PublicationsThe U4 Blog


How corruption and unequal lobbying can undermine COP26 goals – Part 2: The solution

There are a number of options available to facilitate increased and equal access to decision-makers by all relevant stakeholders.
Read the associated publication
31 October 2021
A toy earth inside a lifebuoy floats on the water.
Transparency of processes is often enough to reduce the most serious corruption risks. Photo:

In part one of this blog, I discussed how corruption and unequal access to decision makers, or as we have put it: unequal lobbying, can undermine the three of the four main goals of COP26. Here, I explore what can be done to address these problems.

How corruption and unequal lobbying can undermine COP26 goals

  1. Emissions reductions
    In order to see the promised reductions of GHG and keep global temperatures below 1.5 degrees, governments will need to support the phase out fossil fuels. Unfortunately, when it comes to the analysis of unequal lobbying and corruption in the energy sector, particularly fossil fuel companies do not have a good track record when it comes to applying their influence over decision makers, and the number of corruption scandals involving energy firms is also worrying.
  2. Adaptation
    To adapt to climate change we will require new warning systems and resilient infrastructure. The efficacy of adaptation efforts can also be undermined by special interests and corruption.
  3. Making good on the promise of climate finance
    The choice of what types of climate initiatives receive financing is a policy decision and our research shows that these can be undermined by unequal lobbying and corruption.


Whilst most commentators call for increased regulation of professional lobbying to reduce these corruption risks in lobbying, this may do little to address the main problem of unequal (and often paid) access. But not all is lost. Indeed, in our research we showed that there are a number of options available to facilitate increased and equal access to decision-makers by all relevant stakeholders. We also know that transparency of processes is often enough to reduce the most serious corruption risks. This could also be true for soliciting advice and inputs on climate policy.

There are a number of options available to facilitate increased and equal access to decision-makers by all relevant stakeholders.

Apply an inclusive development conceptual framework

To establish inclusive access to decision-makers, create processes that are built upon the foundations of inclusive development. The messaging of the UN SDGs, particularly SDG 16 and 17 that emphasise inclusive societies, justice for all and strong partnership should be leveraged when engaging different actors and stakeholders in the climate space. SDGs 16 and 17 simplify development practitioners’ task regarding lobbying and climate change initiatives: they need to adopt tried, tested and accepted principles of development and use them as the basis for broad inclusive engagement on climate action.

Applying the transparency and objective criteria principles of Article 9 of UNCAC are relevant to managing corruption risks in lobbying.

Apply tools built from transparent and objective procurement practices

Established standards and legal and administrative tools used in procurement for development programmes can also be used to minimise inequality and exclusion in lobbying. Applying the transparency and objective criteria principles of Article 9 of UNCAC are relevant to managing corruption risks in lobbying. The following specific measures around procurement transparency could be directly adapted to preventing exclusion in lobbying around climate action, though it should be kept in mind that some of the suggestions below may require strengthen of legal and administrative systems:

  • Ease of access for all stakeholders to information about (a) the policy-making process and (b) existing information about an issue being considered by the donor or recipient.
  • Register communications and engagements, e.g., meetings and ban secret meetings between policymakers and other stakeholders.
  • Communicate equally with all parties, e.g., all parties receive all communications about an issue, and all parties’ policy positions are available to all lobbying parties.
  • Create a standard formal response to requests for meetings, stating that meetings can be held only if all programme stakeholders are invited to similar meetings (similar to information meetings around procurement contracts), or the meeting must be publicly disclosed (even if not all the content is disclosed).
  • Where private meetings are advisable, consider what details should be released publicly for transparency purposes.
  • Make information available to the public about the ‘who, what, where’ of communications and engagement, e.g., post online meeting diaries and any written submissions that may have been made (similar to what occurs with public commissions of inquiry).
  • If communications and engagement result in the award of a specific contract, such as for a significant resources project, this contract could be posted online in keeping with transparency standards of, for example, the EITI.
  • Create integrity pacts between stakeholders and policy makers about standards of conduct and commitments to avoid breaching lobbying rules.
  • Adopt a system for managing conflicts of interest and publish it online.
  • Adopt a system for investigating and sanctioning alleged breaches of rules and publish it online.
  • Create and enforce penalties if rules are breached, such as bans on further engagement on an issue, as well as punishments for officials who tolerate — or engage in — exclusionary practices.

Promote inclusion and avoid exclusion

To return to promoting inclusivity and avoiding exclusion in climate action, there are practical steps donors and recipients of development related climate finance can take here too:

  • Map the stakeholders interested in climate policy — there will be a lot — and identify any who appear missing from forums.
  • Identify why stakeholders may be missing (Lack of resources? Unaware of process? Warned not to participate? Lack of communications in local languages? Systemic discrimination?) and remedy the situation.
  • Make participation in policy forums easy, including: subsidies for travel, meals and accommodation for some stakeholders; hold multiple opportunities to have input, including outside major cities; allow submissions in local languages and provide translators and interpreters; use venues that people with disabilities can access (including physical access and hearing assistance); have staff available who can explain the submissions process to uncertain participants.
  • When submissions can be made in-person or via video conference, consider making these sessions public so anyone can attend and listen to what everyone else says, or live-stream and record the session and put it on the web.
  • Actively communicate to stakeholders by letter and at the start of meetings or public hearings, the principles driving the engagement process. Tell them exclusionary practices will not be tolerated and stakeholders risk prohibition and their submissions being disregarded if they seek engagement outside agreed forums.

Educate staff and stakeholders

Finally, and bringing together all these issues, donors and recipients should educate development program staff — especially staff at high risk such as executives, managers, and program design consultants — to be prepared. In particular, that …

  • Lobbying is designed to influence how the lobbied parties thinks about an issue;
  • Attempts to lobby can occur in a variety of settings, from a formal attempt at head office, to an unexpected visit to a program office in a developing country, or at a bar or conference.
  • Ostensibly ‘friendly’ approaches by stakeholders may, in fact, be part a pre-planned, well-resourced, strategy. Just as suppliers offer gifts and experiences to procurement staff to make them feel positively about the giver, offers of gifts or experiences by stakeholders with an interest in climate policy are driven by the same motivation.


Read more in Lobbying, corruption, and climate finance: The stakes for international development (U4 Issue 2021:13)

    About the author

    Saul Mullard

    Saul Mullard is a senior adviser at the U4 Anti-Corruption Resource Centre and a civil society specialist with a background in historical sociology, development studies, and South Asian studies. His research interests include the relationship between corruption and climate change and the role of local communities and indigenous peoples in addressing corruption and environmental protection. Mullard holds a doctorate and master’s in South and Inner Asian Studies from the University of Oxford, as well as a BA in Development Studies from the School of Oriental and African Studies (SOAS) in London.


    All views in this text are the author(s)’, and may differ from the U4 partner agencies’ policies.

    This work is licenced under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International licence (CC BY-NC-ND 4.0)