ISSN 1176-2640

Coordination in Corruption Control: Maximizing the Effectiveness of a Countrys Accountability Institutions the Papua New Guinea example
Dr Manuhuia Barcham White Paper 2011/01

Contents
Introduction ......................................................................................................................................1 Accountability Institutions in the .....................................................................................................1 Papua New Guinea ..........................................................................................................................2 National Anti-Corruption Alliance (NACA) ........................................................................................3 Current structures ....................................................................................................................6 Critical Success Factors ...................................................................................................................7 Transferability to other parts of the Pacific and Beyond ................................................................8 Conclusion ........................................................................................................................................9 References .................................................................................................................................... 9

Introduction
Successfully investigating and prosecuting cases of corruption is a difficult and time-consuming task. More often than not it requires the work of a number of different agencies each bringing different, but necessary skills, to the table. A key issue behind the success of this process is effective coordination. Without good coordination and cooperation between a countrys accountability institutions there exist a number of risks which may decrease the effectiveness of corruption investigations and prosecutions such the same piece of work being done by different agencies or that information obtained by one agency will not be effectively transferred through another agency in the course of an investigation. In the low capacity context of many developing countries around the world these issues become even more pressing. Some have argued that the creation of Independent Commissions Against Corruption (ICACs) may be a way to overcome some of these issues. However, a lack of political will to combat corruption in a country and low levels of state capacity may mean that this is just not a feasible option. There are other options. One possible option of interest to those looking ways to improve coordination and cooperation between a countrys accountability institutions has emerged in Papua New Guinea over the last nine years. The countrys National Anti-Corruption Alliance (NACA), an endogenously created institution has helped to not only strengthen the coordination and effectiveness of the countrys accountability institutions but also begin to change public perceptions that corrupt activity in PNG would go unpunished. After a brief discussion about the role that coordination plays in increasing institutional effectiveness in anti-corruption work, especially in a low capacity context, the article then looks at a specific example drawn from the Pacific. Created in 2004 the Papua New Guinea National Anti-Corruption Alliance (NACA) provides a concrete example of how these ideas can play out in practice. Providing an outline of its genesis and its development from its inception as an idea in 1999 through to the present day this article then ends by looking at the critical factors behind its success and a brief discussion on the possibility of it acting as a model for transfer to other jurisdictions in the Pacific.

Accountability Institutions in the Pacific

As a number of recent studies have demonstrated, the countries of the Pacific region possess relatively well-developed domestic legislative and policy frameworks for combating corruption (Larmour and Barcham 2006; Barcham 2007). However, despite the existence of these frameworks corruption continues to be a problem across the Pacific. This is particularly the case in the countries of Melanesia where massive mineral and resource wealth combined with low levels of state capacity has created perverse incentives for corrupt activity. The ineffectiveness of these frameworks can be traced back to a number of issues including lack of political will and low levels of capacity within the public sector. In recent studies of the national integrity systems of 12 Pacific Island countries, lack of coordination across the accountability institutions of the countries of the region was identified as one of the key reasons for the ineffectiveness of these anticorruption frameworks (Larmour and Barcham 2006).1 One possible answer to overcoming these issues of coordination would be through the creation of an Independent Commission Against Corruption (ICAC). This approach has proved extremely successful in
1

The National Integrity Systems of 12 Pacific Island countries was conducted in 2003-2004. Run out of the Australian National University, the study was funded by AusAID and Transparency International-Australia. The NISPAC Study included the following countries: Cook Islands, Federated States of Micronesia, Kiribati, Marshall Islands, Nauru, Niue, Palau, Samoa, Solomon Islands, Tonga, Tuvalu and Vanuatu. The NISPAC study did not include studies of Fiji, Papua New Guinea, Australia and New Zealand as they were completed as part of other National Integrity System projects.

both Hong Kong and New South Wales, Australia. However, the extent to which these successes are replicable for much of the Pacific is questionable. There are two key impediments. The first is that in both Hong Kong and New South Wales there was a strong degree of political will behind the establishment of these institutions. This political will ensured not only that sufficient resourcing was provided for the successful operation of these institutions but it also helped create a strong signal, from the highest levels, that corruption was not to be tolerated in these jurisdictions. In many Pacific Island jurisdictions the political will to combat corruption is just simply not present to the same extent. Secondly, and this speaks to one of the key issues of this article, there is simply just not the state capacity in many of the countries of the Pacific to support yet another accountability institution. In the much of the region the state is already stretched to capacity. Indeed, this lack of capacity not only prevents the effective operation of anticorruption policies and programs but also provides opportunities for corrupt activity to occur. The creation of yet another accountability institution may do nothing more than merely spread even more thinly the already low level of state capacity in Pacific Island countries and in doing so provide space for even more corrupt activity to occur. There are, however, other ways for increased coordination and cooperation to occur in the functioning and operation of a countrys accountability institutions. One such model has emerged over the last nine years in Papua New Guinea. Developed in arguably one of the most corrupt countries in the Pacific, the operation of the countrys National Anti-Corruption Alliance (NACA) provides useful lessons for both other countries in the Pacific as well as globally about how the effectiveness of a countrys accountability institutions can be improved through enhanced cooperation and coordination.

Papua New Guinea

Papua New Guinea is a country located in the Southwest Pacific. Located just north of Australia, it shares a common land border with Indonesia. With over 900 different languages, it is one of the most ethnically heterogenous countries in the world. It has a rugged natural geography and extraordinary mineral wealth. Colonised only in the late nineteenth century, large sections of the country were not explored by Europeans until the early twentieth century. This late contact, combined with the countrys rugged geography means that there is a low degree of state penetration across the country, with the state being unable to exercise effective control over the entirety of the countrys land mass. This low state penetration means that opportunities are created for corruption to flourish as well as incentives being created for corrupt behaviour. These perverse incentives are exacerbated by the wealth that flows on from the large mineral and other natural resource endowments found in PNG. Corruption can be found in all sectors and at levels in Papua New Guinea. On Transparency Internationals Corruption Perception Index (CPI) Papua New Guinea is ranked 162nd equal.2 This places the country as one of the most corrupt countries in the world on a par with countries like Central African Republic, Bangladesh and Turkmenistan. As the countrys former Prime Minister Sir Mekere Morauta has commented, corruption in Papua New Guinea is both systemic and systematic. Systemic because it has invaded the whole process of policy making and decision making. It has drowned the whole system, so its systemic. Its systematic because its organised.3 In Papua New Guinea allegations of corruption proceed along the following investigative path. Allegations are referred to the Auditor Generals Department for audit. If anomalies are detected then the audit findings are referred to either the Office of Provincial Affairs, the Financial Inspection Branch or the
2

Accessed at http://www.transparency.org/policy_research/surveys_indices/cpi/2007 on Tuesday 6 December 2007 at 19:09.

Helen Vatsikopoulos, (1995) Papua New Guinea: Under the Spell accessed at http://acij.uts.edu.au/PJR/issues/back95/95sbs.html on 26/11/2007.

Ombudsmans Commission depending on the type of offence (or in some cases to all three agencies). The investigative agency then conducts an investigation of the audit issues raised and, at the completion of the investigation, forwards the investigation and recommendations to their relevant department head. If criminal matters are found during the investigation then the findings and recommendations are referred through ministerial level to the Police Commissioner who in turn refers the matter for investigation, with this generally being conducted by the National Fraud and Anti-Corruption Squad (NFACS). In addition to these more general forms of corruption, the countrys Ombudsman Commission is also empowered to police the countrys leadership code (Barcham 2003: 109). The investigative path for these types of investigations is slightly different. If a breach of the leadership code is discovered in the process of the investigation then the evidence is transferred through to the PNG Public Prosecutors Office for prosecution of the accused before a Leadership Tribunal. All of these processes involve both the transfer of information between and across a number of agencies as well as the need for investigations to draw on a variety of skill sets, generally not found within one single agency, such as forensic accounting skills, police search and interrogation techniques and so on. However, with corruption at endemic levels the countrys oversight institutions are stretched to capacity. In exploring how this capacity load can be lessened and how the countrys anti-corruption activities can be made more effective a number of initiatives have been promoted. Twice now, for example, the PNG Government has introduced legislation into Parliament to create an Independent Commission Against Corruption (ICAC). However, each time the legislation has been introduced it has been effectively sidelined. Given the discussion above of the critical success factors behind the successful establishment and operation of an ICAC it would appear, however, that the creation of an ICAC in PNG is not necessarily the best use of the countrys already scarce state resources. Instead, a possible area of focus would be on strengthening the countrys National Anti-Corruption Alliance (NACA), an endogenously created institution which has helped over the last nine years to strengthen the coordination and effectiveness of the countrys accountability institutions.

National Anti-Corruption Alliance (NACA)

One of the most important initiatives in recent years in terms of the countrys oversight institutions was the creation of the National Anti-Corruption Alliance (NACA). Created in 2004 NACA is an alliance of agencies involved in detecting, investigating and prosecuting fraud and corruption. Its member include representatives from the following PNG agencies: Ombudsman Commission; Office of the Auditor-General; Department of Treasury (Inspections Division); Department of Provincial and Local Government Affairs (Standards & Inspections); RPNGC; Solicitor-Generals Office; Department of Personnel Management; and Internal Revenue Commission. NACAs genesis can be traced back to 1998 when John Rennie, an Australian national working as the adviser to the Royal Papua New Guinea Constabulary (RPNGC) national fraud and anti-corruption squad noted that there were considerable time lags in the process of corruption complaints. From his initial assessment, from the time of discovery to the initiation of an investigation, most cases that arrived at the Fraud squad involved a time delay of an average of 18 months.4 He identified two key issues as being behind these delays. Both issues were based on problems of coordination. The first issue was the long period of time required for corruption complaints to move through the chain of PNG accountability institutions. Periods in excess of two years were common for corruption complaints to be fully investigated from the time they were identified at the source by the victim agency, to the incident being quantified by the Auditor Generals office, its subsequent referral to various committees and then
4

John Rennie, 31 November 2007, Port Moresby. Papua New Guinea.

investigation by the relevant authority. Amongst other negative issues, this extended timeframe meant that offenders often had long periods of time in which to destroy evidence vital for the investigation as well as intimidate possible witnesses. It also had the unintended effect of allowing the pubic perception to grow that there was no impetus for genuine anti-corruption investigation in PNG. The second, related issue was that as expertise in investigation and prosecution was spread across a range of agencies, a lack of coordination meant that investigations would often just stop once a limit was reached within a particular agencies human resource capacity. This lack of cross-agency cooperation meant, for example, that police investigators had difficulty accessing a forensic accountant, and finance inspectors could not execute a search warrant to obtain documents.5 Building on the previously successful model of a combined banking-police crime prevention liaison committee, designed to improve co-operation between the banking sector and the police in PNG, representatives of the national fraud and anti-corruption squad (NFACS) drafted a memo in March 1999 suggesting the creation of a similar working group consisting of the NFACS and the other government agencies involved in anti-corruption monitoring or reporting. Distributed to the countrys various accountability institutions the idea gained a wide-degree of support amongst senior leaders from these various agencies. A meeting was then convened in May by these agencies heads with the result being the formation of the Public Sector Anti-Corruption Liaison Committee (PSACLC). In following meetings the group began to discuss how they could cooperate and coordinate their activities to maximise the effectiveness of their combined work. These discussions focused on cooperation in the areas of training, use of experts from each agency to present at workshops, and discussions about how best to combine operationally.6 These discussions resulted in PSACLCs first joint investigations in late 1999 at a number of sites around the country, including: Fly River; Alotau; Kokopo; NCDC; and in the national Works Department. The Fly River Provincial Government investigation was the first investigation to overcome the coordination issues that had typified the previous convoluted reporting and investigation process. Comprising police, provincial inspectors, finance department investigators, and auditor-general auditors the investigation team was able to travel to the province within one month of the reported frauds having been identified. Working together the team were able to complete such a thorough and efficient investigation that the Governor, provincial Treasurer, and 8 other public officials were arrested and charged with corruption offences. This early success gave both impetus and legitimacy to the idea of the PSACLC. In 2000 a formal statement was signed by the department heads of Police, Ombudsman Commission, Finance and Treasury, Attorney General, Provincial and Local Level Government Affairs, Auditor-General, Public Prosecutor and Personnel Management. In this agreement they agreed to pool their resources to fight corruption, and to examine and identify and eliminate processes or practices that inhibit departments from working to the best of their ability.7 As part of this statement they agreed to begin moving forward with the establishment of a National Anti-Corruption Alliance (NACA) as a practical means by which corruption can be attacked, corrupt practices identified, and proactive measures implemented.8 Working with members of the committee, John Rennie and Ashok Ghosh, who was attached the Auditor Generals office, thus began to actively promote the idea of a NACA within the PNG government to build on the success of the PSACLC. The ongoing successes of the PSACLC saw support for the approach grow across PNG government agencies. Part of the support of the plan can be traced back to the fact that it was seen as being a PNG
5

John Rennie, 31 November 2007, Port Moresby. Papua New Guinea. John Rennie, 31 November 2007, Port Moresby. Papua New Guinea. Fight against Papua New Guinea corruption gets a boost Post Courier 30 August 2000. Fight against Papua New Guinea corruption gets a boost Post Courier 30 August 2000.

designed model that uses the existing resources and expertise already in PNG, to tackle the corruption that is crippling this country.9 This domestic ownership of the plan meant that by 2001 both the Commissioner of Police and the Chief Ombudsman were strong supporters of the plan. The success of the initiative also saw the then Chief Secretary Mr Robert Igara take over chairmanship of the PSACLC in late 2001. His ascension to the chairmanship had both positive and negative consequences. His seniority in the PNG public service ensured that the PSACLC was taken seriously across government. However, his senior position meant that he was also pressed for time and the PSACLC began to loose impetus because of a lack of regular availability of the chairman. Nonetheless investigations continued, and later in 2001 a major multi-agency investigation was undertaken in the Southern Highlands with a number of high profile officials also being arrested and charged. The key to the early successes of PSACLC were attributed to its ability to help build stronger relationships between the countrys accountability institutions and on doing so facilitate the exchange of ideas, training expertise and good will between the various agencies.10 As noted above, during this period some of the agencies involved began to argue for a more formalised structure and approach, as up until 2001 PSACLC had existed merely as an informal agreement between agency heads with no real existence under the law. The proposed structure was initially envisaged as operating through an approach where a panel of agency heads would meet together as a proposed NACA Board to decide on major corruption investigations which would then be managed through a working group constituting the heads of the investigation sections of the various member agencies. Funding in this early model would be allocated by the proposed NACA Board from a PNG government-sourced recurrent budget. Moving forward on this plan proved difficult though, for while there was support for the initiatives put forward by PSACLC by the agencies involved there was little support for the further concrete development of the idea of a NACA at the political level, beyond its already established informal remit. And so, with a lack of a dedicated recurrent budget for its operations PSACLC continued to operate through the transfer of existing monies from participating agencies for its operations. The good will of the various agency heads involved in PSACLC was an important factor in the ongoing running of these multi-agency investigations, with these heads of agencies agreeing to the commitment of team members for these multi-agency teams from their already meagre human resource pool. In late 2002 with it looking increasingly unlikely that the legislative support required for the formalisation of the PSACLC structures would be forthcoming, it was suggested within PSACLC that the proposed anticorruption body be described as an alliance as that would both better describe its proposed functions and also help overcome fears that it would be merely another cost burden on the PNG government through the addition of yet another accountability institution to the countrys list of such institutions.11 Throughout this period successful joint-agency investigations continued to be run through PSACLC. The continued success of the PSACLC investigations led to political and administrative pressure being placed on the National Executive Council to recognise the institution and allow the formation of the National Anti-Corruption Alliance. And, after working for five years under the rubric of the PSACLC, NACA was finally established by the National Executive Council in July 2004. Since its formal establishment NACA has continued to successfully mount multi-agency investigations and prosecutions. In its most recent high profile case, members of NACA have exposed serious cases of payroll fraud and the use of unaccounted funds from the provincial government budget in the Southern Highlands. Deputy Chairman of the parliamentary National Emergency Committee Kimson Kare reported that in these investigations the NACA

Quote from then PNG Police Commissioner John Wakon cited in Fight against Papua New Guinea corruption gets a boost Post Courier 30 August 2000.
10

John Rennie, 31 November 2007, Port Moresby. Papua New Guinea. John Rennie, 26 November 2007, Port Moresby. Papua New Guinea.

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team had begun to expose a jungle of corruption never seen before. 12 The NACA investigation team flown into the Southern Highlands consisted of personnel drawn from Police, Treasury Department, Department of Provincial and Local Level Government Affairs, Auditor-General and the Personnel Management Department. As a result of this investigation eighteen people have been arrested, with more arrests pending, as police detectives continue to trace the disappearance of more than PGK1.5 million from the Southern Highlands Provincial Government.13 The most high profile suspect in this case was the Southern Highlands Governor Hami Yawari who was charged under the leadership code for misconduct in office as well as for misappropriation. While the initial charges against the Governor were dismissed due to lack of evidence the investigation in the Southern Highlands is still underway with prosecution underway of a number of senior public officials from the province.

Current Structures
At the highest level NACAs membership currently includes the heads of the various member agencies that comprise the group. This head of agencies group currently meet 2-3 times a year. Below that, a technical working group comprising senior members of the various member agencies meets every month or two. NACA is currently coordinated by a small secretariat which is co-located with the Fraud Squad in the RPNGC. A submission has been made to the PNG National Executive Council for NACA to be formalised (it still operates on the basis of its original Memorandum of Understanding signed in 2004) and for recurrent budget funding to be directed its way for five years beginning in 2009. Whether or not this will occur remains to be seen. However, there is an ongoing awareness with PNG that corruption poses a serious problem to the future development of the country. Recognition of the seriousness of the issue of corruption led to the decision by the National Executive Council in April 2006 to begin drafting a National Anti-Corruption and Good Governance Strategy. And so, the renewed focus on corruption in the highest echelons of the PNG government, including a commitment to draft a National Anti-Corruption and Good Governance Strategy, and the increased focus on corruption by donors in the region such as AusAID, may mean that there is an increased likelihood that this formalisation process may occur. How this would impact on the continued push by some in PNG for the creation of an ICAC is still uncertain. As noted above, the PNG Government has now twice introduced legislation into Parliament to create an Independent Commission Against Corruption (ICAC). However, each time the legislation has been introduced it has been effectively sidelined. And, in the October 2006 draft of the National Anti-Corruption and Good Governance Strategy the establishment of an ICAC is still seen as being a central plank of the plan. This is not necessarily to the exclusion of NACA though. Indeed, some senior PNG public servants see the eventual goal for NACA is for it to act as a point of articulation between the countrys accountability institutions and the Government of Papua New Guineas anti-corruption strategy.14

12

Probe reveals rampant fraud in PNG province The National 18 October 2006. PNG police arrest 14 in corruption probe Post-Courier 10 January 2007. Mosilayola Kwayaila, 23 November 2007, Port Moresby. Papua New Guinea.

13

14

Critical Success Factors

NACA and PSACLCs investigations have been successful for a number of reasons. Two of the key factors have been discussed before. Working together in teams has allowed for the use of complementary skill sets which has not only increased the effectiveness of investigations but also increased their speed, as lengthy delays as data is transferred between agencies have been eliminated. This has meant that the previous time delays between audit inspections occurring, government agencies following up on complaints and police investigation been initiated has been removed. What this has meant in practice is that where criminal matters are identified by inspection agents then these matters can be immediately brought to the attention of the appointed police investigator which means that the identified suspects can be quickly questioned and charged before the disposal of evidence by suspects.15 So too, working in teams has also facilitated the transfer of knowledge between team members. This increase in knowledge of how other aspects of corruption investigations occurs has had the major benefit of helping ensuring that the data collected in various stages of an investigation is in a form useful for those undertaking other stages of the investigation. This too has helped increase the effectiveness and speed of investigations. The operation of these NACA teams has thus helped facilitate increased inter-operability between the countrys various accountability institutions. The operation of these teams has also led to another unintended consequence which has increased the effectiveness of corruption investigations. This is the size of the teams going in to investigate allegations of corruption. Rather than going in as individuals, or as teams of two or three, NACA investigations, such as that carried out in Southern Highlands, can constitute teams of up to eight members, sometimes more. What this sheer size of team has meant is that it has reduced opportunities both for intimidation and for bribery of those involved in anti-corruption investigations, both of which are important risks to be managed in any anti-corruption work.16 Indeed, the increased coordination and cooperation that NACA has helped facilitate between PNGs accountability institutions has led to other concrete improvements in the sector. Probably of most note is that each member agency now has a corporate and annual plan that is linked to the PNG Law and Justice Sectors Sector Strategic Framework. This fact is even more startling when one realises that before NACA a number of these agencies had not produced annual reports for a number of years. This coordinated planning is thus a concrete example of the integration in policy and planning that can occur as a result of the networking and information sharing opportunities that sector wide-networks like NACA can bring about. The speed and effectiveness of NACA investigations has also begun to slowly change public perception that corrupt activity in PNG would go unpunished. While there is still a long way to go to convince the PNG public that corrupt activity will be caught and offenders will be punished (much work still needs to be done in the area of prosecutions) the performance of NACA has at least begun to change these perceptions. The other key success factor identified above is that NACA is seen as being an endogenous institution. While this has obvious benefits in terms of fit with the countrys accountability institutions it also has other benefits. The most important for the long-term success of the project is that its endogenous nature means that it possesses a high degree of ownership by the agencies involved. This high degree of ownership appears to be translating into sustainability as evidenced by its continued existence even in the absence of a committed budget. There are, however, a number of risks which continue to bedevil the continued operation of NACA. The first, and most important, is that operates on the good will of the heads of the countrys accountability institutions. If this good will was to disappear then NACA too would, in all likelihood, cease to exist. This risk
15

Alois Francis, 26 November 2007, Port Moresby. Papua New Guinea. Alois Francis, 26 November 2007, Port Moresby. Papua New Guinea.

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could be removed through the granting of specific budgetary funding to NACA, such as that currently being sought. However, this raises the question of the other key risk faced by NACA. Its strength to date can, in a sense, be traced back to its informal nature and existence as an alliance or loose coalition between likeminded agencies operating in the same sector. By formalising their operations, the nature of the alliance may change and agency heads may be less inclined to support an institution that may be seen as being in competition with their own. Indeed in formalising NACA, one might be merely creating an ICAC in all but name. The key then would be to ensure that while NACA continued to act as a point of facilitation and coordination between PNGs accountability institutions, and a recurrent budget would help reduce uncertainty in the institutions operations and allow for more long term-planning to occur, it must be balanced off with the fear that NACA would become yet another accountability institution competing with the countrys other accountability institutions for limited funds and resources. In summary, the key critical success factors to be drawn from the NACA experience are thus that: It provided early, and ongoing, benefits in terms of increases in the effectiveness of investigations for its various member agencies through the increased levels of coordination and cooperation it was able to facilitate; It gained wide-spread local support quickly as it was an endogenously created institution which was adapted to the PNG context from its inception; Working together in teams has allowed for the use of complementary skill sets which has not only increased the effectiveness of investigations but also increased their speed, as lengthy delays as data is transferred between agencies have been eliminated; Working in teams has facilitated the transfer of knowledge between team members and helped facilitate increased inter-operability between the countrys various accountability institutions; The large size of the teams going in to investigate allegations of corruption has reduced opportunities both for intimidation and for bribery of those involved in anti-corruption investigations.

Transferability to other parts of the Pacific and Beyond

NACA provides a valuable model for those interested in increasing the effectiveness of a countrys accountability institutions, especially in the low state capacity context characteristic of developing countries. Its ability to act as a facilitator of increased coordination and cooperation between PNGs various accountability institutions has led to increased effectiveness and speed in corruption investigations in the country. In an earlier article I discussed the successful transfer of the Melanesian Ombudsman model from Papua New Guinea through to Vanuatu in the mid-1990s (Barcham 2004). This model of transfer provides a useful example of how NACA may be successfully transferred through to other Melanesian countries in the region. Broad parallels between these countries may make institutional transfer between them easier to achieve due to similarities in the state capacities of these countries and a roughly similar pattern of cultural heterogeneity. Indeed, the close cultural proximity of these countries may even allow an introduced NACA to be seen as an almost endogenous institution, endogenous in the sense of emerging from within Melanesia. Indeed, the idea of NACA as a facilitator between a countrys accountability institutions may mean that its transferability may be wider than just to the Melanesian countries of the Pacific. Its flexible nature, its low negative impact on its member institutions internal capacity and its ability to promote increased

effectiveness in corruption investigations could mean that, as a model, it has a high degree of relevancy to many other developing countries in the Pacific region and beyond. While in doing this one would lose the endogenous aspect of the institution the other aspects behind its success would appear on paper to be a positive fit with the capacity constraints of both Pacific Island countries and other developing countries around the world.

Conclusion
A lack of clear coordination and cooperation between Papua New Guineas accountability institutions had long been a major impediment to the effective investigation and prosecution of corruption complaints in the country. And, as this article as shown, in light of both the countrys growing problem of corruption and the limited capacity of the countrys accountability institutions it was clear that the only way in which a sustainable and effective approach to combating corruption in the country would be achieved would be if the existing expertise in the sector was linked and pooled so that the effectiveness of investigations and the quality of evidence could be improved. NACA provides just such a mechanism for this to occur. Right from their inception NACA, and its predecessor PSACLC, have thus helped increase the efficiency of investigations and prosecutions of corruption in PNG through its facilitation of increased coordination and cooperation between the countrys accountability institutions. This success has been a result of a number of factors including the institutions endogenous nature, its ability to successfully facilitate the transfer of knowledge between the countrys various accountability institutions and thereby enhance their interoperability; and its ability through the use of multi-agency investigatory teams to provide reduced opportunities both for intimidation and for bribery of those involved in anti-corruption investigations. Its ability to perform all of this in a country with such a low-level of state capacity as Papua New Guinea makes it even more remarkable and provides options for not only the use of NACA as a possible model for transfer to other Pacific jurisdictions wanting to increase the effectiveness of their own countrys accountability institutions, but also more importantly for how the effectiveness of developing countries public sector agencies in general may be improved through processes of facilitated networking.

REFERENCES Barcham, Manuhuia, (2003) South-South Policy Transfer: The Case of the Vanuatu Ombudsman Commission Pacific Economic Bulletin 18 (2): 79-87. Barcham, Manuhuia, (2007) Corruption in Pacific Island Countries Report for the UNDP Pacific Centre, Suva, Fiji. Larmour, Peter, and Manuhuia Barcham, (2006) National Integrity systems in small Pacific island states Public Administration and Development 26: 173-184.

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