TNRC Guide Anti-corruption Programming in Conservation and Natural Resource Management: Principles for Getting Started

The Targeting Natural Resource Corruption (TNRC) project collaborates with ten World Wildlife Fund (WWF) offices around the world to test approaches to anti-corruption and generate learning for the benefit of all. We are appreciative of their reliable partnership as we jointly problem solve through the sometimes-messy work of learning and adapting. The learning in this guide is a direct result of their innovative thinking in addressing the world’s biodiversity challenges. See their work on the TNRC Knowledge Hub.

This short quick reference is intended to assist conservation practitioners who are considering undertaking an anticorruption project or adding an anti-corruption component to their work.

One of the key messages that the TNRC project has been keen to stress is that anticorruption projects tend to be most successful when they respond to specific corruption problems from a systemic perspective, in a manner that is appropriate to a given context. Simply trying to deliver a one-off solution (e.g., introducing technology, passing new legislation) that worked in one setting to address what may appear to be the same problem (e.g., corruption in the timber supply chain) rarely works in other contexts.

Based on learning from supporting six pilot projects with WWF practitioners in widely varying contexts using widely varying approaches, we suggest these eight principles for teams to consider when starting or adapting projects. They can be used by teams by themselves as well as by teams with the resources to bring in external expertise.

As a starting point for practitioners not familiar with corruption issues and anti-corruption programming in natural resource management, take this free, self-paced e-course that will provide a good introduction to these issues.

Although there is one definition of corruption that is broadly accepted in the world of practice – “the abuse of entrusted power for private gain” – corruption can often be understood differently by people with different professional backgrounds or lived experience, even within one country (see this TNRC resource for more on this). This is especially true if corruption is not defined in the local criminal code. So, you should unpack and clarify the specific definition your project will use. Doing so can often help avoid a lot of confusion about what problem the project is trying to address and what it is trying to achieve, and it can help develop concrete and realizable interventions.

While there are types of activities, particularly in public administrations – like bribery, nepotism, theft of public resources – that most people would instantly recognize as corruption, the term can also blur into issues of good/bad governance, inequality, justice, or violations of civil and political rights. Who has the power to define what is or is not corrupt, and what sanctions flow from that definition, can be an important reason why people will disagree about the types of corrupt actions that should be addressed. One way to help narrow your focus if you’re dealing with a lot of competing ideas about corruption is to ask, as a team, “which of these behaviors is creating critical negative impacts on our goals?” (this question is similar to the recommendations in Principle 3 below) and also, “which of these might be better addressed if we call them something else (like exclusion, injustice, criminality, etc.)?” Remember also that corruption doesn’t happen just in the public sector; private actors can also undertake corrupt acts individually or collectively and create or drive corrupt schemes.

If a team decides to use a consultant as part of their assessment, it is vitally important that a clear understanding is developed within the team and with the consultant about how the project is interpreting the idea of “corruption.” If the team is uncertain about how to frame the corruption problem, it can work with a consultant to help them define the corruption problem through an analysis process. Where a team does not have the funds to hire external help, expanding your professional networks to governance NGOs, anti-corruption professionals at development banks, or academics, can be a useful way to understand how others familiar with the context are thinking about corruption.

Ready to get started? Review documents from a range of stakeholders in your context to understand how those already working on the issue think about corruption. Talk with your colleagues to hear their views and the views of those you work with. Don’t automatically assume you have the same ideas as everyone around you, especially those with different access to power.

What is the broader state of knowledge on your corruption issue? A thorough literature review (of project reports and studies, academic research, and grey literature) should be carried out to create a solid starting point. The perfect foundational review for your project likely won’t exist, and the resources the review turns up may not align completely with the focus of your project. But a thorough review helps identify key parts of the picture that may not already be apparent to the people on your team.

In terms of sources, the regional development banks, and especially the World Bank, usually have analyses on aspects of poor governance or corruption in a given country. These are sometimes stand-alone reports, but they may also be contained within country strategy documents (including IMF Article IV reports) or project appraisal or evaluation documents. Additionally, academic journals and other specialized institutions, such as the U4 Anti-Corruption Resource Centre and the Basel Institute on Governance produce relevant reports and analyses, often from researchers with many years engaged on corruption and governance failures in specific countries, regions or localities. And TNRC’s own Knowledge Hub is a source for information on various aspects of corruption and conservation.

Bringing in external expertise, from anti-corruption NGOs or individual consultants, may be required to assist a team in understanding and thinking through corruption problems. However, paying for an expensive international consultant’s report to simply sit on a shelf adds little value to a program. Instead, any external expertise should include facilitating, supporting, or coaching the organization’s existing staff to understand core concepts in anti-corruption and draw out and structure the team’s existing implicit knowledge. That would increase the team’s capacity to use the assessment the consultant produces.

Teams that think they lack the expertise to deeply understand corruption and also lack the resources to hire an expert still have options. Political economy frameworks or systems mapping activities (see Annex 1 and 4) are approaches for thinking through your own knowledge about the institutions and systems you have worked in. They can help determine where smaller, cheaper gaps of understanding exist that could be more affordably filled via a consultant or other enquiries like discussions with local partners, journalistic coverage, desk reviews, and personal meetings.

Corruption assessments at the sector level can be particularly useful. They can inform a range of project interventions across the organization’s portfolio. Some of those interventions may focus explicitly on anticorruption activities, but others can be “regular” conservation efforts informed by the identified corruption risks. An assessment’s goal could be to provide evidence about key corruption issues, help understand any assumptions, and/or identify pathways for reform, and assessments can be undertaken at any level (country, sector, project, etc.). Integrated into a project’s monitoring, evaluation, and learning, all of these assessments could form part of a corruption assessment. See Principle 6 for important considerations regarding assessments and government stakeholders.

Still, an anticorruption assessment will never give the full picture; it will only be a starting point. By its nature, corruption is intended to be hidden, although in some contexts it can be an “open secret.” There are some guides that attempt to be a complete and comprehensive approach for teams, for example these guides from USAID: here, here, and here. But they are usually fairly long, and many teams find they may not be directly relevant to the issues they are working on. Additionally, many of them have been developed from the perspective of the “external” (foreign) donor who needs to learn about the country/context from scratch with limited prior knowledge. Still, many of the principles may be useful, as even those working in a country for a long time will have a particular perspective and biases. If teams have time, these handbooks may therefore be worth reviewing as part of a desk review/orientation to determine the best assessment approach.

Ready to get started? The table in Annex 1 provides an overview of different common approaches to assessments. It is a good place to start thinking about what type of an assessment you want. TNRC’s webinar on corruption risk assessments also has great information on the different types, important considerations and three examples. It also provides insights on using assessments. You can find the recording here. You can find an example terms of reference for procuring an assessment here. Annex 4 will also walk you through a basic PEA in about an hour.

Corruption is a “wicked,” “complex” problem. The complex systems that underpin wicked problems mean that the effort to solve one aspect may reveal or create other problems. (Annex 2 provides additional information on how to consider the various aspects of “wicked” versus “tame” problems.) To work on a wicked problem, teams will need to identify the root cause: break down as many of the problem’s component parts as possible to determine what a feasible entry point and set of interventions might be. Unfortunately, there is no easy menu of “what works” in anticorruption approaches, and copying a model from one context and pasting it to another without adaptation does not work. Similarly, international data sets or anecdotal discussions may not be enough to point to an obvious entry point.

Instead, teams should take a problem-driven approach. Think through what the specific biodiversity problem is, how corruption does or does not relate to that problem, and the politics (see Principle 4) that underpin both. There are many approaches to problem-driven work but the guidance from Harvard’s (free) Problem Driven Iterative Adaptation (PDIA) framework is a good starting point.

Investing time to challenge assumptions around the “problem” is critical for any project and particularly so in anticorruption. Standardized theories of change from other agencies or organizations may give you a starting point to consider, but they should not be utilized wholesale and without appropriate adaptation/localization. (See this resource from TNRC for important considerations in developing theories of change).

Ready to get started? Annex 3 provides an example of the PDIA approach. View this handout showing the range of possible anti-corruption approaches across the categories of prevention, detection, and enforcement.

Technical reforms usually seek to “upgrade” some aspects of an institution (or government, or policy) to make it look more “modern” or to align with “best practices.” These reforms are often driven in part by a preference for simple, straightforward, noncontroversial approaches. Such approaches might include introducing technology, changing a law, introducing new regulations, revising human resources procedures, or building a road. Anticorruption reforms often involve these approaches, but such reforms alone often fail. Corruption may itself block or undermine the reform, or corruption may just disappear and reemerge in other processes because the root cause was not addressed.

This is where undertaking a political economy analysis (PEA) as part of your assessments is critical. PEAs are intended to get below the surface of an issue and delve into understanding why things are the way they are and what might be effective pathways to support change. An effective PEA shows us not only the constraints to action (“everyone is corrupt, and the government does not care”) but also the potential paths forward (“the Parliamentary Committee on Finance is run by a powerful person willing to challenge the government. If we can get data to them on the diversion of funds from park management, they may be able to support change by holding the government to account publicly”). PEAs can also further highlight the risks of pursuing purely technical reforms without understanding the political nuances. Even if all the best practices in the world are followed, institutions can still be undermined by political incentives.

Conservation has been using PEAs for more than ten years, as this analysis of hydropower in the Eastern Himalayas from 2012 shows. Recently, experts have developed a variation of the approach specifically for conservation, known as political ecology analysis, which places nature more central to the framework. TNRC has developed multiple resources on this topic, which you can find here, here and here. Be aware, however, that some of these terms are used in different ways by different sectors or professionals. This makes it additionally important for teams to be clear about what they want when assigning tasks to external partners or consultants. Ask many questions to be sure that what you will receive is what you need.

Of course, there are occasions where a technical reform can be appropriate, usually where the problem is “tame” (see Principle 3). But even work on tame problems can have political implications. For example, a technology upgrade to better survey animal populations or monitor timber trucks seems straightforward. But officials may prefer the old technology precisely because its weaknesses give them opportunities to benefit. The team should also verify that the technical reform will not create new opportunities for corruption, such as the misuse of more accurate data for better poaching.

Many people dislike politics, and many conservationists or natural resource managers may feel it is outside of their field. Fundamentally, however, “politics” is about shaping how finite resources will be used (or preserved). This makes politics inevitable for anyone working in development or conservation. At the same time, TNRC’s work with project teams has shown that practitioners have ample understanding of the politics of their work. They just might not have thought about it in a structured way, or believed that they could or should address the politics. This is a strong foundation on which any team can build.

Ready to get started? Annex 4 provides an overview of initial PEA type questions that teams can run through in an hour.

A “risk-based approach” to a project asks stakeholders to outline the results the project hopes to achieve and discuss, strategically, what may or may not be possible in the context. For example, a donor may want to immediately fund a project to address the corruption that facilitates timber trafficking in a remote province. A conservation NGO may agree corruption is a problem and believe an institutional reform approach could have impact but will be difficult to implement. Potential partners in the province agree institutional reform is needed, but their knowledge of provincial politics and connections to crime syndicates indicates that any intervention will pose substantial physical risk to staff and threaten relationships they have developed in order to conduct their work. In other words, these three stakeholders have differing perspectives on what is possible and what risks are worth taking based on their different positions, roles, experiences, and expertise.

Putting risk at the center of discussions from the start of the project (and throughout) can be a particularly helpful approach for anticorruption projects, because identifying and responding to corruption issues can be fraught with difficulties. Donors may have different risk tolerances; many have institutionalized rules around 'do no harm' (a good thing!), and many also have political reasons why they must take extra care to avoid supporting activities with certain potentially negative outcomes. But risk is as much about identifying appropriate opportunities as identifying what cannot or should not be done. Proper understanding of the technical and political issues around the project is, ultimately, the best way to manage risks, identify reform opportunities, and anticipate where and when it might be necessary to make an adaptive decision. Try to establish a clear, shared understanding with the funder from the beginning about what results might be achievable within a given context and how projects need to strategize regarding foreseeable risks. This will improve collaboration and increase the chances of a successful project.

Ready to get started? Annex 1 includes information about risk assessments, but as the examples above show, local stakeholders have valuable knowledge of their context, so intensive, costly assessments are not always necessary to get an outline of the risks and opportunities. The only requirement is open and honest conversations and respect for the concerns that emerge, even if they conflict with different interests.

Whether or not a team is able to engage with government authorities in relation to an anticorruption program will have a significant effect on the design and approach of a project. If a team is able to engage with an agency, it may open possibilities: obtaining government data to inform analysis, leveraging internal political relationships to support reforms, ensuring good relations between the team and government, and increasing the chances of project success. This is especially important for projects that teams hope to scale up in the future. For teams that have no funds to implement anti-corruption initiatives now, building relationships with government actors and finding palatable ways to discuss the impact of corruption (or “good governance” objectives) is valuable work to strengthen the foundation for later success when funding becomes available. For more information on how this “soft work” of relationship management matters for anti-corruption work, please see this resource on thinking and working politically, as well as this practical follow-up resource on the same topic.

There may be situations where a collaborative relationship with the government (or certain agencies within the government) is not yet possible. In these cases, projects will need to keep possibilities open. There may be ways to discuss corruption issues without threatening relationships or larger work. Certain departments may be willing to support or accept an assessment or a project under certain conditions, such as that the results will not be made public. Sometimes, extra time must be designated to develop different messages for different stakeholders to increase the chance they will be receptive to assessment or project findings. In all cases, an effective strategy can be to focus on developing “guidelines” or “recommendations,” identifying common goals, and avoiding placing blame on any individual or agency.

Since directly measuring corruption is often impossible, monitoring anti-corruption results can be equally problematic. Well-known international surveys may be tempting to use as indicators, like Transparency International’s Corruption Perception Index. But these have significant time lags from action to change, and the power of any one project to create changes that would register at the scale of the CPI is doubtful.

Given this, teams should use their problem analysis to identify corruption opportunities or vulnerabilities that are driving a specific biodiversity threat. Changes in those opportunities or vulnerabilities can then become the anti-corruption result that can be monitored in combination with changes to the biodiversity threat. If other possible causes for the changes are effectively ruled out, a team can be reasonably certain they have achieved useful results in anti-corruption and biodiversity.

For example, if the biodiversity threat is illegal logging, corruption is likely involved in some way. There may be bribery to rangers and inspection officials, land grabbing, or fraudulent harvesting permits. Surveys of those affected by corruption may provide useful data to compare before and after the intervention. However, perception-based indicators require triangulation with more objective indicators, and the project may not be able to measure corruption problems directly in the objective way needed. As mentioned below, it may even not be safe to do so.

In those cases, the vulnerabilities that enable those incidents include things than can be monitored. Bribing inspection officials is enabled by social norms of integrity. Land grabbing is enabled by exclusionary planning processes. Permitting fraud is enabled by a lack of transparency. Indicators of these factors are more feasible to monitor.

These proxy indicators could be something small, such as a) the percentage increase in on-time payments to park rangers, b) the number of timber harvesting plans verified by the inspection agency, or c) the proportion of a sample of permits that show signs of fraud. Changes in those areas – based on an evidence-based theory of change – may suggest that fewer public funds are being diverted, fewer inspections are being corruptly avoided, and more harvesters are following regulations. You may not be able to conclusively demonstrate that your project reduced corruption risks. But with the right indicators and theory of change, and an adaptive mindset and project design, you will be able to estimate whether your project made a reasonable contribution to the desired outcomes.

Your assessment to inform project design should include a few questions to explore whether the corruption problem can be monitored and, if not, the team should revisit the problem statement further. At the same time, while smaller measurable indicators may be ones that can be tracked and linked to reform interventions, you should still keep an eye on the higher-level outcome, what is often known as the “most significant change.” A higher-level outcome is critical in order to ensure that reforms are actually having an impact, rather than there being not simply the illusion of reform.

Ready to get started? TNRC is developing a resource that summarizes important aspects of monitoring, evaluation, and learning for anti-corruption in conservation.

Even if you have absolute certainty of corruption occurring, through your personal observations, the collective experience of many stakeholders, or respected international or national studies, roadblocks may still stand in your way. You may not have a lot of available funding for anti-corruption projects. It may not be safe, or your existing work may rely on close working relationships with powerholders that might be undermined. Principle 7 may not be feasible, where it is just not possible to adequately monitor change in any relevant indicator.

Even in these cases, you may be able to find productive ways to move forward on corruption issues. Using risk-based approaches (Principle 5) and conducting PEAs (Principle 4) can help identify new partnerships and promising avenues that you may be able to open over time. Implementing a strong safeguards review that includes assessing the impact of corruption can identify important social risks, which can inform wider project and partnering decisions. The value of systematically generating evidence of corruption issues in your work cannot be overstated.

Even if you cannot directly work on corruption issues now, deepening your understanding now can set you up for greater success later. Likewise, beginning to have conversations about the ways that corruption is undermining shared objectives (perhaps using terms like “good governance” if necessary) with partners or government contacts, or even improving your understanding of corruption risks and how they might undermine your conservation project, are all good uses of your time. Even for projects that face no major obstacle to working on corruption, durable change will come in the long term, not the short. Any action you can take today will support those long-term efforts.

Annex 3: Iterating a “problem-based” approach to corruption analysis and programming – an example adapted from a PDIA based approach

Annex 4: WWF PEACI approach to political economy