I have been conducting policy research on NGO governance and problematic financial management in the Cambodian NGO sector since late 2014. It’s an ongoing involvement. The material costs have been covered by the grantmaker that commissioned it, but given my board membership of this grantmaker, the actual work has been pro bono. Work on serious organizational weaknesses and fraud by definition needs explicit attention to unintended harm it may cause. Cambodia’s politico-economic elite (read the global witness reports on the entanglement of political and economic power) quite openly targets any NGO activity that it perceives as a political challenge. Any ‘negative’ information about the NGO sector, however true, is potential fodder for government misuse. Reporting on this work doesn’t seek venues for public debate. Sharing is limited to directly involved stakeholders and the objective is to support them in dealing with the issues with as little risk of blowback as possible.
Nevertheless, research really really needs feedback on its conceptual framework, methodological assumptions, validity of its conclusions, and best next steps. Apart from conversations with stakeholders in Cambodia, I try to seek input from those more broadly interested in aid, financial management and accountability. Matthew Stephenson, Professor of Law at Harvard Law School, and Editor in Chief of the Global Anticorruption Blog, has not only been kind enough to allow me some guest posts on his anticorruption hub, but also incredibly generous with his editing time. What you read below is not my original submission but something much more readable, concise and to the point. I really don’t know how he does it, sleep can’t be part of his agenda. But I’m very grateful.
Corruption Among Development NGOs, Part 1–Getting the Facts
Compared with media attention to corruption among public officials and corporate interests, corruption in the non-profit sector is virtually ignored (though a recent GAB post on NGO corruption in India is a notable exception). This lack of interest is matched by the absence of sustained substantive debates about the sources of NGO sector corruption and the effectiveness of remedial interventions. My own experience with these issues derives from my involvement with the NGO sector in Cambodia. Corruption within our own house is a regular topic of informal conversation, and also makes it into our periodic sectoral assessments (though often through oblique references to concerns like “weak financial systems” and the “lack of checks and balances”). However, there are no efforts at all to go beyond these anecdotes and self-reported “weaknesses” to gather systematic, externally validated evidence about levels of corruption, let alone about issues like costs of corruption or the way it correlates with characteristics of the NGO sector that would offer entry points for positive change.
Given the comparative importance of development aid channeled through the NGO sector in countries like Cambodia, this lack of attention to NGO corruption is unfortunate. Admittedly, gathering information on local NGO (LNGO) corruption is challenging. Yet there are potentially useful sources of information that have not been exploited. For example, LNGOs are funded by grantmakers, and these grantmakers (often criticized by LNGOs for their cumbersome administrative requirements and time-consuming monitoring visits) are a possible source of data about LNGO fraud and its correlates. Additionally, the audit firms with an LNGO client base are another possible source of information.
In 2014, to test the willingness of grantmakers and audit firms to share information on their LNGO partners and NGO client base, we at SADP piloted a grantmaker and audit firm survey. The results were promising enough to repeat and expand the exercise in 2015. In this second grantmaker survey, 18 out of 26 grantmakers approached agreed to participate, and 13 of those 18 shared LNGO partner-level information (for a sample of 93 LNGOs). The grantmaker survey queried incidence and seriousness of (1) financial management problems, (2) governance problems, and (3) fraud. (In order to maximize participation, the survey prioritized brevity and simplicity over depth of information.) The audit firm survey (in which four of the five firms approached agreed to participate) asked only for some aggregate data (total number of LNGO audited, number of audits that identified fraud, number of audits that flagged serious financial system issues, etc.). Admittedly, neither the sample of grantmakers nor the sample of LNGOs is statistically representative of Cambodia’s NGO sector, but the surveys provide more valid information about corruption in development NGOs in Cambodia than has previously been available. And the quantitative picture emerging from the combination of these two data-sources about the organizational quality of Cambodian LNGOs is both revealing and disheartening. Interested readers should check out the full report; the most important findings are as follows:
- First, the survey provides strong evidence that fraud and misgovernance are serious problems. At least 25% of LNGOs in the sample had serious financial management problems, and at least 25% had serious governance problems. Approximately 15-20% on LNGOs had incidents of fraud.
- Second, the survey provides evidence that financial management and poor governance are indeed conducive to serious fraud. Of the LNGOs that had governance problems, 50% had incidents of fraud. Of the LNGOs that had serious financial management deficiencies, 80% had incidents of fraud. And for those LNGOs that suffered both from poor financial management andbad governance, the probability of fraud was a shocking 90%.
- Third, there are deficiencies in oversight both by grantmakers and by external auditors. In the case of grantmakers, approximately one-third of the fraud incidents at LNGOs went undetected by at least one of the grantmakers providing funding, and collectively grantmakers underreported serious problems at LNGO funding recipients by 35%. As for the external auditors, in 80% of the fraud cases, previous external audits failed to raise adequate red flags. And for 60% of the LNGOs with serious financial management problems, that issue was not raised in any previous external audits.
The overarching conclusion drawn in the survey report is that grantmakers need to apply a much improved and ongoing form of due diligence to their LNGO partners. Of course, in development circles the concept of “upward” accountability opens up a can of worms too big to discuss here; I will leave those larger issues to future discussion.
Given that the 2015 grantmaker survey has shown it is possible both to increase participation and to overcome the “confidentiality” hurdle, this year’s third round is going to attempt to gather additional information about both grantmakers and their LNGO partners. To the extent that we’ll manage to remain on the safe side of what time grantmakers are willing to devote to answer the survey, the resulting dataset is going to allow for a way “thicker” description, thus more nuanced understanding, and hopefully more entry-points for action. We are also exploring possibilities to replicate the survey and its approach in another ‘comparable’ country context. I hope that GAB readers will help us improve our research in this area both by offering criticism of the study summarized above, and by pointing me toward other relevant research, literature, and initiatives.
This much for the post itself. In answer to a comment from Narayan Manandhar suggesting the U4 anticorruption resource centre as an interesting place for finding NGO corruption literature my reply referred to some quick and dirty evidence gathering to substantiate the claim in this post that NGO corruption seems a neglected subject:
I once had a quick and dirty go at the corruption bibliography published by the host of this blog: the ratio of publications about corruption in the NGO/humanitarian aid/civil society sector to that in the private/corporate/business sector looked close to 1:40. The ratios for google hits on search terms like ‘NGO corruption’ versus ‘corporate corruption’ or ‘corrupt NGO’ versus ‘corrupt business’ are even more extreme (1:80). None of this is hard evidence but at least suggestive of the differential attention NGO sector corruption gets. I agree that it may be a lesser problem, but not that much lesser, especially for aid dependent countries like Cambodia and Nepal.
As a bonus for reading this far – or at least taking the effort to scroll down, one of the better music videos of all time: