Anti-Corruption Strategy (UK0065)
Action Plan: United Kingdom – Third National Action Plan 2016-18
Action Plan Cycle: 2016
Lead Institution: Cabinet Office and Home Office
Support Institution(s): All government departments; Bond Anti-Corruption Group (ARTICLE 19, CAFOD, Christian Aid, Corruption Watch, Global Witness, Integrity Action, ONE, Public Concern at Work, The Corner House, Transparency International UK), Campaign for Freedom of Information, International Budget Partnership, mySociety, Natural Resource Governance Institute, Publish What You Pay UK
Policy AreasAnti Corruption and Integrity, Anti-Corruption Institutions, E-Government, Public Participation
Objective: To continue to have a robust cross-government Anti-Corruption Strategy that builds on the existing plan and brings together the UK’s current and up-to-date anti-corruption efforts in one place. The plan will be developed with civil society and delivered with strengthened accountability to Parliament.
Status quo: The first UK Anti-Corruption Plan, published in December 2014, features actions that have now been delivered. A new strategy will meet the government’s commitment to create a living document, which evolves alongside the nature of the threat from corruption and our response both here in the UK and abroad.
Ambition: This presents an opportunity for a new strategy to:
• present a strong strategic narrative around our anti-corruption efforts
• to capture international activity from the Prime Minister’s Anti-Corruption Summit
• to maintain our ambition to develop new commitments in areas of concern
Enhanced engagement with civil society organisations and more accountability to Parliament will help demonstrate the government’s openness to ensuring the principle of transparency is applied to all anti-corruption efforts.
IRM End of Term Status Summary
3. Anti-Corruption Strategy
Commitment Text: To develop, in consultation with civil society, and publish a new Anti-Corruption Strategy ensuring accountability to Parliament on progress of implementation.
Objective:To continue to have a robust cross-government Anti-Corruption Strategy that builds on the existing plan and brings together the UK's current and up-to-date anti-corruption efforts in one place. The plan will be developed with civil society and delivered with strengthened accountability to Parliament.
Status quo:the first UK Anti-Corruption Plan, published in December 2014, features actions that have now been delivered. A new strategy will meet the government's commitment to create a living document that evolves alongside the nature of the threat from corruption and our response both here in the UK and abroad.
Ambition: this presents an opportunity for a new strategy to:
• Present a strong strategic narrative around our anti-corruption efforts
• To capture international activity from the Prime Minister's Anti-Corruption Summit
• To maintain our ambition to develop new commitments in areas of concern
Enhanced engagement with civil society organisations and more accountability to Parliament will help demonstrate the government's openness to ensuring the principle of transparency is applied to all anti-corruption efforts.
1. To consult with civil society on the content of and publish a UK Anti-Corruption Strategy
2. To publish progress against actions within the Strategy
3. To introduce a mechanism allowing greater Parliamentary scrutiny of anti-corruption work
Responsible institution: Cabinet Office and Home Office
Supporting institutions: All government departments, Bond Anti-Corruption Group (ARTICLE 19, CAFOD, Christian Aid, Corruption Watch, Global Witness, Integrity Action, ONE, Public Concern at Work, The Corner House, Transparency International UK), Campaign for Freedom of Information, International Budget Partnership, mySociety, Natural Resource Governance Institute, Publish What You Pay UK
Start date: May 2016
End date: June 2018
The commitment stemmed from a series of anti-corruption initiatives in the second action plan and built on the UK's first Anti-Corruption Plan, published on 18 December 2014. The new strategy created a set of aims against which government action can be assessed or judged. The strategy potentially provided a long-term vision and set of priorities across government for the UK's anti-corruption activities.
At the end of the first year, the commitment's implementation was limited and behind schedule. Although consultation and work has taken place, the publication of the strategy was delayed 11 months beyond its November 2016 deadline.[Note 18: Interview with Alice Pilia and Jeremy Foster, Cabinet Office, 15 August 2017.]
The government cited the change of government in July 2016, the General Election of June 2017 and the need for more time to consult with other governments as the key factors delaying the commitment's implementation.[Note 19: Interview with Alice Pilia and Jeremy Foster, Cabinet Office, 15 August 2017.] CSOs confirmed these factors and felt that a delayed strategy was preferable to a rushed, poor strategy.[Note 20: Interview with Rachel Davies Teka, Transparency International, 14 August 2017. ] Nevertheless, they were disappointed in the delay, as they see this as an important area.[Note 21: Interview with Joseph Williams, 5 September 2017,]
End of term: Substantial
On 11 December 2017 the new 72-page strategy document was published, more than a year later than the government's initial commitment date of November 2016.[Note 22: DFID/Home Office (2017), UK anti-corruption strategy 2017 to 2022, https://www.gov.uk/government/publications/uk-anti-corruption-strategy-2017-to-2022 ] It was intended to pull together cross-government strategy and offer a six-point vision for the UK's anti-corruption activities:
1. Reduce the insider threat in high risk domestic sectors
2. Strengthen the integrity of the UK as an international financial centre
3. Promote integrity across the public and private sectors
4. Reduce corruption in public procurement and grants
5. Improve the business environment globally
6. Work with other countries to combat corruption[Note 23: Ibid.]
Following the concerns of partner CSOs, John Penrose MP was appointed as the anti-corruption champion.[Note 24:  John Penrose (2017), John Named Anti-Corruption Champion, http://johnpenrose.org/wp/2017/12/11/john-named-anti-corruption-champion/ ]
According to the final government update of April 2018 the Joint Anti-Corruption Unit are now working with departments to implement the strategy and have developed a monitoring and evaluation framework, which was signed off at the cross-Whitehall Directors' meeting on Anti-Corruption.[Note 25: UK government (2018), 2016-18 Open Government Action Plan: April 2018 Commitment Progress Updates, https://www.opengovernment.org.uk/resource/2016-18-open-government-action-plan-april-2018-commitment-progress-updates/ ] In Decmeber 2018, outside of the timeline, the government published an update to the strategy[Note 26: See Home Office (2018) Policy paper Anti-corruption strategy: year 1 update: https://www.gov.uk/government/publications/anti-corruption-strategy-year-1-update]
While the strategy itself has been published, the move to publish details of what progress is being made is reportedly ‘ongoing' across government.[Note 27: Interview with Katie Holder and Thom Townsend, DCMS, 8 August 2018: UK government (2018) 2016-18 Open Government Action Plan: April 2018 Commitment Progress Updates, https://www.opengovernment.org.uk/resource/2016-18-open-government-action-plan-april-2018-commitment-progress-updates/ ] In terms of the reporting mechanism, it has been decided, according to the UK government, that the parliamentary accountability mechanism will be via an annual written update.[Note 28: Interview with Katie Holder and Thom Townend, DCMS, 8 August 2018.]
Did It Open Government?
Access to Information: Did Not Change
Civic Participation: Marginal
Public Accountability: Did Not Change
The strategy represents an important step forward, but time will be needed to see how or whether the strategy works as a blueprint or guide for action and if it provides the ‘vision' across government that many argued was needed.
The strategy was broadly, if cautiously, welcomed by civil society. The Bond anti-corruption group welcomed the breadth and remit across domestic and international politics, the appointment of a new champion, the maintenance of the Serious Fraud Office and requirement that the government report annually to Parliament. However, it qualified this by saying ‘the Bond Group also feels that in several places the Strategy does not go far enough - for example, on transparency in the Overseas Territories, corruption in UK politics, golden visas and on a criminal corporate liability offence'.[Note 29: Bond Group (2017), UK makes welcome anti-corruption commitments, now action is needed,
https://www.bond.org.uk/press-releases/2017/12/uk-makes-welcome-anti-corruption-commitments-now-action-is-needed ] Transparency International also called the strategy a ‘welcome advance in the fight against corruption both at home and abroad' but made a similar point that ‘the Strategy fails to address corruption in UK politics and avoids confrontation with Britain's infamous offshore financial centres'.[Note 30: Transparency International (2017), Transparency International gives qualified welcome to new UK Anti-Corruption Strategy, http://www.transparency.org.uk/press-releases/transparency-international-gives-qualified-welcome-to-new-uk-anti-corruption-strategy/#.Wjfgn3nLjIW ]
So far, access to information and public accountability have not improved, especially as the parts of the commitment that track progress were incomplete. The strategy did not contain any new information or open up any new areas. There was a marginal improvement on participation, as members of the Bond group were involved in the consultation and met with government for face-to-face discussion in the summer of 2016. The government accepted that the strategy should cover domestic corruption, the UK's international influence, and the nexus between the two regarding, for example, illicit financial flows.[Note 31: Correspondence with Rachel Davies Teka, Transparency International UK, February 2019] The measuring of progress and annual reporting to parliament will provide a means of understanding its effects into the future, though this may depend on what form it takes (e.g. if there are questions in parliament).
This commitment was not carried forward into a new action plan.