Doig 2003

public administration and development
Public Admin. Dev. 23, 317332 (2003)

Published online in Wiley InterScience
(www.interscience.wiley.com) DOI: 10.1002/pad.287
THE NATIONAL INTEGRITY SYSTEM: ASSESSING CORRUPTION

AND REFORM
ALAN DOIG* AND STEPHANIE McIVOR
Fraud Management Studies Unit, Teeside Business School, University of Teeside, Middlesbrough, UK
SUMMARY
This article builds on a Transparency International (TI)-sponsored research study funded by the Dutch Government into the
National Integrity System (NIS) in practice. The NIS is a framework approach developed by TI that proposes assessing corrup-
tion and reform holistically. The NIS not only looks at separate institutions or separate areas of activity or separate rules and
practices, but also bases its perspective on institutional and other inter-relationships, inter-dependence and combined effective-
ness. The study involved 18 countries, using in-country researchers and an overview report. This article assesses the findings of
the study to consider how the approach can work in practice, and what the approach can reveal about the causes and nature of
corruption as well as the implications for reform. Copyright # 2003 John Wiley & Sons, Ltd.
THE NIS APPROACH

The NIS is proposed as a set of objectives (such as an open, genuinely competitive and transparent system of
public procurement) which is supported by key strategies or approaches (termed elements; for example, identi-
fication of government activities that are most prone to corruption and a review of both substantive law and admin-
istrative procedures) and is delivered by or through relevant institutions, sectors or specific activities (the pillars,
such as the Auditor-General). The NIS development was very much a response to the issue of reform within a
matrix of country specificity but looking to the use of common core components as vehicles for reform. As the
initial paper proposing the NIS noted:
This paper does not suggest that there are easy solutions or models that can be applied in the fight against
corruption; nor does it suggest that any country has yet designed an ideal model, or indeed that such an ideal
model exists. What this paper does argue is that while each country or region is unique in its own history and
culture, its political systems, and its stage of economic and social development, similarities do exist and that
experience and lessons are often transferable. A national integrity system is proposed as a comprehensive
method of fighting corruption. It comprises eight pillars (public awareness, public anti-corruption strategies,
public participation, watchdog agencies, the judiciary, the media, the private sector, and international coop-
eration) which are interdependent. Establishing and strengthening such an integrity system requires identify-
ing opportunities for reinforcing and utilizing each of these pillars in the fight against corruption (Langseth
et al., 1997).
*Correspondence to: Professor A. Doig, Fraud Management Studies Unit, Teeside Business School, University of Teeside, Middlesbrough TS1
3BA, UK. E-mail: r.a.doig@tees.ac.uk
Copyright # 2003 John Wiley & Sons, Ltd.

318 A. DOIG AND S. MCIVOR
The NIS approach, as well as the choice of pillars,1 or their respective importance and significance, was not
prescriptive, but borne of a practitioner perception that a comprehensive and holistic approach could address fail-
ings of past evaluation and reform efforts. It was argued that these failings were due to: the inability of any single
individual or agency to address the extent of corruption; the absence of top-level commitment; overly ambitious
reform programmes; piecemeal and uncoordinated reform; over-reliance on the laws as the vehicle for reform; lack
of focus or uneven application of reforms; lack of sustainable institutional mechanisms; the potential for corruption
among those institutions responsible for dealing with corruption; and a lack of integrated or sequenced reform.
Monitoring corruption cannot be left only to public prosecutors and to the forces of law and order. Action
cannot depend solely on detection and criminal prosecution. Rather, action must also include a combination
of interlocking arrangements. In part, this approach includes improving the transparency of relationships, and
to the extent possible, preventing the development of relationships which can lead to corruption . . . Although
corruption can never be completely monitored, it can be controlled through a combination of ethical codes,
decisive legal prosecutions against offenders, organisational change, and institutional reform (Pope, 1997,
p. 19).
Thus the NIS was intended as a framework through which to identify systematicallyand then addressthe key
areas where corruption occurred as well as identify those institutions or areas which would have a role to play in
promoting the need for reform as well as for dealing with corruption. Further, the framework would also go on to
assess the relative strengths and weaknesses of these institutions or areas on an individual and collective basis to
ensure their own capacity to be free from corruption (corruption-proofing) as well as to promote a more inte-
grated approach to dealing with corruption.
Pillars are not necessarily of equal strength, but their overall impact could be achieved through over-compensa-
tion by certain pillars (e.g. a pro-active, pro-public anti-corruption agency or Ombudsman offsetting weak civil
society) or by better integration or coordination to offset individual pillars weaknesses (such as information-shar-
ing or case allocation procedures among law enforcement agencies). In addition, there are core rules/practices that
seek to corruption-proof each pillar by addressing both their internal integrity and their external effectiveness.
1
The current list of relevant pillars and their roles as identified in the TI Source Book (2000) are as follows:
Political Willthe will to fight corruption can reside in many locations . . . together they can form a powerful political constituency and
provide leadership.
Parliamentwatchdog, regulator and representative, the modern parliament is at the centre of the struggle to attain and sustain good
governance and to fight corruption.
Auditor-Generalthe fulcrum of a countrys integrity system . . . the effective Auditor-General acts as a watchdog over financial integrity
and the credibility of reported information.
Attorney-Generalas Chief Law Officer of the State, the guardian of the public interest.
Public Serviceto serve the public.
Rule of Lawto adjudicate whether or not a particular action taken by, or on behalf of, the state is in accordance with the law.
Judiciaryan independent, impartial and informed judiciary holds a central place in the realization of just, honest, open and accountable
government.
Ombudsmanmandate . . . also extends to investigation and investigation of system of administration to ensure that they restrict corruption
to a minimum. Thus it can recommend improvements to procedures and practices and act as an incentive for public officials to keep their files
in order at all times.
Independent Anti-Corruption Agenciesas the corrupt grow more sophisticated, conventional law enforcement agencies are becoming less
able to detect and prosecute complex corruption cases.
Public Procurementfew activities create greater temptations or offer more opportunities for corruption than public sector procurement.
Good Financial ArrangementsOne of the most powerful anti-corruption devices is the establishment of sound financial management
practices, with timely and efficient accounting systems combined with punctual, professional reviews by internal and independent auditors.
Private Sectorimproved corporate responsibility is a powerful tool in fighting corruption.
Information and Public Awarenessthe right to know is linked inextricably to accountability, the central goal of any democratic system of
government.
Mediawithout information, there is no accountability . . . the principal vehicle for taking information to the public is an independent and
free media.
Civil SocietyEncompasses the expertise and networks needed to address issues of common concern, including corruption . . . the real role
must be for civil society to claim and defend its own values, and not leave this integral function to those in power.
International Actors and MechanismsNot so apparent, however, is the much deeper international corruption, which usually does not take
place as openly and as unashamedly as does petty corruption.
Copyright # 2003 John Wiley & Sons, Ltd. Public Admin. Dev. 23, 317332 (2003)
THE NATIONAL INTEGRITY SYSTEM 319
These add to the overall effectiveness of the pillars by identifying what is fundamental to the public image or role
that seeks to achieve this.2
Overall, the NIS is intended, when fully developed, to evolve as a system which, when in existence and working
both interactively and effectively, will be concerned with two goals: first, combating corruption as part of the larger
struggle against misconduct and misappropriation; and, second, creating an efficient and effective government
working in the public interest. In short the ultimate goal of the NIS is about promoting good governance:
. . . the aim is not complete rectitude or a one-time cure or remedy, but an increase in the honesty or integrity
of government as a whole . . . (Pope, 1997, pp. 5, 6).
NIS FLEXIBILITY
The NIS approach is intended to be flexible rather than prescriptive. There is no one single NIS approach and no one
single NIS solution; it is the overall configuration and inter-relationships of the pillars, with overall key strategies and
objectives, which are important within the specific country context. Thus through an NIS assessment, an overall anti-
corruption programme can be developed that identifies the context before assessing the roles and effectiveness of the
pillars. For example, although the NIS had been developed after the end of communist hegemony and many of the
transitional states has also often faced the same developmental issues of other developing countries, their socio-eco-
nomic context and institutional configuration has meant that some of the issues relating to corruption are of a dif-
ferent nature. The country report from Lithuania noted the baseline faced by the new states in 1992:
The young Lithuanian state simultaneously had to carry out a number of complex reforms: 1) to form totally
new structures necessary for the national security of a sovereign state, for the functioning of its economy and
state administration; 2) to denationalise the collective socialist property, to carry out privatisation and restitu-
tion, to move from the centralised command economy to liberal market economy; 3) to rapidly integrate itself
into the European structures, to introduce the Western standards into its economic, political and social life; 4)
to create civil society based on new principles and foundations (Lithuania country report, p. 25).3
In terms of reform in transitional countries therefore, there may be strong reasons for not moving too quickly to
establish mechanisms of accountability or an over-emphasis on the control environment when a wide degree of
discretion combined with good leadership may be more desirable in attracting suitably-qualified or motivated
recruitsof which there should be an appropriate number in many transitional countriesinto political and
administrative life as pre-conditions for institutional consolidation.4 Similarly the engagement of an existing
educated civil society and encouragement of a growing independent media would also help address the threat
2
Examples of rules/practices linked to pillars given in the TI Source Book (2000) are:
Pillar Corresponding core rules/practices relating to
Executive Conflict of interest; administrative law; judicial review of official actors
Legislature/Parliament Fair and transparent elections
Parliamentary Public Accounts Committee Power to question senior officials
Auditor General Public reporting
Public Service Public service ethics; monitoring assets and integrity testing; conflict
of interest, nepotism and cronyism
Judiciary Independence
Media Access to information
Civil Society Freedom of speech; the right to information and giving citizens a voice
Anti-corruption/watchdog agencies Enforceable and enforced laws
Private Sector Competition policy; public procurement; good financial management
International Effective mutual legal/judicial assistance
3
The country studies were first published in hard copy for the Global Forum II conference in May 2001. Revised studies were published later in the
year on the TI website (www.transparency.org/activities/nat_integ_systems/country_studies.html). The page numbers refer to the PDF format.
4
Many of the themes relating to transitional countries were developed by Quentin Reed in a briefing paper prepared for The Hague conference.
He noted that the criteria for institutional consolidation include the existence of a clearly understood structure of authority, the normative
priority of this structure over members behaviour, clear tasks and goals, formal access to resources, internal management structures and
protection from pressures from outside the institution, and a clear accountability structure for the institution in terms of internal and external
formal control mechanisms and a clearly defined degree and manner of political accountability.
of post-communist legacies where authoritarian leaderships exercise undue influence on institutions that may be
seen as pivotal to the development of an NIS framework.
Variations in the primacy or prioritisation of pillars in terms of relative strengths and weaknesses, and potential
added-value, may thus be absorbed within the NIS approach, given the focus on objectives and the configurations
to achieve them. In particular, that priority may focus on specific corruption-proofing of pillars, such as conflict of
interest requirements where responsibility and discretion are encouraged, or focusing on the judiciary as the insti-
tution that ultimately embodies the rule of law, or developing effective institutional means in the areas of party
formation and campaign finance to embed democratisation. Such strategic interventions within the overall NIS
context also reflect the broader NIS point that the best anti-corruption policies are not prescriptive or specific
anti-corruption enforcement strategies, but the pursuit of wider objectives that lead to a reduction in corruption
as one of the consequences.
THE NIS AS THE BASIS FOR REFORM

The NIS offers a strategic approach within which and through which to develop a reform strategy. Such a strategy
would be based on the NISs inclusive nature and the developmental inter-relationship between goals, objectives,
elements and pillars. Any such system however, is dependant on a number of variables, including the impact of
context and the role of the pillars. This in turn requires assessment to be made on the weaknesses and strengths of,
and reforms relating to: specific pillars in terms of their centrality to the working of an NIS; the added-value of
pillar interaction both in terms of addressing corruption and the wider NIS goals; promoting co-ordinated donor
support to pillars; national plans for dealing with corruption and wider public service reform; measuring individual
pillar and NIS performance; and reconfiguring the NIS pillars as a consequence. Further, the NIS provides a hol-
istic and comprehensive approach within which to address key reform issues by governments and donors in rela-
tion to:
* timing and strategic intervention
* prioritising
* coordination
* cooperation
* sequencing
Underpinning the NIS approach is the question of its potential in monitoring effectiveness, not just of the per-
formance of the pillar concerned but achieving the wider goals of the NIS; it must be noted that one of the most
important tasks in any anti-corruption effort is to ensure that progress is actually being made. Statistics by them-
selves are no reliable indicators of progress (Pope, 1997, pp. 23, 24). One of the roles of NIS studies is the parti-
cular perspective they bring among a range of measurement methodologies. The studies are prepared by in-country
researchers with appropriate experience and expertise, working within a given framework and using a range of
methods, which access local knowledge and analysis that can explore in detail the gap between the formal and
actual circumstances of corruption in a particular country. This approach contrasts with quantitative data which
do not always fully show the impact of change and the effect on patterns of corruption in terms of general reform
programmes and specific anti-corruption programmes. Neither do the quantitative data provide that qualitative per-
spective on power and the stateas examples from Senegal and Kazakhstan illustratethat is crucial to deducing
the underlying trends and internal priorities.
. . . The National General Auditors Body has no authority of its own to handle a case. Only the President of the
Republic is empowered to submit a case to the Supreme audit institution. The Supreme audit institution can-
not publish its reports which are intended for the President of the Republic only who discretionarily decides to
follow them up or not (Senegal country report, p. 8).
. . . the Guarding Service of the President gets 1.6 times higher budget than the whole Supreme Court
(Kazakhstan country report, p. 3).
While there is no explicit requirement that donors commit themselves to the NIS approach in whole or in part,
orin relation to the donorsin any collective and coordinated way, there has been a general absence of coor-
dinated and sustained support by multilateral and bilateral donors for anti-corruption initiatives. With much of the
funding and the project design for support of the pillars dependant on the involvement and resources of the bilateral
and multilateral agencies, there are a number of important issues relating to donor support that could benefit from
working, and could be measured, within an NIS framework.
THE NIS IN PRACTICE: FINDINGS FROM THE STUDIES5
A framework
The NIS provides a framework within which to study corruption and the pillars engaged, directly or indirectly, in
dealing with it. It also integrates the internal dimension (the issue of corruption-proofing) with the external per-
spective (the roles and work of those pillars). An NIS gives shape to what individual agencies do; it offers the basis
for, and offers added-value from, interaction and provides the context for a collective purpose and direction. This
recognition is reflected in the reports from Canada, South Korea and Mexico on the relevance of a holistic
approach:
Our findings and observations in this report all point to the need for a comprehensive, government-wide, anti
corruption program that seeks to publicise, educate and persuade the Canadian public service and Canadian
corporations to respect both the letter and the spirit of Canadian anti corruption legislation (Canada country
report, p. 7).
. . . the previous integrity systems in Korea were fragmented and scattered. Various laws and systems were
executed, but they were created by the presidents desire and will without any comprehensive or systematic
plan, and were improvised and calculated by the rule of thumb and thus could not be carried out consistently
to prevent corruption. But the Koreas Anti-Corruption Programs is a comprehensive and systematic plan with
only corruption control as its top priority and therefore can be considered an advanced integrity policy
(Republic of Korea country report, p. 9).
In terms of the development of a National Integrity System, a good general trend is the noticeable political
will (in the Executive branch, the Congress and the State level governments) to start simultaneous programs
(with different levels of technical capacities) in order to fight against corruption and promote transparency.
Despite the common political will, at this point it is easy to establish a contrast with the previous adminis-
tration. The new presidential strategy is an open strategy, well discussed in the Media, that recognizes its legal
and structural limits in the realm of the Public Federal AdministrationAPF, but that encourages civic
organizations and private sector leaders to participate as well (Mexico country report, p. 4).
The pillars
Nearly all country studies reported that, formally, the pillars of the NIS exist, raising the first use of an NIS study;
and thus suggested that combating corruption is more to do with institution failings rather than institution absence.
In turn this gives it a real role in assessing the gap between the existence of the institutions and their failure to
deliver the NIS objectives in practice. Thus the reports from Nepal, Ghana and Lithuania stated:
The above mentioned institutions and provisions in Nepal point out what looks like a rather unfortunate con-
trast between the presence of the countrys National Integrity System and the actual performance of the same.
Institutions are there, laws have been worked out, mechanism of governance has been developed both at the
centre and at the local level; but service cannot be delivered in time and adequately to the needy, commented
a Kathmandu weekly recently (Nepal country report, p. 40).
5
The note on the background to and methodology for the studies is at the end of the article, before the References.
On the face (of it), the institutional arrangements in place are enough to promote national integrity. But the
reality is different. The actual ability of the constitutional, legal and political orders to promote national integ-
rity and the control of corruption is undermined severely by a number of factors. They include: lack of opera-
tional and financial independence on the part of Parliament and the Judiciary; executive/presidential
dominance over those institutions. In the case of Parliament, Executive dominance arises from the constitu-
tional fusion of powers, especially the extensive powers of the President, including appointment of MPs as
ministers . . . (Ghana country report, p. 3).
Separate elements of the NIS function more or less successfully in Lithuania today but not the NIS in its
entirety. Such a conclusion is based on the following grounds: 1) the anti-corruption legislation was enacted
either in the middle or at the end of the decade and, thus, in practice, it started functioning only now. In addi-
tion, the legislation itself is not perfect; 2) the process of reforming of the legal system, courts and public
administration is still going on; 3) the institutions in charge of the prevention and control of corruption are
young and inexperienced; 4) the process of formation of civil society is slow and painful and its anti-corrup-
tion attitude is insufficiently mature and inactive (Lithuania country report, p. 25).
This raises a number of reform and donor project issues, including the likely impact of any focus on specific institu-
tions and the wider political environment in which they operate, where corruption is stated as a significant concern. It
would also suggest that the issue of reform may have more to do with improving the effectiveness of existing institu-
tions or increasing the added-value of greater inter-dependence than, as donor agencies continue to do, simply estab-
lish a new agency or direct the bulk of their funding into one existing agency. Using the NIS in a country where the
NIS was generally ineffective might offer more evidence-based analysis than currently pertains to some donors in
that it allows assessment of the reasons between the formal position and the practice (with consequential opportunity
for devising fit-for-purpose reform), argued in the reports from the Netherlands, Senegal and Brazil:
A combination of the arguments on public disclosure, lack of rules for the elites, weakness of institutions and
neglect of the business sector leads to a plea to initiate an independent body or commission to protect public
integrity and to stimulate integrity policies in the public and the private sector by gathering information, giv-
ing information and advice, developing prevention programs, assisting in investigations and stimulating pub-
lic awareness (Netherlands country report, p. 3).
The control of the legislative power over the executive power is hampered by several factors:
* The illiteracy of an important number of National Assembly members.
* The fact that members of the National Assembly enjoy no technical assistance.
* Complacency in the controls when the parliamentary majority belongs to the same political family as the
executive power.
* A deficit of a parliamentary culture (Senegal country report, p. 17).
The individual institutions charged with mounting casespolice, public prosecutors and courtsdont work in
an integrated fashion. The police suffers from political interference and is vulnerable to organised crime take-
over; furthermore, is ill prepared to conduct investigations. Public prosecutors, whose powers were significantly
enhanced under the 1988 Constitution, are yet finding their new identity and run the risk of becoming entangled
in political considerations. The latter comes from what is perceived by some as a hyper-militant attitude from
some young prosecutors. The courts are affected by opacity and slowness and cant adequately respond to the
growing number of cases that reaches the Judiciary. Reforms of the penal process and in administrative proce-
dures could change the image that, in Brazil, corruption crimes remain unpunished (Brazil country report, pp. 21,
22).
From the initial assessment the NIS also provides the basis to review both the anti-corruption capacity of the
pillars themselves and of the contexts that affect their individual or collective effectiveness.
The pillars: corruption-proofing and inter-dependence

The pillars impartiality, credibility and effectiveness are, as a number of countries illustrate, compromised by a
range of countervailing influences that fall into a range of categoriessuch as a lack of commitment or resources,
self-interest, skewed formal or constitutional arrangements, or failings in other pillarsas well as their own intrin-
sic potential to be corrupt or corrupted:
The Legislative does not show great concern on positively orienting its members concerning expected beha-
viour. There are no clear rules regarding contacts with interest groups (there is not a lobbying regulation law),
acceptance of gifts and travel (only the Senate has a code of ethics), monitoring parliamentarians assets etc.
(Brazil country report, p. 8).
Members of parliament are usually reluctant to register gifts and souvenirs given to them and there is no defi-
nite regulation on how to register and store. Ethics code of MPs does not exist as such. (Mongolia country
report, p. 6).
Further individual pillars may be assessed as how far those weaknesses are inherent, or in whole or in part exa-
cerbated by the performance of other pillars. Such assessments also provide the basis of what type of reform may
be required and how far its success may be dependant on factors not within an individual institutions control.
Many of the reports reflect the concerns expressed in the reports from Kazakhstan, Fiji and Argentina:
The Accounting Committee for the control over the national budgets implementation is accountable to
President, but not to Parliament. Since the right to form and spend the budget is the exclusive prerogative
of the Government, there are no guarantees that in case of respective audits the members of the Accounting
Committee will receive objective information and genuine documents (Kazakhstan country report,
p. 6).
Public concern about the strength and ability of the DPPs office to deliver its functions has been growing and
confidence in the DPPs Office is eroding. One of the reasons argued for such incapability in the office is the
low salary level in the civil service. The DPPs office has in the past been a training ground for lawyers who
eventually make their way into the private sector. Staff turnover is high because resources to retain qualified
staff are not available. As a result a group of newly trained legal officers of government have to stand up
against the more experienced private practitioners, with obvious results (Fiji country report, p. 12).
The weakness of some of the control agencies (Anticorruption Office, National Auditing Commission) is
revealed by their dependenceregarding the appointment and removal of authoritieson the authorities
subject to their control. Accordingly, opportunities for the exercise of political pressure are created, thus
restricting the capacity of carrying out rigorous controls, and publishing the outcomes of investigations. In
the same manner, there is an absence of mechanisms to carry out substantive evaluations on public admin-
istration management, contract fulfilment or convenience, or the performance of public officials . . . The pos-
sibility of civil society to exert control is significantly hampered by the weakness of the control agenciesin
charge of law enforcement and the application of sanctionsand the consequent low risk of being punished
for the commission of irregularities which, added to the lack of mechanisms to produce and publicize infor-
mation on the performance of public officials and the management of public agencies, operates as a system of
protection for the commission of irregularities (Argentina country report, p. 18).
Indeed, one general finding is the universality of the political influence that permeates governmental and parlia-
mentary pillars and the consequential (and often short-term) theme of the exercise of political power that impacts
the pillars, as well as the development of an NIS:
The great majority of Congress members are unused to decision-making, hold no power and have scant, if any,
parliamentarian activity. Their political influence is limited to negotiating personal or group interests in return
of support given to party leaderships when issues come to the floor (Brazil country report, p. 7).
The Legislature is supposed to be separate from the Executive, but because of the ruling Partys majority in
Parliament, enjoyed since independence in 1966, it has become virtually the wing of the Executive. Its effec-
tiveness is therefore weakened (Botswana country report, p. 16).
Two-way dialogue between peoples representatives and the people does not usually continue after election.
The political parties poll manifestos are also not followed once parties capture power in Singha Durbar, the
seat of government (Nepal country report, p. 22).
The question of the exercise of political power is central to the NIS in terms of promoting good government and
good governancewhere the former is concerned with the structure and performance of the state and the latter is
concerned with the ends to which they are put in terms of achieving nation-wide levels of economic, human, social,
political, environmental and institutional development.
THE ISSUES OF POLITICAL POWER, DEMOCRATISATION AND DECENTRALISATION
Political power
One of the benefits of the NIS approach is the ability to assess, as many of the reports do, the inheritance,
and continuing predominance, of the Executive or Presidency in many countries, as the Colombia country report
notes:
The president of the republic is the head of state and the top administrative authority. He is empowered to
freely name and remove the cabinet ministers. He directs international relations. He appoints diplomatic and
consular staff. He directs the public forces and makes use of them as the top commander of the Armed Forces
of the Republic. He directs war operations when he feels they are warranted. He opens and closes Congress
sessions. He regulates the laws. He appoints the presidents, directors and managers of public entities. He elim-
inates or fuses entities. He modifies the structure of ministries by making changes to the law (Colombia coun-
try study, p. 19).
In Fiji and in Ghana, the existing elites and networks are being reconfigured, although in the case of the former,
overt rejection of the democratic process to secure this may be contrasted by the recent acceptance by the latter of
the outcome of the electoral process. Nevertheless, the direction and speed of progress may be inhibited, and the
expectations of a newly-democratised public not achieved. This gives rise to concerns over the phenomenon of
broken-backed democracy (see e.g. Rose et al., 1998) through the recycling of elites or the emergence of the
phenomenon of defensive democratisation where, as Glenn Robinson has suggested in relation to Jordan: uncer-
tain about its ability to survive a deepening crisis the regime undertook sufficient reform to assure its political
longevity, but without altering the core structures of power in Jordan (Robinson, 1998, p. 387). Indeed, the Jordan
country report notes:
The inflated administrative apparatus that was a result of administrative corruption is a heavy burden on the
budget and can not be easily fought. The government still considers itself the guardian on fighting corruption
and does not involve civil society in its plans. Also, the lack of real representation of the society in Parliament
because of the election law is still in force, in addition to the dominance of social traditions such as wasta that
encourages corruption which necessitate long-term policies and programmes to be eradicated. (Jordan coun-
try report, p. 11).
Democratisation
Locating political power and the nature of the political elites is crucial in terms of determining what type of sup-
port, to which pillars to advance the NIS should be considered by donors and by in-country reformers. An unqua-
lified approach and the absence of a country strategy may not necessarily identify those countervailing influences
which may restrain or divert the NIS purpose as the veneer of democracy is being cemented over the old political
systems and power plays which continue to operate beneath the surface. The democratisation route, noted by var-
ious reports, has inherent threats as well as providing the opportunities and incentives for both new and modifica-
tions of the existing types, levels and patterns of corruption. The first issue is that democracy as a process may not
be necessarily intrinsically more honest than other processes concerned with the exercise of power and the winning
and retention of office. The new areas of corruption include elite-managed reform, electoral misconduct and the
development of new patronage networks to sustain electoral support:
In 1981, a new constitutional reform was initiated by President Abdou Diouf, successor of President Senghor.
This new reform sanctions full democratic evolution by establishing free unlimited creation of political
parties. Notwithstanding its importance, this democratic evolution hardly changed the political practice of
the party in power, strongly influenced by the single party system culture. Despite the emergence of a
politically democratic environment relatively speaking, the ruling party continued to resort to the same expe-
dients that is to say favouritism and clientelism in order to consolidate its maintenance (Senegal country
report, p. 3).
Due to the strong political relationships between the Executive and the Legislative parliamentarians swap
parties frequently. Thus, during 1999, a total of 112 parliamentarians from the lower federal house changed
parties; in 2000, they were 41; and in 2001, until February 14th, 23 moved over from one party to another.
After each election, there is a growth of the governments support basis. This happens because parliamentar-
ians loyal to the government influence both the budget and the budgets execution, appoint people to occupy
trust positions, vote legislation that the government is interested in, exert pressures to expedite transfers and
federal-sponsored state and municipal projects (Brazil country report, p. 8).
The past decade, which was supposed to undertake democratization of government and orient the organs of
state towards good governance, witnessed, among other things, squabbles among and within political parties,
unhealthy cut-throat competition for grabbing the seat of government in Singha Durbar, the legendary gov-
ernment secretariat (Nepal country report, p. 20).
Of all the manifestations of democratisation, however, it is party funding that, as the reports from Trinidad and
Tobago and Colombia warn, appears to introduce a corruption-prone dimension into democratisation:
Substantial donations to political parties are not made public. In recent years, major corporations have funded
the political parties. In the past five years members of corporations have also been able to secure Government
appointments at all levels . . . Major contracts have gone to those who supported financially the ruling party
. . . (Trinidad and Tobago country report, p. 13).
The most tenuous area and, as such, the most dangerous for the Colombian business sector, is the issue of
campaign financing. The system for financing electoral activities has given rise to a series of inappropriate
commitments and pending favours with governors, members of Congress and officials elected by popular
vote. The system is not completely transparent and it often leads to behaviours, conduct and decisions that
affect collective well-being (Colombia country report, p. 15).
Decentralisation
Decentralisation is often seen as complementary to democratisation, in pushing down the potential for political
engagement to district or local levels. Again the reports noted that, as with democratisation, existing elite group-
ings seek to colonise, reform or selectively misuse their constitutional powers: both, of course, ensure that the
continuity of centralised networks of control persist. At the same time, the means of horizontal accountability have
not been developed at the same rate, or with the same level of support, to offer a counterbalance to the opportunities
opened up for corruption:
In theory, decentralisation should reduce the level of corruption to the degree that the people are able to over-
see the states performance by giving them the tools to satisfy their needs and by stimulating processes to
control the leaders work. But it has been seen in Colombia, as evidenced by the questionnaires, that admin-
istrative corruption has also become decentralised. The national level shortcomings have reincarnated at the
regional level and the regional institutions require considerable reform in order to enable the decentralising
process to serve its objectives and not be subverted. (Colombia country report, p. 20).
This is not the case at the local government and district council levels where tender procedures can be easily
ignored. This happens primarily because of the lack of proper supervision. Supervision is also insufficient
because the personnel are simply not available. So, while democracy is supposed to bring about accountabil-
ity, because of the insufficient number of trained personnel at the local government and district council levels,
the opposite is the case. Botswana has done the right thing by decentralising responsibilities to the lowest
levels of government, but the consequences are rather the breeding ground for corruption (Botswana country
report, p. 17).
IDENTIFYING TRENDS
At the same time, the developmental paths taken by any country, and the implications for the NIS, are also being
shaped by wider reform which developed countries also continue to promote as reflecting current enthusiasms at
home, or which appear to have served them well in the past decade, even if adverse effects have only recently been
identified. As the Canadian country report notes in relation to New Public Management (NPM) and its implications
for values and ethics in public service:
The focus on de-regulation, the reduction of management supervision, the growing number of alternative ser-
vice delivery agencies, the increasing partnerships with the private sector, the privatisation of certain services
and the adoption of new technologies will have significant impact on ethics and values of public employees,
the private sector and the various recipients of services. Fraud, bribery and other forms of conventional cor-
ruption will continue to be issues as well as more complex issues such as the public trust (Canada country
report, p. 15).
For developed countries, public administration may be in the process of becoming a relic of the past. The
existence of a distinct public sector within a legitimate and responsive state may thus be the consequence of a
distinct development sequence at a time when most developing and transitional countries require both today.
The deliberate construction, or reconstruction, of both public sector and state in developing and transitional coun-
tries thus raises issues about the absence of the development sequence (and its timescale). There are also questions,
as Laking (2000) has suggested, about context and momentum which may be crucial in terms of reform model
transfer and effective implementation, an issue identified in the reports from Brazil and Mongolia:
The impact of the public service managerial revolution is yet an open question in Brazil. The federal, as well
as some states, government has been pursuing administrative reforms along the lines of New Public
Management doctrines, translated by augmenting officials discretionary powers and stimulating a results-
oriented behaviour. Critics point out that this supposes a well-trained professional civil service, protection
from political influence and strong moral enforcement, all of which are currently absent (Brazil country
report, p. 12).
The government of Mongolia has actively been looking for new principles of budget management and effi-
cient functioning of state organizations since 1998. As a result it was decided to introduce new principles of
state budget management (after New Zealand). Though related draft laws were submitted to the Parliament in
1999, they provoked heated arguments around its compatibility with classical model of civil service and
current Law on Civil Service and till present they are pending consideration by the Parliament (Mongolia
country report, p. 10).
Further, financial and management devolution may compound the potential for corruption when implemented,
noted in Fiji and Brazil country reports:
The government prior to the deposed Government had embarked on a Civil Service Reform Program, which
involved the devolving of certain functions normally performed by the Public Service Commission and the
Minister of Finance to respective ministerial/departmental levels. This came with the Financial Management
Program, and delegated budgetary authority and accountability to each ministry. The program was intended to
bringing about efficiency and accountability in the service eliminating wasteful and unprofessional conduct in
public service duty. However this reform was rolled back by the now deposed government, as certain weak-
nesses were discovered in the reform system. There were signs of abuse of the delegated powers in the recruit-
ment and promotion of staff . . . Purchasing of goods and service also became a suspicious affair. It was
perceived that contracting and outsourcing of particular services were going to follow a crony trend or
arranged through bribes and greasing of palms (Fiji country report, p. 11).
The federal bureaucracys opacity and discretionary power concerning voluntary transfers leave space for
corruption of the process. It is symptomatic that one of the first great corruption scandals after the end of
the military dictatorship happened exactly around transfers from the Union to municipalities. Go-betweens
used to offer their services, in return of a stiff charge, to facilitate the transfers. In that scandal, which became
public in 1997, it became obvious that the Brazilian state opacity is a reality even concerning the lower spher-
es . . . (Brazil country report, p. 6).
On the other hand, using assessments of the experiences of countries who have moved further down the reform
route does, as the NIS approach has argued, identify those issues that shouldand couldbe addressed in coun-
tries at an earlier stage in reform process. As such, and in recognition that the NIS approach is intended to be both
dynamic and forward-looking, country reports have noted its capacity to be both flexible and reactive to new devel-
opments or changing circumstances, as applicable to developed as to developing countries (and thus the value in
identifying potential transferable reforms):
In the 2000 Report of the Auditor General, the report noted that Major changes are occurring in the way
government organises and delivers its programs. These changes include deregulation, downsizing, increasing
delegation of decision making to officials in the field, contracting out and entering into partnerships with the
private sector. As well, the government is using new technologies, and its work force is becoming more
mobile and diverse. The report recognised that most of the federal public sector values and ethics initiatives
were in their early stages of development. It also noted a number of issues and areas on concern including a
lack of awareness on the part of most public servants of key reports, a belief that senior managers do not lead
by example, and a lack of follow-up to gauge the success of values and ethics initiatives (Canada country
report, p. 11).
An objective and scientific approach was made by constructing a corruption-prevention infrastructure and
reforming the system. Based on the understanding that banishment of corruption is impossible in practice
without a basic infrastructure, the government is in the process of trying to pass an Anti-Corruption Bill
and examining the possibility of establishing a Presidential Commission on Anti-Corruption consisting
of civilian members to evaluate corruption-prevention measures, support citizens integrity campaigns and
maintain surveillance of assessment organizations (Republic of Korea country report, p. 9).
Integrity policies also include an evaluation by the Ministry of the Interior of the measures that are in place.
This concerns the integrity policies of the national ministries. In 2000 and 2001, parliament was informed
about the state of the art. Most ministries are involved in policies, although they also differ quite significantly
in the methods and measures they implemented. An important more general conclusion is that the ministries
have been paying a lot of attention to rules, codes and procedures to protect integrity but that little is done in
the field of control and compliance and that cultural aspects (raising consciousness) did not get the attention
they deserve (Netherlands country report, pp. 11, 12).
BALANCING REFORMS
Whatever the issues regarding moves toward democratisation and decentralisation, the purpose of participation
will be diluted, if not negated, if the state at any level, and particularly where it interfaces with the public, is neither
responsive nor public-focused, or susceptible to direction for political-partisan rather than public interest reasons.
Firstly, there is a universal need to move beyond the mutual mistrust that has characterised publicofficial relations
in, for example, Colombia or build up general standards of conduct with the transitional Lithuanian state:
There is no confidence on civil society and public officials mistrust the attitude of the average citizen, thus
feeling forewarned when information is requested. Ties between the Government and civil society are not
duly strengthened and, as civil society does seldom find an answer to their demands, participation in the pro-
cess becomes meaningless (Colombia country report, p. 30).
Immaturity of the open civil society is the weakest element in the Lithuanian NIS system. The state has pro-
duced a sufficient number of anticorruption laws, instruments and mechanisms. But if the public servants and
officials, rank and file citizens, entrepreneurs, politicians and lawyers are not honest and moral, if they fail to
adequately perform their duties, if they fail to adhere to the state-of-law principles, the most perfect legisla-
tion will remain but a piece of paper and the principles of democracy will be compromised (Lithuania country
report, p. 6).
Secondly, there is a need to appreciate the long-term approach to delivery of an NIS, and the need to move away
from a single-pillar focus, which provide, as the report from South Korea illustrates, the basis for further devel-
opment:
So far, the integrity system in Korea puts the emphasis on exposure and punishment. But we must focus more
on the dimension of prevention, so that corruption does not occur in the future. Rather than dealing with the
corruption that has already occurred, it is more important to cut off its new sprouts. For this, a more bold
investment is demanded. A clean government and clean society do not happen automatically. They can only
develop through investment, which must include not only financial but also non-financial aspects, namely, the
interest, support and participation of individuals, companies, media and citizens organizations. The eradica-
tion of corruption is possible only when all elements of society participate and actively invest their material
resources, time and interest (Republic of Korea country report, p. 25).
Third, there is the question of which pillar or pillars should be supported, both in terms of the pillar and the
added-value in terms of more effective impact with other pillars and the latters consequential improvement:
Corruption has been prime news material during the last decade. The medias role has been central in turning
corruption into an important issue in the countrys political agenda. Many cases of corruption make their
debut in the press. Whereas the other internal and external control channels are frequently subjected to the
logic of political loyalties and rivalries, printed media became a powerful and independent vehicle for airing
corruption scams (Brazil country report, p. 21).
This in turn allows assessment to be made on the weaknesses and strengths of, and reforms relating to, specific
pillars in terms of their centrality to the working of an NIS; the added-value of pillar interaction both in terms of
addressing corruption and the wider NIS goals; promoting coordinated donor support to pillars; national plans for
dealing with corruption and wider public service reform; measuring individual pillar and NIS performance; and
reconfiguring the NIS pillars as a consequence. Overall, the NIS provides a holistic and comprehensive approach
within which to address key reform issues by governments and donors. When all the barriers to successful anti-
corruption reforms are taken together, the distinct possibility (and probably certainty in some cases) is raised that
transition and developing states may be simply unable to deal with the problem of corruption without support from
international institutions and actors, for whom the NIS approach and the lessons from the country reports offer a
common-ground operating framework.
CONCLUSION
First, the 18-country study was intended to test the use of the NIS as a framework for assessing corruption in
practice (it has also underlined the local knowledge and analysis that in-country researchers bring to the
assessments). The NIS is primarily pillar-focused which invariably means a focus on institutions or on those
institutions which represent more less-defined pillars (such as civil society). Most of the institutions are part of
the state which, in terms of the sources of corruption and the means to deal with corruption, is recognised as having
a central role in terms of reform and progress. They are therefore also central to an effective NIS. In such
circumstances, the framework components have from the outset a functional edge that provides a discrete and
measurable focus.
Thus, broad reform objectivesfreedom of information, citizens rights, for examplemay be diffused in
terms of assessing their existence and their use. Assessment through pillarsfor example, through the activities
of the media (the number and vibrancy of independently-owned publications, the nature of the relationship with the
state) or the presence and effectiveness of Ombudsmengive meaning and measurement to the rhetoric of reform.
Similarly the reality of any official commitment to general anti-corruption programmes and policies, when seen
through the NIS, are benchmarked internally in the context of corruption-proofing (how seriously governments
and legislatures take their own anti-corruption requirements) as well as in terms of the wider governance capacity
(by, for example, the relative levels of resourcing of specific pillars, such as State Audit), and how far their inter-
relationships complement each other in delivering the overall NIS objectives. As a concept and methodology, the
NISs approach is taken up, implicitly and explicitly, by a range of institutions and agencies undertaking country
assessments, invariably because, as it itself claims, it provides a holistic perspective that addresses core institutions
and their roles, within the governance objectives (the approach has appeared implicitly in reports issued by such
diverse agencies as the US Council of Foreign Relations (1999) and the Council of Europes GRECO6).
A related issue is the obvious role that country studies afford to the evaluation process. As Crawford
(2002) effectively argues in his critique of recent evaluation of EU-funded projects, two fundamental components
of his proposed methodology are political context studies and a participatory approach to evaluation. The first
concerns the importance of identifying democratisation trends, and major areas of change at regime level, thus
partly fulfilling the role of a baseline study as well as identifying the opportunities for and challenges to demo-
cratisation (p. 922). In particular, such studies would also inform of the need to understand and analyse the
various economic, social and political forces, including their relative strength, that influence and shape the pro-
spects for democratic reform (p. 922). In relation to the second, he suggests that such studies should be undertaken
by local academic specialists, and also proposes that, in any case, project evaluations should be based on
participation by a range of well-informed national actors, both government and non-government, and inclusive
of non-recipients and non-beneficiaries of assistance, to provide the key input of local knowledge and analysis
(p. 924).
Second, the NIS approach provides the depth to any assessment of the causes and consequences of corruption
that goes beyond quantitative rankings and crude modelling (such as the agent-principal approach). What type of
corruption, and its genesis, in what types of state (from transitional to small-island) the exercise of political power,
the continuing legacies of specific development trajectories and the descriptions of how macro-reform, such as
democratisation or decentralisation, are assimilated or manipulated make a significant case for structured, tailored,
6
See Whats the GRECO?, at www.greco.coe.int
sequenced and sustained reform approaches. It also emphasises how much of that must be home-grown which in
turn posits a particular and specific role for external donors and other agencies.
In doing so, the NIS provides two further advantages over other approaches. Its use across a range of countries
underlines the somewhat obvious conclusion that there is no end-game of the eradication of corruption but also
some interesting perspectives on how developed countries contain and manage continuing areas of concern (such
as political patronage as an integral part of Canadian politics), the awareness that not all reform in developed coun-
tries (such as public management) is unequivocally successful and nor are they necessarily suitable for unadapted
transfer, and the crucial shift from reactive firefighting corruption to a more proactive better governance approach
illustrated by the South Korea country study:
. . . a comprehensive and systematic approach is necessary. As we saw above, a partial and rough integrity
system is ineffective and cannot win the peoples support or approval. Corruption ultimately can be elimi-
nated only when its exact causes are discovered and the connections are cut off . . . Rather than dealing with
the corruption that has already occurred, it is more important to cut off its new sprouts. For this, a more bold
investment is demanded. A clean government and clean society do not happen automatically . . . (South Korea
country study report, pp. 23, 25).
Third, as noted above, the NIS gives donors both a road map to reform and a probability profile of the effec-
tiveness of targeted reform that will resolve many of the weaknesses of past and current reform initiatives and
donor support. One major failing by donors and others has been the lack of awareness of (and planning for) some
of the negative consequences of the unequivocal and unstructured promotion of democratisation, decentralisation
and the public management reform. A number of countries comment on the adverse implications of party funding;
others note the timelag in the decentralisation of the compliance and regulatory agencies (and the over-stretching
of limited resources). Inter-country comparisons also reveal, as in the case of Canada, not just the importance of
continuous attention to the maintenance of standards but also what types of controls and procedures must be intro-
duced to mitigate some of the consequence of wider reforms.
If the NIS provides an assessment of the weaknesses and strengths of, and reforms relating to specific pillars in
terms of their centrality to the working of an NIS, or the added-value of pillar interaction both in terms of addres-
sing corruption and the wider NIS goals, or promoting coordinated donor support to pillars or measuring individual
pillar contribution to the NIS performance, then the NIS provides the context for designing country-relevant
reform programmes. The impact of such programmes, again using the NIS, may be measured over time and
assessed against lessons from other countries. Too often the donors approach reform through single agencies
which, in itself, may be worthwhile but whose impact and effectiveness is diluted by the environment in which
they workand what is needed is an assessment of why that environment inhibits the effectiveness of that agency
and an approach that looks at the timing, sequence and purpose of reform initiatives. At the same time, the use of
the NIS provides context and country-specificity to the questions of where, why and how corruption occursand
thus the appropriateness of proposed reforms.
Finally, the NIS provides the basis of an adaptive approach in terms of means and measurable in terms of
performance and impact as well as in terms of progress, across institutions, countries and time, and in identifying
good practice in operation. Updating country reports and comparing inter-institutional and inter-country progress
gives the impetus to avoid becoming too engaged in the processcombating corruptionat the expense of the
purpose building toward the delivery of the ultimate NIS objectives. Such an approach has a universal resonance,
articulated by Owen Arthur, Prime Minister of Barbados, in June 1999 when he called for a new form of
governance:
After 30 years of independence, the State cannot retreat as a force for good in Caribbean development. It must
redefine its purposes. It must refocus its strategic vision. It must reform its way of doing business. It must
reinvent itself to be relevant to todays purposes and tomorrows needs. It must build new strategic alliances
with the private sector, the non-governmental institutions, and all the institutions of our civil society to create
a new Caribbean, ordered in accordance with the precepts of a just and equitable and good society . . .
It can also reasonably be argued that there has, in our region, been too destructive a competition for political
office; too heavy a concentration of power in the hands of the ruling elites, an unhealthy preservation of anti-
developmental party and tribal divisions, a focus on short-term partisan political concerns rather than long-
term strategic objectives, an efficient patronage and spoils systems which work against sound and progressive
Government . . .
It surely must be the mission of this generation to make consensus building the foundation of a new form of
Governance; to make popular and effective participation and inclusion, the key facets of our political culture,
and to fashion a society in which the peoples business and the Governments business are one and the same
thing . . . (Commonwealth Innovations, 1999, pp. 8, 9).
BACKGROUND AND METHODOLOGY TO THE 18-COUNTRY STUDY

The National Integrity System (NIS) is an approach developed by Transparency International (TI), an international
NGO established in the 1990s to promote corruption awareness and reform initiatives. TI has a Secretariat (TI-S)
based in Berlin; there are independent TI National Chapters in a number of countries. In the year 2000, the Dutch
government funded TI-S to assess the NIS in practice. TI-S worked with the Centre for Fraud Management Studies,
Liverpool Business School, (CFMS; now the Fraud Management Studies Unit, Teesside Business School) to deli-
ver the project. Jeremy Pope was the TI Project Director; Gillian Dell was the TI Project Coordinator and Alan
Doig and Stephanie McIvor of CFMS supervised the research and edited the country studies.
TI-S devised the questionnaire on the basis of previous surveys and secured formal government approvals for
the project. TI-S and CFMS drew up the Terms of Reference. TI-S did not exercise any editorial control over the
country reports or over the reports produced by CFMS which based its work on the two Source Books (1997;
2000), the country reports and independent research.
The project involved two phases. The first involved the preparation of reports from 18 countries, chosen to give
an approximate mix of regions and developmental paths, and based on a framework and questionnaire devised by TI
and CFMS to assess the NIS in practice. The countries chosen were: Argentina; Botswana; Brazil; Bulgaria;
Canada; Colombia; Fiji; Ghana; Jordan; Kazakhstan; Lithuania; Mexico; Mongolia; Nepal; Netherlands; Senegal;
Republic of Korea; Trinidad and Tobago. Authors were selected on the basis of a functioning TI chapter with
research capability or an external researcher orwhere there was not an established TI national Chaptera uni-
versity or research institute with identified research experience. All researcher CVs were submitted for approval and
an appropriate timetable for delivery agreed. In all but one country the researchers were from the country concerned.
All had applied academic and professional backgrounds in corruption research and reform programmes. The indi-
vidual country projects included interviews and focus groups as well as analysis of published material.
The project sought to identify the pillars of the NIS in each country and assess issues concerned with their effec-
tiveness and credibility in combating corruption, internally, externally and interactively. The second phase con-
cerned completion of an overview report, incorporating a review of the NIS as concept and findings from the
country reports. The focus and contents of the country reports was assessed against a range of practitioner, media
and academic material. The country reports, supporting material and the overview report were used to inform the
work of the 2001 Global Forum II conference. Following the completion of the conference, country authors revised
their reports which were then standardised in a format and indexed. They are available on the TI website at: http://
www.transparency.org
REFERENCES
Crawford G. 2002. Evaluating European union promotion of human rights, democracy and good governance: towards a participatory approach.
Journal of International Development 14: 911926.
Commonwealth Innovations. 1999. Opening speech to the CaMDA International Conference, June 1999, Barbados (quoted in Commonwealth
Innovations, the newsletter of the Commonwealth Association for Public Administration and Management (CAPAM), Vol. 5, No. 2, 1999);
124.
Council of Foreign Relations. 1999. Strengthening Palestinian Public Institutions. Chaired by Michel Rocard and directed by Henry Siegman;
Principal Authors: Yezid Sayigh and Khalil Shikaki.
Laking R. 2000. Dont try this at home? A New Zealand approach to public management reform in Mongolia. International Public Management
Journal 2(2A): 217235.
Langseth P, Stapenhurst R, Pope J. 1997. The Role of A National Integrity System in Fighting Corruption. World Bank.
Pope J (ed.). 1997. The TI Source Book. Transparency International: Berlin.
Pope J. 2000. The TI Source Book 2000. Transparency International: Berlin.
Robinson GE. 1998. Defensive democratisation in Jordan. International Journal of Middle East Studies 30: 387410.
Rose R, Mishler W, Haerpfer C. 1998. Democracy and Its Alternatives. Polity Press: Cambridge.

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public administration and development

Public Admin. Dev. 23, 317332 (2003)

THE NATIONAL INTEGRITY SYSTEM: ASSESSING CORRUPTION

THE NIS APPROACH

Copyright # 2003 John Wiley & Sons, Ltd.

THE NIS AS THE BASIS FOR REFORM

THE NIS IN PRACTICE: FINDINGS FROM THE STUDIES5

The pillars: corruption-proofing and inter-dependence

THE ISSUES OF POLITICAL POWER, DEMOCRATISATION AND DECENTRALISATION

BACKGROUND AND METHODOLOGY TO THE 18-COUNTRY STUDY

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