The complex anti-corruption landscape in Cambodia

The terms of engagement for Cambodian non-state actors have changed radically over the past decade. Following the 2013 general election, civil society entered ‘a new and critical phase’,c303b68db12e as legislation passed in 2015 and 2016 increased the regulation of non-governmental organisations (NGOs) and trade unions. The broad political shift to hegemonic authoritarianismba0f2a96285e – signalled by the dissolution of the main opposition party in 2017 (the Cambodian National Rescue Party) and the election of a one-party parliament in 2018 – hailed a new phase of government hostility towards civil society, with prominent leaders accused of supporting the outlawed opposition.

This shift has prompted non-state actors to explore new strategies for engaging with the government. The most common approach has been to avoid confrontation and sensitive issues, and to work more closely with the government.ad3a964e9e80 Some donors have favoured this strategy, and encouraged civil society to pursue constructive engagement.16f28c81cb15 Donors themselves have also been navigating difficult territory: the government has been critical of foreign funding and, since 2017, has maintained that there are collusive connections between international donors, NGOs, and the opposition party (Candlelight Party).

Corruption is a major hindrance to human rights and development in Cambodia, with different impacts according to age and gender.707411e73dc2 In 2023, Transparency International placed Cambodia 158th out of 180 countries in the Corruption Perceptions Index.3214869f7b52 The government has embarked on reforms such as the Public Financial Management Reform Program (PFMRP) and public administration reform, but there is a lack of political will to eradicate corruption more broadly. Recent anti-corruption initiatives, such as an anti-money laundering law requiring scrutiny of NGO finances,d1cc500574ef have in fact consolidated power in the hands of the ruling Cambodian People’s Partyfb7c737ad8ab and targeted civil society.

Donors have supported anti-corruption activities in Cambodia over the past 10 years through collaborations with authorities and with non-state actors. An example was the Partnership for Accountability and Transparency – a supplementary programme to the EU’s sector budget support for the PFMRP during 2016–2022 – which included assistance through collaborations with authorities, as well as core support to Transparency International Cambodia (TIC). Sweden placed a particular focus on collaborations with non-state actors and in 2020 decided to work only with non-state actors. However, in December 2023 the Government of Sweden decided to phase out bilateral development cooperation with Cambodia by the end of 2024. The Swedish withdrawal leaves a gap in the support of anti-corruption work through non-state actors in Cambodia – a gap that other development partners must fill, preferably in a sustained and coordinated manner. The end of financial support to key non-state actors, including TIC as the only civil society actor entirely dedicated to anti-corruption, will likely lead to a significant restructuring of many organisations and in some cases possibly even their collapse.

Following the general election in July 2023, a broad generational transition took place in government, with Hun Manet succeeding his father, Hun Sen, as prime minister and an accompanying swathe of new ministerial appointments. This raises the questions of whether this change opens new opportunities for anti-corruption work, and if so, how. The purpose of this U4 Issue is to analyse how non-state anti-corruption work is best supported going forward, and to identify potential synergies for joint anti-corruption work between development partners taking a collective action approach.

Methods and approach

The aim of this U4 Issue is to suggest avenues for innovating anti-corruption approaches, by identifying opportunities for practitioners engaging in anti-corruption work (the range of approaches to tackle corruption), and possible synergies for development partners in supporting such work.

The research questions are:

1. Since the shrinking of civil society space, what roles do non-state actors play in tackling corruption and what room have they had to push their claims?
2. What anti-corruption work is done by non-state actors, including civil society organisations (CSOs), media, think tanks, researchers, and development partners (UN agencies and donors)? Where are the gaps and opportunities?
3. How can anti-corruption work in Cambodia through non-state actors be supported?
4. Where are the opportunities going forward, according to non-state actors and development partners, considering lessons learned, as well as broader contextual domestic and international factors?
5. What are the plans and priorities for anti-corruption work among development partners, and where are there potential synergies for joint anti-corruption work between those partners? Are there potential synergies with the government’s national plans and policies?

The first part of this research involved 24 interviews with non-state actors and development partners involved in anti-corruption work in Cambodia. Non-state actors were asked to identify what they see as opportunities for practitioners engaging in anti-corruption work, and what kind of support these would require. Development partners were asked about their plans and priorities for anti-corruption work, and to reflect on potential synergies for joint anti-corruption work. Both groups were asked for insights and perspectives on how donors can best manoeuvre in the present context, focusing on what types of actors and spaces to target for action.

Second, a literature review was carried out to analyse the situation for anti-corruption civil society since 2018, focusing on recent academic literature on Cambodian civil society as well as that on civil society under authoritarianism.

Third, internal briefs and organisational documents were also consulted for the charting of ongoing and potential anti-corruption work.

The role of Cambodian non-state actors in tackling corruption since 2018

Cambodian civil society has been a ‘shrinking space’ since at least the 2013 general election and the near defeat of the ruling Cambodian People’s Party (in power in different guises since 1979). In 2017, the president of the main opposition party was arrested on charges of treason and the party banned over government allegations that the party, together with foreign-funded NGOs, had sought to carry out a ‘colour revolution’ to topple it. Absent genuine political party competition, civil society became the proxy political front line, and faced deep suspicion and distrust from government. Advocacy NGOs in particular have been targets of state surveillance, and had their political neutrality monitored,5408c011247e while service delivery CSOs remain tolerated.

The government has employed mixed tactics towards civil society, combining repression (legislation such as the 2015 Law on Associations and Non-Governmental Organizations (LANGO), arbitrary detention of activists, and violence) and co-optation. Co-optative tactics have included the creation and increasing prominence of government-operated non-governmental organisations (GONGOs), including youth organisations functioning as vehicles of state mobilisation;d1ac8698f27d the creation of think tanks and research centres, which have efficiently come to dominate policy debate and academic discourse; and the appointment of some high-level CSO leaders to government positions. The Civil Society Alliance Forum, set up under the Office of the Council of Ministers in 2016, regularly brings CSOs together with local authorities in provincial forums to promote cooperation. Technical Working Groups (TWGs) operate at the line ministerial level, with CSOs as observers (more rarely as full members) and are viewed by some as a co-optation mechanism. Recently, A Roadmap for Government and CSO Engagement and Relations has been drafted by CSO leaders close to the government, calling for the establishment of ‘regular platforms between Government and CSOs’ on the provincial, ministerial, and prime ministerial level.ea5ab5208fed

The government’s strategic emphasis on co-optative measures is in line with a general preference of autocratic regimes for co-optation over repression, for instance by involving CSOs in policy consultations. These narrow measures give CSOs hope that they will be able to influence policymaking, but research in other contexts has found that their impact is usually limited.e1734a001b29

As we have seen, CSOs responded by modifying their engagement strategy, tending to avoid confrontation and sensitive issues, and to work more closely with the government.3a49df5dd05c In a study of how Cambodian CSOs reacted to the government’s repressive and co-optative strategies in 2017–2022 (based on interviews with Cambodian CSO representatives in late 2022) the author found that many CSOs ‘strategically allowed themselves to become co-opted by the regime to avoid repression and exert a limited measure of social and political influence in a context where more confrontative approaches would endanger their organisational survival’.40c7bb199295

The non-state actor community engaging in issues related to corruption mirrors the overall civil society landscape, with a fault line between advocacy and service provision actors. TIC, which approaches corruption from both supply- and demand-side perspectives,82ab885be94f is the main non-state anti-corruption institution in Cambodia, but there is a broad ecosystem of CSOs, think tanks, and media working on related issues through integrity, transparency, and accountability approaches. Advocacy CSOs have, since 2017, continuously tried out different approaches for their work (public advocacy, advocacy online, evidence-based research), to identify which may be acceptable to the government, on a case-by-case basis.

Advocacy CSOs perceive that corruption issues are the most sensitive, as indicated by the 2016 murder of political analyst Kem Ley following his public remarks about an NGO report on high-level corruption. One election watchdog reported that they changed strategies following the election of a one-party parliament in 2018, specifically dropping the parts of their reports which monitored political corruption (government appointments) as this had become too high risk. Leading think tanks have sought to cultivate good relations with the government, in an environment dominated by think tanks set up by the government. CSOs working on service provision have developed their engagement strategies with government, and generally emphasise that these are quite fruitful avenues for addressing issues of corruption. Partnerships between state agencies and CSOs under decentralisation and deconcentration (D&D) frameworks – including the One Window Service mechanism and Implementation of the Social Accountability Framework (ISAF) – have efficiently addressed local-level corruption and been beneficial for grassroots service provision.

Non-state anti-corruption initiatives: Gaps and opportunities in existing partnerships

The non-state space is aptly described by one CSO director as one where ‘there are more doors open, but space is shrinking and funding is shrinking’. This refers to the way in which the new government seeks input on select issues, but the overall space for non-state actors is shrinking and foreign funding is drying up. Non-state actors – facing suppression from the government and a financial drought – perceive an existential treat, whereby without the support of development partners civil society will soon be irrelevant or even extinct. The view of the CSOs interviewed is that the government prefers to engage with CSOs in certain sectors of service delivery, but that it is also open, to some extent, for technical support on anti-corruption to pursue liberal reform. Non-state actors interviewed urge development partners to continue to support them morally and financially, and make the terms of engagement responsive to the challenging context that CSOs operate in.

Non-state actors identify a distance between themselves and development partners, which hampers their anti-corruption work. According to one leading anti-corruption actor, development partners nearly always work directly with the government on key public sector reforms, and there are many areas that civil society ‘cannot touch’. This results in twin ‘gaps’ emerging between development partners and the government on the one hand, and non-state actors on the other: a relationship gap and an information gap, and these affect overall government-driven reform. The government cautiously selects which non-state actors to work with, and approaches others antagonistically. This can cause development partners to distance themselves from those CSOs for fear of a negative impact on their relationship with the government. It is therefore imperative to close the gap between development partners and non-state actors through regular information exchange.

There is no consolidated strategy for open and structured discussions between non-state actors and development partners, which could allow the latter to bring reform priorities raised by non-state actors either directly to the government or to other development partners that work with the government. Development partners can offer recommendations and suggestions without the government feeling they are losing face; this is not always the case when the input comes from CSOs. There was a perception that if development partners want input from non-state actors, they can consult individual representatives prior to their meetings with the government, ad hoc and on demand. The agreement that the EU will host a quarterly meeting between European member states and CSO working groups, as a regular mechanism, was viewed favourably.

The anti-corruption work of development partners was characterised in the interviews as fragmented, lacking coordination, and short-term, while a long-term and joint approach is needed. Non-state actors wish for better coordination between development partners, ideally a joint strategy for anti-corruption work in Cambodia. Several wanted to see a more strategic focus among development partners on supporting local NGOs, which have well-developed capacity and low operation costs. Some wished to see anti-corruption projects spread out to more grassroots and local community actors and involving a greater number of people. Projects, they felt, should be designed to engage and take in ideas and concerns from broader segments of society, including marginalised groups, rather than only a few community representatives. A top think tank representative charged that project objectives in general, including those with anti-corruption scope, were not locally grounded and ‘only practiced and crafted by and among the top fellow white personnel’. According to them, development partners need to engage more with local policymakers, and give authority and ownership to the local organisations they support. Failure to do so makes these partners vulnerable to criticism that they represent foreign interests. Given that local NGOs are sensitive to intimidation from local authorities, development partners should privilege supporting those that have a productive working relationship with local authorities, and support local NGOs through experienced national CSOs that have representatives or local partners at the grassroots level.

In the interviews, development partners were seen as imposing compliance conditions on CSOs that were too restrictive, in terms of checklists of log frames and project delivery. Compliance is onerous as CSOs have budget and time constraints. The lack of core funding was raised (as well as funding for overhead costs), as was the concern that programmatic funding, which is now the main funding mechanism, cannot guarantee the stable operation of CSOs. The public bidding model favours international NGOs (INGOs), to the detriment of local actors. One idea raised was the creation of a trust fund which could offer some funding for local CSOs, working together in different sectors, rather than having NGOs compete for grant proposals, which may weaken their cohesion even among the existing working groups. Indigenous Peoples’ (IP) representatives asked that development partners simplify the funding system to make funds more accessible for IP communities and organisations. Conversely, many CSOs perceive development partners to be lenient on requests for payments by government officials for participating in meetings and trainings, and that some development partners prefer to collaborate with CSOs who aquiesce and do offer such payments to government officials. This has direct consequences for CSOs that do not and whose requests to join events are then more prone to be disregarded by government officials. This calls for an anti-corruption element in all projects and donor coordination on per diem policies.

Many non-state actors see development partners as a bridge between them and the government. Advocacy CSOs requested facilitation and risk mitigation support from development partners in their government interactions. Several asked for more visible moral support for CSOs. They noted from their own experiences that some donors are afraid to support advocacy-oriented organisations out of fear that this may aggravate non-state actors’ problematic relations with the government – but they argued that more support would strengthen rather than undermine them. Development partners should also integrate security considerations for non-state actors – including legal advice, mental health support, and evacuation (in the case of risks to their physical safety) – into projects, as well as back-up funding for staff in case of sudden organisational shutdown. Practitioners also called for whistleblower protection for those who expose corruption cases (eg evacuation).

Some advocacy CSOs requested the creation of consultation platforms, in addition to those set up by the government, that are more open for independent organisations, possibly to be initiated by the UN. Other CSOs wanted development partners to take a step back. It was suggested by a top think tank that the involvement of donors makes the government perceive any agenda, including anti-corruption, as foreign. They advocated privileging direct interactions between non-state actors – who have built relationships and trust with the government – and domestic policymakers. Also, interviewees who were in favour of development partners acting as a bridge between civil society and the government also argued for the value of direct and unmediated interactions between non-state actors and government. A key anti-corruption actor stated that equally important as having a discussion with development partners that the latter then bring to the government is to have direct interaction with the government, through closed-door meetings on specific agendas. Workshops, they stated, have only limited value and can potentially create tensions. Closed-door meetings have so far been valuable for enabling this organisation to give the government input on areas including public procurement and public services, and they are seeking more of this kind of interaction.

There is broad agreement that anti-corruption efforts need to be presented as contributing to government objectives: development partners need to position themselves as working to achieve government objectives through non-state actors. Development partners that do not work directly with the government need to engage state actors through non-state actors and through other development partners. Dialogue with the state party through the intermediary could be made an official objective.

Leading anti-corruption actors assessed that demand-side work in previous decades had been impactful, and that there is great public demand for accountability. The implication was that work on the supply side is currently key, and that work on the demand side should be more strategic. There is a gap – and an opportunity – in more stakeholders working on technical areas at the national level, especially on grand corruption. According to the Global Corruption Barometer 2020,c1ccdf820169 petty corruption has decreased in Cambodia thanks to joint efforts by the government and non-state actors. The proportion of people who reported having paid a bribe over the past 12 months decreased from around 60% in 2013 to 37% in 2020. Currently, there is substantial funding from development partners for non-state actors focusing on service delivery at the subnational level.

The government’s recent approach to anti-corruption and non-state actors

In August 2023, a broad generational transition took place in government after four decades of rule by the same core elites. Of the 28 government ministries, new ministers were appointed to 20 – overwhelmingly the scions of the previous government ministers. The average age of the 28 ministry leaders is around 49 years155acdb49a45 and many are Western-educated PhD holders. Only three ministers are female. The ministerial ranks have swelled from 641 officials (secretaries or undersecretaries of state) under the previous administration to 1,422 officials in the current term,b07c934a617c likely as a means to maintain elite cohesion.

The new government has launched the Pentagonal Strategy-Phase 1 to promote reform of governance, with a focus on strengthening public administration.3308272b7bbd The Pentagonal Strategy-Phase 1 is described as the socio-economic policy agenda of the Political Platform of the Royal Government of the Seventh Legislature of the National Assembly. Together with the Political Platform, it is intended to provide a comprehensive policy framework for formulating the National Strategic Development Plan (NSDP) 2024–2028, Sectoral Development Plans, and other related plans.982bf40b76b0 The Pentagonal Strategy includes five priority sectors, or ‘sides’: public; economic; financial; human and social capital; and environmental and response to climate change. The core of the strategy focuses on governance and the modernisation of state institutions, making them ‘modern, competent, strong, smart and clean …’.b2c2e79cee47 Side 3 of the pentagon includes the ‘enhancement and strengthening of accountability and integrity in public administration’ through five strategies:

• Developing and implementing a code of ethics and professional conduct in civil service and fostering compliance by public officers with the principles of functional incompatibility and conflict of interests.
• Strengthening the effectiveness of inspection and audit mechanisms and creating rules of audit and inspection systems to ensure the harmonisation of inspection and audit functions in public administration.
• Strengthening mechanisms for public service management and deliveries, merit-based incentives, and the adoption of strict legal measures for public conduct and responsibilities to promote trust and to increase the effectiveness of public service delivery.
• Further strengthening and expanding anti-corruption education and corruption prevention efforts, as well as strengthening stringent enforcement of laws to combat corruption.
• Enhancing cooperation between the Anti-Corruption Unit (ACU) and public institutions, especially through a ‘focal person’ mechanism, both in the provisions of anti-corruption education and in the prevention of corruption, to put in place the monitoring, evaluation, and implementation of strategic plans, and plans for promoting integrity in public institutions.5894e90cb8b3

Presenting the five government strategies for combating corruption in public administration to the public, Prime Minister Hun Manet has called on ‘all ministries, institutions, authorities, the private sector and the people’ to support and cooperate with the government and the ACU to combat corruption.a4cff2932623 An ACU spokesman has also announced that the ACU has its own new strategies, which include ‘increasing the number of suggestion boxes in public places and at some state entities’, for citizens to report on corruption.dafc615a6cff

Despite, or perhaps because the new government is dominated by the sons of the previous ministers, a discourse of meritocracy is being strongly pushed by the prime minister. Hun Manet has promised a cabinet reshuffle in 2024, in which underperforming ministers will be replaced. Certain ministries have similarly pledged to fire staff members found to have committed corrupt practices. However, there are competing incentives for the new government regarding corruption. The government seeks to shore up performance-based legitimacy, based on efficient governance and economic development. This necessitates anti-corruption measures but leaves the government vulnerable to business and economic performance risks, as well as reputational risks. At the same time, the political economy of the generational transition needs to be carefully managed.

The Ministry of Interior has embarked on large-scale internal cleansing. In September 2023, incoming minister Sar Sokha suspended all activities of the Cambodian Counter Counterfeit Committee (CCCC) and ordered an internal investigation by the General Department of Inspection of complaints from members of the public over alleged misconduct by National Police officers.b68f7fa510b7 This followed the leaking on social media of a sensitive phone conversation between two high-ranking officials alleging widespread corruption in the CCCC.f2c9d2b05f44 In December 2023, 50 police officers working with the CCCC were reshuffled to work in other departments at the General Commissariat of the National Police, and vice-president of the CCCC, Kem Cheat, was dismissed from his position as undersecretary of state at the Ministry of Interior (after documents alleging he had taken bribes were leaked on social media). As part of the crackdown on criminal offences within the police force, there is an ongoing drug-testing campaign among the National Police, aimed at reducing conflicts of interest in the anti-narcotics department, which has led to the dismissal of officials. In December 2023, Prime Minister Hun Manet instructed the police to implement the law and arrest suspects without waiting for approval from their superiors – ‘even if they are the children of senior [government] officials’, reassuring them that there would be no repercussions.85259880de35 In early January 2024, the Clean Our House (somart pteah yurng) strategy was rolled out, which aims at removing or demoting high-ranking police officers who are ‘not clean’.

Political will among top government leadership is recognised by non-state actors as a key factor for the success of anti-corruption work, especially on grand corruption. A slight majority of non-state actors interviewed saw more opportunities to engage with the new government, whereas slightly fewer thought that it was too early to pass verdict or did not envisage change in a positive direction. Those who saw more opportunities stressed that the new government of young technocrats has more capacity and knowledge and they understand that rampant corruption may pose a risk to their political lives. Incoming ministers are also defining their portfolios. The new government is consequently believed to be more willing to engage on a policy level, though is not open to criticism. This leaves an opportunity for CSOs to pitch policy ideas. According to a prominent think tank, there is an opportunity for many more non-state actors to take this solution-based approach. This requires CSOs to work actively on desensitising issues, to enable them to make suggestions with lower political risk. If pursuing this approach, non-state actors also need to balance this engagement with engaging with the public – selling policy solutions both to ministries and their constituencies. One CSO stated that there is now an opportunity to ‘be part of the solution’ through assisting the government to develop the tools of various mechanisms, and that there are ‘more and more doors opened’. This CSO, in the past, had difficulty engaging with the relevant ministries and inter-ministerial committees, but now has open doors for engagement with the ministry, which welcomes the CSO’s knowledge of local experiences and technical expertise. Yet this service delivery CSO also recognised that although space to operate in this way (proposing policy solutions relevant to the government) was expanding, overall space is shrinking because of the stricter legal requirements for NGOs and the government’s strong grip in holding them accountable to the law. Other non-state actors point out that lower-level civil servants, who benefit less from corruption, could also become a part of the movement for change within the state.

Ministries that were mentioned during the interviews as being open for engagement and policy suggestions included the ministries of Interior and of Economy and Finance (both on a few select areas); Justice; Agriculture (though some actors were now less able to carry out policy dialogue there); Transportation; Civil Service; Education, Youth and Sports; Health; Environment; Science, Technology and Innovation; and Rural Development. Among these, the Ministry of Interior and Ministry of Justice were identified as those with the strongest and most visible political will for anti-corruption, with the Ministry of Justice being stronger on planning, and Ministry of Interior being stronger on implementing actions. The prime minister was also identified as open for engagement.

Another group of non-state actors interviewed stated either that there had not been much change in their interactions with the government, or that more time was needed to judge the possibility of engagement. They pointed to continued restrictions on CSOs, the shutting down of independent media, and arrests of activists.

The new government maintains China as its closest political and economic ally. At the same time, it seeks to avoid having to choose between China and Western allies. China is Cambodia’s largest donor and source of foreign direct investment. Many Chinese investment projects are perceived to be surrounded by a great amount of politically tied, high-level corruption. China has also shown some interest in exporting its anti-corruption model. For example, in September 2023 a Chinese delegation from Henan province visited the ACU to enhance cooperation on anti-corruption.da2ac11b51b8 Several Western actors are eager to seize the opportunity that the generational transition presents to reboot relations with Cambodia without accompanying demands for democratic concessions, an ambition which the government appears to welcome.

Recommendations for development partner practice

Opportunities for non-state anti-corruption work going forward

Despite the challenges they face, non-state actors identify a range of avenues for continued work towards anti-corruption goals, and these are discussed below. When corruption is deeply embedded in the political system, research suggests that a dual approach may be employed to avert the risk of politicisation: direct interventions (such as targeting the most feasible reform areas, mobilisation for anti-corruption goals, and capacity building to support anti-corruption efforts) and indirect reforms (including promoting access to information and developing platforms for collaboration).4a374a5f0ddd The strategies outlined below should be considered as complementary.

Work on solutions based on robust research and evidence

The new government is believed by many non-state actors to be open to evidence-based policy suggestions, if they are politically non-threatening. One CSO leader advocated cultivating a new kind of actor, emerging from the younger CSO leaders, who does not do advocacy as such and lacks political affiliation, but who present themselves as ‘policy people with policy convictions’.

One approach suggested by a leading think tank is to approach anti-corruption to tangible ends. People in general find corruption an abstract notion, and ‘fighting’ corruption implies confrontation. It is therefore more fruitful to suggest solutions for tangible issues, in the form of better policies and better mechanisms of enforcement which will address anti-corruption goals. Tangible benefits that speak to people at this moment in time may include agriculture, education, health, and traffic. These sectors may be understood as entrenched ‘corruption systems’, in which systemic corruption endangers the broader institutional framework.73e37e0240df

Non-state actors identify that the government is interested in the research they report back from their constituencies. One CSO, which is in a strategic partnership with the government, testified that the government started to listen when presented with a robust research report. The CSO collects feedback from its constituencies and presents this to government as an ‘issue on the table’, to be considered when designing policy. One CSO for Indigenous Peoples (IP), for which land access is a key issue, conducted a study with the government on collective land rights to build trust on land issues, and tries to work closely with the government on the national report on IP data. The ministry then integrated IP issues into its planning processes and the CSO hopes that this engagement can lead to more sustainable support from the government.

Some advocacy CSOs have therefore adopted an evidence-based approach, though results have been mixed. One advocacy CSO leader interviewed judged that an evidence-based advocacy approach is the ‘only way to convince the government’. The CSO consults independent researchers with proper technical expertise, and seeks to convince the government through scientific data, photos, videos, and interviews with local people. The evidence serves as proof that issues are real, and not politically motivated to serve the opposition party. However, in only one case out of six that this organisation has presented did the government accept the report and address the issue. Other reports were rejected, and in some cases – where business interests protected by government officials were affected – these led to government threatening local people on the ground. This CSO still considers the evidence-based approach the most efficient way of bringing issues to the government, but judges that it must be combined with online campaigning. In the one case in which the issue was addressed, there had been a successful online campaign leading to a strong public reaction, which was decisive. So while it can be productive to take an evidence-based approach to discussions with government, CSOs that also use evidence to mobilise the public through the smart use of social media are more likely to achieve policy change (see further discussion below).

Work on technical areas at the national level

There is room for more stakeholders working on technical areas at the national level, including on issues of anti-money laundering, relations between business and politics, electoral integrity, beneficial ownership, and oversight. Organisations with a focus on gender request that a broader range of non-state actors, including themselves, also be invited for consultation on such technical areas. Key actors assess that the government could be open to change if more non-state groups were to focus more of their efforts on grand corruption.

Work on best practice in state administration

In de-democratising contexts, research points to the importance of anti-corruption work in strengthening institutions.225229fff0eb One approach for non-state actors is to work not on policy but on best practice for state administration, as this is considered apolitical and thus ‘safe’. Showing civil servants methodologies for best practice equips them to resist political decisions and corrupt practices. One non-state actor, working to strengthen the administration of parliament by advising on technical approaches, noted progress. In their work to improve transparency and accountability by training parliamentary staff, they discovered that parliamentary staff have been receiving an increasing number of requests for information from members of parliament, and from the Senate and National Assembly commissions.

Ongoing projects are heading in the right direction and there are opportunities for expansion. However, the tight control over parliament by the ruling party and the executive nonetheless puts a limit on what such training can achieve.

Work on access to service provision and access to information on services

Facilitating access to services can be another effective approach towards anti-corruption goals. For one CSO, collecting evidence and feedback around the challenges people faced in accessing the government’s social assistance scheme opened the door to engage with the government. Presenting the evidence to the National Social Protection Council has enabled this CSO to sit at the policy dialogue table as a frontline organisation in the provision of social protection for all, and they have acted successfully as intermediaries between government and communities.

CSOs have been vital in improving access to – and information about – local services by setting up one-stop services (‘One Window Service’). These have reduced the incidence of bribery and promoted the disclosure of information on public services. CSOs have also successfully worked on increasing access to information on government decisions and processes, making local authorities reveal information on budgets and development plans from the commune (sangkat) to the provincial (khétt) level. Commune investment plans, in which the commune council has a dialogue with citizens on the yearly budget, were raised in the interviews as a fruitful way to combat corruption and promote gender equity as women are often involved in such local dialogues. Regularly engaging with the authorities has reportedly led to improved service provision in those localities. However, public information about most development projects is still insufficient and more work is needed.

Further, CSOs work to build citizens’ understanding of how public funds for public services are planned and spent, encourage citizens to request local authorities to display fees for public services, and to monitor public services and local government development plans. CSOs report that following such trainings communities have been better equipped to demand information and raise their concerns, and that negotiations with public officials have become more effective.

Official information about and citizen awareness of prices for public services and government development plans nonetheless remain limited. It is hoped that increased digitalisation will help to promote transparency on fees, prices, and development plans, and encourage more civic engagement. Non-state actors have been engaged in developing the ‘citizen budget analysis’ app, which helps citizens understand the commune expenses and give feedback on the authority’s service delivery performance. Through the ‘Pidor chatbot’, citizens can access information about the One Window Service, submit complaints, and rate their experience of accessing public services.

There is an opportunity for non-state actors to educate citizens on the costs of public services and provide capacity building for local communities to be digitally literate, exercise their rights, and develop their legal awareness. They are also well positioned to develop systems that collect citizen feedback.

Work on access to information through journalism

Though the media space has further shrunk over the past year, independent media actors remain active and innovative. Media is a key non-state space for anti-corruption work, for its ability to point out corruption. The Cambodian Journalists Alliance Association (CamboJA) and Newsroom Cambodia websites are important for publishing stories that cover topics on corruption and good governance. There are several workable strategies for non-state actors in the current context, including training programmes for those wanting to learn and practice journalism (eg Newsroom Cambodia). Another initiative – Kamnotra – is a public database of government documents concerning government projects, land concessions, and the leasing of public assets, among other topics. In a context in which the writing of investigative pieces is now considered too controversial, simply publishing this information has been beneficial.

On citizen journalist websites, entry level journalists in the provinces are trained to report local issues; for example, Indigenous youth reporting on economic land concessions. There are trainings on media literacy and civic engagement, for example how to verify information on social media. Non-state actors have also scrutinised several draft laws proposed on cybercrime, cybersecurity, and personal data protection (the draft Cybercrime Law; Law on Access to Information; and a proposed Law on Data Protection), and digital rights more generally. Further, there is advocacy to enhance media freedom, raising awareness on issues like access to information, and the provision of legal support for journalists who face lawsuits. The embattled and struggling independent media should be a priority sector for the support of development partners.

Work on awareness raising and education

Key anti-corruption actors judge that awareness-raising work on corruption has been successful, where it has targeted citizens. At the same time, most non-state actors hold that further awareness-raising work is needed. Given that there is already popular demand for anti-corruption, the focus should be on action-oriented programmes to build specific skill sets and mobilise citizens to take concrete actions that can address corruption. In our interviews, it was those CSOs working closely with local communities that raised the importance of educating citizens on the costs of public services and on identifying what constitutes a conflict of interest. The new government’s emphasis on accountability and integrity is an opportunity for CSOs to present such work as in line with the government agenda. Research suggests that awareness raising must be approached carefully so as not to reinforce beliefs that corruption is too big a problem to be solved, and that messaging should be tested before being rolled out.8fdb1d728f5a

Raising awareness through media outreach is at times a critical tool for obtaining policy responses. Local and international media coverage of the human trafficking/scam ‘industry’ in recent years461519c7fe80 was impactful, and helped force a shift in response to public, international, and regional pressure. It provides a case study of how large-scale corruption could be challenged. However, for members of the public and CSOs, social media use carries potential risks that must be assessed. An independent CSO working on electoral integrity charged that although the government routinely rejects its reports on the performance of the National Assembly, when the reports were discussed on the CSO’s radio programmes and social media, the government sought to address some issues. When to expose issues in public is, however, a delicate balancing act. If an issue is very sensitive, this CSO will seek to meet with the government directly and not report it to the public to avoid conflict. Since 2018, this has been the preferred approach. Social media users who have unearthed or even discussed corruption cases have faced legal action.

Another approach is to provide human rights education in the legal realm. Non-state actors operating in this area judged that the government has been in favour of human rights education, possibly because it needs legally educated people to ‘play the human rights game’. Many members of the small academic human rights community consequently now hold important positions in or advising the government. This complicates the assessment of the efficiency of this strategy for anti-corruption goals. On the one hand, human rights education has equipped the government with expert staff who can defend it – using the ‘language’ of human rights. However, it has created a network in the ministries, administration, and universities, who may still be open for engagement on issues.

Complementarity of approaches

It is important to recognise that there is complementarity between different approaches, and that even those advocacy approaches that seem to meet a dead end with the government can still change policy outcomes. One example is the way in which doors opened to one CSO, in strategic partnership with the government, because whistleblowers created urgency for the government to act. A report by an independent and outspoken human rights CSO about an issue proved a perfect ‘entry point’ for a second CSO, in strategic partnership with the government, to start a dialogue to address this with the national bank and a private sector association, in closed-door conversation. Although the government sought to discredit the advocacy CSO’s report, the second CSO used knowledge assembled from communities on the ground to reinforce the credibility of the report.

Should we talk about corruption?

Most organisations employ alternative discourses to that of corruption and anti-corruption. This is in response to a government narrative that has flagged the term ‘corruption’ as sensitive, and implying confrontation. Some organisations work within frameworks of transparency and accountability, for example, and others adopt a discourse around the difficulty of accessing services. The language of human rights is also widely employed by CSOs, although this too is gradually being undermined. At universities, the notion of ‘human rights’ has in some instances been replaced by ‘values-based pedagogy’ and some CSOs wish to see development partners express concerns over this.

However, leading anti-corruption actors did advocate in favour of using the word ‘corruption’, concerned that using softer terms may be counterproductive. Supporting their argument, there is broad public awareness of and intolerance towards corruption. One interviewee also noted that framing issues as being in the common interest of society enables discussion of potentially sensitive issues – including corruption, which can be named as such.

Potential synergies for joint anti-corruption work among development partners

Work via multilateral agencies

There is agreement among different UN agencies interviewed that corruption is a priority area. In the United Nations Sustainable Development Cooperation Framework for Cambodia 2024–2028, a key target output of the cooperation framework (4.1) is that ‘Institutions are more accountable and effective in upholding human rights to deliver justice and protection services to vulnerable groups’.dfa0778284eb

The United Nations Development Programme (UNDP) will continue to strengthen institutions (duty bearers) and public participation (rights holders), particularly at the subnational level, to enhance access, quality, and transparency of service delivery. This approach to localising the SDGs promotes transparency and accountability and fosters a culture of public engagement. (It should be noted, however, that there is no specific indicator on corruption under the Cambodia SDG 16.) Among the key areas of this work is the promotion of digital transformation and digital literacy to enhance the coverage and delivery of social protection, for example, in collaboration with national entities and other development partners. This involves digitalising data collection and the targeting of beneficiaries under the national IDPoor Program5c13ae385967 (implemented by the Ministry of Planning); developing an online, anonymous complaint mechanism for stakeholder engagement; and continuous improvement of social assistance for the Ministry of Social Affairs, Youth and Veterans. Progress is measured through governance indicators related to voice and accountability and government effectiveness.

The UN Educational, Scientific and Cultural Organization (UNESCO) is committed to anti-corruption efforts with a focus on access to information, among other areas, through a three-pronged strategy. First, in terms of legislation, UNESCO has been providing technical assistance to the government and civil society for the adoption of the Law on Access to Information, which promotes good governance and transparency. Second is capacity building and training of government officials and media professionals on international standards and principles around access to information and freedom of expression, and the promotion of media and information literacy, to equip them with the tools to conduct accurate and investigative reporting on issues related to good governance and anti-corruption measures. Third, UNESCO supports the government and media organisations/associations in the implementation of the UN Plan of Action on the Safety of Journalists and the Issue of Impunity, which involves advocating for the safety and legal protection of journalists and training of civil society partners, security forces, and judicial actors, including lawyers. Some CSOs point to a gap to be closed between UNESCO’s initiative on Access to Information and the positions of Cambodian CSOs, as expressed by the Access to Information Working Group (A2iWG).

Donors should take coordinated action to build synergy, promoting an independent, critical media that can make meaningful contributions on corruption. They can argue that the government has a political incentive to allow a certain amount of free speech – including discussions of corruption – because it will improve its performance.

One UN agency suggests making corruption a UN country team issue. However, it is vital that UN engagement on corruption does not undermine non-state actors’ anti-corruption efforts. UN agencies should be aware that some advocacy CSOs hold that the government refers to its engagement with UN agencies, particularly the UN Office on Drugs and Crime (UNODC) via the UN Convention against Corruption (UNCAC), as a justification not to engage with CSOs on anti-corruption.

The EU continues its support for public financial management reform, one component of which will be supporting CSOs working in accountability and transparency.

Instituting more regular forums and mainstreaming anti-corruption

One idea raised is to start a regular, possibly quarterly, forum for development partners to discuss corruption, collect information, brainstorm, and become more vocal. Corruption could also be raised as an issue at development partner meetings and could be a priority for some meetings during 2024 or 2025.

Since the launch of the Pentagonal Strategy, the government speaks about ethics, efficiency, and integrity as euphemisms for anti-corruption in dialogues with development partners. Some development partners have shifted discourse accordingly, whereas some insist on maintaining the language of anti-corruption.

There may be an opportunity to mainstream anti-corruption into the next four phases of the Pentagonal Strategy, if such a discussion is started in a timely manner. Anti-corruption may be embedded in bigger reform agendas such as administrative reform, public financial management reform, or the budget programme for SDGs.

There is uncertainty among development partners as to the political will of the new generation of political leaders and the political economy of the generational shift, as well as what is meant by the public messaging about meritocracy. The prime minister is another point of uncertainty, though it is believed that he wants to achieve anti-corruption goals. There is agreement among development partners on the importance of high-level engagement, but different opinions on its terms.

One suggested approach for CSOs is to work on thematic topics with the government and development partners, bringing in the expertise of different additional stakeholders as needed. In this way, corruption is wedded to different topics that the government is concerned about. Suggestions include human trafficking and corruption, drug trafficking and corruption, transnational organised crime and corruption, waste and corruption, forest crime and corruption, or water governance and corruption.

Work more politically or economically

One development partner advocated the international community putting political pressure on the government on anti-corruption, which – coupled with social media stories – may build momentum, and make the government turn anti-corruption into a priority (as happened with the human trafficking scams). Another development partner was less optimistic about what could be achieved by political pressure, pointing to the current government’s strong sense of sovereignty. They believe instead that the entry point should be economic – insisting, for example, that trade requires transparency and responsible production. Areas to push may include digital, economic, and environmental governance (transparency for carbon markets), as well as open data and access to information.

Working with local authorities

Several development partners judged that local authorities provide the most fruitful entry point for anti-corruption work at this moment in time.There was some discussion in the interviews of a collaborative pilot project targeting low- and mid-level officials in a less contentious sector. This could create a model for fighting corruption which could then be expanded to other sectors. It also promises high feasibility, in the sense that it is often easier to engage with low- and mid-level officials. At the same time, there are risks attached to primarily addressing low- or mid-level corruption, as this neglects grand corruption. Development partners also need to bear in mind the possibility that the government could move in the direction of weaponising anti-corruption as a political tool, exposing or scapegoating select low- and mid-level corruption, as has been seen in China and Vietnam.

Work more regionally

One promising approach is addressing anti-corruption at the regional (ie, international) level. The regional approach is fruitful because many corruption issues are cross-country, and because it provides cover for and protects local CSOs and media. It is also the case that regional initiatives that are not labelled as anti-corruption initiatives as such may further anti-corruption goals. One example of a regional – explicitly anti-corruption – initiative is the ASEAN Parliamentary-Civic Partnership to Combat Corruption. Another is the Southeast Asian Anti-Corruption Network for civil society organisations, which was launched in December 2023 (Cambodia leads one of its four thematic areas). A new media network also began in July 2023, bringing together prominent investigative journalists from across Southeast Asia. The network investigates corruption under different thematic areas, for example through the lens of human trafficking. Funding for these last two regional initiatives is promised only until the end of 2024. A regional academic network is also under discussion. Anti-corruption practitioners ask for a more structured regional coordination of these networks, rather than ad hoc workshops and exchanges, to systematically address and follow up on corruption-related themes.