In May of this year, the government announced that the UK would publish its first-ever Anti-Corruption Strategy before the year end – a commitment renewed by the government of Theresa May.  But times have changed.  When it was announced, corruption was a clear priority of the then prime minister, and the Strategy was a chance to show a long-term commitment to the UK putting its own house in order as a platform for leading a global debate on the subject. Then we had the Brexit referendum and the US election.  The purpose of the Strategy has now changed.  Corruption as an issue will not be spoken of as frequently as it was before, now there is a government dominated by Brexit – but the challenges posed by corruption have if anything been heightened, and the Strategy needs to set out the government’s response and long-term vision in three key areas:

• Domestically – to respond to the concerns revealed by the referendum about inequality, injustice, vested interests and the lack of trust in politics – emphasising strong British institutions and standards in public life
• The UK as a safe haven for corrupt capital – to show that the UK will operate to high standards and not a race to the bottom when it comes to money laundering and offering a home to the world’s corrupt elite
• Internationally – to show leadership in global institutions, to create a new paradigm for global trade and to support an international architecture based on the rule of law.

Why do we need a strategy as well as a plan?

TI welcomed the publication of the government’s anti-corruption plan in December 2014 .  It was not perfect (perhaps merited a rating six and a half out of ten), but a very creditable attempt to bring together existing activities within a more coherent framework, set timelines (mostly missed) and above all take ownership of an issue that most previous governments has been content to ignore.  But it was never clear what the strategy was, and whether this was really a series of related actions assembled together to look like a plan.

It’s perhaps worth re-capping the distinction between a strategy and a plan.  Though definitions vary and overlap, a plan is usually tactical – showing in detail how a specific objective or set of objectives will be achieved.  A strategy provides the framework for annual or sectoral plans, with a comprehensive articulation of the problem, a wider set of objectives, and a long-term vision.  A strategy typically contains an overall goal, a set of priorities and an analysis of the capabilities that will be needed.  The current Anti-Corruption Plan contains a single page which lays out some strategy in a table: it has some good thoughts, but begs as many questions as it answers.

The experience of the past twenty years – the time in which the international community has acknowledged and started to address corruption – is that tackling corruption is a long-term endeavour.  Like the Sustainable Development Goals, of which corruption now forms a part due in no small measure to the efforts of DFID and the UK, the UK’s approach to corruption needs a fifteen-year horizon.

The Government typically sets out strategies for certain key issues, such as defence, overseas development, serious and organised crime and economic growth.  Like these other issues, corruption is such a large subject, encompassing so many complex sub-areas, countries and different UK government departments, that it needs a coherent, long-term vision and framework.

Six things we don’t know and the strategy should tell us

• How bad is the problem (scale, type, prevalence, impact) and if we don’t know, how will we find out?
• How will the Strategy approach corruption risk that is legal but unethical, such as inappropriate lobbying and the revolving door?
• How does the Strategy relate to the UK’s commitment to deliver Sustainable Development Goal 16?
• How does the government rate the UK’s current anti-corruption capabilities, and are there gaps to address?
• Which areas of the current Anti-Corruption Plan are really important, and need to be sustained over the long-term and not quietly dropped?
• Where is this all heading – what is the overall narrative, direction of travel and destination of the UK’s fight against corruption?

What happens without a strategy?

Here is an interesting example of what happens without a strategy.  Recent changes in the public sector have resulted in heightened corruption risk in local government, the police, and the NHS: respectively the abolition of the Audit Commission, and the lack of anti-corruption controls in the creation of Police & Crimes Commissioners and Clinical Commissioning Groups.  There was a plan to privatise the Land Registry, identified by the government itself as a key focus for tackling corruption.  And recent reports have alleged that basic conflicts of interest are going un-reported in Academy schools.  Yet each of these five institutions has been dealt with in isolation, with no over-arching anti-corruption lens being applied by the government – perhaps the kind of thing the government’s Anti-Corruption Champion might be expected to do.  There’s no guarantee that with an anti-corruption strategy this would not have happened; but you can be fairly sure that it is likely to happen if you don’t have an anti-corruption strategy.

The data gap

We actually know very little about corruption in the UK, and that means it is easy to ignore, and difficult to know where the impact is greatest and what to prioritise.  So a good starting point would be stimulating more research.  The UK has world-class academics who research corruption, as well as a clutch of specialist NGOs and think-tanks.  DFID has taken a very smart approach to filling its own information gaps on corruption – tying up with the British Academy to run a small but potentially ground-breaking corruption research programme.  Where is the equivalent for corruption in the UK?

How might a strategy be structured?

The current Plan is structured around the 4Ps approach (Pursue, Prevent, Protect, Prepare).  That seems to work, but the key thing is that any strategy should recognise there are three inter-related areas for the UK:

• UK domestic corruption – public procurement, open data, transparency and standards of integrity; and known specific high-risk areas of police, prisons, borders, local government, housing and development, the NHS. Others will occur over time, and the Strategy needs the flexibility to encompass them.
• The UK’s interface with global corruption – money laundering and the role of the UK as a safe haven for corrupt capital; there must be clear reference to the problems associated with the OTs and CDs, not simply a vague intention to continue engaging them.
• The UK’s influence in the wider world – the Bribery Act, the UK’s role in forums such as the G8 and OECD, reinforcing the international rule of law, and recognising that a genuinely free trade environment means a business sector operating without corruption.

Timescale

The strategy should look to last until 2030.

Resources

A crucial point is that this strategy, unlike defence or ODA, need not cost very much.  There are some critical areas to which existing resources could be re-allocated, but not much new money is required, if any.  The Cabinet Office’s Joint Anti-Corruption Unit (JACU) needs to be continued, and sufficiently resourced to do the job of making sure the strategy is delivered.  The prime enforcement agencies – NCA, SFO, and others linked to anti-money laundering – need security about their institutional longevity and proper funding.  Research needs to be commissioned, possibly using the DFID/British Academy model outlined above.  We might be talking about an additional annual cost of some £60-90 million, some of which could be re-allocated from existing budgets like the ODA budget.  The government’s own estimate is that ‘cutting corruption by just 10% could benefit the global economy by $380 billion every year’, quite apart from the human misery it causes: that’s a fairly impressive return on investment.

Responsibility for delivery

The Strategy will need an Anti-Corruption Champion with the energy, understanding, clout and time to devote to the role.  Perhaps this is an opportunity to institutionalise the role and give it a clearer remit.  Likewise, TI has identified over sixty different public sector institutions and law enforcement agencies in the UK that have responsibility for corruption: is the strategy to promote consolidation or simply cooperation?  There is also the nagging question of who holds the government to account for all this.  Many countries have Anti-Corruption Agencies that report publicly; others have independent committees, commissions or extensive parliamentary oversight mechanisms.  At the moment, the government marks its own homework – giving itself an optimistic 65.5 out of 66 for completing actions in the Anti-Corruption Plan.  The appointment of an Independent Commissioner would give weight to the assurances that the government is seriously committed to the Strategy.

What to avoid

Very little has been said publicly about what the Strategy will look like and what it will contain, so it is not possible to comment on its contents with any authority. However, it is possible to highlight features which will cause it to be criticised rather than welcomed:

• Excessive focus on the outcomes of the London Anti-Corruption Summit to the exclusion of other domestic anti-corruption priorities, which have for too long been ignored.
• Politics. Lobbying, the revolving door, party financing, parliamentary ethics: with trust in politics at a low ebb, the Strategy needs to address issues that are of strong concern to the wider public.  If they are left out, that will tell its own story.
• Low ambition. If the Strategy is not world class, it will not address the key challenges that face Britain today.  This would not only be a missed opportunity; it will suggest a poor diagnosis of the problems that this government will be facing.
• Strong rhetoric but weak delivery mechanisms.  How will the Strategy be delivered – including the plans for strengthening the national anti-corruption defences, effective law enforcement and filling the information gaps.
• Poor coordination. The Strategy will need to outline how the government intends to tighten up anti-corruption coordination across departments.  This has improved already – from a very low base – with the creation of the Cabinet Office’s JACU, and re-instatement of the inter-ministerial group.  But if this is going to be a world class strategy, the coordination needs to be demonstrably improved.

Why it matters

Here is a quick reminder of why this is important.  The UK is entering uncertain times socially, economically and politically.  Those within the country are looking for substantial changes in the deal they get from the government; those from outside the country are looking at whether Britain is still a player, a good long-term business partner and a good place to invest.  The UK’s first-ever national Anti-Corruption Strategy will help communicate the government’s intent, and set a course for how this country will deal with some of the key issues with the day.  A weak or mediocre Strategy will send out all the wrong signals, and mean that some of the most important challenges inherent in Brexit and the new world will be unaddressed.  That would be bad for the government, bad for the country and an unnecessarily bad result for citizens throughout the UK.