Query

Please provide an overview of the core principles of integrity management in multilateral organisations.

Caveat

The focus of this paper is on the key features of integrity systems of multilateral organisations rather than multilateral development banks (MDBs), which have been previously covered in a different paper that can be found here. The integrity features and various examples drawn from a range of multilateral organisations are meant to be illustrative rather than exhaustive.

Moreover, there is limited information available in the public domain about bilateral donors’ working practices vis a vis multilaterals. Several integrity frameworks at particular agencies only cover fraud risks. While the phenomenon of fraud and corruption overlap in several areas, they must not be understood interchangeably. Finally, this Helpdesk Answer includes boxes containing reflections on potential entry points for bilateral donors to engage with multilaterals on integrity issues. These boxes are drawn from a judicious reading of the literature and insights gleaned from conversations with practitioners.

Background

Over the last two decades, addressing corruption and good governance in institutional structures as well as operations has gained significant traction in international organisations across the world, including multilateral and bilateral development agencies (Kohler and Bowra 2020: 2, OECD 2018: 4; Biscaye 2017).

This focus on strengthening integrity systems is motivated by the fact that corruption directly undermines the ability of these agencies to achieve their development goals, by “fuel[ling] inequity as it skews how resources are allocated and distributed” (Kohler and Bowra 2020: 2).

Multilateral vs Bilateral vs Multi-bi assistance

When it comes to the disbursement of aid, a distinction can be made between (Biscaye 2017; Kilmister 2016):

• bilateral aid: involves the transfer of overseas development assistance to entities in aid-recipient countries by individual bilateral donors
• multilateral aid: is allocated by bilateral donors to multilateral organisations such as the World Bank or United Nations agencies, which then go on to disburse this aid for developmental purposes.

Overseas development assistance can be provided in various forms by donors, ranging from budget support, to projects implemented directly by donor agencies in-country, as well as financial and technical assistance to non-state actors such as civil society organisations. Development assistance now frequently takes the shape of multi-stakeholder partnerships that can include bilateral and multilateral agencies, along with civil society and private sector partners. The idea behind such initiatives is to make best use of the “knowledge, expertise, resources and capacities of all development actors” for better outcomes (USAID 2018).

It is important to note that bilateral donors and multilateral organisations share a common objective “to achieve development results from the funding they provide and the programmes they implement” (OECD 2018: 3). Some multilateral institutions even have a specific commitment to anti-corruption. For instance, the African Union established an Advisory Board on Corruption to support "Member States in the sustainable implementation of the AU Convention and the fight against corruption in Africa" (AU n.d.). However, they differ in terms of their respective priorities, aid disbursement modalities, institutional structures, and accountability mechanisms, among others.

There is little consensus in the literature over the respective advantages of bilateral and multilateral development assistance. A study by Davies and Pickering (2015: 46) submitted to the OECD Development Assistance Committee (DAC) finds that aid recipients “want development assistance, in no matter what form” to be able to support the achievement of their national priorities; and while multilaterals are frequently viewed as “very important, high-quality providers”, in a bid to spread risk, aid-recipient countries are increasingly seeking to diversify sources of assistance from a range of bilateral agencies.

Gulrajani (2016: 16) lists the comparative merits of the two channels by looking at the strength of evidence for six common claims as shown below (Source: Gulrajani 2016: 16):

Multi-bi aid flows that involve bilateral donors allocating funds to multilateral organisations that are earmarked for particular purposes offer an opportunity to combine both channels (Biscaye 2017).

While globally 30% of aid is disbursed multilaterally, as of 2018, 15% of all allocated funding to multilateral organisations by DAC members’ official development assistance (ODA) was earmarked (Bosch et al. 2020: 2; Biscaye 2017).

Earmarking is reportedly contributing to the “bilateralisation” of multilateral institutions (Gulrajani 2016: 17). Such practice fuels concerns around fragmentation of the multilateral system, shifting focus away from “strategic priorities set by their broad membership” and undercutting “broad-based governance” (Bosh 2020: 2). Gulrajani (2016: 19) notes that, while multi-bi aid “may be a response to perceived inefficiency and waste in multilateral institutions”, it does not always perform efficiently. In fact, multi-bi aid can also worsen problems of efficiency by “overwhelming multilaterals with unpredictable finance flows”. Moreover, such a practice “incentivises mission creep” and “disparate decision-making” while encouraging the increase of administrative burdens, which can result in the depletion of multilaterals’ core administrative resources.

There are also other effects of earmarked funding being felt across institutions. For instance, Weinlich et. al (2020: 5) notes that “a gap has evolved between how organisations are supposed to operate and how earmarking practices push them to operate. Earmarking makes them less strategic and independent, and more commercial and donor oriented.”

However, experts believe that there are knowledge gaps on “the variety of earmarking modalities and their respective implications” which are connected, in part, to the “limitations of existing statistics on aid flows and the absence of recognised benchmarks” (Bosch 2020: 3).

A few recommendations by Barder et al. (2019: 23), on mitigating some of the challenges posed by earmarking include:

• Donors using multi-bi modalities ought to be “encouraged to route all their new contributions through multilaterals’ core funding mechanisms and their governance processes”, while multilaterals should ensure that the new programmes are in sync with core policies.
• Donors to core funds should be offered more “systematic, persuasive and specific ‘virtual earmarks’ to satisfy their domestic needs for attribution and visibility”.
• When it comes to information on multi-bi financing, multilaterals should publicly make information available to the “same standards of transparency as they do for core funding”.

Corruption and multilaterals: need for integrity management

The United Nations Joint Inspection Unit conducted a study in 2016 looking into corruption and fraud in UN agencies and identified risks including but not limited to “procurement, contract management, human resources management, programme and project management, financial management, entitlements and the selection and management of third parties” (Bartsiotas and Achamkulangare 2016: 3). UN system organisations were found to be “exposed to high risks” particularly because of their dependence on third parties (i.e., vendors, suppliers and implementing partners) for programme delivery. The risk exposer was deemed to be greater when operations were set in fragile environments and remote project sites. The report also found that existing controls, as well as accountability and management systems, in most cases, did not “match the high risk of fraud and corruption found in such environments”. (Bartsiotas and Achamkulangare 2016: 22).

Often times a “zero tolerance” policy towards fraud and corruption is adopted by several donor agencies (including UN agencies such as UNDP) which has several benefits including setting a tone from the top, creating a deterrent effect, and showcasing the resolve of the organisation to fighting corruption by all means (Bartsiotas and Achamkulangare 2016: 22). Zero tolerance also shows to “domestic audiences in donor countries that misuse of development aid will not be accepted” (De Simone and Taxell 2014: 1). However, in reality, there are several challenges to implementing a zero-tolerance strategy such as arbitrary application of the policy, creation of disincentives to reporting amongst project beneficiaries, third party vendors, and staff, disproportionate burden of compliance on smaller contractors and/or NGOs, and donors can lose credibility if they lack the will or capacity to investigate and prosecute all cases of corruption (De Simone and Taxell 2014: 1). Thus, implementing such a policy in “certain environments” can even become “impractical or cost prohibitive” (Bartsiotas and Achamkulangare 2016: 22).

Recognising both the practical constraints of the zero-tolerance concept and the fact that corruption is unacceptable, Strand (2020) suggests that it is possible to adopt a “scaled approach” to apply the idea in a way where the “do no harm” principle is still respected. Making this approach work in practice requires that partner organisations must be willing to identify or admit to corruption (either alleged or suspected), following which the scale and type of corruption challenge would be assessed. Then, based on the findings of the investigation, the degree of response from the donor end could be decided (i.e., extent to which an organisation’s funds can be frozen) (Strand 2020).

UN agencies for instance, acknowledging such operational realities and constraints, address “fraud tolerance in the context of fraud risk management”. Therefore, such declared risk appetite levels “provide guidance for appropriate risk tolerance levels in certain environments” (Bartsiotas and Achamkulangare 2016: 22).

Moreover, compared to bilateral donors, multilaterals sometimes display a high-risk appetite, operating large-scale activities via complex mechanisms in precarious settings. Thus, they can be at greater risk of exposure to an array of integrity challenges, including fraud and corruption, which are often underreported (Jenkins 2016: 3). Hence, well-designed integrity mechanisms are crucial for multilateral organisations.

Integrity management systems

While there is a broad consensus on the need for multilateral organisations to establish robust integrity management systems, there is no “one size fits all” system that would cater to the various requirements of different organisations that work in distinct institutional, strategic and operational realities. Thus, this paper aims to set out core functions of integrity management systems that should be reflected one way or another in each organisation. The exact form for each of these functions can be customised to the needs of the multilateral in question as well as the context in which they operate.

In addition, this paper attempts to provide illustrative examples of potential entry points for communication and coordination between bilateral donors and multilateral organisations for each of the various core integrity functions discussed below. These examples are not meant to be comprehensive or exhaustive.

Given that a previous Helpdesk Answer has assessed multilateral development banks’ (MDBs) approach to integrity management, this paper prioritises examples from other types of multilateral organisations.

Recommendations for integrity mechanisms

Various bodies have established recommendations for integrity management that are relevant to the work of multilateral organisations.

The Institutional Integrity Initiative by the United Nations Office on Drugs and Crime (UNODC) sets out certain recommendations for the UN System Chief Executives Board for Coordination (CEB) to guide the incorporation of the principles of the United Nations Convention against Corruption (UNCAC) into the UN system (including its numerous subordinate agencies).

These are as follows (UNODC 2015: 11):

• Development of thorough anti-corruption systems based on a “full assessment” of the corruption risks faced by each organisation.
• Ensure that there are entities within each institution with a clear mandate to prevent, detect, investigate and respond to corruption. Moreover, these bodies ought to be provided with the due independence, training and resources to adequately equip them to carry out their functions.
• Adopt suitable procedures for the selection of staff in positions considered particularly vulnerable to corruption.
• Staff ought to be given access to independent, confidential ethics advisory services to enable ethical conduct as specified by organisational policies, while preventing, mitigating and remedying conflicts of interest.
• Mechanisms for reporting corruption in organisations should be simplified.
• Public reporting on corruption risks as a part of the organisations’ information disclosure policies ought to be considered.

While these recommendations were designed specifically with UN agencies in mind, they provide broad guiding principles for multilaterals outside the UN system.

The Recommendation of the Council for Development Co-operation Actors on Managing the Risk of Corruption issued by the OECD (2016) includes the following elements:

• Code of conduct or equivalent for all concerned officials, which clearly establishes expected standards and practices of behaviour with regards to corruption.
• Availability of ethics or anti-corruption assistance/advisory services to guide and support day-to-day operations.
• Training and awareness raising on anti-corruption, including on the topic of ethics. Such training also ought to be arranged for locally engaged staff in partner countries.
• Audit and internal investigation that includes both internal and external audit services that comply with international standards.
• Multi-level assessment and management of corruption risks in an “active, systematic, on-going manner”.
• Ensure that donor funding is complemented with sufficient measures to prevent and detect corruption.

These international standards and benchmarks for internal integrity management systems can be distilled into five core principles: a) prevention; b) detection; c) investigation; d) sanctions; e) disclosure. The remainder of the paper treats each in turn.

a) Prevention

Prevention is the first step in managing corruption risks in multilateral operations. Preventive measures ought to be customised to the context at hand. Diagnosing the nature, forms and extent of corruption a multilateral organisation faces is key to the success of its mitigation strategy. Diagnostic tools can include political economy analysis, stakeholder mapping, corruption risk assessments and other forms of evidence gathering, including commissioning further background studies and research.

Political economy analysis (PEA)

The success of anti-corruption interventions depends on not just internal factors but also the external environment in which they are implemented. A few features known to affect such measures include the quality of local accountability structures (Brautigam 1992: 21; Grimes 2013), the state of the rule of law in the aid-recipient country (Mungiu-Pippidi and Dadašov 2017), the extent of media freedom (Brunetti and Weder 2003) as well as free and competitive elections for public office (Winters and Weitz-Shapiro 2013).

Against this backdrop, ex-ante political economy analysis (PEA) is crucial to understand the environmental factors and the integrity risks to which multilateral organisations are exposed. These assessments are typically conducted before engaging in a new partner country or launching a new programme of work. They can also be conducted at sub-national or sectoral level and are worth revisiting periodically to reconsider initial assumptions in light of political developments. In any case, once a clear evidence base has been marshalled, this serves to inform the development of the proposed interventions, by pointing to existing loopholes in the anti-corruption framework, key weaknesses and vulnerable sectors or processes, potentially hostile actors and corrupt networks, as well as opponents of reform within the government and state institutions.

This analysis can also be used to stress-test existing preventive functions, such as risk management systems, due diligence procedures and operational guidance on minimising exposure to corruption.

When it comes to PEA, the conducted research can also be made public. This is so that the research not only benefits the understanding of multilaterals but also provides for open debate while simultaneously driving up the quality and transparency of the analysis.

Historically, there has been only limited sharing of PEA findings between donor agencies. Fisher and Marquette (2013: 14) reported that even institutions committed to knowledge sharing did not always do so with PEA studies. For instance, staff from the World Bank reportedly deployed several strategies so as to not release PEA documents. One such method is “classifying PEA studies as ‘drafts’ – to render PEA reports ineligible for publication under the organisation’s wide-ranging information-sharing regime” (Fisher and Marquette 2013: 14).

However, another example from the World Bank 2017 piece on World Development Report: Governance and the Law, which proposes means to conduct analysis about the set of reforms that can be realistically accomplished, can be used as inspiration for supporting with the conducting of such research.

In practice, while information exchange has gone some way in recent years to establish common donor responses in the wake of corruption scandals, little headway has been made in terms of joint political economy analysis or mutual policy development forums (Jenkins 2017: 20-23).

An evaluation of anti-corruption efforts commissioned by several donors found that even mapping exercises of development agencies’ respective activities in the governance field are rarely undertaken (SIDA 2012: 57).

Corruption risk management

The political economy analysis discussed above can also serve as the first diagnostic step in risk management systems. Indeed, the UNODC’s Institutional Integrity Initiative recommends that UN agencies conduct thorough risk analyses specific to the particular operational conditions as a prerequisite to curb corruption in multilateral operations (UNODC 2015: 11, 19). Similarly, Disch and Sandberg Natvig (2019) observe that there should be “active, systematic, on-going multi-level assessment and management of corruption risks.”

Following comprehensive risk analysis, appropriate mitigation measures have to be designed and implemented alongside a means of monitoring the effectiveness of these measures. When it comes to multilaterals’ programming, corruption risk management ought to be a “reiterative activity” taking place throughout the life cycle of a project (Johnsøn 2015: 19). Moreover, successful corruption risk management, instead of focusing on a single integrated solution, entails a multitude of “smaller solutions that address specific risks effectively” (Johnsøn 2015: 13). A few anti-corruption tools highlighted by Johnsøn (2015: 16) that could be applied (especially during the programme design phase) include:

• due diligence (see also below)
• corruption measurements and indices at sector and institution levels
• value chain analysis, vulnerability to corruption assessment
• political economy analysis at sector and institution levels
• public expenditure tracking surveys
• community monitoring
• quantitative service delivery surveys

For further details on corruption risk management approaches in development, see Johnsøn (2015) and Jenkins (2016).

Looking at a risk management body within a multilateral organisation, the example of the Office of Compliance, Risk Management and Ethics (CRE) created in 2014 within the World Health Organisation (WHO) can be considered. Its key features include (WHO 2021):

• confidential ethics advice
• promotion of ethics awareness and education
• promotion of ethics standards
• protection of staff from retaliation for reporting wrongdoing
• administration of declarations of interest for staff and external experts
• authorisation of external activities

Due diligence

Due diligence processes and screening of potential third parties and partners is another key prevention strategy for multilaterals. Given that multilaterals engage with and fund a variety of stakeholders often from high-risk environments, due diligence in the screening of third parties (and integrity checks during multilaterals’ own hiring processes) can help to identify potential integrity issues before the formalisation of a partnership (Bartsiotas and Achamkulangare 2016: 22). Good practice suggests that due diligence should be carried out at regular intervals even after a formal arrangement, such as a contract being signed, as this enables continuous scrutiny and risk management (Bartsiotas and Achamkulangare 2016: vii).

For instance, the Intergovernmental Authority on Development (IGAD) revised its grants manual in 2020 to set out due diligence criteria for applicants for awards of more than US$300,000. The conducted due diligence not only considers financial records and audit reports but also focuses on organisational structure and managerial capability to successfully complete the work for which it has been awarded a grant (IGAD 2020: 27).

Operational guidelines for anti-corruption

Organisational guidelines supporting increased transparency, accountability, participation and oversight are key components of integrity management frameworks.

The United Nations Environment Programme (UNEP) has comprehensive anti-fraud and anti-corruption guidelines (2020). A few defining features of the guide include (UNEP 2020: 2-11):

• lists definitions of fraud and corruption
• delineates a “zero tolerance policy” applicable to its staff, other UN personnel and third parties
• assigns specific roles and responsibilities to those tasked with dealing with fraudulent or corrupt acts. For example, the UNEP executive director is to set a culture of integrity in the workings of the entire organisation, among others. The Corporate Services Division is tasked with the implementation of the guideline, and it conducts preliminary assessments of complaints of alleged fraudulent acts and carries out fact-finding investigations (the Office of Internal Oversight Services does this internally).
• sets out high standards and codes of conduct for staff as well as non-personnel and third parties engaging with UNEP, including provisions for dealing with conflicts of interest
• similarly, for third parties participating in a procurement process, they are to abide by the UN Supplier Code of Conduct. Compliance is also required for standards of ethical conduct regarding fraud and corruption, conflicts of interest, gifts and hospitality, and post-employment restrictions
• for implementing partners, not only do they have to abide by the aforementioned anti-corruption codes of conduct but also have to ensure that the third parties they engage with do so as well
• conducts corruption risk assessment and setting specific internal controls
• provides anti-corruption training and toolkits
• while UNEP staff have the duty to, other UN personnel and third parties are strongly encouraged to report on acts of fraud or corruption
• sets out detailed procedures for conducting preliminary assessments and carrying out investigations
• donors are notified of any suspected fraudulent acts relating to the use of their funding in the implementation of projects as soon as UNEP receives a preliminary complaint and at the stage of issuance of the report on the complaint
• incorporates whistleblower protection
• includes provisions for anti-money laundering actions
• focus on systemic sharing of learning within the organisation

b) Detection

Preventive measures can only go so far. As such, detecting integrity incidents that may arise is also crucial to mitigate and remedy the situation. Two major tools that facilitate detection include reporting by whistleblowers and monitoring by the organisations themselves.

Whistleblowing

A UN joint inspection unit report looking at workings of UN agencies found that whistleblowers are responsible for uncovering more fraud and corruption than all other measures of detection combined (Bartsiotas and Achamkulangare 2016: viii).

However, mechanisms to enable reporting by ensuring effective safeguards for whistleblowers differ between organisations, with implementation in some being particularly patchy. For example, not all UN agencies make their whistleblower provisions readily available on their external websites (Bartsiotas and Achamkulangare 2016: 44). Evidence also points to a systemic issue within the UN as there have been reports of staff who have blown the whistle on fraud and corruption being subject to harassment in the form of denial of promotions/employment extensions, retroactive revocation of whistleblower status and at times even the loss of their jobs (Maslen 2022: 1).

Despite this, many multilateral organisations operate a whistleblowing hotline, including the Food and Agriculture Organisation (FAO), World Food Programme (WFP), World Intellectual Property Organisation (WIPO), International Fund for Agricultural Development (IFAD), and the United Nations Population Fund (UNFPA). Information on such hotlines is also publicly available on their websites (UNODC 2015: 61).

A few good practices for whistleblower hotlines are as depicted below (Source Bartsiotas and Achamkulangare 2016: 45):

Importantly, whistleblowing and reporting mechanisms ought to be sensitive to gender differences, especially to facilitate reporting with gendered forms of corruption, such as sextortion (Zúñiga 2020: 1). Online platforms and hotlines are examples of whistleblowing processes that allow for reporting to be done both conveniently and in some cases, anonymously, especially for cases of gender violence linked to corruption. Other measures include fomenting gender sensitivity in institutional culture and collaborations with women’s organisations to gain better understanding and of how to handle particularly sensitive cases (Zúñiga 2020: 8).

For a more comprehensive overview of whistleblower protection in the UN system, see Maslen (2021).

Monitoring, evaluation and learning (MEL)

Monitoring and evaluation systems embedded in development projects may yield significant amounts of policy-relevant data that could provide insights into corruption risks, both within and outside organisations. Until recently, however, there was a lack of common monitoring and evaluation standards that could facilitate the collection of comparable data, which inhibited inter-organisational learning (Trapnell 2015: 18). Encouragingly, the OECD DAC Network on Development Evaluation (EvalNet) has recently set out six evaluation criteria for development assistance – relevance, coherence, effectiveness, efficiency, impact and sustainability (OECD 2021).

Proactive monitoring of a development project can also serve various purposes, from assuring donors of the success and viability of projects to supporting with identifying misconduct and highlighting areas needing more stringent anti-corruption controls (OECD 2018: 4; Smith 2021).

In fact, as part of the new US focus on corruption in the context of its overseas development aid, it has placed monitoring “the efficacy of assistance” at the heart of its new strategy on countering corruption (White House 2021).

Often a key challenge faced by bilateral donors relates to the monitoring of their financial contributions to multilaterals as donors have varying institutional arrangements for managing the terms of their engagement with multilaterals. Bilateral donors conduct individual assessments of the multilateral bodies they support, usually in the form of desk reviews. Nevertheless, this process can involve large burdens on the multilateral organisation being reviewed due to the primary data collection involved at their end (OECD 2018: 3-4).

One good practice in this regard is ongoing proactive transparency around multilaterals’ budgets and expenditure. Open budgets would not only support a bilateral assessment of their financial contributions to multilaterals but would also serve as an important accountability tool for affected communities, civil society organisations, journalists and so on. UNFPA, for instance, makes available their past expenditures and future allocations for each outcome area that they are working towards.

To enable monitoring of the performance of multilateral development organisations at the national level, a conglomeration of “like minded donors” established the Multilateral Organisation Performance Assessment Network (MOPAN) in 20027ef76036e8bf. MOPAN assesses results of multilateral projects against four key performance indicators (KPIs) “measuring the level of achievement as well as the relevance, efficiency and sustainability of the results achieved” (MOPAN n.d.; OECD 2018: 4).

However, MOPAN is described as serving a “accountability or compliance function” (for instance showing that taxpayer funding channelled via multilateral organisations provides adequate returns) better than a “learning or self-improvement function” (for example that are directed at improving multilateral organisations, either through “members engagement in the organisations’ boards” or via “direct support to internal change effort led by management”) (OECD 2018: 5).

Nevertheless, such monitoring mechanisms still provide an insight for integrity controls. For example, findings from a results-based management review of the Global Environment Facility (GEF) showcased several gaps requiring action, such as a “lack of a clear theory of change, long duration of the feedback loop, need to incorporate the relevant SDG indicators in its results-based management framework, lack of focus on the most strategic information, gaps in tracking tools, poor quality of information, and need to adapt to the growing expectations from the partnership” (OECD 2018: 6).

The trend towards the remote monitoring of development projects has accelerated the response to the ongoing COVID-19 pandemic, which can complicate efforts to detect fraud and corruption. This could potentially be mitigated through the use of reliable data and local knowledge in remote monitoring, although gathering local knowledge in a remote monitoring setting is a challenge in itself as this data is not readily available in English, or in written reports (SDC 2019: 10). Nevertheless, a list of tools that can help facilitate remote monitoring include (SDC 2019: 11-13):

• remote context analysis
• creating a bespoke remote monitoring toolbox using a mix of:
  – field visits
  – remote contact with partners/ partner meetings
  – partner reports and data
  – third-party monitoring
  – GPS photos and video
  – tablet based GPS surveys
  – call centres
  – remote sensing
  – web surveys, WhatsApp, Skype
  – text messaging
• having written guidelines, share lessons learned and enabling peer support across organisations

For example, third-party monitoring (TPM), as one component of remote monitoring initiatives, has been used by a variety of multilaterals and bilateral development practitioners. USAID spent roughly US$9 million to support TPM in complex emergencies in 2017. WFP spent almost US$3 million on TPM contracts across the Middle East North Africa (MENA) region in 2015-2016 (SDC 2019: 3).

c) Investigations

Once an integrity lapse has been detected, good practice requires thorough investigation and consequent action against the perpetrators (Smith 2021). Investigative functions in multilateral settings can be housed in specific units within the institution (as is also recommended by UNODC [2015: 11]).

In terms of conducting the investigation, it can be done upon the receipt of a report or in a proactive manner. Such proactive reviews are separate from general investigative procedures in the sense that they provide checks and quality control for ongoing projects (especially those known to be high risk) (Smith 2021).

Bartsiotas and Achamkulangare (2016: xii) recommend that multilateral organisations establish key performance indicators for the conduct and completion of investigations as well as to ensure that their investigative capacities are commensurate with the level and complexity of risk.

Internal and external audit functions also serve as a key investigative, compliance and assurance tool.

At UN Women, for example, the Independent Evaluation and Audit Services (IEAS) oversees “independent evaluation, internal audit assurance, and advisory services relating to UN Women’s programmes, controls, business systems, and processes” (UN Women 2020). Governed by its charter, IEAS also provides good practices and recommendations for improvement. IEAS is supported by two other bodies (UN Women 2020):

• Independent Evaluation Service: providing systematic and impartial assessment of interventions with respect to the overall goals of UN Women
• Internal Audit Service: working as an independent, objective assurance and consulting service for UN Women

Apart from the IEAS, other instruments providing integrity support to UN Women include the United Nations Board of Auditors, UN Office of Internal Oversight Services (OIOS), UN Ethics Office, Advisory Committee on Oversight and the accountability framework (UN Women 2020). The OIOS provides investigation services to UN Women on cases related to allegations of fraud, corruption or any other wrongdoing by personnel or third parties (UN Women 2018).

The UN Women anti-fraud policy framework (2018) sets out three lines of defence in integrity management, of which the third is purely focused on the role of investigative functions (UN Women 2018: ):

1. Implementation and management of fraud prevention and detection controls designed to manage potential risks that may expose the organisation to fraud.
2. Quality assurance and risk management to provide oversight, assess governance structures and make recommendations on mitigating fraud risks.
3. Internal and external audits carried out at regular intervals to prevent and detect controls to manage fraud risk. Moreover, the investigative function “is responsible for receiving, analysing, and investigating all information received on alleged cases of fraud” while simultaneously feeding findings from these investigations back into the fraud prevention activities.

e) Sanctions

The realistic and likely prospect of being sanctioned for corrupt behaviour is an important part of tipping incentive structures (and individuals’ risk-reward calculus) in favour of integrity.

Sanctions regimes are a reactive apparatus generally focused on the supply side of corruption, such as external partners and suppliers (Rahman 2020: 4). While differing considerably between organisations, they penalise those known to violate integrity practices and act as a deterrent for future acts of corruption.

The African Union (AU), for example, in dealing with corrupt entities in procurement processes, uses a declaration of suspension for them, by which they are rendered ineligible to submit bids. Recent calls for tenders in the AU have been issued with special measures to deal with fraud and corruption. Any collusive, coercive or obstructive corrupt practices by bidders in winning AU tenders results in the rejection of contract awards (AU 2021: 27-18).

Debarment lists/sanctions lists/blacklists which prohibit known corrupt entities from partaking in future public procurement processes due to past misconduct are also becoming more common at the multilateral level (Rahman 2020: 3).

At the United Nations Office for Project Services (UNOPS), there is a zero-tolerance policy against vendors that engage in corrupt, fraudulent, coercive, collusive or unethical practices. All vendors sanctioned by UNOPS feed into the UN Ineligibility List, which acts as a central roster for sanctioned entities available to UN agencies participating in the programme (UNOPS 2022). The entries in the UNOPS ineligibility list can be found here.

A good practice example in use of cross-debarment lists come from the multilateral development banks, wherein the World Bank Group, Asian Development Bank (ADB), European Bank for Reconstruction and Development (EBRD), Inter-American Development Bank (IDB) and African Development Bank (AfDB) have agreed certain criteria for the debarment of firms and individuals (Rahman 2020: 4).

f) Disclosure

Disclosing information on corruption cases can play an essential role in integrity management systems to “prevent, deter and sanction fraud and corruption in the use of development assistance funds” (Chêne 2019: 1). It can also help other donors to identify patterns or hotspots of corruption and better safeguard their own operations.

Nevertheless, there is a great discrepancy in disclosure practices across multilaterals. Most development agencies disclose general information online such as operational statistics on the function of integrity units (such as the number of complaints received, investigated and substantiated) and annual reports.

For instance, the United Nations Development Fund (UNDP), “is committed to making information about its programmes and operations available to the public” (UNDP 2020). It proactively discloses information on country programme management (including country analysis, work plans, social and environmental screenings, assessments) and reports on their operations (such as procurement, internal audit, finances, disciplinary measures in response to corruption and fraud, among others). UNDP also has a transparency portal which contains information on all of its projects.

As mentioned in the previous section on sanctions, debarment lists also make the details of corruption offenders public, which in turn benefits due diligence processes in other organisations.

However, when it comes to disclosure of corruption cases by multilaterals, there is limited information in the public domain except those reported in the media, such as the recent revelations about corruption in GEF climate projects (White and Hook 2020).

One good practice example comes from MDBs. All closed cases and a list of all debarred and cross-debarred firms and individuals, including the name, address and country of the sanctioned firm or individual is made publicly available by the World Bank and the Inter-American Development Bank (IADB) on their website (Chêne 2019: 3).

In fact, when it comes to external disclosure, the World Bank’s access to information policy “is based on the principle that [it] will disclose any information in its possession that is not on its list of exceptions” (Chêne 2019: 7). On disclosure of corruption cases, IADB states that “Notices containing the identity of a sanctioned party and the sanctions imposed on a firm, entity or individual by the Bank’s Sanction Committee shall be published by the Office of Institutional Integrity (OII) no later than five (5) working days after the bank has notified the sanctioned party, the decision of the Committee” (IADB 2010).

In terms of information sharing between bilateral donors and multilateral agencies, practices vary depending on the agreement between them as well as the disclosure policies of individual multilaterals. For example, in the aforementioned case of UNEP, bilateral donors are notified of any suspected fraudulent acts in projects they funded and are given reports on the outcomes of such investigations (UNEP 2020: 9).