How the UK can start to reverse a decade of anti-corruption decline

Transparency International (TI)’s latest Corruption Perceptions Index (CPI) did not offer much good news.

The annual ranking of 180 countries by their perceived levels of public-sector corruption contained a few notable success stories, with Denmark, Finland and New Zealand, for example, each holding on to their position in the top three.

However, the overall picture was bleak. The data showed that 155 countries had made no significant progress or had fallen behind in their efforts to counter corruption since 2012.

In measuring perceived levels of public-sector corruption on an annual, country-by-country basis, the CPI draws on data from 13 external sources, including the World Bank, the World Economic Forum, private risk and consulting firms and think tanks. The data is combined to allocate a corruption perception score on a scale of zero to 100, where zero indicates high levels of corruption.

This year more than two-thirds of countries received a score below 50. The pandemic, the climate crisis and growing security threats were all cited by researchers as potential explanations for the downturn.

However, the performance of the UK in particular is likely to attract attention.

The UK has ‘slumped’ to its lowest-ever CPI rating, moving from a score of 78 in 2021 to 73 last year. Although still in the top 20 countries, therefore, the UK has fallen ‘sharply’ in the rankings from 11th to 18th position. 

UK Corruption Perceptions Index Ranking

This dramatic shift puts the UK alongside Myanmar, Azerbaijan, Oman and Qatar in a list of only five countries who saw their year-on-year scores drop by five points or more in this latest assessment.

Indeed, in TI’s various analyses of the data, the UK has the dubious honour of being mentioned among the ‘most significant five-year movers’, as well as the ‘countries to watch’, alongside Brazil, Sri Lanka and Ukraine.

TI offers several explanations for this. In the period over which the data was collected, the UK has suffered accusations around ‘VIP lane’ access granted to PPE firms with political links; seats in the House of Lords provided to wealthy governing party benefactors; and donations made by large property developers to ministers responsible for housing, all of which has led to what TI calls a ‘worryingly low’ public trust in politics.

The news will come as a fresh blow to legislators after TI’s criticism last year of the UK’s efforts to sanction corruption caused by private companies abroad, as covered by us in a previous piece. 

Amid the noise generated by these figures and the associated speculation, it is worth reflecting briefly on what this could mean for the UK’s private sector.

As usual, this year’s CPI is accompanied by a wide range of recommendations, pitched at both the international and the local level, in the hope that its figures will become a catalyst for meaningful change.

The involvement of private actors in many of the corruption scandals referred to by TI this year shows that this kind of change cannot be achieved without the private sector’s active participation.

We focus briefly below on three of the recommendations with the greatest potential impact on the UK private sector. 

To counteract the worrying trends observed in this year’s CPI, its creators call for ‘anti-corruption agencies and oversight institutions’ to receive ‘sufficient resources and independence to perform their duties’.

Although pitched at the international level, this recommendation could just as easily be directed at the UK. Indeed, it already has been. Last year’s Exporting Corruption report called on the UK to ensure that its Serious Fraud Office had the resources and leadership it needs to carry out its enforcement role effectively.

We have discussed in a previous piece the troubling lack of resourcing observed recently at the UK’s anti-corruption enforcement body. What is notable from this latest development is that lack of resourcing appears to be a global issue, underpinning concerning developments in our efforts to counter corruption more broadly.

In this context, we could feasibly see a renewed focus on enforcement, not just among the UK’s domestic institutions, but also among the enforcement bodies encountered by UK companies on the world stage. 

Pitched again at the international level, the researchers behind this year’s CPI call for the countries within their scope to ‘limit private influence by regulating lobbying and promoting open access to decision-making’.

Again, although the intended audience of the recommendation is broad, the UK could be forgiven for taking this one personally. As set out above, many of the scandals to have occurred domestically in the period over which the data was collated relate to inappropriate influence over public officials by private actors.

This recommendation could add wind to the sails of the ‘Foreign Influence Registration Scheme’, a controversial plan to increase transparency around foreign lobbying of the UK political system, which has been incorporated recently into the National Security Bill as a government amendment.

However, it also has the potential to influence the outcome of the Lobbying and Influence Inquiry currently being conducted by the Public Administration and Constitutional Affairs Committee in the House of Commons, which recently heard calls for stricter regulations around ministerial meetings with lobbyists.

Taken together with these changes proposed in Westminster, the CPI’s recommendations could be seen as part of a broader increase in the scrutiny of public-sector lobbying carried out by private-sector organisations in the UK, bringing the potential for a near-term regulatory response. 

Finally, in a recommendation aimed at the UK specifically, the CPI developers call for an increase in ‘leadership’ and ‘commitment to transparency’ through the establishment of an anti-corruption ‘champion’ and ‘strategy’.

This is not without precedent. John Penrose MP held the position of UK Anti-Corruption Champion until his resignation in June last year amid the ‘party-gate’ scandal. Despite calls for an interim replacement to be appointed, the position has since remained vacant.

One of the UK Anti-Corruption Champion’s key responsibilities is to help ‘drive the delivery of the UK’s Anti-Corruption Strategy’, a framework for the implementation of the government’s anti-corruption policies, including in the private sector. However, this strategy has also remained unrenewed since it expired last year.

The UK is therefore arguably without leadership or clear direction on the issue of corruption and, amid the announcement of its worst ever CPI rankings, it will be difficult for legislators to argue against reinstating both. 

This assessment of the UK’s anti-corruption record has been described by its authors as worthy of ‘alarm bells’.

If these bells ring true in Westminster, where many of the most significant accusations are targeted, we could see a renewed focus on resolving some of the corruption-related issues highlighted by the latest CPI results.

Insofar as the CPI’s own recommendations are taken into consideration as the UK Government decides how to do this, the coming year could feasibly bring:

• Increased action by anti-corruption enforcement bodies, as agencies are given the resourcing and powers they need to follow up effectively on corruption-related scandals
• Stricter rules and transparency around the involvement of private-sector organisations in public-sector decision-making though lobbying activities
• A renewed anti-corruption agenda in the UK, with the establishment of a revised anti-corruption strategy and the appointment of a leadership position to ensure it is implemented 

In the 12 months between now and the next CPI, the UK has a lot of ground to make up. However, the scandals underlying these latest results show us that private actors need to play an active part in this process.

These ‘alarm bells’, therefore, could bring about the first step towards meaningful improvement, but only if the private sector also wakes up to the need for change.

For information on how we are helping clients to meet the increasing demands of international anti-bribery and corruption regulation and best practice, please contact Michael Pollitt or Simon Stiggear.