Query
What are the pros and cons of establishing hotlines for reporting
on instances of corruption or suspicions of corruption for
aid agencies? Which aid agencies have established such hotlines?
What are their routines for such hotlines? Have any reports
or literature been written on this topic?
Content
Part I sets out the advantages and challenges
of establishing an anti-corruption hotline.
Part II describes existing aid agency
anti-corruption hotline procedures.
Part I: Advantages and challenges of establishing a hotline
In this section we outline the many advantages - and challenges - of
establishing hotlines to facilitate reporting of suspected corruption.
We also include here some recommendations for best practice. We have
synthesised the advantages, challenges and lessons learned from a variety
of sources and we provide links to key reports in Part III of this response.
We especially recommend the report "Public
Service Commission Report on Anti-corruption Hotlines" (April
2002).
What are the advantages in having a hotline?
To deter potential fraudsters so employees and stakeholders aware
that the aid agency is not a soft target.
To raise awareness that the aid agency takes corruption seriously.
To detect incidents of fraud by creating a channel through which
irregularities may be reported.
To assist aid agencies in identifying corruption risk areas so
that preventive and detective control measures can be improved or
developed.
Allowing hotline callers to anonymously report corruption encourages
whistle-blowers.
To help policy-makers take concrete action on corruption and be
seen by the public to take action.A hotline is a relatively clear
and simple concept to package and present to the public
The following recommendations address common challenges
associated with establishing a hotline:
Hotlines should be introduced as part of a larger anti-corruption
strategy, with special attention paid to management issues and infrastuctural
demands.
The hotline must be supported by management buy-in and management
political will. Elements such as staffing, authority to receive
and evaluate information and the relationship and responsibilities
of other departments should be included in the hotline establishment
documents from the outset.
The day-to-day running of the hotline system should be at the
appropriate management level to ensure the cooperation and compliance
of subordinate organizational elements.
Reporting channels should include a dedicated local area/toll-free
telephone number; a specific address or Box number for correspondence;
and an email form for complaints. Consider the technological capacity
of the locality where the hotline operates.
Care should be taken so that the phone lines do not collapse under
excessive caller response. Take similar care that email capacity
is not overwhelmed and ceases to function.
Specific hours should be established during which information
can be reported: such hours should allow for calls before and after
normal working hours.
Have clear, effective operational procedures for logging calls
and callers and recording complaints.
Clear procedures for deciding whether and how to follow up should
be determined. Complaints may be followed up internally or referred
to external authorities or agencies.
Hotlines need adequate budgets.
Consider human resources in terms of number, expertise and skills
of hotline staff. Experienced and trained operators should be on
duty who are capable of explaining to callers all their rights and
of proposing a basic strategy for resolving their problems.
A specific training course is needed to support the specialized
staff working on hotlines. Staff should be trained in distinguishing
corruption from other crimes or inefficiencies.
Establish an evaluation and data capturing mechanism: how is the
success of the hotline measured and what data is available about
number and nature of calls? NB consider that disclosure of specific
reported cases may not be appropriate given the need to protect
the anonymity of callers and the confidentiality of information.
To encourage whistleblowers from within an aid agency it must
be clear that the hotline infrastructure is separate from the rest
of the aid agency and that a whistle-blower's anonymity is not compromised.
Consider giving feedback to the callers (where they identify themselves)
by reporting back to them what has happened.
The hotline must be successfully and continually publicised so
that employees and stakeholders are aware of this option for reporting
corruption.
The publicity surrounding the hotline and the programme itself
should avoid negative perception of callers and whistle-blowers.
Publicity should emphasise how avoiding and tackling corruption
can avoid waste and inefficiency as well as protect jobs.
Aid agency employees should be educated about how the hotline
operates and what is to be reported. They should have an understanding
of what is meant by corruption.
Hotline information (posters etc) should be displayed prominently
in the aid agency and other locations where the aid agency works.
Publicise successful actions taken as a result of hotline information,
and reward the personnel providing the information as an incentive
for others to come forward.
Again, it is essential to develop a Standard Investigating Procedure
for the hotline investigation unit. Make sure there is a follow-up
to the complaints and allegations made.
Part II: Current experience with aid agency anti-corruption hotlines
We have located information on the World Bank and Danida's
hotlines.
World Bank
The following information was taken directly from the World
Bank website:
The Bank's anti-corruption initiatives related to its own lending
portfolio are spearheaded by the Department of Institutional Integrity
(INT), an independent unit reporting to the President. INT investigates
allegations of fraud and corruption in Bank-financed projects, as
well as allegations of possible staff misconduct, and refers its findings
to decision makers such as the Bank's Sanctions Committee for action.
The Bank maintains an international hotline (1-800-831-0463) to receive
allegations of possible corruption, and reports also can be made to
the INT team online. It accepts and investigates complaints of abuse
recounted by Bank staff and the public both within the United States
as well as internationally. The hotline operates 24 hours per day,
seven days a week. It is operated by an independent firm staffed by
multilingual, trained specialists, who work within the guidelines
of strict universal standards of confidentiality. Investigations that
involve staff members are conducted in full compliance with staff
regulations.
The Department of Institutional Integrity can also be contacted directly.
The Department conducts a preliminary inquiry of each allegation submitted,
which includes an interview of the person submitting the allegation
when possible, and at least a preliminary document review. Based on
those elements it then decides whether to conduct a full investigation.
Investigations can result in the withholding or cancellation of
loans with countries sometimes having to repay loans affected.
Possible reasons include contract irregularities and violations of
the Bank's procurement guidelines, bid rigging, collusion by bidders,
fraudulent bids, fraudulent contracts, bribery, and misuse of Bank
funds or positions.
Involvement of Bank staff in irregularities can lead to termination
of their contract and legal actions. As for firms and external
individuals involved in irregularities the Bank can debar them from
future contracts it finances, for a stated or unlimited period of
time. Currently about a hundred firms and individuals are on a
public 'blacklist'. Debarment decisions are made by the Bank's
Sanctions Committee, appointed by the President and composed
of Bank senior staff, two managing directors and the Bank's legal
counsel, which reviews the findings of investigations. The Bank says
information-sharing procedures with other international financial
institutions are in place, which can lead to a Bank investigation
if a company is under fire from another multilateral development bank,
for example. However there is no rule or mechanism that would automatically
trigger multiple debarments.
An evaluation of the Bank's hotline was done by Richard Thornburgh
of Kirkpatrick & Lockhart LLP, a former US Attorney General and
Deputy Under Secretary to the UN, and completed in January 2000. The
reference is: Thornburgh, R., Gainer, P. & Walker, C. (2000).
'World Bank: Concerning Mechanisms to Address Problems of Fraud and
Corruption'. Report to Shengman Zhang, Managing Director and Chairman
of the Oversight Committee on Fraud and Corruption, 21 January (rev.),
(internal document).
Danida Anti-Corruption Hotline
The following information is taken from
Danida's website:
If you encounter cases of corruption, Danida would like you either
to disclose these cases to the responsible Danida contact, to contact
Danida direct through the Hotline, or by sending a letter to the Ministry
of Foreign Affairs of Denmark. Danida guarantees that your report
will remain confidential or anonymous if you so wish.
Danida's fight against corruption is based upon trust and integrity.
Danida guarantees that your report will remain confidential and will
only be seen by the persons in Danida's anti-corruption task force.
You can choose to remain anonymous. That means, however, that in certain
situations Danida cannot proceed with an investigation of the conditions
that you have reported as corrupt. Furthermore, an investigation will
always be more difficult to undertake if it is based on an anonymous
report.
In some situations the case will be handed over to a lawyer or the
police. The measures taken in case of corruption are based on an overall
assessment and with two main considerations: the level of corruption
and the will to rectify evident misuse.
"Hotlines and other reporting mechanisms are potentially valuable
if properly managed. A screening process would help reduce false accusations.
Independent investigations and protecting whistle-blowers are important
elements. Donors should work individually to create these protections
and share lessons in properly managing hotline-style operations."
"The
TI Source Book" has tips on setting up an anti-corruption
hotline. Although this refers to government or NGO hotlines the advice
is applicable to aid agencies too.
From the Source Book: "Increasing use is being made of telephone
"hotlines" to facilitate the making of complaints by aggrieved
members of the public. For example, two types of anti-corruption hotlines
operate in the Ukraine. There, a government hotline allows workers
to phone in complaints concerning tax offices. However, the government
hotlines have not yet gained public trust, as they are run by government
officials. The hotline established by the Citizens Advocacy Office
(CAO) … is the more widely used. Their hotline is open 24-hours
a day and is answered either by an operator or an answering-machine.
Where complaints are anonymous they are documented, and as and when
patterns emerge, appropriate action is initiated. … This is not
to suggest that no government department should run hot-lines. Clearly
there are departments in various countries who run these perfectly
satisfactorily, be it police, tax, or customs. But where public trust
is lacking, a government agency can join in a strategic partnership
with a respected NGO to provide a hotline service to the agency."
