GAB welcomes back Alan Doig, Visiting Professor at Newcastle Business School, Northumbria University, who contributes the following guest post:
About a year ago (in January 2018) I saw an advertisement from the NGO Publish What You Pay (PWYP) seeking applications for a consultant to draft a “mandatory disclosures charter” for PWYP India members and other allies working to advance natural resource governance in India. It’s not unusual to see an advertisement encouraging publicly-available standards for others, and this led me to question how good the anitcorruption advocacy industry is in practicing and publishing what it preaches for others. For governments and public bodies, after all, there are a whole host of documents, agreements, and declarations (such as the UN Convention against Corruption, the Kuala Lumpur Statement on Anti-Corruption Strategies, and the G20 High-Level Principles on Fighting Corruption to Promote Strong, Sustainable And Balanced Growth) that point to what are invariably thought to be the necessary requirements for transparency, accountability, and integrity—often in the form of lists that include items on things like financial transparency, institutional control and oversight arrangements, conflict-of-interest procedures, codes of conduct, whistleblowing arrangements, and so on.
PWYP is a UK-registered charity and thus subject to a government regulator which provides guidance on what is required, but many other advocacy bodies–as organizations–are left to their own devices. To look into what this may mean in practice, I selected five NGOs, chosen unscientifically for their engagement in different aspects of anticorruption advocacy; an international advocacy organization, a national advocacy organization, an investigative body, an educational body, and the secretariat of an NGO coalition. I looked for evidence specifically published on their websites of what may be considered a basic anticorruption prevention framework, including: board oversight, a statement of values, a code of conduct for staff, a whistleblowing policy (including external reporting), an anticorruption and fraud policy, conflict of interest procedures, a declaration of annual income by source and amount, identification of expenditure by category (including highest-paid staff), and whether or not the organization is subject to any evaluation as an organization. This is what I found:
|Board Over-sight||Organiz’l Values||Code of Conduct||Whistle-blowing||AC/ Fraud Policy||Conflict Of Interest||Income (Names and Amts)||Expenditure (Program and Organization)||Evaluation of Organization|
|International||Y||Y||Y||Y||N||Policy; no register||Y||P – Y
O – General headings
|National||Y||N||N||N||N||N||Funder Names Only||P – No
O – No
|Investigative||Y||N||N||N||N||Y||Y||P – N
Y – And Salary Bands
|Educational||Y||Y||N||N||N||N||Y||P – N (Budget only; no salary bands)
O – N (Budget only; no salary bands)
|Secretariat||Y||N||N||N||N||N||Y||P – Y
O – General Headings
It appears from this preliminary, unscientific and unvalidated survey that many anticorruption NGOs don’t always practice what they preach. Now, I may be doing them a disservice and that, hidden away within the organization, are all things I have been looking for. Further, it could be argued that for many of these organizations, they don’t have a large administrative budget or specialized staff, making the more formalized, institutionalized control systems unnecessary and overly bureaucratic. Maybe, but that misses the point: At the very least, the commitments and safeguards should be accessible and demonstrable. Published procedures and other arrangements safeguard the organization and its staff, and to give the organization more credibility when criticizing the lack of transparency and accountability of others.
Why not an equivalent of the Kuala Lumpur Statement on Anti-Corruption Strategies (or Jakarta Statement on Anti-Corruption Agencies) on the basic organizational requirements to safeguard the organization against corruption? Perhaps there should also be a Publish Your Commitment and Costs (PYCC) Index that measures the presence and accessibility of these arrangements as evidence of good practice. Whether the sensitivities and issues of reputation management of the anticorruption industry will foster such a public embracing of the transparency and accountability that they require of others is another matter.
I don’t have in mind anyone associated with this blog, but more broadly do individuals active in the FCPA, compliance, transparency space practice what they preach? In my experience and estimation the answer is no. Lots of non-compliance and undisclosed conflicts of interest in the FCPA commentator community.
I looked into the same issue with @Transparify a few years ago. We found that only 11 out of 34 transparency organizations assessed published details on who funded them:
Click to access Transparify+report+on+IODC15.pdf
Note that PWYP-USA and PWYP-Canada both meet the gold standard (5-star) for nonprofit disclosure, and so do TI-UK, TI Georgia and TI-EU (Brussels):
Click to access Transparify+2018+Think+Tanks+Report.pdf
In contrast, last time we assessed Transparency International Canada, it only received 3 stars out of 5, receiving a rating of “not transparent”:
Click to access Think+Tank+Transparency+in+Canada%2C+Lagging+behind+the+US+and+UK+Transparify.pdf
To date, the TI Secretariat has not made public financial disclosure a binding condition for (re-)accreditation of its national chapters.
International networks of transparency and anti-corruption NGOs (such as TI, PWYP, EITI, and FiTI) should ensure that all network members model the transparency they preach. This includes each and every local NGO participating in their work, including external players (such as LNGOs participating in national PWYP or EITI round tables).
This is especially important as “look we have nothing to hide” can be a powerful way for NGOs to push back against crackdowns by authoritarian govts that love to argue that NGOs push the hidden agendas of secret foreign donors:
Click to access distract-divide-detach.pdf
(In the past, two NGOs we had certified as “highly transparent” have already used this to defend themselves against authoritarian govt accusations of hidden agendas: one in Eurasia, one in Latin America. Also, we’ve found 5-star NGOs in Ethiopia and Pakistan, so clearly it’s possible even in very difficult contexts.)
See also this previous GAB blog of mine on the topic:
Till Bruckner / Transparify & TranspariMED
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Recently, I applied in response to a call by Transparency International Secretariat Berlin for a small assignment. To date neither I received their acknowledgement nor disapproval of my application. So I take it as a normal for lack of transparency and accountability in other institutions.
Thank you Professor Doig. You raise a very important issue that in my view suffers from a shortage of attention. As you mentioned, “[p]ublished procedures and other arrangements safeguard the [anticorruption advocacy] organization and its staff, and […] give the organization more credibility when criticizing the lack of transparency and accountability of others.” However, some people do not want to criticize the lack of transparency or accountability of certain anticorruption advocacy organizations due to a fear of being falsely accused of criticizing the substantive work that these organizations do.