Category: Responsible Defence Governance

Our research shows Freedom of Information regimes in countries across the world are not good enough at protecting the public’s right to know

By Ara Marcen and Najla Dowson-Zeidan

The ‘right to know’ for citizens to learn what public institutions are doing on their behalf is a crucial component of human rights law, and vital to combat corruption by providing transparency and accountability. But as with all rights, there is often a big difference between being entitled to them and being able to realise them. With the right of access to information, nowhere is this gulf more apparent than in the defence and security sector.

Militaries, security institutions and ministries of defence are notoriously opaque. Despite robust international (and some national) anti-corruption and freedom of information legislation that governs public sectors, the defence sector is frequently given a green light to remain secretive and evade accountability by utilising the ‘national security’ exemptions so often contained in this legislation. The result is that secrecy is often the norm and transparency the exception.

This approach to transparency in defence needs to change. The secretive nature of defence, and a lack of transparency and access to information, impairs civilian control of the security sector, hampers oversight bodies and increases corruption risks at all levels. It allows corruption to occur unexposed, unaddressed, and in the shadows.

Transparency should be the norm and secrecy the exception. While some information in the defence sector may need to remain classified for legitimate national security reasons, this should be a well-founded exception – not a rule. Maintaining high levels of secrecy limits scrutiny and allows the vicious circle of secrecy, opportunity for corrupt acts and self-enrichment to flourish.

This International Right to Know Day, we call on all governments and public authorities to limit the opacity around security to only the most sensitive information – where the likelihood of harm as a result of its disclosure clearly outweighs the harm to the public interest in withholding it – so national security is not a pretext for limiting citizens’ right to information. Defence and security sectors should not be treated as exceptional when it comes to the public’s right to know how their money is being spent and how key policy decisions are being made.

Initial findings of our global Government Defence Integrity Index, a vast pool of data that assesses how government defence institutions protect themselves against the risk of corruption, show that in most countries there is a long way to go to make mechanisms for accessing information from the defence sector effective. Of the 86 countries assessed, almost half were assessed as at a high to critical risk of corruption in relation to their access to information regimes, meaning that the legal frameworks for access to information, implementation guidelines, and effectiveness of practice at the institutional level are currently not good enough at upholding citizens’ right to access information.

Weaknesses in legal frameworks regulating access to information in defence expose countries to high levels of corruption risk as they reduce transparency and hamper effective oversight of the sector. However, the implementation of these frameworks in practice presents even more significant risks. Poor implementation of Access to Information regulations in defence makes information extremely difficult to obtain and undermines the effectiveness of legislation.

The GDI data shows a significant implementation gap; even where legal frameworks are in place, most countries score less well in terms of actually putting this into practice The vast majority of countries fall well short of the good practice standard for implementation, whereby ‘the public is able to access information regularly, within a reasonable timeline, and in detail’. Most were assessed as having at least some shortcomings in facilitating access to defence-related information to the public (for example, delays in access or key information missing), and in more than one in three of the countries assessed the public is rarely able to access information from the defence sector, if at all. While corruption in every sector wastes resources and undermines trust between the state and its citizens, corruption in the defence and security sector, among institutions tasked with keeping peace and security, has a particularly detrimental impact. In fragile and conflict states, corruption – both a cause and a consequence of conflict – frequently permeates all areas of public life.

And the costs of this are high – both financially (with annual global military expenditure estimated to be almost $2 trillion^[1]) and in terms of human security. Corruption damages populations’ conception of the legitimacy of central authorities, threatens the social contract, and ultimately the rule of law and attainment of human rights.

The right to information and transparency are key pillars for good governance and accountability and are crucial tools in the fight against corruption. They enable external oversight of government – and the military – by legislators, civil society and the media, increasing accountability of political decision-making and institutional practice. They enable informed participation of the public and civil society in public debates and development of policy and law. And they bring corruption risks – and actual incidents of corruption – to light, facilitating the push for accountability and reform.

Recommendations:

We’re calling on states to renew their commitment to the right to information. They need to ensure that their national legal frameworks include laws that enable the public to exercise the right of access to information across all sectors. Rules for classification and declassification must be rigorous and publicly available, with clearly defined grounds for classifying information, established classification periods. And there should be the possibility of appeal for those who wish to access information withheld in Freedom of Information proceedings.

Defence institutions should have in place rigorous and publicly available rules for withholding information, with clearly defined procedures and grounds for classifying information, established classification periods, and a possibility of appeal for those who wish to access information withheld in Freedom of Information proceedings. They should be accompanied by clear criteria and process for public interest and harm tests that can help balance genuine needs for secrecy with overall public interest. Adopting and endorsing the Global Principles on National Security and the Right to Information (the Tshwane Principles) would be a good step towards having the right access to information regime in place.

To make sure that secrecy does not trump the right to know – and to strengthen the ability of defence institutions to protect themselves against the risk of corruption – governments should consider these key principles:

Freedom of information is a right. Any limitations of this should be the exception, not the rule.
Transparency is a key tool against corruption. Enabling public scrutiny, rather than undermining a public institution, can lead to better use of resources and reduce risk of corruption.
The interest of preventing, investigating, or exposing corruption should be considered as an overriding public interest in public interest and harm tests, as corruption is not only a waste of public resources, but also seriously undermines the national security efforts of a country.

For more on Access to Information in the defence sector, see our factsheet.

[1] https://www.sipri.org/media/press-release/2021/world-military-spending-rises-almost-2-trillion-2020

May 6, 2021 – Close links between the defence industry and governments in Europe are jeopardising the integrity and accountability of national security decisions, according to a new report by Transparency International – Defence and Security.

Defence Industry Influence on Policy Agendas: Findings from Germany and Italy explores how defence companies can influence policy through political donations, privileged meetings with officials, funding of policy-focused think tanks and the ‘revolving door’ between the public and private sector.

These ‘pathways’ can be utilised by any business sector, but when combined with the huge financial resources of the arms industry and the veil of secrecy under which much of the sector operates, they can pose a significant challenge to the integrity and accountability of decision-making processes – with potentially far-reaching consequences.

This new study calls on governments to better understand the weaknesses in their systems that can expose them to undue influence from the defence industry, and to address them through stronger regulations, more effective oversight and increased transparency.

Natalie Hogg, Director of Transparency International – Defence and Security, said:

“When individuals, groups or corporations wield disproportionate or unaccountable influence, decisions around strategy and expenditure can be made to benefit private interests rather than the public good. In defence, this can lead to ill-equipped armed forces, the circumvention of arms export controls, and contracts that line the pockets of defence companies at the public’s expense.

“The defence and security sectors are a breeding ground for hidden and informal influence. Huge budgets and close political ties, combined with high levels of secrecy typical of issues deemed to be of national security, means these sectors are particularly vulnerable. Despite the serious risk factors, government oversight systems and regulations tend to be woefully inadequate, allowing undue influence to flourish, with a lot to gain for those with commercial interests.”

Transparency International – Defence and Security calls on states to implement solutions to ensure that their defence institutions are working for the people and not for private gain.

Measures such as establishing mandatory registers of lobbyists, introducing a legislative footprint to facilitate monitoring of policy decisions, strengthening conflict of interest regulations and their enforcement, and ensuring a level of transparency that allows for effective oversight, will be important steps towards curbing the undue influence of industry over financial and policy decisions which impact on the security of the population.

Notes to editors:

Defence Industry Influence on Policy Agendas: Findings from Germany and Italy is based on two previous reports which take an in-depth look at country case studies. The two countries present different concerns:

In Italy, the government lacks a comprehensive and regularly updated defence strategy, and thus tends to work in an ad hoc fashion rather than systematically. A key weakness is a lack of long-term financial planning for defence programmes and by extension, oversight of the processes of budgeting and procurement.
In Germany, despite robust systems of defence strategy formation and procurement, significant gaps in capabilities have led to an overreliance on external technical experts, opening the door to private sector influence over key strategic decisions.

The German report can be found here and the Italian report here.

The information, analysis and recommendations presented in the case studies were based on extensive document review and more than 50, mainly anonymous, interviews.

Contact:

Harvey Gavin

harvey.gavin@transparency.org.uk

+44 (0)20 3096 7695

+44 (0)79 6456 0340 (out of hours)

New report warns close relationships and weak regulations leave door open to undue influence

28 April, 2021 – A close relationship between the defence industry and the Italian government jeopardises the integrity and accountability of the political decision-making process, according to new research by Transparency International – Defence and Security.

Released today, Defence Industry Influence in Italy: Analysing Defence Industry Influence on the Italian Policy Agenda details how defence companies can use their access to policymakers to exert considerable influence over defence and security decision-making in Italy.

The report, prepared by Transparency International – Defence and Security with the support of the Italian Coalition for Civil Liberties and Rights (CILD) and Osservatorio Mil€x sulle spese militari, invites the Italian government to understand better the weaknesses of its system such as to expose the decision-making process to undue influence by the defence industry, as well as to address them through more stringent regulations, more effective control and greater transparency.

In particular, Transparency International, Osservatorio Mil€x and CILD call on the Italian government to:

Establish a process to publish and review a regular, clear and comprehensive national defence strategy with meaningful participation of different stakeholders including civil society.
Introduce a new law to regulate lobbying and implement a mandatory stakeholder public register, with clear definitions and a public agenda of meetings between stakeholders and authorities, to allow full scrutiny.
Widen the scope and applicability of ‘revolving door’ regulations to prevent conflicts of interest and reduce opportunities for undue influence
Increase transparency in the export licensing process to allow for full and meaningful oversight.

Notes to editors:

The full press release, in Italian, is available here.
The report “Defence Industry Influence in Italy: Analysing Defence Industry Influence on the Italian Policy Agenda” was prepared by Transparency International – Defence & Security with the support of Italian Coalition for Civil Liberties and Rights (CILD) and Osservatorio Mil€x sulle spese militari.
The report examines the structures, processes and legal regulations designed to ensure transparency and control based on 20 expert interviews. The report is part of an overarching study of the influence of the defence industry on politics in several European countries.

Contact:

Harvey Gavin

harvey.gavin@transparency.org.uk

+44 (0)20 3096 7695

February 25, 2021 – Stabilisation and peacebuilding efforts in West Africa are being undermined by a failure to address underlying corruption and a lack of accountability in the region’s security sectors, according to new research by Transparency International.

The Missing Element finds that strengthening accountability and governance of groups including the armed forces, law enforcement and intelligence services – not just providing training and new equipment – is a crucial but often neglected component to successful security sector reform (SSR).

Read the report.

By analysing examples from across West Africa, the report details how the high threat of corruption has undermined the rule of law, fuelled instability, and ultimately resulted in SSR efforts falling short of their objectives.

The report serves as a framework for policymakers to assess how corruption is fuelling conflict, then embed anti-corruption measures to reform the security sector into one which is more effective at maintaining peace and more accountable to the population it serves.

Natalie Hogg, Director of Transparency International’s Defence & Security Programme, said:

“Stabilisation and peacebuilding efforts across West Africa have focussed largely on providing training and equipment but rarely resulted in major change. This report details how a focus on anti-corruption and strengthening accountability has been the missing element. Only by recognising and understanding the impact of corruption in the defence and security sector and taking steps to combat it can these programmes hope to transform the sector into one which is both efficient and accountable.”

The Missing Element analyses security sector reform and governance in five countries that our research has previously flagged as being at a high risk of defence sector corruption: Côte d’Ivoire, Ghana, Mali, Niger and Nigeria.

It concludes these interventions fell short because the focus was on providing practical support such as training programmes and new weapons and equipment (with between 80-90% of funding for SSR initiatives typically spent on these) rather than addressing underlying corruption.

The report assesses the main corruption risks in West Africa which are undermining SSR efforts, including:

Financial management

Limited or ineffective supervision over how defence budgets are spent present a huge corruption risk, but reforms to improve transparency in this area have often been neglected as part of SSR programmes.

National defence strategies in Niger and Nigeria are so shrouded in secrecy that it is impossible to determine whether defence purchases are legitimate attempts to meet strategic needs or individuals embezzling public funds. In Mali, Ghana, and Côte d’Ivoire, a lack of formal processes for controlling spending has resulted in numerous examples of unplanned and opportunistic purchases.

Defence sector oversight

Effective oversight and scrutiny of the defence sector by parliamentarians is essential to increase accountability and reduce opportunities for corruption, but despite being a key pillar of SSR, parliamentary oversight remains poor in West Africa.

In Ghana, only a handful of the 18 members of the Parliament Select Committee on Defence and Interior have the relevant technical expertise to perform their responsibilities. In Mali, the parliamentary body charged with scrutinising the defence sector was chaired by the president’s son until mid-2020. In Niger, the National Audit Office, which is responsible for auditing the defence sector’s spending, published its audit for 2014 in 2017.

Recommendations:

SSR policymakers at institutional level, such as United Nations (UN), African Union (AU) and the Economic Community of West African States (ECOWAS), to publicly acknowledge the nexus between corruption and conflict, and adapt SSR policy frameworks accordingly.
SSR practitioners operating in West Africa to undertake corruption-responsive SSR assessments to better inform the design of national SSR strategies and in all phases of their implementation.
SSR practitioners to build on anti-corruption expertise to ensure that corruption is addressed as an underlying cause of conflict.

Notes to editors:

Security sector refers to the institutions and personnel responsible for the management, provision and oversight of security in a country. Broadly, the security sector includes defence, law enforcement, corrections, intelligence services and institutions responsible for border management, customs and civil emergencies.

Security sector reform (SSR) is a process of assessment, review and implementation as well as monitoring and evaluation led by national authorities that has as its goal the enhancement of effective and accountable security for the state and its peoples without discrimination and with full respect for human rights and the rule of law.

The five countries analysed in this report (Côte d’Ivoire, Ghana, Mali, Niger and Nigeria) were previously assessed in Transparency International Defence & Security’s Government Defence Integrity Index.

About Transparency International Defence & Security

The Defence & Security Programme is part of the global Transparency International movement and works towards a world where governments, the armed forces, and arms transfers are transparent, accountable, and free from corruption.

By Benedicte Aboul-Nasr, Project Officer, Transparency International – Defence & Security

On October 17, 2019, Lebanese citizens took to the streets in response to a government proposal to tax WhatsApp communications, in what would become known as the “Thawra”, or “Uprising” against widespread corruption and worsening economic conditions. A year after the beginning of the protests, and two months after the explosion in the Port of Beirut killed 191 people, injured over 6,500, and uprooted nearly 300,000, Lebanese citizens still have no clear answers as to why for six years, 2,700 tons of explosive chemicals were stored in hazardous conditions at the heart of Lebanon’s capital. Many suspect that a long history of negligence and corruption, the very factors that pushed people to the streets last year, are at least partly responsible for the devastation that took place on August 4, 2020.

The government response has been uneven and in the aftermath of the explosion authorities were slow to support immediate relief efforts. Instead, when Lebanese protesters took to the streets on August 8 to voice their anger towards a political class that many believe has benefited from Lebanese resources for decades, security forces responded harshly, deploying tear gas and live ammunition against protesters. Two days later, Hassan Diab’s government resigned, noting that corruption in Lebanon is “bigger than the state”. And, on August 13, eight days after the explosion, Parliament voted for a state of emergency, giving defence forces a broader mandate than the one they already had under the general mobilisation adopted to help contain COVID-19. Since then, Prime Minister-designate Mustapha Adib stepped down, within a month of his nomination, having failed to achieve the consensus necessary to form a government. At the time of writing, Lebanon remains in a political impasse, while former Prime Minister Hariri, who had stepped down two weeks into the protests in October 2019, is in the running to replace his successor.

Allegations of government corruption are not isolated incidents, and mismanagement has led to numerous crises and leadership vacuums over the years, which paved the way for the protest movement. Lebanon is now facing one of the most serious financial crises in its history which has crippled the economy. The state has defaulted on debt payments and banks are imposing de facto capital controls on withdrawals while Carnegie’s Middle East Center estimates that close to US$800 million were transferred out of the country within the first three weeks of the protests. The Lira lost 80% of its value over nine months; by July this year and Lebanon became the first country in the region to enter hyperinflation. Even before the COVID-19 crisis hit, the World Bank had estimated that up to 45% of Lebanese citizens would be below the poverty line by the end of 2020. Despite undeniable evidence that the situation was untenable, prior to the explosion, discussions with the IMF had been stalled for months, and Alain Bifani, the finance ministry’s director-general, had resigned over state officials’ unwillingness to acknowledge the scale of the crisis and achieve consensus to identify solutions. The contract for a forensic audit of the Central Bank was only signed in August, and the audit itself did not begin until September.

The international community has offered loans and significant humanitarian aid to support victims and the reconstruction of Beirut. Tellingly, several governments have pledged that they would not disburse aid through the government, and are prioritising non-governmental organisations that have been at the forefront of assessment and reconstruction needs. Aid disbursed through the government, and renewed commitments to unlock funds promised by the CEDRE conference in 2018, are conditional on stringent anti-corruption reforms being adopted and must be accompanied by strict oversight. In this regard, it is crucial that Lebanese civil society and non-profit organisations are granted access to sufficient information to oversee the disbursement of aid and prevent funds from being lost.

As part of the broader powers and responsibilities granted to the Lebanese Armed Forces (LAF) under the state of emergency proclaimed after the explosion, the military has been given the crucial role of coordinating the distribution of humanitarian aid and supporting other public bodies in their reconstruction efforts. In carrying out these roles, and with the additional powers from which they benefit, it is crucial that the LAF ensure the highest standards of integrity and transparency with the Lebanese public. The LAF has benefitted from a high level of trust in the past, and remains one of the most representative branches of government – the institution must ensure that it maintains trust and supports ways forward for the Lebanese, in particular as Lebanese citizens and organisations rebuild.

The coming months will be crucial for Beirut’s reconstruction and to help lift Lebanon out of the crisis it is experiencing. Anti-corruption measures and transparency, not only in the disbursement of aid but also in reform efforts, should be prioritised by the armed forces themselves, and more broadly by an incoming government committed to resolve the financial and political crises Lebanon currently faces as the country seeks international support. The Lebanese Transparency Association (LTA), Transparency International’s national chapter in Lebanon, has been advocating alongside Transparency International – Defence & Security for increased transparency and accountability of the defence sector since 2018. In 2020, LTA continued to emphasise the urgent need for further transparency with constituents, and for the armed forces to implement access to information legislation to allow Lebanese citizens to understand how the body functions. As the LAF maintain responsibility in the aftermath of the explosion, both for aid disbursement and for maintaining security alongside security forces, clear communications and oversight of the defence sector are critical.

The explosion and its aftermath have brought issues that Lebanese citizens were familiar with – and which pushed many to the streets over the last year – to the forefront of Lebanon’s dealings with the international community. Only by tackling the root causes, continuing to push for reform, and beginning to rebuild institutions in which the public can trust, will Lebanon have a chance to become more stable and pave a way out of the crisis. Lebanese politicians have often shown willingness to commit to reforms when dealing with the international community in the past. However; reforms have then stalled due to a lack of consensus, for instance leading to delays in implementing access to information legislation, or in selecting members for the National Anti-Corruption Commission. As the international community aims to support Lebanese citizens and help rebuild Beirut, they should be wary of attempts to divert assistance, and of mismanagement in the disbursement of funds. Instead, any international and national initiatives should support Lebanese citizens’ calls to dismantle the root causes of corruption, for the political class to seriously address the financial crisis, and for concrete and measurable steps for reform and accountability.

Benedicte Aboul-Nasr is Transparency International – Defence & Security’s Project Officer working on Conflict and Insecurity, with a focus on the MENA region. She has a background in international humanitarian law and the protection of civilians, and currently researches links between corruption and situations of crisis and conflict.

Governance reforms, including to security sector, are urgently needed

23 October 2020 – Transparency International condemns the Nigerian state’s excessive use of force and the continued perpetration of violence against peaceful protesters.

Protests that began with demands for an end to police brutality and the Special Anti-Robbery Squad (SARS), have since transformed into wider calls for an end to corruption and the looting of public funds. The government must respond to these calls with serious evidence-based anti-corruption reforms, including to the security sector, in dialogue with civil society.

Natalie Hogg, Director of Transparency International – Defence & Security, said: “The appalling violence we have seen against peaceful protestors has to end. The only way to restore the much-needed trust in relations between Nigerian citizens and the security sector is to respect and protect basic human rights. Further repressive actions against legitimate demands for an improved security sector in Nigeria will only escalate the situation.”

Nigeria’s score on the Government Defence Integrity Index by Transparency International – Defence & Security rates corruption risks in the country’s security sector as Very High, with extremely limited controls in operations and procurement. While oversight mechanisms are in place, they often lack coordination, expertise, resources, and adequate information to fully perform their role.

In addition, Nigeria has seen no significant improvement in Transparency International’s Corruption Perceptions Index since the current methodology was introduced in 2012. The 2019 Global Corruption Barometer for Africa found that Nigerians rate the police as the most corrupt institution in the country. Almost half of those surveyed reported paying a bribe to the police in the previous 12 months.

Delia Ferreira Rubio, Chair of Transparency International, said: “Corruption deprives ordinary people of their rights to peace, health, security and prosperity. It robs young people of a future in which they can fulfil their potential, and it misappropriates the wealth of a nation for the benefit of the few. Peaceful protesters exercising their right to freedom of assembly must never be met with violence and brutality. Citizens’ demands for an end to corruption must be heard and acted upon.”

Auwal Musa Rafsanjani, Executive Director of the Civil Society Legal Advocacy Centre (CISLAC), Transparency International’s national chapter in Nigeria, said: “The government of Nigeria must immediately stop deploying troops against protestors. The young people who have taken to the streets have a constitutional right to express their grievances through peaceful protest without facing violence and brutality from the state. Together with our civil society partners in Nigeria, we stand ready to work with the government on the root and branch reforms needed to the police and security agencies, and to stop the looting of public funds through corruption. We also condemn the violence and the destruction of property by groups that have infiltrated the peaceful protests.”

Despite promising initiatives, tackling corruption in the Nigerien security sector is still hindered by secrecy

By Flora Stevens, Project Officer – Global Advocacy

Africa’s Sahel has been plagued with conflict and insecurity for more than a decade, and the recent ramping up of violence in the region is putting already weakened armed forces under increased strain. Defence sectors across the region suffer from low levels of civilian democratic control, weak institutional oversight and are struggling to fulfil their mission to improve security in the face of a sharp uptick in attacks from non-state armed groups.

Sandwiched between jihadi militants operating in Mali and Burkina Faso to the west, Boko Haram and affiliated groups continuing to launch devastating attacks in Nigeria to the south and war-torn Libya to the north, Niger has found itself drawn into these conflicts. The complex operational requirements of bringing security to the country, with the huge distances between major settlements, porous borders and hundreds of thousands of displaced people, would pose a challenge for any armed force. But Niger, like its neighbours in the region, is also grappling with the debilitating issue of corruption in its defence sector.

Transparency International Niger has been part of the fight against corruption since 2001. The chapter works to raise public awareness of corruption issues and offers anti-corruption training to citizens. “This has enabled us to mobilise and engage citizens in the fight against corruption in our country,” said Hassane Amadou Diallo, head of the organisation. Transparency International Niger has recorded a series of major successes in its work, including a long-running advocacy campaign which culminated with Niger ratifying the United Nations Convention against Corruption in 2006, and a separate effort to abolish the ‘entrance exam’ to the civil service, a highly competitive processes which on two occasions was marred by fraud and corruption.

More recently, working with Transparency International – Defence & Security, the chapter has been involved in tackling the pernicious issue of defence corruption. Despite recent promising initiatives at national level, efforts designed to fight corruption and improve defence governance have been hindered by a high level of secrecy. It was recently revealed that almost 40% of the $312 million Niger spent on defence procurement contracts over the last three years was lost through inflated costs or materiel that was not delivered, according to a government audit of military contracts. “More than 90% of the contracts awarded to the Ministry of Defence were negotiated by direct agreement, which favoured corruptive practices and overbilling”, said Hassane Amadou. “The competition is unfair, fictitious and sometimes non-existent.” These findings came as the crisis in the Sahel continues to worsen, with hundreds of Nigerien security forces killed in fighting. At the same time, troops on the front line have complained about a lack of kit or being provided with inadequate equipment. Hassane Amadou said the audit that uncovered the extent of the procurement mismanagement would now be subject to a lengthy legal challenge. “TI Niger is hoping a fair trial will take place and that those responsible will be punished in accordance with the law,” he said.

While the findings of the audit are shocking, they unfortunately do not come as a surprise. Transparency International – Defence and Security’s Government Defence Integrity Index (GDI) recently found that while government procurement regulations are clearly spelled out in law, there is a long-standing exemption for defence procurement. The 2016 Code of Public Procurements omits goods, equipment, supplies and services related to defence and security, which effectively leaves the door open to the sort of corrupt practices uncovered by the audit.

Hassane Amadou said that TI Niger has shared the main conclusions of the GDI findings with those in charge of the defence and security forces in the country. “On the basis of the GDI, we then developed an action plan targeting various stakeholders, namely the Ministry of Defence, the parliament, defence and security officials, technical and financial partners, the media and civil society,” he said.

But while there have been signs that Niger is striving to improve its security sector governance as a key pillar for future development and long-term peace and stability, the lack of emphasis on the issue of corruption could critically undermine the effectiveness and sustainability of the whole process.

Despite the impressive reform efforts of the past few years, including the 2016-2021 Renaissance Programme, the 2016 Anti-Corruption Bill, and the 2018 National Strategy to Fight Corruption, Niger is struggling to ensure their effective implementation. The Nigerien government should primarily focus on closing this gap and on rectifying loopholes that allow for corruption in the defence procurement sector to thrive. This could include revising relevant legislation to ensure it effectively applies to all defence acquisitions, with no exceptions.

It is fundamental for the Nigerien military to fully grasp the intrinsic link between corruption and operational efficiency. An important focus area must be the deployment of trained professionals to monitor corruption risks in the field. There is unfortunately currently little evidence of this. There is no pre-deployment corruption-specific training for personnel and no guidelines on addressing corruption risks during operations.

To tackle the security threats Niger is facing, mitigating corruption risks in the defence sector is paramount and requires a robust, disciplined and integrated approach on the part of the Niger government. It needs to ensure civilian oversight is strengthened through well-functioning oversight mechanisms, while making sure corruption is approached in a systemic or comprehensive manner during troop deployment.

With security threatened by increasingly belligerent armed actors and a hastened drawdown of international troops due to COVID-19, Iraq cannot afford to leave its defence institutions open to corruption.

By Benedicte Aboul-Nasr

Since October 2019, Iraq has seen tensions in its political sphere, including public protests, declining oil prices, increasing risks of proxy war between the US and Iran, and the resurgence of violent armed groups; the COVID-19 pandemic has exacerbated an already precarious security situation. After six months without a government, Iraq’s parliament appointed Prime Minister Mustafa Al-Kadhimi in May 2020, and granted his full cabinet confidence in June. To respond to the state’s most urgent priorities, the incoming government and its international partners should urgently consider addressing risks of corruption and human rights violations, in particular in the defence sector, to guarantee that the defence forces have the capacity, resources, and popular backing, to respond to priorities.

In research published this week, Transparency International – Defence & Security has found Iraq’s defence sector to be at critical risk of corruption, and lacking anti-corruption and transparency mechanisms. In fact, our Government Defence Integrity Index (GDI) indicates that Iraq is particularly vulnerable to risks relating to finances and personnel, and does not fare much better in the areas of political, operational, and procurement corruption risks, with an overall score of 9/100 on the Index. Corruption has been linked to the erosion of institutions and of trust, and is one of the main grievances driving the protests that broke out last October. As critical as these results are, they offer the new government a blank slate to meaningfully reform the defence sector from the ground up; this will be imperative to secure longer-term security for the country.

COVID-19 has added another threat; the crisis has severely affected Iraqi citizens, as security forces enforce curfews against a backdrop of unrest and accusations of forces deliberately firing on protesters, killing over 600, injuring thousands, and recent reports of ill-treatment and torture of anti-government protesters. It is also likely to disproportionately affect displaced populations, more vulnerable to the pandemic following years of conflict and displacement, with more poorly resourced accommodation, protection, and health systems. Crucially, the pandemic has also generated additional security challenges, as the government and defence institutions redirect resources towards its pandemic response, while simultaneously countering the apparent resurgence of extremist groups. Indeed, Iraq is already facing the resurgence of the Islamic State in Iraq and the Levant (ISIL), which are seeking to exploit the governance vacuum and the pandemic to resurface.

Governments around the globe have rapidly shifted their own priorities in response to COVID-19. Within weeks of the outbreak, France, Canada, the United States and several European countries in the global coalition against ISIL announced temporary withdrawals of their troops from Iraq and from NATO Mission – Iraq. Meanwhile, Operation Inherent Resolve announced that it had stopped training Iraqi security forces, as the Iraqi military also suspended its trainings to reduce the spread of the virus. Against this backdrop, ISIL has actively called for its members to ‘act’, encouraging supporters to ‘exploit disorder’ and is increasing the pace and violence of attacks, taking advantage of the drawdown of international troops.

Countering corruption risks in defence must therefore become a priority. Doing so would limit the risks of abuses of civilian populations, illegal trade of cultural property, of theft or diversion of already limited resources, and would ensure that Iraq’s defence institutions can respond to the multiple challenges it faces. Iraq has seen the consequences of a poorly governed and corrupt defence sector: the military cannot afford vulnerabilities akin to those that enabled the rise of ISIL in 2014. At the time, corruption fuelled problems which left troops hollowed out and outnumbered, such as equipment theft and ‘ghost soldiers’ – members of the military whose names were registered and salaries disbursed, without being present in military ranks. ISIL actively used these issues as recruitment tools in its propaganda, and militants developed government functions in areas where relations with government had deteriorated for years. The group benefitted more concretely from the erosion of security services, where corruption had thrived, to take over swathes of territory, leading to the prolongation of the conflict. Despite the military defeat of the group in 2018, these vulnerabilities remain and risk weakening the Iraqi armed forces when they are most needed.

Iraq’s defence institutions and oversight are severely lacking, and do not fulfil basic requirements of anti-corruption and transparency. Yet they can no longer afford a weak stance on corruption, nor on human rights. To avoid exploitation of existing vulnerabilities and erosion of the defence and security forces similar to those that led to Mosul’s fall in 2014, the government must turn its attention to defence governance, and tackle existing vulnerabilities such as those highlighted by the GDI. The incoming government is in a unique position to do so, and has already pledged to investigate the allegations of torture disclosed by the UN. The government could also take concrete steps and measures to strengthen integrity and accountability within the armed forces. In addition, both the new Defence Minister, Juma Inad, and Interior Minister, Osman Ghanimi, have extensive and highly respected military backgrounds and an in depth understanding of Iraq’s security challenges which could support reform of the defence and security sectors.

International partners have a critical role to play and should actively promote instilling anti-corruption systems into longer-term institution building and reconstruction efforts. For instance, international partners should prioritise including anti-corruption and integrity building within training courses and partnerships with the armed forces. They could also, as a means of supporting longer term development of defence institutions, support the development of accountability structures, such as streamlining a code of conduct for all military forces, developing and implementing mechanisms to allow whistle-blowing and whistle-blower protections within the armed forces, and setting up clear systems for investigations of allegations of abuse.

Armed groups in the country and its neighbourhood are becoming more belligerent, taking advantage of the pandemic and withdrawal of international forces. In this context, weeding out corruption in institutions, and strengthening anti-corruption mechanisms in the longer term, will be essential for Iraq’s government to begin restoring trust, and for armed forces to effectively respond to security threats and the resurgence of non-state belligerents.

Benedicte Aboul-Nasr is a Project Officer at Transparency International – Defence & Security. Her areas of focus are the MENA region, and how corruption affects conflict and security in the region.

This article originally appeared on the Royal United Services Institute (RUSI) website.

By Ara Marcen Naval and Karolina MacLachlan.

Throughout the coronavirus outbreak, all eyes have been on the sector providing the frontline response to the epidemic: healthcare. But as the military steps in to assist in a growing number of countries around the world, there are questions about whether that could lead to additional problems.

The military capacity for rapid, large-scale movements – whether to protect hospitals, distribute supplies or increase transport capabilities – can be essential in responding to an infectious disease outbreak. Large-scale military deployments are likely to have the biggest impact in countries with weak healthcare systems and governance, limited civilian response capacities, vastly dispersed populations, or ongoing conflict and insecurity.

As low-income countries brace for the onset of the coronavirus pandemic and health authorities warn of challenges ahead, it is important to remember that large-scale military operations in support of the response to coronavirus in fragile and conflict states carry significant risks. Political, financial and health crises often expose cracks in the system that are less noticeable in more settled times. For instance, long-term governance gaps and ongoing corruption in armed forces can undermine civilian trust, making their work during crises more difficult. Military deployments during the Ebola outbreaks in the DRC and Liberia in 2014 and 2019 are examples of the role armed forces can play in limiting the scale of an epidemic – yet groups such as Médecins Sans Frontières also argued that years of abuse at the hands of the DRC’s military had made the local population wary of these troops, undermining their efforts.

Transparency International’s Defence and Security research shows that in many developing and fragile states, defence sectors tend to be poorly governed. High levels of secrecy and dysfunctional oversight structures often enable fraud, corruption and a wide range of abuses. The coronavirus crisis, like others before, has the potential to exacerbate these vulnerabilities, weakening militaries when they are needed most.

For example, where frontline soldiers go unpaid or have their salaries stolen by senior officers – a problem which research indicates affects the DRC, Iraq, Mali and Nigeria – militaries could see ill-disciplined units prone to avoiding service, busy trying to secure other sources of income or abusing civilians. A health and humanitarian emergency, which puts frontline responders at additional risk, could prove too much for those troops to handle, while sudden access to scarce resources could provide opportunities at the expense of the civilian population. Where militaries are already affected by corrupt practices, acceptance of small bribes and other favours can undermine containment efforts. Simultaneously, favouritism or corrupt networks could skew distribution of healthcare equipment by influencing the choice of priorities. Disciplinary issues, usually more widespread in states with weaker overall defence governance, could make an appearance or be exacerbated by the crisis. In the Philippines, for instance, President Duterte has already given police and military officials the order to shoot ‘troublemakers’.

Finally, a health and humanitarian crisis could see deployments of foreign troops into fragile and conflict states. As the Ebola example suggests, sizable deployments of US and UK forces into Liberia and the DRC helped construct and protect health facilities, distribute supplies and train healthcare workers. However, as international forces intervene in crises, the tangible and intangible resources they bring – such as cash, necessary items and political support for local actors – could further strengthen corrupt networks, as has been seen in countries such as Afghanistan. As Transparency International’s guidance on military interventions indicates, international forces themselves are also not immune to corruption, exacerbating challenges already in existence.

As economies weakened by coronavirus will require additional investment to rebuild, countries cannot allow uncontrolled resource outflows through defence and security institutions. Governments should take measures to strengthen defence governance immediately, offering a maximum level of protection in the short term and strengthening the global response. The authors recommend, for instance:

Inserting anti-corruption measures and the highest levels of transparency at the core of any new legislation (including that governing the distribution of resources) to respond to the emergency. This should include making publicly accessible contracts that govern financial flows and procurement associated with the crisis.
Ensuring that military deployments to help manage the emergency have clear timelines, independent oversight and are subject to review and audit mechanisms.
Extending protection to whistleblowers to help ensure that those who see corruption, whether in healthcare or in defence, can safely report it.
In the longer term and as the crisis recedes, it is key that attention to oversight and control of the defence sector becomes a priority, especially in fragile and conflict-affected states. Defence, healthcare and development are not mutually exclusive; slippage in one is likely to endanger progress in the other. Without fixing defence, sustainable development and better healthcare are unlikely to take root, especially in the most vulnerable countries.

Ara Marcen Naval is the Head of Advocacy for Transparency International – Defence & Security.

Karolina MacLachlan is Transparency International – Defence & Security’s Regional Programme Manager for Europe.

The theme of this year’s annual Munich Security Conference was ‘Westlessness’. Awkward to pronounce and going by the evidence, equally awkward to discuss in (polite) internationally mixed company. That those countries self-identifying as ‘Western’, are having a moment of self-doubt is not in dispute. But as the US Secretary of State, Mike Pompeo was at pains to stress during his speech to the conference, the list of the West’s competitive advantages is as long as it is impressive. Despite that, somehow the doubts remain. There is no shortage of books, journal articles and editorials attempting to explain why the assumptions that have dominated global discourse and conduct on security and defence for the past 70 years are now under siege. Aside from concerns over the US’s continued commitment to fortify the West’s key brands like NATO, the other most often cited evidence for Westlessness was the sense that the international rules based order too is no longer the default standard it once was.

For some, including the authors of the Conference’s report and leaders such as France’s President Macron, the answer lies in finding – and presumably before that, agreeing to – a joint plan for action. For Macron, this would come from the European Union. Others continue to look to the US in the hope that at some point, and maybe as early as November, signs will emerge that normal business will soon be resumed. Nonetheless, some things once said cannot be unsaid, and now that the genie of self-doubt is out the bottle, and has been named, any re-set will require sustained stewardship and patient hard work by all those with an interest in maintaining the West’s values and its underpinning ideals.

So what might be done while the West waits for the emergence of a plan, be that joint, US led, EU led or otherwise? Are there parallels with other governance reform efforts that seek to help institutions that have lost their way? For some fifteen years, Transparency International’s Defence and Security programme (TI-DS) has been working tirelessly to raise awareness of the corrosive effects of corruption in the global defence sector. Challenging the view that corruption is merely an economic or financial cost, its work continues to show that once a more rounded interpretation of corruption is combined with a sector specific approach and a deeper appreciation of its precursors, patterns are revealed and wider implications become better understood. TI-DS work indicates how the onset of institutional malaise can help create the conditions for corruption to take root in a sector, while also pointing to decay in the broader governance of the political system of which it is a part. Running in parallel, is corruption’s relationship with the breakdown of trust between the public and those they fund (through their taxes) to protect them, undermining confidence in the State and if left unchecked, how it can lead to instability, insecurity and ultimately to conflict.

This is not to say, that what lies at the heart of the West’s strategic drift is corruption. The temptations that can lead to corrupt behaviour, in all its guises, can and do exist in the most transparent and accountable of systems, and the bastions of the West’s defence are no less immune to it than others. Rather, that the common thread that connects the two is ‘complacency’. It is complacency that starts the erosion of oversight mechanisms and institutional safeguards. The difficult and often mundane work that politicians, military leaders and bureaucracies are required to do to tend and maintain the complex web of checks, balances, customs and practices, needs constant attention and insistent reaffirmation. The problem for the generation that inherits a system, as opposed to generation that built and in some cases fought for it, is that the prevailing conditions are seen as a given, somehow self-governing and possibly even inevitable. And what might be true for institutions that govern national defense and security, can also true for a wider political system and by extension, a broader international system, especially one built on rarely explained shared values and inherited assumptions. In the absence of a conscious effort to maintain its safeguards, it is perhaps inevitable that cracks will appear that can be exploited by those motivated to take advantage of perceived weakness or discord.

For Transparency International Defence and Security, the first step in any successful institutional reform programme is the identification of reform-minded leaders willing to take on the challenge of re-instilling the confidence in the organisations they lead. In turn, those that are led need to believe that’s their leaders understand the problem and mean to do what it takes to mend it. But this leadership must come from within the institution; be that a single branch of the military, a ministry, or within a government. Rarely, does it come from outside. In the same way, calls by Western leaders for joint action, or US leadership, overlook important options much closer to home. The complacency that crept up on the West after the fall of the Berlin Wall arguably took hold because collectively, the West took its values, its justifications and its popularity for granted. Moreover, they believed that liberal democracy’s victory in the Cold War, had proven that it was inevitable; and as such it didn’t need to be explained, justified or renewed.

The first step in redressing the West’s moment of self-doubt therefore, like the first step in tackling corruption within an institution, is to recognise that reform starts when its leaders re-build and re-assert the case for shared values with its disillusioned rank and file, and begin the process of reconnecting with sceptical populations. Reform and renewal isn’t easy at any level, but it is best led by those closest to the problem. Waiting for the leadership of others, or a proposal for a joint action, will only allow the doubt to linger and unpalatable alternatives to gain greater currency and increase their traction. If and when joint action or the leadership of others is eventually offered, those that have already started to tackle to problem at source, will always be better placed to contribute

By Matthew Steadman, Project Officer – Conflict & Insecurity

2019 was a deeply concerning year for the Sahel. Attacks by extremist groups have increased five-fold in Mali, Niger and Burkina Faso since 2016, with the UN now describing the violence as “unprecedented”. The past year was the deadliest by far with more than 4,000 deaths reported. Niger lost 89 soldiers in a single attack by Islamic State in Changodar in January, whilst two ISGS attacks in Mali in November claimed the lives of 92 soldiers. In Burkina Faso alone, 1,800 people were killed in the past year due to extremist violence. The intensification of extremist activity in the Sahel threatens to engulf West African coastal states, as already weakened national defence and security forces come under increasing pressure. Much international coverage of the developing events has focussed on the operational aspect of the crisis, from the various armed groups operating in the region to the international response, spearheaded by France’s Operation BARKHANE but also including MINUSMA, the G5 Sahel, the United States and the EU. However, one aspect that has been regularly overlooked is the poor capacity of the region’s national defence forces to respond to security threats as a result of poor defence governance, corruption and weak institutions.

Corruption and conflict go hand in hand, with corruption often fuelling violence and subsequently flourishing in afflicted regions. Because of corruption and poor governance, defence and security actors are often seen not as legitimate providers of security, but as net contributors to the dynamics of conflict; with poor training, management and institutional support leading to a downward cycle in which it is the civilians that more than often feel the brunt – as has been seen in Burkina Faso, Nigeria and Mali. When security institutions are perceived as corrupt, public confidence in government erodes further. Fragile governments that are unable to respond to the needs of citizens can exacerbate existing grievances, heightening social tensions and hastening the onset of violence. Across the Sahel, armed groups have been able to entrench themselves first and foremost in those areas which have been neglected by weakened and corrupt central authorities, often by positioning themselves as providers of security, justice and basic services. In this way, it is crucial to view corruption not just as the consequence of conflict, but more often as its root cause and therefore a critical element for any attempt at resolution to address.

Against this backdrop, research by Transparency International – Defence & Security’s Government Defence Integrity Index (GDI), highlights the deficiencies in the safeguards which should provide protection against corruption in the defence sectors of Burkina Faso, Cote d’Ivoire, Ghana, Mali, Niger and Nigeria, increasing the likelihood of defence funds and capabilities being wasted due to mismanagement of human, material and financial resources. In doing so, the GDI outlines a number of key issues which need to be addressed in order to enhance security forces’ ability to respond to threats and protect local communities:

Reinforce parliamentary oversight

Despite most countries having formal independent oversight mechanisms for defence activities, policies and procurement, our research has found that these are often only partially implemented, easily circumvented and insufficiently resourced to carry out their mandates. The result, is defence sectors which are still largely the preserve of the ruling elite and shrouded in secrecy, raising concerns over the use of vital defence funds and the management of resources and assets.

Strengthen anti-corruption measures in personnel management and military operations

Personnel management systems are also vulnerable, with inadequate or non-existent whistleblowing protections and reporting mechanisms, unclear appointment, and promotion systems open to nepotism, and codes of conduct which fail to specifically mention corruption or enforce appropriate sanctions. Equally, despite many countries in the region being actively engaged in on-going counter insurgencies, there is no evidence of Mali, Niger, Burkina Faso or Nigeria having up to date doctrine which recognises corruption as a strategic threat to operations, meaning there is little if any appropriate training on the pitfalls associated with operating in corrupt environments and little appreciation of how soldiers’ conduct might exacerbate the violence they are trying to quell.

Increase transparency and external oversight of procurement processes

Perhaps most concerning of all is that corruption risks in defence procurement remain extremely high across the region. The procurement process is opaque and largely exempt from the checks and balances which regulate other areas of public procurement in countries like Mali and Niger for instance. Across the region, the effectiveness of audit and control mechanisms over the acquisition of military goods and services is heavily restricted by blanket secrecy clauses and over-classification of defence expenditure. This raises serious concerns over the utility, relevance and value for money of purchased equipment and increases the risk of that frontline troops will not have the resources required to deliver security.

Despite these structural vulnerabilities, international assistance in the region has been heavily focussed on security assistance rather than on improving the underlying structures that govern and manage defence and security in the states that make up the region. The 13^th January summit between French President Emmanuel Macron and the leaders of the G5 Sahel countries, was emblematic of this with the meeting focussed on reaffirming France’s military presence in the region and announcing the deployment of further troops, whilst side-lining the governance deficit which underlies so much of the crisis. Programmes have tended to focus on training and equipping military and police forces in Mali and Burkina Faso for instance, or improving strike capabilities by investing in US drone bases in Niger. The concern however, is that the impact of these efforts will be blunted without a more sustained engagement in addressing the more fundamental failings that lay at the hearty of the problem. Mali’s recent announcement of a recruitment drive for 10,000 new defence and security forces personnel for example, will only be effective if it is accompanied with improvements in the way these troops are trained, led, equipped and managed and if the political and financial processes which govern them are strengthened and corruption risks reduced.

A successful response, at the national, regional and international levels, to the violence cannot be just security focussed. Poor defence governance and corruption risks will continue to hamper national forces’ operations and will hinder the impact of international efforts which support them. A more comprehensive approach is needed which addresses the underlying corruption risks which permeate the region’s defence sectors. Improving oversight, transparency and accountability is a critical step in securing a sustainable peace in the region and ensuring that defence and security apparatuses do what they should, which is to further the human security of populations that they should be serving.

January 14, 2020 – Sweeping reforms to controls on American arms sales abroad are increasing holes in checks to identify and curb corruption – measures that can also be used to assess whether sales may help or hurt efforts to address terrorist threats and attacks – according to new research by Transparency International Defense & Security.

Launched today, Holes in the Net assesses the current state of US arms export controls by examining corruption risk in three of the most prominent sales programs, which together authorized at least $125 billion in arms sales worldwide for fiscal year 2018.

Across all three different arms sales programs, which are managed by the Defense, State, and Commerce Departments, there is a clear gap in American efforts to assess critical, known corruption risk factors. This include the risks of corrupt practices – such as theft of defense resources, bribery, and promoting military leaders based on loyalty instead of merit – weakening partner military forces.

The United States is one of the biggest arms exporters to countries identified as facing ‘critical’ corruption risk in their defense sector, including Egypt, Jordan, Oman, Qatar, and Saudi Arabia, according to recent analysis by Transparency International – Defense & Security.

Steve Francis OBE, Director of Transparency International – Defense & Security, said:

“Given the corrosive effect corruption has on military effectiveness and legitimacy, it is deeply concerning to see that these reforms to American arms export controls have made it easier for practices like bribery and embezzlement to thrive. In order to ensure American arms sales do not fuel corruption in countries like Egypt, Qatar, and Saudi Arabia, it is imperative to understand and mitigate the corruption risks associated with countries receiving US-made weapons before approving major arms deals.”

Of the three programs assessed in the report – Foreign Military Sale, Direct Commercial Sale, and the 600 Series – the 600 Series was identified as having the biggest gaps in its anti-corruption measures. Overseen by the Commerce Department, sales through this program do not require declarations on a series of major corruption risk areas, including on certain arms agents or brokers, political contributions, company subsidiaries and affiliates, and any defense offsets. These areas are common conduits used for bribery and political patronage.

More recently, the Trump administration has proposed moving many types of semi-automatic firearms and sniper rifles to Commerce Department oversight. The proposal calls for additional controls for firearms, but also reduces overall oversight of small and light weapons exports.

Colby Goodman, Transparency International – Defense & Security consultant and author of the report, said:

“Over the past 30 years, America has established some of the strongest laws to prevent bribery and fraud by defense companies engaged in arms sales. However, defense companies selling arms through the 600 Series program no longer have to comply with key anti-corruption requirements. As a result, US officials will likely find it harder to identify and curb bribery and fraud in sales of arms overseen by the Commerce Department.”

The report analyzed five priority corruption risk factors for American arms sales programs: 1) Ill-defined and unlikely military justification; 2) Undisclosed or unfair promotions and salaries in recipient countries; 3) Under-scrutinized and illegitimate agents, brokers and consultants; 4) Ill-monitored and under-publicized defense offset contracts, and 5) Undisclosed, mismatched or secretive payments.

The report makes a series of policy recommendations that would help strengthen anti-corruption measures in these prominent arms sale programs, including:

Creating a corruption risk framework for assessing arms sales through programs managed by the Defense, State, and Commerce Departments. These assessment frameworks must examine key risk factors identified in our report, including theft of defense resources and promoting military leaders based on loyalty instead of merits, among others.
Strengthening defense company declarations and compliance systems for sales of arms overseen by the Commerce Department, including declarations of any defense company political contributions, marketing fees, commissions, defense offsets, and financiers and insurance brokers of arms – all clear conduits for corruption.
Increasing transparency on arms sales and actions to combat arms trafficking overseen by the Defense, State, and Commerce Department. Critically, the Defense and State Departments need more details on defense offsets in order to properly review proposed arms sales. There is virtually no information on Commerce Department approved arms sales.
Legislation requiring for firearms and associated munitions to remain categorized as munitions to ensure further relaxing of export controls do not adversely impact US national security or foreign policy objectives.

Notes to editors:

Interviews are available with the report author.

Holes in the Net is available to download here.

Saudi Arabia, a major importer of US-made arms, failed to defend against an attack on its oil facilities in September 2019. Reports have suggested that corrupt ‘coup-proofing’ measures designed to shield the ruling family likely contributed to the ineffective response.

Contact:

Harvey Gavin

harvey.gavin@transparency.org.uk

+44 (0)20 3096 7695

+44 (0)79 6456 0340