Before I move on to the concluding posts in this series on Collective Action, I’d like to respond to some of the comments which you have made over the last few weeks. In this post I’d like to talk about the role of the World Bank in promoting Collective Action.
Commenting on part 2, Sterl Greenhalgh refers to the Fighting Corruption through Collective Action Initiative sponsored by the World Bank Institute in 2008.
In fact, that early work by the WBI has very much influenced the current generation of anti-corruption experts’ thinking. The Collective Action pyramid which we are using is loosely adapted from WBI’s more complex model:
For anyone wanting to get into more detail about Collective Action, the WBI’s study is certainly a great source. Even though some of the WBI’s case studies are a few years old, they are as relevant today as they were then. The only difference is that since that original work, there has been a lot more experience in setting up Collective Action projects. Much of this is captured in Mark Pieth’s more recent study Collective Action: Innovative Strategies to Prevent Corruption.
I should also point out that the idea of collaborative efforts between business, government and civil society is not new. Since the early nineties, IBLF pioneered the concept of cross-sector partnerships for sustainable development. That work is still going strong under the Partnering Initiative. What’s new is the application of this approach to the world of anti-corruption.
The World Bank has also promoted Collective Action in practice: in the World Bank Group Integrity Compliance Guidelines, Collective Action is directly related to how sanctioned companies can end their debarment. Clause 11 reads: “Collective Action:…endeavour to engage with business organizations, industry groups, professional associations and civil society organizations to encourage and assist other entities to develop programs aimed at preventing Misconduct”.
The World Bank also allowed Siemens to settle their case by creating the Siemens Integrity Initiative, a $100 million fund to support Collective Action project run by NGOs in emerging and developing markets.
Despite this pioneering role, I am not 100% convinced that the World Bank has maintained its leadership since those early days of enthusiasm.
For example, how many companies that ended their debarment can demonstrate the level of commitment to Collective Action suggested by the Integrity Compliance Guidelines and with what impact on the local markets?
Are there any examples of funding Collective Action as a major component of the settlements with other companies other Siemens?
Has the World Bank commitment to Collective Action been successfully transferred to other International Financial Institutions and national Aid agencies? Debarment as a deterrence has, but has Collective Action as an incentive? The recent report on the approach to anti-corruption of DfID, the UK’s overseas aid agency, would suggest that more remains to be done here.
And to what extent has the World Bank been able to successfully persuade the governments of developing nations to which it lends to support Collective Action?
Indeed has the World Bank actively encouraged developed nations’ national enforcement agencies to follow their example and to allocate a small percentage of the penalty or the recovered assets to these kinds of initiatives in the countries where the corrupt practices occurred?
In my opinion, Collective Action still remains somewhere on the periphery and until more is done, the jury must still be out on its ability to catalyse change. It requires more publicity, advocacy, more success stories – and dare I say it – more funding to demonstrate real impact in changing the culture of corruption. The World Bank, as one of the most influential players, will, I hope, return to lead the charge.
Brook Horowitz is a contributing editor of the FCPA Blog. He’s the CEO of IBLF Global, a not-for-profit promoting responsible business practices worldwide.