PROMISE TO PRACTICEMONITORING GLOBAL PROGRESS OF THE 2016 ANTI-CORRUPTION SUMMIT COMMITMENTS

UNDER STRICT EMBARGO UNTIL 19TH SEPTEMBER 2017, 1300 BST

Transparency International (TI) is the world’s leading non-governmental anti-corruption organisation. With more than 100 chapters worldwide, TI has extensive global expertise and understanding of corruption.

Transparency International UK (TI-UK) is the UK chapter of TI. We raise awareness about corruption; advocate legal and regulatory reform at national and international levels; design practical tools for institutions, individuals and companies wishing to combat corruption; and act as a leading centre of anti-corruption expertise in the UK.

Acknowledgements:

Author: Lucas Amin

Editors: Robert Barrington, Rachel Davies Teka, Duncan Hames, Casey Kelso, Maggie Murphy, Jameela Raymond, Deborah Unger

Design: Jon Le Marquand

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Published September 2017.

ISBN: 978-1-910778-73-9

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Promise to PracticeMonitoring global progress of the 2016 Anti-Corruption Summit commitments.

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IntroductionIn May 2016 then-UK Prime Minister David Cameron convened 43 countries and six international organisations at an Anti-Corruption Summit, in London. The Summit didn’t just generate a declaration against corruption, but instead encouraged countries and organisations to pursue ambitious individual action plans. There were 648 promises made to promote integrity and defend against corruption across 20 issues.

The purpose of this report is to evaluate what the Summit’s participants have since achieved. A great deal has changed since last May, and new leaders with different priorities are at the helm of key countries. Have countries kept their promises?

Following the Summit, Transparency International and a network of partner organisations began monitoring the implementation of pledges: 384 made by governments and 69 by international organisations. The Summit announced the 2017 United Nations General Assembly as a point in which progress would be reported; now is a good time to take stock of what the Summit has delivered, and what it still can.

Transparency International’s pledge-tracking database is published as open data, and is available for download1, for those who wish to review the performance of a country, region or theme. This short report presents a high-level briefing on a handful of key issues, as well as significant case studies and an overview of the pledge tracking data.

The first section of this report summarises the results and describes five trends in the delivery of anti-corruption commitments. Section two reviews the progress made in the three areas which attracted the most pledges: beneficial ownership, asset recovery and public procurement.

Section three highlights three areas that did not receive enough attention at the summit and still require greater attention. Finally, Transparency International offers some conclusions and recommendations on what needs to happen next to ensure that the Summit efforts are not wasted.

1 Search through the full findings at our interactive website: anticorruptionpledgetracker.com

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I. Post-Summit Delivery on Anti-Corruption Pledges

Two thirds of the 384 commitments made by governments at the Summit are either complete, ongoing or underway.

The results are encouraging, but it is too early to call the Summit a major success, because only 18 per cent of pledges have actually been completed. Table 1 shows a summary of the pledges’ status by anti-corruption theme.

After the Summit, Transparency International analysed government pledges from 41 countries and the European Commission, in different phases.

1. Pledges were classified as ‘ambitious’, ‘somewhat ambitious’ or ‘not ambitious’.2. Pledges were graded as ‘new’, ‘somewhat new’ or ‘not new’.3. Pledges were categorised as ‘concrete’ or ‘somewhat concrete’. All ‘not concrete’ commitments were

removed from the final analysis.

Of the 648 commitments in this sample, a selection of 384 pledges across 27 countries was assessed on their progress:

• Inactive – no activity on the commitment, or there is no publicly available evidence of progress• Ongoing - a pledge has no fixed end-date but progress has started• Complete – the commitment has been fully delivered• Underway – the work to implement the pledge is not yet finished• Overdue – not completed by the deadline

A full methodology can be found in the annex.

Total Pledges Complete Inactive

 # # % # %

Beneficial Ownership 67 9 13% 25 37%

Asset Recovery 47 11 23% 14 30%

Public Procurement 42 9 21% 6 14%

Tax 30 9 30% 9 30%

Anti-Money Laundering 28 4 14% 7 25%

International Anti-Corruption Architecture 25 4 16% 9 36%

Sports 18 3 17% 6 33%

Law Enforcement 17 4 24% 6 35%

Natural Resources 16 1 6% 6 38%

Whistleblower/Civil Society Space Protection 14 5 36% 2 14%

Training and assistance 14 2 14% 6 43%

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Anti-Corruption Environment 12 1 8% 1 8%

Open Data 10 2 20% 1 10%

Public Sector Integrity 10 2 20% 2 20%

Innovation 10 2 20% 5 50%

Private Sector 8 1 13% 2 25%

Denial of Entry 6 2 33% 0 0%

Defence and Security 4 0 0% 2 50%

OECD 4 0 0% 4 100%

Bribery 2 0 0% 1 50%

Total 384 71 18% 115 30%

Table 1. Status of pledge by issue.

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1. Political will was a key to success Political will was an important factor in delivering Summit commitments. When governments demonstrated that they wanted change by making ambitious pledges, they were more likely to achieve it. Ambitious commitments have the highest completion rate, at 20 per cent, and the lowest rate of inactivity (19 per cent) of all pledges within this schema. New and ambitious commitments have seen the highest rate of delivery, with 69 per cent of these being marked as complete, ongoing or underway.

Sitting on the fence, by contrast, did not yield results. Somewhat ambitious and somewhat new pledges – which often reflect a lack of intent – had much poorer implementation rates. Just four per cent of these commitments have been completed, and 59 per cent haven’t been started at all.

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Total Complete Inactive Ongoing Overdue Underway

  # % # % # % # % # % # %

Ambitious 135 100 27 20 25 19 34 25 7 5 42 31

New 64 100 12 19 16 25 15 23 4 6 17 27

Not New 65 100 14 22 7 11 19 29 3 5 22 34

Somewhat New 5 100 1 20 2 40 0 0 0 0 2 40

Somewhat Ambitious 117 100 16 14 49 42 18 15 6 5 28 24

New 46 100 5 11 20 43 5 11 3 7 13 28

Not New 44 100 10 23 13 30 10 23 3 7 8 18

Somewhat New 27 100 1 4 16 59 3 11 0 0 7 26

Not Ambitious 80 100 15 19 28 35 14 18 1 1 22 28

New 11 100 1 9 5 45 2 18 0 0 3 27

Not New 59 100 13 22 19 32 8 14 1 2 18 31

Somewhat New 10 100 1 10 4 40 4 40 0 0 1 10

Other 20 100 7 35 6 30 2 10 2 10 3 15

No Information Available 32 100 6 19 7 22 9 28 0 0 10 31

Total 384 100 71 18 115 30 77 20 16 4 105 27

Table 2. Status of ambitious and new pledges

The data on ambitious pledges also suggests that the format of the Summit led to some success. The Summit broke with the practice of other consensus-based, multilateral forums such as the G7 and G20, where all participants must subscribe to a single declaration. This allowed some, although not all, governments to be ambitious in their individual country statements. And ambition, generally, led to action.

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2. Two unanticipated standout performers: Spain and Indonesia

Analyses by TI’s in-country chapters found that Spain and Indonesia were the standout performers of the Summit. The two countries are responsible for 51 per cent of all the completed pledges, however, only 13 per cent of Indonesia’s completed pledges were new, in comparison to 40 per cent of Spain’s. These results do not mean that Spain and Indonesia have solved their well-documented corruption problems, but it offers encouragement that they are serious about tackling them.

France, Mexico and the UK complete the cluster of stronger performing countries and have each completed six pledges, although France is overdue on three pledges and Mexico is inactive on six, while the UK is overdue on three commitments and inactive on another three. The majority of both France and the UK’s overdue and inactive pledges were classified as new, which suggests these governments might yet improve their results in time.

3. Three high-income laggards: Japan, Switzerland and United States of America Four countries are responsible for close to half of the country commitments on which no action is being taken. Afghanistan, Japan, Switzerland and the USA are inactive on a total of 52 of the 115 inactive pledges. It is perhaps unsurprising that Afghanistan’s highly ambitious programme is mostly inactive, but the poor performance of three high-income global financial centres is more noteworthy.

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Switzerland and Japan stand out among the Summit’s worst performers. Their rates of inactivity were 77 per cent and 68 per cent, respectively. Moreover, all of their pledges were graded not new or somewhat new, which suggests that a lack of time to implement commitments was not a hindrance. The USA is inactive on 55 per cent of its Summit pledges, even though more than half of its pledges were also not new, and the new administration’s commitment to anti-corruption remains to be seen.

Three highly significant governments, which each regulate major economies, disperse US$ billions in aid and are usually expected to show global leadership, failed to take effective action against corruption following the Summit. This has held back overall progress since the Summit.

4. Works in progress: Argentina, Colombia, France, Mexico and Nigeria Twenty seven per cent of government commitments are classified by Transparency International as underway. The average number of underway pledges is five - but a handful of governments have 10 or more. These include Argentina, Colombia and Mexico in the Americas, and France and Nigeria. In the case of Argentina, Colombia and France, six or more of their underway pledges were not new, which raises concerns about their delivery process. The final outcomes of the 105 underway pledges, particularly in these countries, will further shape the legacy of the Summit.

A further 20 per cent of government pledges are classified as ongoing. Mexico, Russia and Colombia each have eight ongoing pledges, which accounts for nearly one third of the total. Whether these pledges remain ongoing in years to come will also define the Summit’s ultimate impact.

5. International OrganisationsUnlike the commitments made by governments and the European Commission, which were assessed by TI chapters and national contacts, the remaining international organisations self-reported on their progress.

Total Complete Inactive

# # % # %

Commonwealth Secretariat 13 2 15.4 7 53.8

European Commission 1 0 0.0 0 0.0

International Monetary Fund 8 2 25.0 0 0.0

OECD 12 0 0.0 0 0.0

United Nations 23 0 0.0 3 13.0

World Bank 12 1 8.3 0 0.0

Total 69 5 7.2 10 14.5

Table 3. Status of pledges by international organisations

International Organisations have started making progress, but have completed relatively few of their commitments in the 16 months since the Summit. Although their average completion rate of seven per cent is less than half the government average of 18, only the Commonwealth Secretariat and the UN have any inactive pledges. The Commonwealth Secretariat stands out as the worst performing organisation with more than half of its 13 pledges inactive, although it has completed two. The Commonwealth Summit, to be held in the UK in April 2018, will be another opportunity for the Commonwealth Secretariat to showcase its international anti-corruption work on a global platform.

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Almost half of the 69 pledges are reported as ongoing and many relate to the continuation, promotion or expansion of existing anticorruption initiatives. This suggests that governments now have additional capacity and resources in the fight against corruption.

The UN is responsible for half of the underway commitments that have not yet been delivered – while the World Bank owns another quarter. Thus, the jury is still out on whether these two organisations have made a success of the Summit.

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II. Key Anti-Corruption Themes

1. Beneficial Ownership

Sixty seven of the 384 government pledges relate to beneficial ownership, which makes it the issue to have received the most attention. Table 4 shows the delivery status of these pledges broken down by focus theme.

Beneficial Ownership Total Complete Inactive Ongoing Overdue Underway

Public Register 10 1 2 3 1 3

Public Contracting 9   6 1   2

Central Register 7 2 1     4

Property 7   2 2   3

Global Beneficial Ownership Register 1       1  

Table 4. Status of Beneficial Ownership commitments

Public registers, African promise

Among the most significant commitments at the Summit were the 10 pledges to create or explore the creation of public registers of information on the people who ultimately own or control companies (known as “beneficial owners”). Public registers of beneficial ownership are effective tools because they facilitate the work of domestic and international law enforcement, as well as civil society and the media, by guaranteeing free and immediate access to data.

The UK launched its public register in June 2016, although the policy long predated the Summit. Three African states who announced their register pledges at the Summit have since taken promising steps towards implementation. Ghana amended its company law in August 2016 to mandate the company registrar to

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collect data and maintain a register of beneficial ownership but the register is not yet public. A provision in a new bill, which would correct this, has been drafted and civil society groups hope it will be read in Parliament before the end of 2017.

The Ghanaian bill’s success will depend on the support of the New Patriotic Party and its leader Nana Addo Dankwa Akufo-Addo, who was elected President in January. In opposition, Afuko-Addo said it was necessary to “lift the veil off public officials who hide behind cronies to amass wealth”. Ghana and the international community are now watching to see if President Afuko-Addo and his party will deliver a public register.

In Kenya, a bill to introduce a register of beneficial company ownership had its third reading in June; however, it does not currently include commitments to make the register public. Nigeria, meanwhile, is preparing a bill on beneficial ownership after it sent a delegation to the UK in February to exchange information and learn about register design. These countries, if they can push through their Summit pledge to implement public registers, will set a precedent on the African continent.

Beyond national borders: public contracts and property Sixteen commitments focused on creating registers of beneficial ownership for all companies, domestic and foreign, involved in public contracting and buying property. Six of the nine pledges on public contracting are inactive, which perhaps reflects the challenge of the task, although governments are doing better with property (only two of seven are inactive). The UK, which made commitments in both areas, ran a public consultation in the spring and has committed to introduce primary legislation by April 2018.

Open Ownership: standardising data for quality and comparabilityOpen Ownership is a global civil society initiative that was created in the wake of the Summit. It has three functions. Firstly, it links beneficial ownership data from multiple sources to create a single, global source of information which is easily accessible to stakeholders. Secondly, it develops a common data standard so that information from multiple jurisdictions meets a commonly defined norm and can be linked and compared. Finally, it provides technical support to help stakeholders with implementation and best practice. Open Ownership currently hosts data from the UK, Slovakia and the Extractive Industries Transparency Initiative – a global standard for disclosing information about oil, gas and mining sectors that now has 52 government signatories.

Colombia, the only country to make a Summit pledge to provide data to Open Ownership’s global register, has not yet submitted any information. However, in May Ukraine became the first country to agree to integrate its beneficial ownership data with the global register, which means the Ukrainian information in Open Ownership will automatically update in line with Ukraine’s database.

2. Asset RecoveryAsset Recovery was another major theme of the Summit and attracted 47 of the 384 government commitments. Table 5 shows the delivery status of these pledges broken down by focus theme.

Asset Recovery Total Complete Inactive Ongoing Overdue Underway

Accountable Repatriation 16 4 6 3   3

Global Forum on Asset Recovery 4 1 1   2

Unexplained Wealth Orders 6 1 1 2 1 1

Table 5. Status of Asset Recovery Commitments

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The Global Forum on Asset Recovery

Asset recovery initiatives are often costly, long-term, multi-party, multi-jurisdictional efforts that are not always successful. At the Summit, four countries and two international organisations pledged to participate in the Global Forum on Asset Recovery (GFAR), which aims to improve outcomes by addressing the need for strong political commitment, international cooperation and practitioner interaction.

The GFAR, which was originally scheduled for July 2017 but postponed until December 2017, will focus on assisting recovery in four countries; Nigeria, Sri Lanka, Tunisia and Ukraine. The US and the UK will co-host with support from the World Bank and UNODC. Nigeria’s priority is expected to be the return of the ‘Abacha loot’ - the estimated US$5 billion which the former military dictator appropriated in the 1990s and hid in numerous offshore locations. Debate is likely to focus on the US$480m that was forfeited to the US Department of Justice in 2014, but not yet returned to Nigeria.

Two of the many obstacles the recovery has faced include a US legal challenge to the asset forfeiture (dismissed in February 2017) and a bill in the US Congress which stipulated that the returned money should support victims of Boko Haram. The latter triggered a debate about national sovereignty and the accountable management of returned assets, including the rights of other states to impose conditions on them.

The Abacha case reflects many of the common challenges in asset recovery cases. Nearly 20 years after the dictator’s death, Nigeria has had returned only a fraction of the money which was laundered through Europe and America. For the GFAR to work, its hosts and participants will need to step up their ambition and cooperation.

Accountable repatriation

More than one-third of asset recovery pledges were on accountable repatriation but a closer reading of the data suggests the Summit was not particularly effective on this issue. Half of the 16 commitments focused on the development of “internationally endorsed guidelines for the transparent and accountable management of stolen assets”. Yet five of these pledges are inactive - in Afghanistan, Argentina, Mexico and Switzerland (x2) - and only one is complete (in Spain), suggesting that no government has taken the lead in developing the guidelines so many have committed to. Given the lack of progress, and the upcoming GFAR, one potential next step for the World Bank and UNODC would be to begin devising an international framework to assist the drafting and adoption of new guidelines.

Spain and Switzerland

According to our national chapters’ analysis, the standout performer on asset recovery was Spain, which completed all five of its pledges. The country’s new Asset Recovery and Management Office became fully

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operational in January and staff have been trained on how to enforce legislation passed in 2015 on non-conviction based confiscation, extended confiscation and confiscation of third-party assets. Switzerland, by contrast, did not complete any of its four commitments (none of which were new). Yet this is not to say that Spain’s asset recovery system is better than Switzerland’s - some experts would say the opposite – merely that the countries’ momentum appears to be taking them in opposite directions. Switzerland is the only country to return a significant amount of the ‘Abacha loot’ - more than US$700 million at the last count.

3. Public ProcurementProcurement was another major theme of the Summit and attracted 42 of the 384 commitments. Table Six shows the delivery status of these pledges broken down by focus theme.

Public Procurement Total Complete Inactive Ongoing Overdue Underway

Corrupt Bidders 6 1 3 2

Debarment 1 1

Debarment Database 7 1 2 1 1 2

Open Contracting 6 1 2 3

Open Contracting Data Standard 9 2 1 1 5

Open Contracting in Health 3 2 1

Table 6: Status of procurement commitments

Mexico: an emerging leader in open contracting

Mexico is emerging as a global leader within the growing field of open contracting. The country is making good progress on its six procurement pledges (twice as many as any other country) with two complete, two ongoing and two underway.

Mexico has successfully implemented the Open Contracting Data Standard (OCDS) in its flagship infrastructure

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project, the New International Airport for Mexico City, worth US$13 billion. Data and documents from the tender and awards of US$7.3 billion worth of contracts, in 291 procedures, are now accessible on an intelligently designed platform. The country’s second flagship open contracting project, a Public Private Partnership (PPP) in the telecoms industry worth approximately US$392 million, launched in June. With support from the World Bank, the project is piloting the first PPP extension of the OCDS.

The Mexican government is now aiming to scale the implementation of OCDS to all federal public contracts and plans to launch the beta version of a new procurement platform before the end of 2017. Mexico was also a founding member of the Contracting 5 (C5) - a global network for governments to share procurement ideas and innovations. Mexico was the C5’s first President and has led on website development and accession processes for new country members - both of which should be launched at the Open Contracting Summit in November.

Open contracting in health

Four governments committed to implementing open contracting in their healthcare sectors at the Summit and there is encouraging progress to report. Argentina’s Ministry of Health began using a transparent e-Procurement system in January while Nigeria’s new open contracting portal - co-created with civil society - will be piloted by the Ministry of Health and the National Primary Health Care Development Agency. Mexico has made progress through its whole-government approach described above - while Malta, the fourth country to make a healthcare pledge, is not within TI’s sample of countries. The UN made a pledge to work with the WHO to strengthen global, regional and country initiatives on open contracting in health, but this is currently inactive.

Debarment and corrupt bidders

Fourteen pledges looked at strengthening procedures for debarring corrupt companies from public tenders - primarily by creating or improving central databases and sharing data across borders. Only two commitments were ambitious and, instead, most pursued commitments that sought to “explore ways of sharing information”. 36 per cent of the pledges on debarment are currently inactive or overdue - in Brazil, Jordan, New Zealand and Switzerland (x2) - but even among the active countries, it does not appear that any government has found a strong solution to the challenge of debarring bidders and sharing information effectively. The World Bank’s pledge to share information on its efforts to debar bidders and share information, which is underway, could be instructive when completed.

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III: Looking ahead Numerous issues did not receive the attention they deserved at the London Anti-Corruption Summit in May 2016, or in the 16 months that followed. Four areas that still require greater action are sport, law enforcement, professional enablers and whistleblowing.

SportEvents in recent years have reminded the world that sport is still at serious risk of corruption. As a multi-billion dollar business with close ties to political and private interests, international stakeholders must work closely together to minimise that risk.

The Summit saw governments make 18 commitments around sport, specifically on governance, integrity in sport, and the development of an International Sports Integrity Partnership.

The International Sports Integrity Partnership was launched in February 2017 in Lausanne, Switzerland, and plans to help prevent the risk of corruption in sport, enable better cooperation between key stakeholders and ensure a coordinated approach to the implementation of dedicated measures. Afghanistan, France, Georgia, Jordan, New Zealand, Spain, Switzerland and the UK pledged to support or join the Partnership. However, the concrete steps that the Partnership intends to take are yet to be made public.

People from all backgrounds, all around the world, have a stake in keeping sports clean. Sponsors, athletes, supporters, governments, journalists, business people, and those within sporting organisations could form a powerful partnership for sending a strong message that integrity in sport is non-negotiable. It will be important to watch the International Sports Integrity Partnership closely, measuring its effectiveness further down the line.

Law EnforcementMost cases of grand corruption are cross-border, and the inability of law enforcement bodies to operate in multiple jurisdictions has, for a long time, been something of an Achilles heel.

Twelve countries sought to address law enforcement cooperation at the Summit and made pledges towards creating or supporting the International Anti-Corruption Coordination Centre (IACCC). The centre was formally launched in July by the UK’s National Crime Agency, which will host the centre until 2021, with the participation of bodies from Australia, Canada, New Zealand, Singapore and the US. The IACCC is a forum for sharing intelligence between the primary jurisdictions in which stolen assets are laundered and for coordinating cross-border law enforcement investigations in countries where companies are known to bribe for public contracts. It also accepts referred cases of grand corruption from external law enforcement bodies.

The IACCC could be the catalyst for change towards a new chapter of greater international cooperation between law enforcement bodies. Its success will hinge on securing intelligence sharing commitments from governments that regulate global financial centres. Although Switzerland has participated in the development of the Centre, and completed its somewhat ambitious pledge, its government has not committed to full participation and the sharing of intelligence. Interpol is expected to join the Centre before the end of the year.

The IACCC will also require meaningful participation from countries where bribes are paid for public contracts. Political will and robust resources are crucial for intelligence agencies to function at their full potential. Law enforcement bodies from across the world, with different levels of funding and expertise, will need to collaborate pragmatically to pursue and prosecute criminals.

Professional Enablers Asset recovery can be a relatively expensive and challenging process and, while it remains absolutely necessary, it is logical that governments should do more to prevent the illicit transfers of assets abroad from happening in the first place. This may sound common-sense but a crucial vulnerability remains in the integrity systems of almost all countries. To steal, hide and spend corrupt money, criminals rely on networks of lawyers, bankers and estate agents, but regulation and enforcement against these ‘professional enablers’ is patchy and weak.

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The Summit participants in Transparency International’s sample did not effectively address professional enablers of corruption. In the context of tax evasion, France, Mexico and Nigeria pledged to review or enhance penalties against professional enablers but the latter two pledges are inactive while France’s is underway. Despite a growing acknowledgement of the problem in the run-up to the Summit, these three pledges were the sum-total of action against enablers.

The difficulties of developing and enforcing workable regulations are leading to a debate about whether a shift in focus would be productive. A small but growing number of countries are introducing banking regulations that ensure senior company executives can be held individually accountable for the non-compliance of their companies with anti-money laundering regulations. This principle of executive accountability could be deployed more widely to promote a reappraisal of the risk of handling tainted money in professional services.

Whistleblowers The clear consensus among anti-corruption experts is that whistleblowing serves an important democratic function, but many of those who speak out in the public interest continue to face professional persecution, as well as civil and criminal lawsuits. There are whistleblowers in jail in all regions of the world.

A mere seven pledges to protect whistleblowers were made by six countries at the Summit. In one of these countries, the UK (which is inactive on a pledge which is unfortunately both ambiguous and unambitious), proposals were drafted by the Law Commission to increase criminal penalties for whistleblowing from two to 14 years. This shift toward greater persecution broadly reflects the negative global direction of travel.

France, however, which completed both its whistleblowing pledges, stands out for the right reasons. The anti-corruption law 2016-1691 (9 December 2016), which is also known as ‘Sapin II’ after the Finance and Economy Minister Michel Sapin who drove it through Parliament, enshrines several protections for whistleblowers. This includes the exoneration of criminal responsibility for disclosing public interest information under certain conditions, the opportunity for whistleblowers to seek guidance and assistance from an independent body (called the Defender of Rights), and criminal and civil sanctions that guard against reprisals and defamation.

In 2015, the UN Special Rapporteur for the Promotion and Protection of the Right to Freedom of Opinion and Expression David Kaye, conducted the UN’s first major review on whistleblower and source protection, while the OECD also conducted a review in 2016 of whistleblower protection frameworks in its member countries. There is, then, a model for governments to use when reviewing their existing whistleblowing frameworks.

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IV. Conclusions and recommendations The Anti-Corruption Summit has proven to be a successful forum for tackling many issues. But while there has been a high rate of implementation across the board, some key players have dropped the ball on delivering commitments, even those which are recycled and unambitious. And though the Summit deserves credit for the high standard it set and the quantity of anti-corruption commitments it generated, the real impact of those commitments remains to be seen. The Summit set the agenda for the next decade in terms of what is important in the fight against corruption, and since then there has been even more clarity on where efforts should be focused.

Looking ahead, there are two major international opportunities for governments to showcase their commitment to anti-corruption by reiterating existing pledges or making new and ambitious ones. The Commonwealth Summit will be hosted by the UK Government in April 2018, and the International Anti-Corruption Conference will be hosted by the Danish Government in October 2018. At both events the global anti-corruption community and stakeholders will be watching closely, and leaders should use these opportunities to demonstrate they are serious about tackling corruption.

Recommendation 1: Governments should embed anti-corruption commitments into relevant accountable national procedures, such as anti-corruption strategies or OGP National Action Plans.

Recommendation 2: Governments should ensure that anti-money laundering reforms are approached in a coordinated manner, with specific emphasis on beneficial ownership transparency, professional enablers, asset recovery, visa denial and robust law enforcement.

Recommendation 3: Governments should implement the Open Contracting Data Standard, and learn from the leaders in the Contracting 5.

Recommendation 4: Governments and international organisations should fulfil their existing anti-corruption commitments, and proactively publish information on when and how progress is made.

Recommendation 5: Governments and international organisations should be ambitious and concrete in developing new anti-corruption commitments, ensuring that they are time-bound, with clarity over which departments or public bodies are responsible for delivering them.

Recommendation 6: Governments and international organisations should collaborate with civil society, business and other stakeholders in the formation and delivery of anti-corruption commitments, ensuring anti-corruption efforts remain a priority on global agendas.

Recommendation 7: Governments and international organisations should ensure that major anti-corruption meetings bring together leaders with genuine political will, and are open, multi-stakeholder and transparent, as was the 2016 Anti-Corruption Summit.

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Annex – Methodology note

Progress since the SummitTransparency International UK worked with 28 TI national chapters or partner organisations and 5 international organisations to track progress on the Anti-Corruption Summit commitments since they were announced.

Chapters were asked to:

1. Select the commitments to monitor:

• Go through the relevant country commitments and eliminate which were too vague to track.

2. Contact and work with government:

• Identify government department responsible for delivering each commitment

• Inform the responsible department that their progress will be monitored

• Identify expected timeline for delivering each commitment

3. Track the commitments:

• Look for and provide public evidence1 for each commitment where progress had been made

• Make a note of which commitments were ‘inactive’, ‘overdue’, ‘ongoing’, ‘underway’ or ‘complete’

International Organisations were asked to provide an internal analysis of progress on each commitment, providing public evidence for each and making a note of which commitments were ‘inactive’, ‘overdue’, ‘ongoing’, ‘underway’ or ‘complete’.

Bearing this methodology in mind, it is important to acknowledge the limitations of this project.

Whilst the selection used is large (around 60 per cent of the total commitments counted in September), it is still only a selection, and should not be seen as indicative of progress in areas or across themes that are not addressed. We were unable to monitor progress in all countries.

The definitions of the categories ‘inactive’, ‘overdue’, ‘ongoing’, ‘underway’ or ‘complete’ are outlined below.

• Complete This commitment has been completed, based on publicly available evidence.

• Underway Activity has started on delivering this commitment, based on publicly available evidence.

• Ongoing Commitment has no clear end point and activity has started, based on publicly available evidence.

• Overdue This commitment was not completed by the deadline.

• Inactive No activity has taken place on this commitment OR there is no accessible public evidence of activity having taken place on this commitment.

Strength of Summit commitmentsIn September 2016 TI released an assessment of the strength of Summit commitments. Each commitment was assessed as to how ‘concrete’, ‘new’ and ‘ambitious’ it is.

1 Publicly available evidence could be a link to a government website, an online letter, a media article or blog – anything that is publicly available and supports the chapter’s assessment that progress has started.

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Concrete commitments are those with measurable language such as “we commit to join’, or “we commit to establish’. ‘Somewhat concrete’ commitments include language that signal intent to make progress without there being an easily measurable outcome. This includes phrases such as “we commit to explore’ or ‘we support’. Commitments identified as ‘other’ are those indicating existing actions that can be monitored, such as ‘we will continue’ or ‘we are in the final stage of’.

“New” commitments were defined as those generated by the Anti-Corruption Summit. “Somewhat new” commitments are those that are facilitated by or reinvigorated by the Summit but had been previously discussed. “Not new” commitments were already in place prior to the Summit. “Other” commitments refers to pledges that were already on the table but it is unclear when the commitment was made official.

National civil society organisations took national context into consideration when assessing the level of ambition. For this reason similar commitments in different countries receive different assessments.

Where we were unable to receive a response from civil society on a certain national issue in the available time, the commitment is marked as ‘no information available’.

Organisations credited for monitoring their relevant governments2

Afghanistan Integrity Watch AfghanistanArgentina Poder CiudadanoAustralia Transparency International AustraliaBrazil Transparency International BrazilBulgaria Transparency International BulgariaChina Transparency International ChinaColombia Transparencia ColombiaEuropean Commission Transparency International EUFrance Transparency International FranceGeorgia Transparency International GeorgiaGermany Transparency International GermanyGhana Ghana Integrity InitiativeIndonesia Transparency International IndonesiaJapan Transparency International JapanJordan RasheedKenya Transparency International KenyaMexico Transparencia MexicanaNigeria Civil Society Legislative Advocacy CentreSouth Korea Transparency International KoreaRomania Transparency International RomaniaRussia Transparency International RussiaSouth Africa Corruption WatchSpain Transparency International EspañaSri Lanka Transparency International Sri LankaSwitzerland Transparency International SwitzerlandTrinidad Trinidad and Tobago Transparency Initiative UK Transparency International UKUkraine Transparency International UkraineUSA Global Witness (USA), ONE (USA), Global Financial Integrity (USA)

2 The Norwegian Government was not responsive to Transparency International Norway’s attempt to monitor its Anti-Corruption Summit commitments. Norway is therefore not included in the database.

www.transparency.org.uk