Launched in January 2019 with funding from the Norwegian Agency for Development Cooperation (Norad), the WCO Anti-Corruption and Integrity Promotion (A-CIP) Programme is aimed at improving the business environment for cross-border trade in some countries by making changes to the operational and administrative context that facilitates corrupt behaviour and hinders good governance in Customs operations and administration. The initiative is guided by the ten key factors of the WCO Revised Arusha Declaration concerning Good Governance and Integrity in Customs. The Programme team employs results-based management and has therefore developed a performance measurement system making use of different methods and tools, both in terms in data collection and data analysis

Performance measurement in the area of integrity is not an entirely new area of work for the WCO. The qualitative diagnostics undertaken as early as 2005 based on the WCO’s Customs Capacity Building Diagnostic Framework included over 90 questions in the area of good governance and integrity.

Moreover, in 2010, working jointly with the World Bank, the WCO assisted Cameroon Customs to introduce a system of performance contracts for appraising its staff, using statistical data together with various indicators. Findings from this exercise were incorporated in a new guidance tool for WCO Members: the Why and How of Performance Measurement Contracts. Performance indicators identified at that time were also incorporated in UNCTAD’s ASYCUDA SYstem for Performance Measurement (ASYPM), which automatically draws performance data from the Customs management system.

Lastly, the WCO’s Integrity Development Guide (IDG), revised in 2014, expands on the Diagnostic Framework and includes a self-assessment tool comprised of over 245 questions aimed at assessing the current integrity situation in a Customs administration.

Despite not being an entirely new area of work, measuring corruption and integrity has remained a challenge. As noted in the publication of the World Bank’s “Enhancing Government Effectiveness and Transparency: The Fight Against Corruption”, information and data analytics for assessing integrity problems in Customs and monitoring progress of anti-corruption reforms are generally weak.[1]

Corruption is difficult to measure. In its User’s Guide to Measuring Corruption and Anti-Corruption, the United Nations Development Programme (UNDP) pointed out that: “The fact that corruption takes various forms – ranging from embezzlement, fraud, nepotism, bribery, extortion and money laundering – makes it impossible to capture corrupt practices in a single indicator.” Furthermore, assessing the effectiveness or impact of anti-corruption initiatives is hard due to the non-linear and complex environment that enables corruption. Finally, the development of corruption indicators is more often than not “a dynamic process”.[2]

Despite these challenges, measurement remains critical in order to reveal the nature, scope and impact of corruption, as well as develop effective anti-corruption responses. It is also necessary in order to focus and prioritize efforts in the face of limited resources. This has prompted the international community to look deeper into more effective ways of measuring integrity. The most recent common consensus is that rather than focusing on a one-size-fits all approach, it is necessary to combine several different methods of measurement, or hybrid approaches, in order to establish a more thorough understanding of the norms, incentives and environment that shape corruption or integrity.

UNODC, for example, combines two types of monitoring and evaluation for national anti-corruption strategies: “one that assesses implementation and a second that reviews impact.” This echoes Transparency International’s new approach to evaluating the impact of anti-corruption advocacy campaigns, that includes looking both at policy changes in the public, private and civil society sector, and at behavioural changes in individual people and institutions.

Indeed, the literature available on the topic of measuring corruption reflects the vast range of different approaches, including but not limited to: static versus dynamic analysis, direct versus indirect methods, experience versus perception, and quantitative versus qualitative indicators. Each of these approaches comes with its own set of pros and cons, benefits and disadvantages.

This need for a diversity of approaches is reflected in UNDP’s User’s Guide to Measuring Corruption and Anti-Corruption, which offers a range of tools as well as general principles to consider when designing sound anti-corruption assessments or evaluations, reflecting a shift “from a focus on objectively and precisely measuring corruption to a focus on measuring “around” corruption for good-enough data.”

Following these international practices, the WCO A-CIP Programme team utilises a number of different methods in order to assess the impact of measures which have been implemented and build a thorough enough picture of corruption in Customs.

These methods include:

• Output/Implementation measurement: the extent to which measures recommended by the A-CIP team are implemented, including those adopted as a result of new policies developed within the scope of WCO technical assistance.
• Outcome/Impact: behavioural changes are observed and measured, for example the extent of compliance with new policies, or the application of new knowledge learned.
• Static: the WCO diagnostic tools, including the Integrity Development Guide (IDG) self-assessment tool, are used to analyse the static elements of integrity systems (for example, policy frameworks, institutions) and identify problems and areas of risk which the A-CIP Programme team will need to address.
• Dynamic: working with A-CIP partner administrations, dynamic environmental drivers of corruption are identified, along with opportunities and constraints for addressing them.
• Experience: individual experiences and knowledge relating to corruption are gathered.
• Perception: individuals’ opinions are collected.

Data is collected in both quantitative and qualitative forms, via three main methods:

• Document and material review: administrations share strategic documents, policies, and any other relevant materials to provide a picture of the integrity systems in place.
• Facilitated assessments: using the WCO Integrity Development Guide’s self-assessment tool, WCO experts and administration staff work together to bring to light the current state of integrity within each administration.
• Survey: a Customs Integrity Perception Survey (CIPS) has been developed and piloted under the WCO A-CIP Programme to provide insights into the perceived success rates of each Customs administration in promoting integrity and combating corruption, and collect experience and data on existing behaviours.

The survey has been conducted in ten of the participating countries so far. In total, 2,793 private sector representatives and 3,019 Customs officials have been interviewed. In order to overcome some of the problems with existing corruption measurement surveys, the design of the CIPS questionnaire was based on two important principles:

• each question was designed to collect information that a Head of Customs can act or make a decision on. The objective was to avoid the issue of aggregate data not providing sufficiently specific information, or providing information irrelevant to the realm of Customs administration and operations, such that it becomes impossible to act upon.
• the questions were grouped around each of the 10 key factors of the WCO Revised Arusha Declaration, to help identify priorities for each respective administration and thus optimise the use of limited resources.

It is worth noting that the CIPS is not intended to be used for cross-country comparison or analysis. Most CIPS result variables are ordinal, and a 4-point scale has been applied in order to conduct a quantitative performance analysis. The results form a baseline and the survey will be conducted again, across the lifetime of the A-CIP Programme, in order to enable administrations to measure change and performance.

Along with the general consensus that a ‘hybrid’ approach is necessary, a model to measure integrity has emerged based on the principles of ownership and stakeholder participation, which all WCO Members can refer to.

Several lessons can be drawn here. Firstly, implementing the hybrid model takes time: a certain amount of time and capacity is needed in order to deploy the various methods of measuring integrity (material review, facilitated assessment, and survey). The A-CIP Programme team dedicated its entire first year of work to this process, otherwise known as the “Scoping Phase”. In just the same way that WCO Members should not expect to find one-size-fits-all indicators for integrity, they should also not expect to gather all the necessary information overnight.

Secondly, ownership is key: there are many reasons why international initiatives and indices of corruption tend to have limited impact or utility for national policymakers and implementers. One of them is lack of national ownership. Ownership by the administration offers a greater chance that corruption measurements will be utilized to inform actions and decisions. When entering the WCO A-CIP Programme, administrations become partners and sign Letters of Intent that specify the administration’s role in the collection and utilization of integrity measurement data. Administrations have a clear role in shaping their individual results framework under the Programme, as well as in the deployment of each of the phases (material reviews, facilitated assessments, and CIPS).

Lastly, stakeholder participation in the measurement process – most notably by the private sector – is important. The WCO has always advocated partnerships to combat corruption and enhance integrity, particularly with the private sector, as set out in Principle 10 of the Revised Arusha Declaration. The WCO has outlined the case for Customs administrations to use “Collective Action”, which demands an active and participatory approach by the participants. The A-CIP Programme team promotes the collective action approach and involves the private sector as well as other government agencies and civil society actors, where appropriate, in all methods of data collection. This not only strengthens ownership and credibility, but also aligns with the WCO’s general finding that increased engagement with stakeholders by Customs can greatly facilitate reform initiatives.

Lessons learned will be used to review the Integrity Development Guide (IDG), enabling all administrations wishing to enhance their assessment process to benefit from the experience gained from the deployment of the Programme. Moreover, the survey methodology, questionnaire, implementation process and analysis will be revised as well, as conducting the first surveys has shed some light on ways in which they can be improved. The new survey guidance and methodology will be made available to all WCO Members on request.

In particular, adjustments to the survey implementation process may be necessary to reduce social contact in light of COVID-19. It is worth noting that the A-CIP Programme team has been working remotely with beneficiary administrations since the pandemic, adapting training and capacity development formats in order to ensure continuing assistance. The Programme is on-going and all WCO Members can already benefit from lessons learned on the measurement of integrity in the Customs environment.

More information
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[1] “Corruption in Customs: How can it be Tackled?”, Odd-Helge Fjeldstad, Ernani Checcucci Filho and Gaël Raballand Chapter 4 in Bernard Myers & Rajni Bajpai (Eds.), Global Report on Anti-Corruption 2020, World Bank.

[2] “Measuring Corruption Indicators and Indices”, Article in SSRN Electronic Journal · January 2014, Debora Valentina Malito (2014). Measuring Corruption Indicators and Indices. SSRN Electronic Journal. 10.2139/ssrn.2393335.