In its drive to combat corruption and promote integrity, the WCO has always advocated the creation of partnerships, in particular with the private sector as set out under key factor 10, entitled “Relationship with the Private Sector”, of the Revised Arusha Declaration Concerning Good Governance and Integrity in Customs. Over the past few years, the WCO has been encouraging Customs administrations to leverage “collective action”, a term used to describe multi-stakeholder initiatives in which all participants are to take an active stance. The June 2017 edition of the magazine focused on how this collaborative process is used to address the multiple dimensions of corruption, its causes and its remedies.

Since 2019, some countries of West and Central Africa have been workig with the WCO Secretariat to implement collective action under the Anti‑Corruption and Integrity Promotion (A-CIP) Programme. This article will look at the initiatives undertaken by Ghana and Mali, before going on to highlight the ongoing efforts in the region to build communities of practice.

In the light of its scoping work under the WCO A-CIP Programme, the Ghana Revenue Authority (GRA) reported the need for more active and impactful stakeholder engagement. Expanding on a series of training activities intended for officials that have stakeholder engagement responsibilities, and who are in a capacity to influence, impact or foster organizational change, the GRA decided to move stakeholder engagement on to the next level.

It therefore invited not only traditional stakeholders – private-sector entities – but also “lesser known” partners to establish a Steering Committee for Collective Action on Corruption in Customs. Comprising representatives of the GRA itself, the Commission on Human Rights and Administrative Justice[1] (CHRAJ), the Committee of Freight Forwarders’ Association[2] (CoFFA), the NGO Ghana Integrity Initiative (GII) and the Office of the Head of Civil Service (OHCS), the Committee aims to identify measures – to be carried out collectively or in parallel – to fight corruption and promote integrity, and ultimately to make Ghana’s business environment more conducive to cross-border trade. The Committee is committed to fostering constructive dialogue among the partners, collecting perspectives from outside the group and engaging partners in the design and implementation of reform and modernization initiatives.

The Steering Committee is not by any means starting from scratch: the GRA and its partners have already achieved results, the GII assisting the GRA, for instance, with the development of its Corruption Reporting Mechanism, thus making it possible for GRA staff and any GRA-associated individual or organization to report acts of corruption, misconduct or malpractice via an independent platform, which is subject to oversight by the GII.

In June 2023, the partners organized the Ghana Collective Action Event for Integrity in Customs, during which they presented their achievements to date and their pledges for action in the future. For example:

• The CoFFA would ensure that its members use reporting mechanisms to expose corruption, misconduct and malpractice; embrace automation to minimize human interaction; build compliance capacities; and develop staff and customer knowledge of ethics and compliance.
• The OCHS would focus on strengthening the institutional reporting frameworks; provide incentives for reporting unethical acts; and promote integrity across the entire civil service staff.
• The CHRAJ would continue to implement Ghana’s National Anti-Corruption Action Plan (NACAP), a roadmap containing 135 actions focused on building public capacity for condemning and fighting corruption; institutionalize efficiency, accountability and transparency; involve both individuals and media and civil society organizations in the reporting and combating of corruption; and undertake the effective investigation and prosecution of corrupt conduct.
• The GII would assist the GRA in deploying the Corruption Reporting Mechanism and further consolidating its application with regard to accessibility, transparency, fairness and safety.

All partners will report achievements and lessons learned via the Steering Committee.

Mali Customs is likewise fully committed to implement collective action. It has taken advantage of the Customs Integrity Perception Survey (CIPS), which is one of the tools developed under the A‑CIP Programme, to obtain more detailed information on private-sector stakeholder perceptions of Customs activities.

In order to present the findings of the analysis of the survey responses and create the conditions for a constructive discussion, Mali Customs brought together some 40 senior Customs managers and representatives of the private sector and employers at a three-day workshop in July 2023. The two sides agreed on the need to work collaboratively, with a view to creating a climate of trust between the private sector and Customs, and to avoid considering corruption as a taboo subject.

Furthermore, the stakeholders all expressed their commitment to:

• boosting communication between the partners and revitalizing the framework for dialogue, ensuring that the subjects under discussion are relevant and determining the practical measures to be implemented;
• appointing “integrity influencers” in each organization, with responsibility for boosting measures to foster integrity and for promoting the appropriation of values and good practice within their organization;
• streamlining Customs processes (reducing discretionary measures, focusing on speed, taking the informed opinion of the private sector into consideration, reforming and modernizing both in word and in practice);
• implementing a process for reporting corruption, misconduct and malpractice which is accessible, transparent, fair and safe, and which guarantees protection and confidentiality for whistleblowers;
• forging ahead with digitalization and improving the reliability of tools;
• ensuring that sanctions are proportionate and have a deterrent effect.

The lessons learned in terms of stakeholder engagement include:

• limiting the number of challenges to be resolved so as to avoid spreading energies and resources too thinly;
• focusing on those measures for which there is a general consensus and expressing the expectations of all stakeholders in a clear manner;
• communicating regularly at all levels as well as focusing on listening and finding solutions;
• formalizing the mutual commitments in a roadmap.

A community of practice is one of the many forms that collective action can take. In simple terms, CoPs refer to groups of people or professionals who share a common concern, a set of problems or an interest in a topic, and who, on that basis, interact regularly to learn together and from each other.

In 2023, the WCO A-CIP Programme team delivered two workshops on building CoPs for the Customs administrations of the WCO Americas and Caribbean (AMS) and West and Central Africa (WCA) regions. Participating Customs representatives explored their respective practices, in particular those relating to the WCO Revised Arusha Declaration key factors of Audit and Investigation, Morale and Organizational Culture, and Relationship with the Private Sector. They agreed that there was a clear need to build communities of practice in matters of integrity that would share information on regulations, procedures, best practice and experiences as well as guidance and handbooks. Possible methods of exchange considered by the workshop participants included e-learning platforms, group discussions, joint training, technical working groups, professional attachments and study visits.

In early 2024, the WCO announced that it would be dedicating this year to the theme of “Customs Engaging Traditional and New Partners with Purpose”. Efforts by Customs administrations within the WCA region to bring together a variety of stakeholders for fighting corruption and building a CoP are aligned with this call for action.

In the coming months, thanks to Norway’s re-affirmed commitment to the ongoing funding of the programme, the WCO A-CIP Programme team and its partner administrations will continue to establish partnerships and thus forge a united front against the scourge that is corruption.

More information
capacitybuilding@wcoomd.org

[1] CHRAJ is Ghana’s Anti-Corruption Commission.

[2] A major private-sector representative.