illustrates an administrative culture that is more inward-
looking and more attentive to deepening its autonomy and authority than to building
collaborative strategies to improve technical environments for the implementation of
anti-corruption reforms.

Bureaucratic identity vs. social identity in local governments

The pursuit of representative bureaucracy in contemporary public administration has
involved several sets of public sector reforms. The key principle in the local
 ECONOMIC AND POLITICAL STUDIES 17

government reforms in Kenya is to address corresponding social or ethnic tensions

that may contrain the effectiveness and subsequently the legitimacy of the government.
A focus on social composites of public organisations views governmental institutions
as mirror organisations that always reflect the social or ethnic demographics of the soci-
ety. That is, understanding the social composition of public bureaucracies is essential
for understanding administrative behaviours and actions (Pepple, Davies, and Davies
2017). In this study, working groups in Kenyan public administration are found to
largely coalesce along their ethnic groups, i.e. ethnic identity corresponds to the degree
of organisational solidarity. In the language of Pepple (2020, 1), the organisational soli-
darity can ‘manifest in employees’ self-efficacy, organisational self-identity and
employee voice behaviours’ in public bureaucracies. Kinship structures, in particular,
embody social ideologies that tend to stimulate identity considerations. Kinship struc-
tures are also essential in the socialisation of administrators on most administrative
matters, including whistleblowing or indulgence in corruption.
Thus, a negative correlation is found between kinship enclaves and the effectiveness
of internal whistleblowing mechanisms, wherein bureaucratic identity is overridden by
social identity. As a result, anti-corruption committees are weakened by divided loyal-
ties between ethnic and bureaucratic identities. Administrators are often biased in their
responses to whistleblowing and illicit practices. This is because some departments are
largely staffed by workers with a particular ethnic identity who politically and adminis-
tratively position themselves against ‘Others’. Indeed, organisational conflicts along
ethnic identities often come into play in the way administrators respond to malpractice.
Thus, anti-corruption strategies are too loosely embedded in administrative practices
to stimulate whistleblowing behaviours in the studied contexts. This is further exacer-
bated by the politicisation of the illicit behaviours, especially if powerful political
administrators (governors and their executives) are involved, leading to iden-
tity conflicts.
Therefore, the way in which organisational solidarity and bureaucratic identity are
constructed prohibits external whistleblowing and protects certain individuals. This
means that whistleblowers may become formally and informally apprehended, conse-
quently resorting to silence, either through fear of victimisation or by protecting a co-
worker. This shows how whistleblowing can draw on either competing conceptualisa-
tions of bureaucratic identity or the clash of identities and values in public administra-
tion. Again, uncertainty of whistleblowing outcomes and ignorance of investigative
procedures push administrators to seek directions from or confide in administrative
executives, including seeking guidance on how to cooperate with external investigative
agencies. This means that investigative processes to build adequate proof in corruption
cases could become distorted and redirected from the key culprits. It is reported that
inadequacy of proof is the key impediment to organisational action after whistleblow-
ing by external agencies and subsequently a constraint to the integration of anti-cor-
ruption strategies in public administration in Kenya.
In such cases, acquiescent and quiescent responses by administrators to corruption
are subject to the fact that a potential whistleblower can either be unaware of the scope
of the corruption and the parties involved or uncertain about the course of action to
take after whistleblowing. An affective administrative culture and a social identity
18 G. ONYANGO

dilemma, therefore, pose challenges in demarcating clear boundaries between a corrup-

tion scandal and parties involved and ethical decisions making, mainly, whistleblowing.
Furthermore, the kinship orientation of administrative culture in Kenyan public
administration aggravates the problems of collective action, i.e. collegial stigmatisation
and victimisation of whistleblowers and ineffective implementation of anti-corruption
legislation. It also points to the role of the social culture as the supply side of adminis-
trative culture in determining the ethical climate of public administration.

Accountability deficits in the structure of the local government model

With respect to the effectiveness of external oversight agencies in the implementation
of anti-corruption strategies and the enforcement of a whistleblowing culture, these
agencies mainly suffer from underlying institutional blind spots. These are reported
both in the design of the mandate of these agencies and in that of the local govern-
ment. Design deficits of accountability agencies and loose inter-institutional relations
at the local-state level are blamed for conflicting bureaucratic jurisdictions and collect-
ive action problems. These deficits aggravate legal constraints on whistleblowing in
public administration. For example, senior accountants under the tutelage of county
governors could rationalise their actions based on these institutional blind spots to
sabotage ongoing investigations. This increases uncertainties of whistleblowing proc-
esses and delays action on corruption culprits.
In other words, the legal framework in county administration and approaches pur-
sued by oversight agencies are either inconsistent or fluid when they come to some
forms of corruption. This, in turn, impedes the building of effective inter-agency and
inter-sectorial whistleblowing mechanisms. For example, Section 41, Part VI of the
Public Officer Ethics Act 2003 (POEA) cautions administrators against divulging of
information, failure to which will give rise to hefty penalties levied on the whistle-
blower. These ethical guidelines present corrupt executives with legal advantages,
which they could employ to cover up corruption, as well as leeway to victimise or
retaliate against whistleblowers. The looseness of the anti-corruption framework within
local government institutions and attendant implications for whistleblowers were veri-
fied by a respondent as follows:
We have our own investigative body comprised of the service delivery unit which is in
charge of all monitoring of projects. But you see, this being an in-house thing, it does
not have a legal arm in it that is why we have to refer it to the EACC in accordance to
Chapter Six which is basically the EACC (cited from my interview data, 11
August 2015).
But the EACC official further reiterated that even after receiving such referrals from
governmental departments, they often confront legal and political challenges during
investigations of corruption in county governments, especially where senior adminis-
trators are suspects. Retrospectively, institutional and legal inconsistencies in the anti-
corruption implementation framework are not clearly understood by administrative
executives with respect to compliance with the EACC directives on matters of investi-
gations. For example, based on a study conducted by the CAJ in 2014, it was not
unusual that administrators failed ‘to respond to inquiries on complaints (by CAJ) (or
 ECONOMIC AND POLITICAL STUDIES 19

failed) to honour summonses issued by the Commission’ (CAJ 2015, 60). Internal
investigations are conducted in an ad hoc manner based on unclear legal guidelines
and processes made on directives from the chain-of-command rather than on existing
due-processes.
As argued by Rothschild and Miethe (1999), institutional blind spots can allow cor-
rupt managers to promote administrative norms that are antagonistic to those of exter-
nal mechanisms and codes of conduct. In fact, it is reportedly not unusual for
administrative executives in county administration to capitalise on implicit institutional
gaps to beat corruption cases built against them. Studies have shown that institutional
blind spots are generally a challenge in the pursuit of public accountability in county
governments in Kenya. This has been largely because of the complex power relations,
loose control of mechanisms, and poor coordination between central and local govern-
ments (Onyango 2018a). In consequence, if the anti-corruption framework is not
appropriately designed, it may succumb to inter-governmental reform complexities
that make whistleblowing riskier, thus creating a quiescent and acquiescent administra-
tive response to corruption by employees and problems of organisational commitment.
Indeed, prevailing institutional inconsistencies on corruption make it harder for execu-
tives to act on whistleblowing in some government ministries.

A retaliatory administrative culture, bureaucratic politics and whistleblowing

Whistleblowing could escalate workplace conflict partly because of bureaucratic politics
and intricate power-relations between different working groups (either perceived or
actual) in a particular department of studied contexts. The relationship between
administrative factions in the studied contexts is commonly characterised by distrust,
malice and rivalry. This fosters a general culture of intolerance by managers and their
‘loyalists’ towards organisational or individual dissidence, mainly perceived to come
from an opposing group. In most cases, divergent administrative opinions or suggestions
from a working group or individuals perceived to be ‘disloyal’ to the executive are
considered suspicious and largely treated as potential sabotage. As such, whistleblowing
could appear as a form of divergent behaviour or organisational dissidence. Retaliatory
responses are traced to autocratic management styles, an extensive scalar-chain and
politically oriented power relations in public administration. In reflection of this a
respondent states that: ‘This is due to when [sic] the head of department is found
misbehaving the other employees under him or her should report [but] the decision the
boss makes is the final’ (cited from my interview data, 5 May 2015).
Altogether, the existing administrative-political synergies create, most of all, bureau-
cratically arrogant administrators endowed with scores of legitimate discretions to
devise and instigate unrelated disciplinary action against perceived and actual ‘threats’
in domain organisations. Even though disciplinary actions are often difficult to admin-
ister in public organisations (Onyango 2019b), executive managers could still instigate
informal actions to isolate and subsequently open windows of opportunity for formal
punitive measures against the perceived and actual dissidents. Alternatively, if there are
limited chances of action against the whistleblower or ‘disloyal’ subordinate, executive
managers could build evidence over time that could eventually create a strong case
against the targeted personnel. It is stated that some of the formal retaliatory responses
20 G. ONYANGO

to whistleblowers include a transfer to unfavourable stations of work, staff movement,

and poor performance appraisal evaluation (Onyango 2019b).
Potential whistleblowers in the studied contexts usually factor in these parameters
before they blow the whistle on their superiors or co-workers. Hence, in line with devi-
ance theorists, despite a few incidences or positive attitudes towards whistleblowing,
there is a general atmosphere of withdrawal from management issues by administra-
tors, including on matters of whistleblowing in the studied contexts. That is, adminis-
trators hardly get involved in those responsibilities that are not relevant to them, and,
by all means, avoid ‘trouble’ with senior managers. As such, whistleblowing is a contro-
versial behaviour and could not be easily considered by administrators unless one has
powerful connections in the hierarchy or if their identities are fully anonymised. This
points to complexity in the administrative conceptualisations of organisational and
public interests, as well as alluding to a problematic organisational citizenry in Kenyan
public administration.
Consequently, even if whistleblowing is essentially a role-specialisation for adminis-
trators, e.g. internal auditors or IAOs, their actions to blow the whistle are more likely
to be interpreted differently by the management and co-workers. That is, whistleblow-
ing is, in general, perceived as vindictive, with an element of un-forgiveness and self-
centredness. Other respondents also consider whistleblowing as a form of administra-
tive pettiness, lack of brotherliness, malice and putting your nose in others’ business,
mainly because of jealousy. Thus, whistleblowing is hardly founded on the genuine
intentions and motivation of whistleblowers to uphold ethical standards in their
departments. In fact, when administrators were asked whether they thought whistle-
blowing could improve anti-corruption behaviours, the feedback received revolve around
the role i.e. managerial commitment and the fear of retaliation. This is partially due to
unequal power relations and lack of clear role conception (i.e. it is not my business atti-
tude) with respect to whistleblowing.
To further understand trends of whistleblowing in local administration, administra-
tors were asked what would you consider before whistleblowing on your superiors? Some
of the following responses came forth. Regarding the consequences of blowing the
whistle on the supervisor, a female member of staff, whose department is ‘not at all’
concerned with whistleblowing, responded that she would not want to appear as the
odd one by blowing the whistle on witnessed corruption. However, when she was asked
whether there were adequate measures to address corruption in her department she
answered, ‘yes, there are’; but she replied ‘no’ when she was asked whether she thought
whistleblowing would aggravate anti-corruption behaviours (based on the author’s
interview data, 7 July 2015). Another administrator also considered ‘the consequences
of ‘me reporting him’ [sic]. ‘If it can lead to me losing my job, then I’ll have to hesitate’
(cited from author’s interview data, 10 July 2015). This respondent further said,
‘misconducts are a great concern to my department. In terms of time I can say that the
concern is on monthly basis [ … ] but the greatest challenge is lack of professionalism,
and integrity among the enforcers’ (cited from author’s interview data, 10 July 2015).
But, when he was asked whether whistleblowing can control corruption in his depart-
ment, he answered:
 ECONOMIC AND POLITICAL STUDIES 21

No! [it] will not curtail their occurrences as everyone is culpable. It is the reporter who
will suffer in the long run. As regarding my boss, I have not thought about it because
he upholds professional ethics [ … ] anytime a complaint is raised about misconduct
(cited from author’s interview data, 12 May 2015).
The above-cited responses describe two scenarios of whistleblowing in public
administration in Kenya. The first describes a ‘disengaged behaviour based on resigna-
tion, [and] self-protective behaviour based on fear’ (Dyne, Ang, and Botero 2003,
1360). The second, which is tied to the first, indicates the intervening role of organisa-
tional culture, leadership and bureaucratic personalities in determining ethical decision
making by administrators. The stewardship approach upon which anti-corruption
strategies are founded in Kenyan public bureaucracies can, therefore, either create an
internal organisational environment for whistleblowing or institutionalise retaliatory
responses to whistleblowers, both imagined and actual. In general, the existing account-
ability frameworks in Kenyan public administration need to insulate potential whistle-
blowers from the prevailing emotional and professional ‘attacks’ and isolation to post-
whistleblowing.

Concluding remarks
Analyses and findings presented in this article have demonstrated the ubiquitous
nature of whistleblowing and underlying factors that either enhance or frustrate whis-
tleblowing behaviours in public administration. Much as administrative culture pro-
vides unusual behavioural considerations on why and how potential whistleblowers go
about interacting with existing mechanisms and dominant norms in public bureauc-
racies, and despite generic limitations provided by its frame, ethical and transparent
bureaucratic processes positively correspond to high possibilities of whistleblowing
behaviours. In line with extant studies on organisational whistleblowing across the
globe, this paper demonstrates that common variables, mainly the fear of victimisation,
inaction on malpractices, lack of confidence in accountability mechanisms and ignor-
ance of related procedures and processes, are the key determinants of whistleblowing
behaviours in most bureaucratic contexts. The general limits of rationalisation of
organisational processes may therefore need to be addressed in public organisations to
enhance both structural and behavioural repertoires for anti-corruption strategies and
whistleblowing behaviours in public administration. As shown by the data presented in
the present discussion, anti-corruption strategies and by extension whistleblowing
intentions, which are largely embedded in the technical capacities and ethical bounda-
ries of administrative executives, may confront management ‘blindness’. Management
‘blindness’ perhaps relates to an absence of available data that allow public managers to
understand the impact of their behaviours on the effectiveness of anti-corruption
mechanisms and the probable sustainability of their progress through whistleblowing
behaviours. This would most likely result in increased managerial uncertainty, resist-
ance to change that may further accrue from successful implementation of anti-corrup-
tion requirements and whistleblowing tendencies by public administrators. Hence,
little organisational commitment and collective chastisement of whistleblowers in pub-
lic administration may aggravate the management and employees’ ethical-blindness.
22 G. ONYANGO

By illustrating the difficulties in creating effective whistleblowing mechanisms as

demonstrated in Kenya, this article builds on the neoinstitutionalist perspective that
partially believes that bureaucratisation and rationalisation deficits may be attendant to
the complex nature of informal processes and culture both inside and outside public
bureaucracies. The embeddedness of anti-corruption and whistleblowing strategies in
the organisational stewardship approach in Kenyan public administration does little to
promote whistleblowing behaviours and the effectiveness of attendant mechanisms.
Such an approach not only tends to succumb to problems of principal-agent arrange-
ments but also leads to an interpretation of anti-corruption strategies within the con-
text of a deep-seated administrative culture such that its very foundations and
evolution over time may hinder rather than promote public accountability. In such a
case, whistleblowing and anti-corruption processes are mostly linked to the discretion-
ary powers of administrative executives who decide on the course of action.
This article further demonstrates that even though whistleblowing is an essential
component of accountability reforms and can bolster the functionality of bureaucratic
and political oversight mechanisms, weak whistleblowing structures are most likely to
promote relatively complex problems of capacity in enforcing ethical guidelines in pub-
lic administration. Weak whistleblowing mechanisms can also compound the instru-
mental-cultural gaps between oversight and public institutions with respect to
controlling administrative corruption. It has been proven that components of adminis-
trative culture, mainly privilegism and autocratic management styles in Kenyan public
administration, influence whistleblowing and anti-corruption behaviours. This alludes
to the general nature of the relationship between policymaking and implementation
processes in public administration of developing countries.
In addition, the collectivist attitude of public administrators may complicate the
pursuit of administrative justice and create collective chastisement of whistleblowing
behaviours. This could arguably be one of the primary impediments to the implemen-
tation of the collective action approach to anti-corruption reforms in the global south.
Problems of collective action are likely to incapacitate organisational learning processes
on the benefits of effective anti-corruption norms and practices that may otherwise be
measured by the degree of tolerance and occurrences of whistleblowing incidences in
public entities.

Disclosure statement
No potential conflict of interest was reported by the author(s).

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