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Humanitarian
HPG Policy Brief 32
Policy Group September 2008
Overseas Development The high level of needs of crisis-affected The scale of corruption, corruption risks in
Institute populations means that they can ill-afford specific programming areas and how
corruption that compromises their access to corruption impacts people affected by
HPG Briefing 32 2nd 10/9/08 9:40 am Page 2
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worth an estimated $8.75 billion were plagued by commodities, such as expensive and scarce drugs,
the mutually reinforcing problems of waste, fraud, fishing boats and tents, are a target for diversion
abuse and mismanagement. The narrow focus on because of their value. In Sri Lanka following the
financial forms of corruption and limited inter- and tsunami, corruption was perceived in the allotment
intra-agency dialogue on corruption cases add to of newly constructed houses according to political
the difficulty of describing its scale. Because those support and affiliation, rather than need. In Northern
affected by crisis have limited information to Uganda, payment for inclusion on recipient lists was
determine whether corruption is hindering their associated with highly valued tents and non-food
access to assistance and few channels to report items. In Liberia, diversion was chiefly related to
such problems, agencies may not grasp the scope food aid and medicines.
of corruption related to assistance in these
communities. The assessment, targeting and registration of
recipients determines who gets what in
Identifying the risks humanitarian assistance. Efforts by aid agencies to
reach the right people are challenged by attempts to
Types of corruption risks and high-risk areas are distort information, direct assistance to certain
better understood than issues of scale. From groups or solicit bribes for inclusion in assistance.
community leaders subverting the targeting
process to logisticians accepting bribes to award Whereas aid agencies are most concerned about
contracts, the list of areas where corruption can inclusion errors because this diverts their
occur is long. resources, recipients themselves are most concerned
about exclusion. For people affected by crisis, being
Interpretations of what acts constitute corruption registered as a camp resident, for a food ration card,
differ according to contexts, cultures and for home reconstruction or other assistance is the
individuals. Perceived corruption may or may not primary entry-point to accessing aid. Perceived
fall under a standard interpretation of abuse of corruption includes the deliberate inclusion of non-
entrusted power for private gain. For example, eligible households and the exclusion of eligible
kinship and social networks may play a greater role ones, multiple registration and bribes or sexual
in business interactions than in Western cultures, favours for inclusion on beneficiary lists. Refusing to
whereby kickbacks and hiring or making submit to extortion can affect access to assistance,
purchases through relatives is considered normal as in Liberia, where women have reported not
practice even one that ensures the quality of receiving food aid because they would not have sex
goods and services. For aid recipients, leaders with camp leaders. Corruption in registration can
benefiting disproportionately from assistance may also take the form of manipulating household
be seen as an acceptable privilege, while aid statistics (e.g. family size) to increase or decrease
agencies transporting undistributed relief supplies assistance packages, the trafficking of fake ration
back to their warehouses may be perceived as the cards and the sale of ration cards by those
theft or diversion of relief commodities belonging responsible for distributing them. The perceived
to those affected by the crisis. There is also the gains to those responsible include helping friends
ethical question of whether the exaggeration of and family, rewarding supporters, punishing enemies
needs by crisis-affected populations is corruption or obtaining money, sex and increased assistance
or a survival strategy when access to critical that can be gifted, used or sold.
resources has been lost. Despite these issues,
certain processes, sectors, programme support Corruption in the distribution of material assistance
areas and methods of engagement in humanitarian occurs when those in charge of doling it out control
assistance are considered by aid agency staff and the amounts or have the discretion to give it to
aid recipients alike as particularly vulnerable. people who are not registered for it. The distribution
of pre-packaged food (rather than using scoops,
Food aid, construction and other highly valued which can be filled to varying amounts), using
assistance are perceived as at highest risk of beneficiary lists in addition to beneficiary/ration
corruption. Bountiful and highly prized in humani- cards (rather than only using cards), and direct
tarian contexts, food aid can be diverted physically oversight by aid agencies all reduce this discretion.
during transport and storage, or indirectly through Announcing the type and quantity of assistance
the manipulation of assessments, targeting, enables recipients to determine if they received the
registration and distributions to favour certain correct amount. Even if people receive the correct
groups or individuals. In construction and shelter, amount, local elites can impose taxes once the
the copious opportunities for diversion and profit distribution is over and the aid agency has left. In
through substandard workmanship, kickbacks for Afghanistan, one bus driver reported that camp
contracts and favouritism in the delivery of valuable leaders would hire his truck once a week to take
shelter material make it a high-risk sector. Other relief commodities to the local market items that
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The relationships and structures through which aid An implicit assumption in electing new represen-
agencies implement their programmes create their tation structures to liaise in the assistance
own risks. Working through local partners builds process is that pre-existing leadership structures
local capacity to respond to emergencies, can may not impartially allocate assistance because
increase local accountability and might provide they are entrenched in local power systems.
greater knowledge of local power relations, but However, elected structures can also be involved
partnerships may also decrease oversight in in extortion or other corruption. Aid agencies
comparison to the direct implementation of need to ensure that the representation systems
programmes. Partners could engage in any of the they create or use are accountable and transpar-
risk areas mentioned above; aid agencies often lack ent, rather than assuming that this is an inevitable
clear and predefined response strategies should result of an election or the formation of a commit-
corruption occur in partnership arrangements. tee.
Engaging through committees elected by crisis-
affected populations opens these groups to
potential control by local elites, while local leaders, emergency settings, deployment of special surge-
often an asset in reaching people in need because of capacity staff, segregation of duties, rotation of
their influence and intimate knowledge of their key staff, complaints mechanisms, communication
communities, can use this power to divert assistance of information on entitlements, training on
to unintended recipients. Corruption poses a threat organisational values and the use of committees in
in any process that passes through gate-keepers hiring, contracting and procurement.
people or groups who control access to information
and assistance. The best way for an agency to Agencies have also developed measures that
engage depends not on an isolated focus on directly address corruption risks in emergencies.
corruption risks but on a variety of factors. However, Whistle-blower policies are confidential mechan-
many agencies shy away from analysing the risks isms designed to encourage aid agency staff to
inherent in these methods of engagement. report corruption. The effectiveness of these rel-
atively new procedures is an open question, but
Addressing corruption risks: policies many staff are simply not aware of their existence
and perceive disincentives to reporting corruption,
and practices of aid agencies
such as reduced job security or creating grudges.
Aid agencies policies, procedures and ethical They are generally not accessible to local partners or
standards are seldom specific to corruption or aid recipients.
emergency settings; rather, they are measures
with the intent or effect of preventing fraud and Zero tolerance policies can reduce corruption by
abuse, commingled with other procedures in conveying to local actors that the agency does not
finance, procurement, logistics, human resources engage in corrupt actions, but can also discourage
and programming guidelines: codes of conduct, open discussion of corruption pressures by
sexual exploitation policies, audits, spending and reinforcing taboos. One humanitarian worker
approval limits, adaptation of procedures to described such a policy as a dreamers opinion,
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areas
Scaling up local offices for direct delivery HR recruitment and other programme support risks;
bribes required for permits or access to public services
Working through committees Diversion of assistance to their own networks,
acceptance of bribes for inclusion on lists
Working through local leadership structures/ Diversion of assistance to their own networks and
local government political supporters, acceptance of bribes for
inclusion on lists
Adapted from P. Ewins et al., Mapping the Risks of Corruption in Humanitarian Action (London, Berlin and Bergen: ODI,
Transparency International and the Christian Michelsen Institute, 2006).
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HPG Briefing 32 2nd 10/9/08 9:40 am Page 6
while others understand zero tolerance as evidenced by the fact that the one agency that
meaning that corruption must be addressed openly actually had a complaints desk was considered the
by the agency. In areas with endemic corruption, least responsive by aid recipients.
agencies may avoid direct involvement but end up
outsourcing corruption to intermediaries, No system is fool-proof; it ultimately boils down to
transporters or even partners and lower-level staff, the individuals who operate it. However, human
implicitly using a dont ask, dont tell policy to resources in emergencies has not received nearly as
accomplish tasks requiring bribery. much emphasis as finance and procurement
functions, even though successfully implementing
Actions taken by aid agencies in preparing for and programmes and addressing corruption risks depend
undertaking emergency responses directly and on the quality and commitment of staff. Aid agency
indirectly address certain high-risk corruption areas. staff believe that organisational values, when
Inter-agency coordination offers a forum for sharing communicated and reinforced through training,
blacklists of contractors and discussing consolidated opportunities for advancement, appraisals and
approaches for dealing with corrupt authorities. examples set by senior managers, promote honesty
Developing a surge capacity of trained staff, and loyalty to the agency. Finding the balance
including finance and procurement staff, who can between trusting and empowering staff and partners
deploy quickly to establish or support humanitarian on the one hand and control and effective verification
operations reduces the risks inherent in the rapid on the other is complicated by the power imbalances
scale-up of programmes. Establishing policies between international aid agencies and local
specific to emergency humanitarian programming partners, and between expatriate and national staff.
(e.g. to permit rapid hiring and procurement) reduces
the likelihood that standard procedures will be The practices of individual aid agencies that address
ineffective or unofficially short-circuited. Emergency corruption risks have not been accompanied by
preparedness should take into account corruption system-wide analysis and action in the humanitarian
risks as time pressures in the early stages of community to promote information-sharing and
response leave little space for this analysis; however, joint action. In particular, coordination forums could
this is rarely done by aid agencies. be used to develop common strategies dealing with
specific emergency environments where corruption
Policies alone are inadequate to address corruption is endemic.
risks. There is a clear gap between policy develop-
ment in agency headquarters and implementation in Conclusion
the field. Project monitoring key in verifying the
effectiveness of systems, detecting corruption and Corruption poses a serious threat in the complex
more generally a standard good practice part of endeavour of humanitarian assistance to the
programme quality, learning and accountability people trying to access life-saving resources, to the
continues to be hampered by under-investment. Aid ability of agencies to programme assistance in
agencies are increasingly committed to enhancing exploitative and corrupt settings and to the
accountability through complaints mechanisms and reputations of all actors involved in saving lives and
community participation in assessments, regis- alleviating suffering in the wake of crisis. The extent
tration and targeting, but time, staff and training are to which agency practices that mitigate corruption
still too limited. Even the basic act of communicating risks do or do not slow down responses in the early
information about aid entitlements is not always stages of a crisis needs to be further explored, but
undertaken. there are clear steps that agencies can take. Reports,
evaluations, guidelines and good practice reviews
When channels for aid recipients to file complaints recommend investment in programme quality and
do exist, fear of losing access to assistance accountability to aid recipients; preventing cor-
discourages the reporting of corruption against ruption is yet one more reason why these measures
those who control it. Yet complaints are often routed are essential. Humanitarian agencies can benefit
through the very aid governance systems from examining anti-corruption tools and strategies
responsible for the two high-risk areas of targeting developed by institutions outside of the humani-
and registration. Complaint mechanisms that tarian world, and a handbook focusing on preventing
require literacy or amount to symbolic gestures that corruption in humanitarian assistance is being
do not result in action or resolution are likewise developed by Transparency International. Donors
discouraging and ineffective. Aid recipients can help by providing more resources for audits and
distinguish and can identify by name agencies monitoring, increasing the flexibility with which
that address their complaints and ones that do not. funds are allocated to programme support and
In Northern Uganda, whether or not these agencies quality enhancement functions, and refraining from
had official complaints mechanisms was of little pressuring agencies to unnecessarily accelerate
consequence in their ability to address complaints, spending. The humanitarian enterprise is inherently
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risky, and aid agencies and donors need to have grabbing scandals about greed, abuse and wastage.
realistic expectations about delivering relief in More importantly, it supports the fundamental
contexts where corruption and diversion are all but objective of humanitarian assistance: to provide
inevitable. Addressing corruption risks might not assistance wherever it is needed, to the people who
itself make headlines, but it may prevent attention- need it.
References and further reading (Berlin, Boston, and London: Transparency Inter-
national, Feinstein International Center and the
Sarah Bailey, Perceptions of Corruption in Overseas Development Institute, 2008).
Humani-tarian Assistance among Internally Kevin Savage et al., Corruption Perceptions and
Displaced Persons in Northern Uganda (London: Risks in Humanitarian Assistance: An Afghanistan
HPG, 2008). Case Study (London: HPG, 2007).
Samir Elhawary with M. M. M. Aheeyar, Beneficiary Kevin Savage et al., Corruption Perceptions and
Perceptions of Corruption in Humanitarian Assis- Risks in Humanitarian Assistance: A Liberia Case
tance: Sri Lanka Case Study (London: HPG, 2008). Study (London: ODI, 2007).
P. Ewins, P. Harvey, K. Savage and A. Jacobs, US House of Representatives, Committee on
Mapping the Risks of Corruption in Humanitarian Government Reform Minority Staff, Special
Action (London, Berlin and Bergen: ODI, Investigations Division, Waste, Fraud, and Abuse in
Transparency International and the Christian Hurricane Katrina Contracts, 2006.
Michelsen Institute, 2006). Barnaby Willitts-King and Paul Harvey, Managing
Dan Maxwell et al., Preventing Corruption in the Risk of Corruption in Humanitarian Relief
Humanitarian Assistance: Final Research Report Operations (London: HPG, 2005).
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hpg
Humanitarian
Policy Group
Overseas Development
Institute