THE

ASIA PACIFIC JOURNAL OF PUBLIC ADMINISTRATION VOL. 31, NO. 2 (DECEMBER 2009): 171-195

Benchmarking for Excellence: A Comparative Analysis of Seven Asian Anti-Corruption Agencies

Jon S T Quah

Anti-corruption agencies (ACAs) have been established in many Asian countries to tackle the problem of corruption. However, with the exceptions of the Corrupt Practices Investigation Bureau in Singapore and the Independent Commission Against Corruption in Hong Kong, many Asian ACAs have been ineffective. What criteria should be used to evaluate their effectiveness? After analyzing the functions of the ACAs in India, Hong Kong, Macao, Philippines, Singapore, South Korea and Thailand, this article recommends that their performance should be benchmarked according to 22 indicators. It concludes that benchmarking provides an ACA with an objective method for evaluating its performance by comparing it with the performance of more effective ACAs. Benchmarking also enables an ACA to improve its performance by introducing reforms to remove the weaknesses exposed by comparison with more effective ACAs in other countries.

Introduction Corruption is perceived as a serious problem in many Asian countries today according to Transparency s International 2008 Corruption Perceptions Index (CPI). The most common response in these countries is the establishment of anti-corruption agencies (ACAs) to combat corruption. However, according to Pope (2000: 104), ACAs have been more often failures than successes. What criteria should be used to evaluate their effectiveness? This article addresses this question by suggesting several criteria for benchmarking the performance of Asian ACAs. The article is divided into five sections. The first section defines benchmarking and identifies its rationale. The second section discusses the advantages of establishing ACAs. The third section focuses on the different types of ACAs and describes the functions of these ACAs: the Corrupt Practices Investigation Bureau (CPIB) in Singapore; the Independent Commission Against Corruption (ICAC) in the Hong Kong SAR; the Commission Against Corruption (CCAC) in the Macao SAR; the Central Bureau of Investigation (CBI) in India; the Korea Independent Commission Against Corruption (KICAC) in South Korea; the National Counter Corruption Commission (NCCC) in Thailand; and the Tanodbayan or Ombudsman in the Philippines. These seven ACAs are selected for
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comparative analysis to illustrate their diverse functions and also because of their available published performance data. The fourth section compares their performance according to several indicators. The concluding section recommends that Asian ACAs should benchmark their performance according to 22 indicators, as benchmarking enables their political leaders and policy-makers to assess their effectiveness and make the necessary changes for improving their performance. Benchmarking: Meaning and Rationale The origins of benchmarking can be traced to Japanese business firms which visited other countries in the 1950s to benchmark the best organisations from which to transfer technology and business practices to themselves. These Japanese companies described what they did as industry tours instead of benchmarking. The process of the tours involved these four steps: researching published data to identify the best organisations; contacting the organizations to schedule a visit; visiting the organizations and carefully selecting pertinent data; and returning home and adopting (with relevant adaptations) the lessons learnt to gain a competitive advantage (Harrington & Harrington 1996: 29). The application of benchmarking to measure business performance in terms of cost/sales and investment ratios during the 1950s encouraged companies in the United States to identify their own strengths and weaknesses by comparing them with those of their counterparts within the industry. The growth of computer technology in the 1960s and 1970s further spurred the application of benchmarking (Kozak 2004: 9). Xeroxs success in reinventing itself through benchmarking resulted in the recognition of benchmarking as an important tool of continuous improvement for American companies in the 1980s. Benchmarking is now employed in the automotive, education, health, medicine, telecommunications, transport and tourism industries and is recognised internationally as a quality improvement tool (Kozak 2004: 9-10). In his content analysis of 11 widely-used definitions, Kozak (2004: 7) found that all these definitions have a common theme, namely: the continuous measurement and improvement of an organization s performance against the best in the industry to obtain information about new working methods or practices in other organizations. The most useful definition for this article is Spendolinis (1992: 9) definition of benchmarking as a continuous, systematic process for evaluating the products, services, and work processes of organizations that are recognized as representing best practices for the purpose of organizational improvement. Here, benchmarking refers to the process of evaluating the effectiveness of Asian ACAs with the objective of improving their performance. What is the rationale for benchmarking? Internal benchmarking refers to two-way communication and sharing opinions between departments
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within the same organization or between organizations operating as part of a chain in different countries (Kozak 2004: 10). In contrast, external benchmarking involves a comparison of work with external organizations in order to discover new ideas, methods, products and services. External benchmarking enables an organisation to improve its performance by measuring how it performs, comparing it with its competitors, and determining how the latter have achieved their performance levels. Thus, external benchmarking provides an organisation with opportunities for learning from the best practices and experiences of others who are at the leading edge (Kozak 2004: 11). This article focuses on external benchmarking to compare the performance of seven Asian ACAs on the basis of several indicators. Rose (2005: 35) contends that benchmarking provides policy-makers with a tool for evaluating a national programme and enables them to learn about successful programmes in other countries. Thus: The intention of benchmarking is constructive: to evaluate a programme s performance by a measure independent of the opinions of policymakers . . . Evaluating a programme against a benchmark standard will show whether, or to what extent, satisfaction is justified. Insofar as the results are positive, the process endorses the predisposition to ignore what is done abroad. But insofar as benchmarking shows that a programme producing domestic satisfaction is not so successful as others evaluated by the same standard, benchmarking can stimulate policymakers to adopt improvements by learning from comparable countries that do do better. In short, the advantage of benchmarking Asian ACAs is that it identifies those ineffective ACAs and encourages them to perform better by emulating the best practices of their more effective counterparts. Rationale and Advantages of ACAs ACAs are specialised agencies established by governments for the specific purpose of minimizing corruption in their countries. Meagher (2005: 70) defines ACAs as separate, permanent agencies whose primary function is to provide centralized leadership in [such] core areas of anti-corruption activity . . . [as] policy analysis and technical assistance in prevention, public outreach and information, monitoring, investigation, and prosecution. Nicholls et al (2006: 476) observe that an ACA has four advantages: reduced administrative costs; enhanced public profile; concentration of expertise; and reduced uncertainty over the jurisdiction by avoiding duplication of powers and work. The United Nations Office on Drugs and Crimes AntiCorruption Toolkit (2004: 89-90) has identified nine advantages of an ACA:
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a high degree of specialisation and expertise; a high degree of autonomy to insulate it from corruption and other undue influences; separateness from the agencies and departments that it will be investigating; a fresh start when new, and thus free from corruption and other problems that may affect existing institutions; considerable public credibility; established security protection; political, legal and public accountability; clarity in the assessment of its progress, successes and failures; and swift action against corruption as task-specific resources are used and officials are not subjected to the competing priorities of general law enforcement, audit and similar agencies. The most important advantage of creating an ACA is that it sends a powerful signal to the citizens in the country that the government is committed to fighting corruption (UNODC 2004: 90). However, this initial advantage is eroded if the government does not demonstrate its commitment by providing the ACA with sufficient legal powers and adequate human and financial resources. Also, the government should provide the ACA with operational autonomy so that it can investigate anyone, regardless of status or position. All of the operational advantages listed above will count for naught if the government does not support the ACA by allowing it to operate independently and by providing it with adequate resources for performing its functions effectively. Types and Functions of Asian ACAs Types of ACAs Table 1 shows that 16 ACAs were established in Asia between 1952 and 2006, from the CPIBs formation in Singapore in October 1952 to the creation of the Independent Authority Against Corruption (IAAC) in Mongolia in December 2006. There are several types of ACAs depending on whether they are concerned with combating corruption solely, or with the performance of many functions including anti-corruption; on whether their jurisdiction is limited to the public sector only, or to both the public and private sectors; and on the nature of their anti-corruption functions. Table 2 summarises the features of the seven ACAs which are analysed below. Functions of CPIB During Singapores colonial period, the British authorities relied on the Anti-Corruption Branch (ACB) of the Criminal Investigation Department (CID) in the Singapore Police Force to curb corruption. This was a serious mistake for three reasons. First, the ACB was a small unit of only 17 men with a difficult task to perform: the eradication of corruption in the civil service. Second, as the CIDs top priority was to deal with serious crimes
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Table 1 Anti-Corruption Agencies in Asian Countries

Country
Singapore India Malaysia Hong Kong SAR, China

Anti-corruption agency
Corrupt Practices Investigation Bureau Central Bureau of Investigation Anti-Corruption Agency Independent Commission Against Corruption Anti-Corruption Bureau Tanodbayan* (Ombudsman) Commission for the Investigation of Abuse of Authority Commission to Investigate Allegations of Bribery or Corruption National Accountability Bureau National Counter Corruption Commission** Commission Against Corruption Korea Independent Commission Against Corruption*** Corruption Eradication Commission Anti-Corruption Commission Office of the Anti-Corruption Commission Independent Authority Against Corruption

Date established
October 1952 April 1963 October 1967 February 1974

Brunei Darusalam Philippines Nepal Sri Lanka Pakistan Thailand Macao SAR, China South Korea Indonesia Bangladesh Bhutan Mongolia

February 1982 May 1988 1990 November 1994 November 1999 November 1999 December 1999 January 2002 December 2003 May 2004 January 2006 December 2006

*The Tanodbayan was originally established by President Ferdinand Marcos in July 1979. As it was ineffective, it was reorganised when President Corazon Aquino issued Executive Order No 242 on 24 July 1987. The Office of the Ombudsman became operational on 12 May 1988. **The NCCC was renamed the National Anti-Corruption Commission (NACC) on 15 July 2008. ***The KICAC was merged with the Ombudsman and the Administrative Appeals Commission to form the Anti-Corruption and Civil Rights Commission (ACRC) on 29 February 2008.

like homicide, the task of fighting corruption received lower priority as the ACB had to compete with other branches for limited resources. Third, the ACB was ineffective because of the rampant police corruption in colonial Singapore (Quah 2007: 14-15). In October 1951, a consignment of 1,800 pounds of opium worth S$400,000 (US$133,330) was stolen by a gang of
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Table 2 Types of Anti-Corruption Agencies in Seven Countries

Anti-corruption agency CPIB, Singapore Functions Jurisdiction Location

Investigation, prevention and education Investigation, prevention and education Inspection of assets of public officials, investigation, prevention and education Anti-corruption, economic crimes and special crimes (organised crime and terrorism) Anti-corruption and ombudsman Anti-corruption, ombudsman, prosecution, discipline, and public assistance Anti-corruption, ombudsman and administrative appeals

Public and private sectors Public and private sectors Public sector only

Prime Ministers Office

ICAC, Hong Kong SAR, China

Chief Executives Office

NCCC (NACC from 15 July 2008) Thailand

Senate

CBI, India

Public sector only

Central Vigilance Commission

CCAC, Macao SAR, China Ombudsman Philippines

Public sector only Public sector only

Chief Executives Office

House of Representatives

KICAC (ACRC from 29 February 2008), South Korea

Public sector only

Office of the President

robbers, which included three police detectives. A special team appointed by the British colonial government to investigate the robbery found that corruption was widespread especially among those policemen involved in protection rackets (Quah 2007: 16). The opium hijacking scandal made the British authorities realise the importance of creating an independent ACA that was separate from the police. Accordingly, the ACB was replaced with the CPIB, which was formed as the first Asian ACA in October 1952, to perform these functions: receiving and investigating complaints concerning corruption in the public and private sectors; investigating malpractices and misconduct by public officers; and examining the practices and procedures in the public service
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to minimize opportunities for corrupt practices (CPIB 1990: 2). As part of its preventive function, the CPIB is also responsible for screening candidates selected for positions in the civil service and statutory boards to ensure that only those candidates without any taint of corruption or misconduct are actually appointed (Republic of Singapore 1994: 638). Functions of ICAC The same story can be told in Hong Kong, which was under British rule from 1841 to 30 June 1997. Following Singapores experience, the ACB of the CID in the Royal Hong Kong Police Force (RHKPF) was also responsible for curbing corruption from 1948 to 1971, when the ACB was upgraded to the Anti-Corruption Office (ACO), which was also ineffective in tackling the extensive police corruption. The escape of a corruption suspect (Chief Superintendent Peter F Godber on 8 June 1973) to the United Kingdom angered the public and undermined the ACOs credibility. Consequently, the Governor, Sir Murray MacLehose, was compelled by public criticism to accept the Blair-Kerr Commissions recommendation to establish an independent ACA, separate from the RHKPF, to fight corruption (Quah 2003: 137-140). Unlike the CPIBs investigative model, the ICAC is described as the universal model because of its three-pronged strategy of focusing on investigation, community relations and prevention (Heilbrunn 2006: 136). The ICAC was formed on 15 February 1974 to root out corruption and to restore confidence in the Government (Wong 1981: 45). The ICACs raison detre is to perform a trinity of purpose comprising investigation, prevention and education. The ICAC s three-pronged approach is critical for developing a new public consciousness and is reflected in its organisational structure of the three Departments of Operations, Corruption Prevention, and Community Relations (ICAC 1989: 28-29). Functions of NCCC/NACC Section 19 of the Organic Act on Counter Corruption B E 2542 (1999) identifies the powers and duties of Thailand s NCCC (ONCCC 2006a: 10-11). The NCCCs first function is to inspect and verify the declaration of the assets and liabilities submitted by politicians and civil servants. Officials who fail to declare their assets or make false declarations are reported to the Constitutional Court by the NCCC. Those found guilty are removed from their positions and barred from holding political office for five years. The NCCC s second role involves making recommendations on preventing corruption to the Cabinet and other government agencies; enhancing the integrity of the officials and public by organising contests, meetings and seminars on fighting corruption among the people and civil servants; and fostering cooperation among the public by conducting
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seminars on countering corruption in Bangkok and the other provinces. The NCCC s third function is to suppress corruption by taking disciplinary action against corrupt politicians and bureaucrats. It investigates corruption complaints against politicians and civil servants, and the Senate has the power to impeach them for having unusual wealth, or for committing corruption, malfeasance, or abuse of power. Section 58 empowers the Senate to initiate the removal from office of political leaders and senior bureaucrats for such offences. Section 59 specifies that the Senate can also initiate the impeachment of corrupt politicians and bureaucrats if it receives a request that is supported by one-quarter of the House of Representatives, or if the complaint is signed by 50,000 members of the public (ONCCC 2006a: 23). Functions of the CBI In April 1963, the government of India created the CBI by incorporating the Delhi Special Police Establishment as one of its six divisions, namely the Investigation and Anti-Corruption Division. In February 1964, an Economic Offences Wing was added to the CBI (CBI 2008: 2). To meet the increase in the number of securities scam cases and economic offences with the liberalisation of Indias economy, the CBI was reorganised in 1994 and three investigation divisions were formed. First, the Anti-Corruption Division was established to deal with cases of corruption and fraud committed by public servants of all central government departments, public sector undertakings and financial institutions. Second, the Economic Crimes Division was formed to handle bank and financial fraud; import, export and foreign exchange violations; large-scale smuggling of narcotics, antiques and cultural property; and smuggling of other contraband items. The third division is the Special Crimes Division, which deals with cases of terrorism, bomb blasts, sensational homicides, kidnapping for ransom, and crimes committed by the mafia or underworld (CBI 2008: 3-4). Functions of CCAC To enable the CCAC to combat corruption more effectively, Macao s Legislative Assembly enacted the Organisational Law of the CCAC (Law No 10/2000) on 14 August 2000 to give the CCAC powers of detention, search, seizure and use of weapons; and its investigators are also given the status of criminal investigation police officers (CCAC 2007: 12). The CCAC performs four functions: preventing acts of corruption and fraud; investigating crimes of corruption and fraud committed by civil servants; investigating allegations of corruption and fraud in electoral registration and the election of members of government institutions in Macao; and protecting human rights, freedom and legitimate interests of individuals, as well as ensuring fairness, lawfulness and efficiency of the public
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administration (CCAC 2001: 12). Unlike the previous ACAs, the CCAC is concerned not only with investigating and preventing corruption among civil servants. It also performs the function of an Ombudsman to protect the rights, freedom and interests of individuals in Macao. Functions of the Ombudsman In the Philippines, the Office of the Ombudsman was originally formed in July 1979 when President Ferdinand Marcos issued Presidential Decree No 1630. In fighting corruption, the Ombudsmans role was to file and prosecute civil and administrative cases involving graft and corrupt practices and other offences committed by civil servants. However, the Ombudsman was ineffective during the remaining seven years of Marcos rule, as corruption reached its all time high and permeated almost all aspects of bureaucratic life and institutions, resulting in the systematic plunder of the country (Varela 1995: 174). When President Corazon Aquino assumed office in February 1986, there was high expectation that the end of the culture of graft and corruption was near (Varela 1995: 174). Among the anti-corruption measures introduced, the Tanodbayan was reorganised in 1988 during Aquino s term of office. The rejuvenated Ombudsman is the constitutionally mandated lead ACA in the Philippines and performs the following functions: investigation of anomalies and inefficiency; prosecution of graft cases in the Sandiganbayan (Special Anti-Graft Court); disciplinary control over all elected and appointed officials except for members of the Congress and Judiciary and impeachable officials; requiring public officials and employees to give assistance to the public; and graft prevention by analysing anti-corruption measures and increasing public awareness and cooperation (Office of the Ombudsman official website). Functions of KICAC/ACRC In South Korea, President Kim Dae Jungs comprehensive anti-corruption strategy met with stiff resistance in the National Assembly. Consequently, it took more than two years before the Anti-Corruption Act was passed on 24 July 2001. Six months later, the KICAC was formed on 25 January 2002 as the de jure ACA in South Korea (Quah 2003: 169). In its Annual Report 2005, the KICAC (2006: 4, 7) identified its functions as: formulating and coordinating anti-corruption policies by organising regularly the InterAgency Meeting on Corruption; evaluating the levels of integrity and anticorruption practices of public sector organisations; monitoring corruption and protecting and rewarding whistle-blowers; promoting cooperation to fight corruption by encouraging civil society involvement and publicprivate partnership against corruption, and engaging in the global fight
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against corruption; improving the legal and institutional frameworks to remove laws and practices which encourage corruption; and inculcating ethical values in society by promoting public awareness of corruption risks and by enforcing the code of conduct for public sector employees. Unlike the other six ACAs, the KICAC cannot investigate corruption cases by itself; it has to rely on the Board of Audit and Investigation and other agencies to do so. On 29 February 2008, the KICAC was merged with the Ombudsman and the Administrative Appeals Commission to form the Anti-Corruption and Civil Rights Commission (ACRC), which performs these functions: handling and addressing public complaints and improving related unreasonable systems; building a clean society by preventing and deterring corruption in the public sector; and protecting peoples rights from illegal and unfair administrative practices through the administrative appeals system (ACRC website). Comparative Analysis A comparison of the functions of the seven ACAs shows, first, that only Singapores CPIB and Hong Kongs ICAC are concerned with combating corruption in both the public and private sectors. In contrast, the other five ACAs devote their anti-corruption efforts only to the public sector. Second, the CPIB and ICAC are the two ACAs which focus on the investigation of corruption offences, the prevention of corruption by reducing the opportunities for corruption, and the education of the population on the negative effects of corruption. However, as the CPIB has a relatively limited number of staff (eg, only 89 in 2007), it devotes more attention to investigation than the other functions of prevention and education (Republic of Singapore 2008: 374). In contrast, the ICAC, which had 1,200 staff in 2007, emphasises all of the functions of investigation, prevention and education (ICAC 2008: 30). Third, the other five ACAs perform other functions in addition to combating corruption. Thailands NCCC, for example, is also concerned with the inspection and verification of the assets and liabilities of politicians and senior bureaucrats, along with its anti-corruption functions. Similarly, the CBI in India is responsible not only for combating corruption, but also for economic crimes and special crimes like terrorism and organised crime. Macao s CCAC and the Philippines Ombudsman not only combat corruption but also perform the functions of an Ombudsman. However, the Philippines Ombudsman performs more functions as it is also responsible for the investigation, prevention and prosecution of corruption cases, disciplinary control of civil servants, and the provision of public assistance. South Koreas KICAC was concerned only with the preventive and educative aspects of combating corruption during its first six years as it did not have investigative powers. After the KICACs merger with the Ombudsman and the Administrative Appeals Commission on 29
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February 2008 to form the ACRC, the ACRC is now responsible for anticorruption (without investigation), ombudsman functions, and considering administrative appeals. Thus, the KICAC and ACRC have been unique as ACAs, as they have not been responsible for investigating corruption cases even though their function is to combat corruption. Benchmarking the Seven ACAs Performance As the first step in benchmarking the performance of Asian ACAs, it is necessary to identify the most effective ACAs. Rose (2005: 35, 37) describes this first step as the agreement on a standard for comparing programme outcomes. The second step is to compare programmes with the chosen standard so as to create a league table indicating the performance of all of the ACAs according to the selected indicators. National Indicators Three indicators are used here: Transparency Internationals 2008 CPI score; the World Banks 2008 control of corruption indicator; and the Political and Economic Risk Consultancy s (PERC) 2008 survey on corruption. These indicators reflect the effectiveness of the countries anti-corruption strategies which are implemented by their respective ACAs. Table 3 ranks the seven Asian countries according to their scores on the 2005 CPI and PERC and their percentile rank on the World Banks control of corruption indicator. As shown in Table 4, the ranking of the seven Asian countries does not change very much if they are ranked according to the 2008 CPI, PERC scores, and the control of corruption percentile rank. The only changes are the higher ranking of South Korea and India over Macao and Thailand, respectively, in 2008. As political will is the most important factor for ensuring the effective implementation of a comprehensive anti-corruption strategy in a country (Quah 2003: 181), how can it be ascertained? Political will refers to the commitment of political leaders to minimize corruption. It exists when these three conditions are met: comprehensive anti-corruption legislation exists; the independent ACA is provided with sufficient personnel and resources; and the anti-corruption laws are impartially enforced by an independent ACA (Quah 2007: 37-38). Agency Indicators: Per Capita Expenditure and Staff-Population Ratio To assess whether the seven ACAs are provided with adequate personnel and budget by their governments to perform their functions, data on their personnel numbers and budgets for a selected year (2005) are used to calculate these two indicators:

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Table 3 CPI, CC and PERC Indicators for Seven Asian Countries, 2005
Economy Singapore Hong Kong Macao South Korea Thailand India Philippines CPI score* 9.4 8.3 6.6** 5.0 3.8 2.9 2.5 Control of corruption* 98.1 92.7 68.9 70.4 54.4 46.1 34.0 PERC score* 0.65 3.50 4.78** 6.50 7.20 8.63 8.80 Rank 1 2 3 4 5 6 7

*CPI score ranges from 0 (most corrupt) to 10 (least corrupt); PERC score ranges from 0 (least corrupt) to 10 (most corrupt); and control of corruption uses a percentile rank. **2006 figures are used as Macao was not included in the 2005 CPI and PERC survey. Sources: World Bank (2009), Transparency International (2005), and PERC (2008).

Table 4 CPI, CC and PERC Indicators for Seven Asian Countries, 2008
Economy CPI score Control of corruption 99.5 94.2 69.6 58.0 44.4 43.0 26.1 PERC score Rank

Singapore Hong Kong South Korea Macao India Thailand Philippines

9.2 8.1 5.6 5.4 3.4 3.5 2.3

1.13 1.80 5.65 3.30 7.25 8.00 9.00

1 2 3 4 5 6 7

Sources: Transparency International (2008), World Bank (2009), and PERC (2008).

1. 2.

Per capita expenditure that is, the ACAs budget for 2005 in US$ (to ensure comparability), divided by the total population in the country for the same year. Staff-population ratio that is, the ratio of the population in the country in 2005 to the number of ACA personnel in 2005.

Table 5 shows that while Hong Kong s ICAC is the best funded of the seven ACAs with a budget of US$85 million, it is ranked second as
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Table 5 Per Capita Expenditure of the Seven ACAs in 2005

ACA CCAC ICAC CPIB KICAC NCCC CBI Ombudsman Budget US$10.6 m US$85 m US$7.7 m US$17.8 m US$22.8 m US$30.3 m US$12 m Population 488,100 7,000,000 4,300,000 47,800,000 64,200,000 1,081,200,000 81,400,000 Per capita expenditure US$21.72 US$12.14 US$1.79 US$0.37 US$0.36 US$0.28 US$0.15 Rank 1 2 3 4 5 6 7

Sources: Budget data are obtained from CBI (2006), CCAC (2006), ICAC (2006), KICAC (2006), Office of the Ombudsman (2006), ONCCC (2006b), and Republic of Singapore (2007). The 2005 population figures are taken from Economist (2007).

its per capita expenditure of US$12.14 is below that of Macaos CCAC, which has a per capita expenditure of US$21.72. Singapores CPIB has the second smallest budget of US$7.7 million, but its per capita expenditure of US$1.79 is ranked third as Singapores population of 4.3 million is the second smallest among the seven countries. In contrast, the per capita expenditures of the other four ACAs are less favourable because of their larger populations, with India having the worlds second largest population (1.0812 billion). This explains why the CBI is ranked sixth in terms of per capita expenditure even though its budget of US$30.3 million is higher than the budgets of the NCCC, KICAC, and the Ombudsman. The KICAC s per capita expenditure of US$0.37 is fourth, as South Korea has a smaller population than Thailand and the Philippines. The NCCC is ranked fifth with a per capita expenditure of US$0.36 even though its budget is larger than the KICACs budget, as Thailand has more people than South Korea. The Ombudsmans lowest per capita expenditure of US$0.15 is not surprising in view of its budget of US$12 million and the countrys population of 81.4 million. While the per capita expenditures of the ACAs indicate their level of funding, their staff-population ratios indicate whether they are adequately staffed or not. Table 6 shows that even though the CBI has the most staff with 4,711 personnel, it is ranked sixth with a staff-population ratio of 1:229,505. On the other hand, the CPIB has the smallest staff with 82 personnel, but its staff-population ratio of 1:53,086 is ranked third, behind the CCAC, which has the best staff-population of 1:4,358, and the ICAC, which is ranked second with a staff-population ratio of 1:5,863. The NCCC s staff-population ratio of 1:69,481 is ranked fourth, and the Ombudsman
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Table 6 Staff-Population Ratios of the Seven ACAs in 2005

ACA CCAC ICAC CPIB NCCC Ombudsman CBI KICAC
Sources: as in Table 5.

Personnel 112 1,194 82 924 957 4,711 205

Population 488,100 7,000,000 4,300,000 64,200,000 81,400,000 1,081,200,000 47,800,000

Staff-population ratio 1:4,358 1:5,863 1:53,086 1:69,481 1:85,057 1:229,505 1:233,171

Rank 1 2 3 4 5 6 7

is ranked fifth with a staff-population ratio of 1:85,057. The KICACs least favourable staff-population ratio of 1:233,171 indicates that it is understaffed with 205 personnel given the countrys population of 47.8 million. Agency Indicators: Independence and Credibility In his analysis of the strategy of relying on an ACA, Johnston (2002: 255) has identified four prerequisites for its success: independence, permanence, coherence, and credibility. However, for this discussion, only the criteria of independence and credibility are considered. The first prerequisite of independence is important to prevent an ACA from being used as a political weapon against the opponents of the government, as corruption investigations do become weapons in partisan conflicts and tactics of reprisal. Indeed, where corruption investigations are politicized, powerful officials can protect their own and conceal evidence (Johnston 2002: 256). An independent ACA can follow the evidence of corruption wherever it leads and resist pressures to conduct investigations and prosecutions of political targets. Furthermore, it publicises all its activities freely and conducts them in a transparent manner to assure citizens that the evidence they give will be taken seriously, and that they can file reports without fear of reprisals (Johnston 2002: 257). Independence ensures that an ACA will have adequate funding and access to information. Second, how does an ACA enhance its credibility? Johnston (2002: 261) contends that: if the public believes that all complaints will be carefully considered, and pursued as far as the evidence takes them; that investigatory and monitoring functions are sustained and broadly employed; that prevention activities are available to all; that choices
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and priorities are guided by a vision of the overall good, rather than by expediency or partisan gain; and that the agency itself is incorruptible (no small challenge in its own right), a credible image of independence can be built up over time. To sustain its credibility, an ACA has to conduct public education campaigns regularly. Credibility is perhaps the most important criterion as an ACAs reports and efforts will become suspect or seen as futile if it loses its credibility (Johnston 2002: 261). Based on Johnstons criteria of independence and credibility, how can an ACAs independence and credibility be evaluated? An ACAs degree of independence can be assessed according to these indicators: 1. 2. 3. Location: Where is the ACA located in the government? Appointment of director: Who appoints him/her and to whom must he/she report? Independence from police: As the ACAs in former British colonies originated from the police, is the ACA still part of the police or is it an independent agency? Investigation of political leaders and senior civil servants: Has the ACA investigated political leaders and senior civil servants if they are accused of corruption? Taking action against big fish: Has the ACA taken action against corrupt prominent individuals? How many big fish have been prosecuted and convicted? Weapon against opposition: Has the ACA been used by the government as a weapon against its political opponents?

4.

5.

6.

How does an ACA ensure its credibility among the citizens in the country? There are four main indicators of an ACAs credibility: 1. Consideration of all complaints: Does the public perceive that all complaints, no matter how small, will be considered by the ACA? What is the proportion of complaints investigated by the ACA? Public perceptions of the ACA s professionalism: Does the public perceive the ACA to be impartial in its investigations and not abuse its powers? Does the public believe that the ACA will keep the corruption reports confidential?

2.

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3.

Enforcement of the anti-corruption laws: Does the ACA enforce the anti-corruption laws impartially? Does the ACA focus on petty corruption and ignore grand corruption? Are the rich and powerful protected from investigation and prosecution for corruption offences? Public image of the ACA: How is the ACA viewed by the public? Is it seen as an incorruptible agency or as an agency riddled with corruption? How are complaints against ACA officers dealt with?

4.

To illustrate the use of the first indicator of an ACA s credibility, available data on the actual proportion of corruption complaints investigated by the ICAC, CPIB and CCAC are provided in Tables 7, 8 and 9, respectively. Table 7 shows that the proportion of pursuable reports in the ICACs Operations Department increased from 78.3 percent in 2001 to a peak of 91.5 percent in 2004. The ICAC received 23,927 corruption reports during 2001-2006, and 19,844 reports (82.9 percent) were pursuable. Unlike the ICAC, the CPIB has received fewer reports of corruption, as Table 8 shows that 4,563 reports were received by the CPIB during 1998-2002. The proportion of reports investigated by the CPIB varied from 47.6 percent in 2002 to 68.9 percent in 1999. On average, however, nearly 60 percent of the reports received by the CPIB from 1998-2002 were investigated. Like the CPIB, the CCAC has also received fewer reports than the ICAC. Table 9 shows that the CCAC received 5,942 cases during 2000-2007. However, only 949 cases (19 percent) were commenced or investigated by the CCAC during that period. The proportion of commenced cases varied from 9.7 percent in 2004 to 25 percent in 2007. To assess the public perceptions of an ACA s professionalism and public image, surveys must be conducted of a country s population to obtain information on these aspects. The relevant findings of surveys conducted in Hong Kong and Singapore are highlighted in Tables 10 and 11, respectively. Table 10 demonstrates the tremendous public support for the ICAC and their positive assessment of its professionalism. The ICAC s annual surveys from 2003-2006 showed that nearly all of the respondents said that the ICAC deserved to be supported. Ninety-five percent of them indicated that their confidence would increase or remain the same in the next year. Their high level of trust in the ICAC was manifested in the fact that an average of 72.6 percent of the respondents would reveal their identity when reporting corruption to the ICAC. Nearly 68 percent of them believed that the ICAC s anti-corruption work was effective. Finally, about three-quarters of the respondents in all of the four surveys viewed the ICAC as an impartial agency. Table 11 shows, first, that 13 percent of the respondents rated corruption control in Singapore as excellent; 42 percent as very good; 39
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Table 7 Proportion of Pursuable Reports by ICAC, 2001-2006

Year Total corruption reports 4,476 4,371 4,310 3,746 3,685 3,339 23,927 Pursuable reports 3,504 3,255 3,930 3,426 3,022 2,707 19,844 Proportion of pursuable reports 78.3% 74.5% 91.2% 91.5% 82.0% 81.1% 82.9%

2001 2002 2003 2004 2005 2006 Total

Sources: ICAC (2004, 2007).

Table 8 Proportion of Reports Investigated by CPIB, 1998-2002

Year Reports received Reports investigated 575 777 515 497 371 2,735 Proportion of reports investigated 67.5% 68.9% 52.0% 61.2% 47.6% 59.9%

1998 1999 2000 2001 2002 Total

Source: CPIB (2003: 5.36).

852 1,128 991 812 780 4,563

percent as good; and only 7 percent as fair. Second, 71 percent of them agreed or strongly agreed that the CPIB had done well in solving corruption offences; 61 percent of them trusted the CPIB to keep Singapore corruption free; and 56 percent of them agreed or strongly agreed that the CPIB was world-class in curbing corruption. Third, when the respondents were asked whether the CPIB was impartial or fair in its investigations, Table 11 shows that 69.9 percent said that it was impartial or fair, 5.6 percent said that it was partial or unfair, and 24.5 percent did not know or have an opinion. Similarly, when the respondents were asked whether the CPIB had abused its investigation powers, Table 11 shows that 65 percent of them said that

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Table 9 Commenced Cases by CCAC, 2000-2007

Year Commenced cases Not-commenced cases 783 1,062 917 333 708 438 377 375 4,993 Proportion of commenced cases 14.7% 11.2% 12.5% 21.3% 9.7% 24.5% 23.5% 25.0% 19.0%

2000 2001 2002 2003 2004 2005 2006 2007 Total

Source: CCAC (2001-2008).

135 134 131 90 76 142 116 125 949

Table 10 Public Perceptions of Hong Kongs ICAC, 2003-2006

Survey Item % indicating that the ICAC deserves to be supported % indicating that their confidence in ICAC would increase or remain same next year % believing that ICAC would keep corruption reports confidential % indicating that they would reveal their identity when reporting corruption to ICAC % believing that ICACs anti-corruption work is effective % believing that the ICAC is an impartial law enforcement body
Source: Compiled from ICAC (2004-2007).

2003 99.3% 94% 88.9% 75.9% 67.3% 73.4%

2004 99.1% 93.9% 89.3% 71.8% 67.5% 70.9%

2005 98.9% 96.0% 88.6% 70.7% 67.9% 72.6%

2006 98.9% 97.1% 92.6% 72.0% 68.5% 80.3%

Average 99.1% 95.3% 89.9% 72.6% 67.8% 74.3%

it had not, 7.2 percent said that it had done so, and 27.8 percent had no opinion or did not know. Finally, 66 percent of the respondents believed that the CPIB would keep the corruption reports it received confidential, and only 10 percent said that it would not do so.
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Table 11 Public Perceptions of CPIBs Performance in 2002

Survey item 1. How would you rate corruption control in Singapore? 2. CPIB has done well in solving corruption offences 3. CPIB can be trusted to keep Singapore corruption-free 4. CPIB is world-class in fighting corruption Survey findings Excellent = 13%; very good = 42%; good = 39%; fair = 7%; poor = 0 Strongly agree = 20%; agree = 51%; not sure = 28%; disagree = 2%; strongly disagree = 0 Strongly agree = 24%; agree = 37%; not sure = 32%; disagree = 6%; strongly disagree = 1% Strongly agree = 17%; agree = 39%; not sure = 36%; disagree = 7%; strongly disagree = 1% Yes = 69.9%; no = 5.6%; dont know/no opinion = 24.5% No = 65%; yes = 7.2%; dont know/no opinion = 27.8% Yes = 66%; no = 10% dont know/no opinion = 24%

5. Do you think CPIB is impartial/fair in its investigations? 6. D o y o u t h i n k C P I B h a s a b u s e d i t s investigation powers? 7. Do you think CPIB will keep corruption reports it receives confidential?
Source: CPIB (2003: 5.40 & 14.97)

Performance Indicators for ACAs Meagher (2005: 80-81) suggests three types of performance indicators for ACAs: output indicators based on their workload; outcome indicators to measure their effectiveness in attaining goals; and efficiency and productivity indicators such as cost-effectiveness, input-output ratio, and unit costs. However, only the performance indicators of the CPIB and ICAC are available and shown in Tables 12, 13 and 14 as illustrations. Table 12 identifies and defines the CPIBs performance indicators and data from 1997 to 2002. Table 13 shows that the number of cases investigated by the ICACs Operations Department increased from 1,522 in 1987 to 4,989 in 2002. The Operations Departments staff also grew from 744 to 966 during the same period. While the Operations Departments productivity ratio increased from 2.05 in 1987 to 5.16 in 2002, it declined from 4.71 in 1994 to 4.39 in 1999, and increased again to 5.09 in 2000. Finally, Table 14 shows that 2,751 persons were prosecuted for corruption and 1,068 civil servants were disciplined during 2001-2006. The ICACs average conviction rate during this period was 83 percent.

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Table 12 CPIBs Performance Indicators and Data, 1997-2002

Performance indicator 1. Cycle time 2. Completion rate 3. Prosecution rate 4. Conviction rate 5. Attendance to visitors 6. Number of persons charged and disciplined Definition Time taken to complete an investigation Percentage of cases completed in a year Percentage of case resulting in prosecution Percentage of cases convicted in court Target is to attend to 80% of its visitors within five minutes Number of persons charged and number of public officers disciplined Performance data Exceeded target by an average of 31% from 1999-2002 Exceeded target of completing 90% cases from 1999-2002 Increased from 47% to 60% from 2000-2002 Increased from 97% to 99% from 2000-2002 Exceeded target by 1% to 6% from 1997-2000 680 persons were charged and 293 public officers were disciplined from 2000-2002

Source: CPIB (2003: 3.24, 3.25, 5.36, 14.96).

Table 13 ICAC Operations Departments Productivity Ratio, 1987-2002

Year 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002
Source: ICAC (2003: 104).

Number of staff (a) 744 739 736 791 794 758 773 814 827 885 929 925 943 932 943 966 190

Number of cases investigated (b) 1,522 1,699 1,895 2,065 2,430 2,502 3,086 3,836 3,710 3,257 3,307 3,774 4,139 4,748 4,954 4,989

Productivity ratio (b/a) 2.05 2.30 2.57 2.61 3.06 3.30 3.99 4.71 4.49 3.68 3.56 4.08 4.39 5.09 5.25 5.16

Benchmarking for Excellence: A Comparative Analysis of Seven Asian Anti-Corruption Agencies

Table 14 Number of Persons Prosecuted for Corruption, ICACs Conviction Rate, and Number of Civil Servants Disciplined, 2001-2006
Year Number of persons prosecuted 535 604 421 494 356 341 2,751 Conviction rate Civil servants disciplined 188 165 234 161 170 150 1,068

2001 2002 2003 2004 2005 2006 Total

79% 83% 85% 84% 81% 88% 83%

Sources: Compiled from ICAC (2004-2007).

Benchmarking for Excellence: An Agenda for Action The previous section has suggested that the performance of Asian ACAs should be benchmarked according to 22 indicators, which are listed in Table 15. These 22 indicators are not exhaustive as not all of the performance indicators employed by other Asian ACAs are included. Benchmarking provides the Asian ACAs with an objective method for evaluating their performance by comparing their performance with the performance of more effective ACAs; identifying their strengths and weaknesses; and learning from the experiences of more effective ACAs by eliminating their weaknesses and reinforcing their strengths. It gives these ACAs and their governments the necessary data for making improvements if they are dissatisfied with the effectiveness of their anti-corruption strategies. Another advantage of benchmarking the ACAs performance is that governments which are considering the creation of an ACA will find the benchmarking data on the existing Asian ACAs useful in identifying their strengths to emulate and their weaknesses to avoid. In their overview report on Pacific Island countries, Larmour and Barcham (2004: 33-34) found that the 12 countries considered did not have any ACA. In discussing the utility of introducing an ACA in these countries, they recommended caution as the existing auditor-general offices and other watchdog agencies are under-staffed and ineffective. Furthermore, as senior appointments in these countries are often made to reward political support, the position of anti-corruption commissioner may end up being just such a resource (Larmour & Barcham 2004: 22). In view of their low state capacity, more resources must be allocated by their governments
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Table 15 Indicators for Benchmarking the Performance of Asian ACAs

National Indicators (3) 1. Transparency Internationals CPI score for a selected year. 2. World Banks control of corruption percentile rank for the same year. 3. PERCs corruption score for the same year. Agency Indicators (19) 4. ACAs per capita expenditure 5. ACAs staff-population ratio 6. ACAs independence a. Location b. Appointment of director c. Independence from police d. Investigation of grand corruption e. Frying big fish f. Weapon against opposition 7. ACAs credibility a. Consideration of all complaints b. Public perceptions of ACAs professionalism c. Enforcement of anti-corruption laws d. Public image of ACA 8. ACAs performance indicators a. Cycle time b. Completion rate c. Productivity ratio d. Prosecution rate e. Conviction rate f. Attendance to visitors g. Number of persons charged and disciplined

if they wish to establish ACAs; otherwise such ACAs would have to compete with other existing agencies for the limited resources available. Benchmarking the performance of Asian ACAs enables Pacific Island states and other countries to learn from the experiences of both the effective and the ineffective Asian ACAs to make the right decision in deciding whether or not to establish ACAs. If they decide to introduce ACAs, their governments must demonstrate their political will by providing these agencies with the necessary legislation, personnel and financial resources, as well as the autonomy for them to perform their functions impartially and without political interference. In view of these advantages of benchmarking, the recommendation here is that Asian ACAs should initiate the benchmarking of their performance by adopting a definite agenda for action, including collecting data on the 22 performance indicators; comparing their performance with the performance of other ACAs; and making improvements to rectify those
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weaknesses exposed by comparison with the more effective ACAs. Benchmarking enables the Asian ACAs to strive for excellence by providing them with a tool for measuring their performance against the best ACAs to improve their own performance by initiating reforms to rectify those weaknesses exposed by the comparison with best practices elsewhere. Benchmarking an ACAs performance also enables interested stakeholders to assess the governments political will to curb corruption in the country. The vast disparity in policy contexts and the varying degrees of political will in fighting corruption in Asian countries require their policymakers to heed Johnstons (1999: 225) sound advice that ACAs are unlikely to be right for every country. However, if a government has established an ACA to spearhead its anti-corruption strategy, it can enhance the ACAs prospects for success by providing it with adequate staff and budget, by not interfering in its daily operations, and, most importantly, by resisting the temptation to use the ACA as a political weapon against its opponents. In short, an ACA is a double-edged sword and can be used by a government for good or for evil. In the hands of a clean government, the ACA is an asset and a powerful weapon against corrupt politicians, bureaucrats and businessmen. Conversely, a corrupt government can make a mockery of its anti-corruption strategy by using the ACA to victimize its political foes. References
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Jon S T Quah is an anti-corruption consultant in Singapore: http://www.jonstquah.com . This article is a revised version of a paper presented at the Third Anti-Corruption Expertise Workshop on Excellence in Management of Anti-Corruption Agencies organized by the Corrupt Practices Investigation Bureau in Singapore, 14-16 October 2008.

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