M. Johnston - Philippines Working Paper

8/6/2019 M. Johnston - Philippines Working Paper

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Printed: October 2010

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Po l it i ca l and Soc ia l Founda t ions fo r Reform:Ant i -Corrupt ion S t ra tegie s for the P hi l ippin es

Micha el J ohn ston

Ch ar les A. Dan a P r ofessor of P olitical ScienceColgate University

Ha milton, New York 13346

USA

Asian In stitu te of Man agementWork ing Pa per

Manila

September 1, 2010


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Table of Conten ts

Ackn ow le dge m e n ts ..................................................................... 6Su m m ary ....................................................................................... 7

I. In tro du c ti on ........................................................................ 12

Wh y is th ere not m ore corru pt ion? ........................................ 14

II. Co rr u pt io n in t h e P h i li p pi n e s : Oli g ar ch s a n d Cl an s 1 8

From d em ok rasya to dem ocracy ........................................... 23

No way out of it but t h rough i t ............................................. 25III. An Age n da for th e Ne w P res ide nt ................................. 28

What not to do ........................................................................ 28

Early in it ia tives ..................................................................... 30

Ini tia tiv es for the longer t erm ............................................... 38

T he bigger pictu re .................................................................. 42

IV. Co ll ec t ive Ac t i on and t he Soc i a l Founda t i ons o f

Re fo rm .................................................................................. 43

Ma k ing reform real: ind icators an d benchm ark s ................ 45

Lead ersh ip ............................................................................. 48

V. Lo o k in g F orw a rd : A Co rr u pt io n -R e s is t an t S oc i e ty .. 5 0

Wh y w ould th ese ideas succeed wh ere oth ers hav e not? ...... 50

Wh y w ould corrupt Oligarchs tolerate these activities? ...... 51

No m agic bu llets .................................................................... 52

Appe n dix ..................................................................................... 53

Indica tors and ben ch marks: a p oss ib le t ime l ine .............. 53

Re fe re n c e s .................................................................................. 57


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Acknowledgemen t s

This pr oject was origina lly conceived by Roder ick M. H ills, founderof the Hil ls Program on Governance (HPG) at the Center forStrategic and International Studies in Washington, DC. It wasma de into rea lity by the support of HP G with th e active coopera tionof the Asian Institute of Management (AIM), Manila, and thePh ilippines Office of The Asia Foun da t ion (TAF), also in Man ila.Angela G. Ga rcia J D, Execut ive Director of both AIMs RVR-CVSt ar r Cent er for Corpora te Governa nce an d HP Gs Man ila Cent er,and Dr. S teven Rood , TAF Count ry Represen ta t ive fo r thePhilippines and Pacific Island Nations, and Regional Advisor forLocal Governa nce, went to grea t lengths to ar ra nge my t wo visitsto Manila, and to set up and carry out a demanding but highlysuccessful series of interviews and public events. Ky Johnson,Mar ibel Buena obra , an d J err yl Reyes of TAF also devoted mu chtime an d en ergy to those visits, a s did Crist ina Gregorio and Olivia

Ledesma of AIM. Special th an ks go to J err y Hyma n of HP G for hisexcellent advice on severa l levels. F ina lly, a lar ge nu mber of peopletook t ime to meet with m e, at ten d our public event s, and pa ss onadditional thoughts both during and after my visits. To all, forth eir tim e, ener gy, pat ience, and good coun sel, hu ge tha nk s.

The views expressed in t his pa per a re m y own, an d not necessarily

those of HP G, AIM, TAF, or a ny ind ividua l associat ed with t hoseorganizations.


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Political and Social Foundations for Reform: Anti-Corruption Strategies for the Philippines

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both at (re)launching reform and at earning public credibility.Longer-term m easu res a re noted as well, an d can build upon ear lyactions and credibility. Some proposals can be acted upon byexecut ive order a nd a dmin istr at ive implemen ta tion; oth ers wouldrequ ire legislat ion or even const itu tiona l cha nges.

The sh ort -term recomm endat ions:

Relent lessly fra me corr upt ion cont rol in ter ms of fight ing povertyand impr oving t he qua lity of life for cit izens; build tr us t t hr oughthe effective provision of services in which large parts of thepopulat ion sha re an int erest.

Consolidat e an ti-corr upt ion responsibilities now scat ter ed am ongth e Ombuds ma n, P AGC, blue-ribbon bodies, an d oth ers:

The consolidat ed agency would n ot be th e cur ren t Office of

th e Ombudsma n un der a noth er n am e. That office should beabolish ed, an d its core a nt i-corr up t ion fun ct ions sh ould m oveto th e n ew agency (actions requir ing const itut iona l cha nge).

The new consolidated a gency should be th e clear inta ke/citizenfocus point for invest iga tory an d pr osecu tor ial pr ocesses.

The consolidat ed an ti-corr upt ion office should ha ve ar rest an dsubpoena powers, and should either possess the power toprosecute or be able to compel prosecution of cases uponappeal to th e President .

The consolidated agency should avoid donor-driven an ti-corr upt ion a nd service-delivery pr oject s. The most wort hwhile

of su ch project s sh ould be delega t ed elsewher e, on a select ivebasis, depending upon th eir goals.


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The consolidat ed agency mu st h ave sufficient s t aff an dresources to follow up complaints effectively, guaranteeingsecurit y an d confident iality for citizens.

Recruit a n Eminent Persons Group (EPG) from ma ny segmentsof society t o a dvise on and oversee evalu a t ion of reforms , reportto th e pu blic, an d a ppoint/remove t he hea d of th e consolidat edan ti-corr upt ion a gency.

Speed up the Sandiganbayan, in par t by restru ctur ing its caseload bu t a lso th rough full sta ffing an d resources. End t he pr acticeof trying cases in separate stages at widely-separated times.In sofa r a s possible, once a case h a s been pla ced on t he docket itshould move toward resolution in a continuous, expeditiousmanner.

Est ablish a Citizen Advocat e with in each Cabinet-level Pu blic

Service Depart ment .

Choose one or t wo sectors with direct impact on the quality of lifesuch as the Department of Education and BIR or otherta xat ion bodiesan d:

Regular ly gath er and publish dat a on perform an ce, such a s

t h e t i m e a n d n u m b e r o f s t e p s r e q u i r e d f o r r e g u l a radministrative functions.

Regular ly gath er and publish dat a on th e quality an d costsof services.

Compar e the dat a a bove to appropriate benchma rks, again

publishing results, and make clear that the resulting datareceive t op-level r eview.


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Condu ct a nd publish regular t op-down perform an ce-an d-int egrit y reviews of t hose sectors ; involve citizens and NGOsin t hose reviews.

Pu blicly cite a nd rewa rd officials r esponsible for improvedperformance; require unsuccessful officials to account forresults .

Al locat e resour ces to rewa rd a gencies an d jur isdict ionsshowing impr ovement .

Over time, expan d such a ssessments t o include oth er sectors

Condu ct a nd pu blish r epeat ed lifestyle-an d-a sset disclosur es fortop-level officia ls.

E n d lu m p -s u m b u d ge t i n g ; s h a r p l y r e d u ce or e l im i n a t e

presidential discretionary funds.

Support reform -minded burea ucra ts with bonu ses, recognition,whist leblower protections , an d pr omotions . When corr up t officialsar e dismissed, roll th eir sa lar ies over int o higher pay for t hosewho rema in.

The Longer TermAnother fam ily of an ti-corr upt ion mea sur es is aimed a t th e longerterm. That does not mean that those actions should wait untilsome distant date, but rather that their effects are likely to beseen over a great er nu mber of years:

Laun ch, sust ain, an d refine an a nt i-corr upt ion cur riculum in th e

schools.


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E l e ct S e n a t o r s b y d i s t r i ct s ( a n ot h e r a ct i on r e q u ir i n gconst itut iona l a mendm ent).

En ha nce t he p r ofe s s iona l ism , pol it i ca l i ndependence , an dcredibility of the judiciary, emphasizing protection of humanright s, an d property right s

Simplify th e ta x code, crea tin g broa d but progressive ban ds of taxation that feature few exemptions, low rates, and uniformtr eat men t of ta xpayers, in order t o redu ce th e discret ion of ta xcollectors/assessors

R e focu s p ol i t i ca l fi n a n c e p o li cy t o e n cou r a g e b ot t o m - u ppar ticipat ion a nd well-str uctu red compet ition a mong part ies withbroad an d legitima te social bases.

Ultimately, the strongest anti-corruption force in society will be

the Filipino people themselves.


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I . Introduct ion

Corr upt ionent ren ched, persisten t, lucra tive, an d usu a lly facingrelatively weak constraintsis a major cause, and consequence,of th e P h ilippines per sist ent problems of economic developm entand democratic consolidation. No one would attribute all of thena t ion s pr oblems t o corr upt ion, a nd in n o way does corr up t ionnegate a ll th at is good about th e na tion a nd its people. Furt her,t he Ph ilippines is by no mea ns a lone in facing such p roblems forevery coun tr y ha s corr upt ionnor ar e its difficult ies th e worst inth e world.

Still, corruption has helped produce a chronically ill economy;specta cula r inequa lities of wealth an d pr ivilege; a weak -but -hea vyst at e; political pr ocesses th at a re cont ent ious but ra rely decisive,sa ve in t he sen se of giving one elit e fact ion a dvan ta ges over other s;represent at ive institu tions th at ar e par t of th e coun tr ys elite- and

fact ion-dr iven pol i t ica l pat tern , ra ther than aggregat ing andexpressing grassroots interests; a judiciary facing many threatst o its indepen dence, and in need of sh orin g up its own cred ibility;an d a citizenr y tha t m ust cont end with poverty while coping witha ll of t he a bove. Moreover, each of t hose pr oblems, a mong others ,creates opportunities and incentives for further abuses. If, as Iwill suggest in t he pages t o come, corr upt ion is such a n embedded

problemnot something that happens to a society, but ratheran outgrowth of history, culture, problems of development, andcon tempora ry difficult ies in t he way t he society govern s its elf andorganizes its economywhat, if anything, can be done? If, as isthe case through history, a number of formerly high-corruptionsocieties have brought the problem under control, what lessonscan be lear ned from such cas es, an d how can we apply th em in t he

Philippines?

This is working paper draws upon two visits to Manila in July,2009, and February, 2010, both of which featured a demanding


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and extremely inform at ive series of meet ings and public discussionson th e genera l issue of an ti-corr upt ion str at egy for th e P hilippines.I brought to th e ta ble a ser ies of ideas a nd findings based on ma nyyear s of compara t ive st ud y of cor ru pt ion a nd reform, but fa r m oreimport an t were t he cont ribut ions of ma ny individua ls who freelygave of th eir kn owledge and experiences. While th ey ar e not n am edin th is report , I am very much in th eir debt.

Ra ther t ha n dwelling upon specific impr ovemen t s to public sectora d m i n i s t r a t i o n a n d r e l a t e d p r o c e s s e s , t h i s d i s c u s s i o n w i l lemphas ize ways o f bu i ld ing new expec ta t ions and l inks o f accoun ta bility between citizens a nd t he st at e. While the qu estionof how best to reform public sector inst itu tions a nd a dminist ra tionis far from a set t led issue, we know a great deal about bestpr act ices an d oth er opera t iona l s t a nd ar ds for doing pu blicsbusiness. But the sustained, long-term poli t ical support suchmeasu res needboth from top-level figu res a nd from society as a

wholeis oft en la cking. Too oft en we a ssu me t ha t because it is inthe interest of most citizens and businesses to check corruption,t hey will actively back r eform; an d t oo oft en su ch expect a t ions fa llvict im to collect ive-act ion pr oblems 1 and other vaga ries of politica llife. Wor thwh ile inn ovat ions a nd pot ent ially valuable reform s, inmany soc i e t i e s w i th ex t ens ive co r rup t i on , w i the r and l o seeffect iveness because few people feel a rea l sta ke in ensu r ing th eir

effectiveness.

Thus this paper does not recommend or develop an inventory of pr ocess-orien t ed reform s. In st ead, it empha sizes ways of building

_____________________________1 Collective action problems ar ise when individuals th ink t hey sta nd to gain from th e

accomplishmen t of a group goal, or a public good, whet her or n ot t hey cont ribut etoward t he effort th emselves. In such a si tuat ion m an y will rely on other s to put inth e effort an d assum e th e risks. Natu ra lly, when everybody acts t his way nothinggets done. Collective action problems ar e comm on in an ti-corr upt ion work, pa rt icu-larly when r eform s ar e presented solely as benefi ts for a l l rath er t ha n a s conn ectedto peoples a nd fam ilies own in ter ests, becau se fight ing corr upt ion is often difficult,risky, and a long-term proposition.


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politica l foun da t ions for corr upt ion cont rol over t he middle t o longterm. I will offer a list of specific proposals to be laid beforePr esident Aquino and his a dvisors, both for sh ort -ter m a nd longer-ter m a ction, a nd will out line a basic implement at ion sequence forthe most distinctive aspect of the strategy recommended hereth at is, th e gath ering and publicat ion of indicat ors a nd benchma rksof government performance. Ins tead of proposing new ant i -corruption projects or massive national morality campaigns, thefocus is upon ways of bu ilding th e politica l founda t ions, social t rustan d expecta tions, a nd new r elationsh ips of accoun ta bility n eededto support any specific rem edies t ha t might be put in place (see,on t hese issues , Mon t inola , 1999; Bat a lla et. al. , 2001; Hu tchcroftand Rocamora, 2003). In those political and social senses it is atr an sform at iona l agenda: it a ims at cha nging basic relat ionsh ipsindeed, a nd forging a new kind of social cont ract 2between citizensan d t hose who govern.

Wh y is th ere not m ore corrup tion ?

We oft en worry, with good r ea son, a bout t he scope and t enacity of corr upt ion in ma ny societies. But in a way we might also ask whyth ere is not m uch more of it, an d how it was ever brought u ndercont rol anywher e. Corr up tion, aft er a ll, broadly benefits t he ha vesat the expense of the have-nots: even where widespread favors

an d petty pat rona ge is the ru le, as ha s been t he case in places asdiverse as Chicago, 17th century England (Roberts, 1966; Peck,1990), and the Philippines, such favors are a means of control.Corrupt figures frequently use money, special connections andaccess, and particular kinds of expertise in their schemes; thoseresources are scar ce, un equa lly distr ibut ed, an d fa cilita te corr uptactivities that are anything but altruistic. The major benefits of

corr upt ion a re genera lly tan gible, imm ediate, an d concentr at ed in

_____________________________2 My th an ks to Jerr y Hyman for suggesting that way of th inking about th e relat ion-

ships envisioned here.


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r elat ively few ha nds, crea t ing st rong incent ives for t hose involvedto protect the i r advantages and res is t controls . The cos ts of corr upt ion, by cont ra st , ar e genera lly widely-sha red, a nd ar e oftenlong-t erm and in t a ngible. While th ose cost s a re n o less serious fora ll t ha tcorr upt ion, in t he long run, helps keep poor people poorand dem ocra t ic pr ocesses in effect ive in a var iety of societiestheincent ives an d opportunit ies for a ny one per son t o fight corr upt ionon any one day are usually small. When we add to those factorsth e clan destin e na tu re of ma ny corr upt processesfrequen tly, allwho know of a corrupt act have an interest in keeping it secret,an d th ere is no imm ediat e victim (as t here is when, say, a car ha sbeen stolen)it seems all the more remarkable that corruptionha s ever been r educed an ywhere.

The a nt i-corr up tion accomplishm ent s of Hong Kong a nd Singaporeare the bes t -known success s tor ies , a l though both are smal lundemocratic city-states unrepresentative of any wider group of

cases. While progress h as often been ma de at th e program or a gencylevel , at least for a t ime, sustained and broad-based progressagainst corruption in full-scale, socially diverse societies aredifficult to identify, even after a generation of anti-corruptionpr ogra mm ing an d effort (Mun giu-P ippidi, 2006). Lar ge su ms h avebeen expended by governm ent s, aid a gencies, an d some businessesin a id of corr upt ion cont rol th rough a dmin istr at ive improvemen ts ,

stronger parliaments and civil societies, and rule of lawoften,with out mu ch last ing benefit.

But th ere a re some historical su ccess stories with rea l relevan cefor the future of the Philippines. Several societies have broughtonce-extensive corruption under control, often in the course of s t ruggl ing wi th o ther i ssues . Progress was not made merely

through fear of punishment or appeals to civic virtue, but rathergrew out of long-t erm politica l cont ent ion over t he sources, uses ,and limits of power. That contention was not driven by reformschem es, but r a th er by people an d groups with vested int erest s in


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In a ll t hr ee ca ses limits on power, import ant civic values , r eform edinstitutions, and mechanisms of accountability were outcomes of politica l cont ent ion over power, pr ivilege, and fa irn ess in societyconflicts ener gized by rea l an d last ing self a nd group int erest srather than good-governance schemes pushing for reform as apu blic good.

I will explore t he implica t ions of su ch ca ses in more det a il below,but for n ow a few point s ar e wort h em pha sizing. One is the meaningof st r a t egy. Most an t i-corr upt ion effort s a r e called st r a t egies,but are real ly tactics an administrative improvement programhere and a t r anspa rency i n i t i a t i ve t he r e , a l l wor thwh i l e i nthemselves but not addressing the underlying forces shaping theways a society is, an d is not, govern ed. Strategies, by cont ra st, ar elong-ter m effort s t o build sust ain ed resist an ce to corr upt ion at asocieta l an d syst emic level, using a coord ina t ed mix of direct a ndindirect mea ns. St ra tegies should not be th ought of only, or even

prima rily, in t erms of tar geted a nt i-corr upt ion measu res. Instea d,t hey should encour age th e sort of deep dem ocra t izat ion sket chedout above, in wh ich citizens t ake issu e with official abuses becauseit is in t heir own bes t in t eres t s t o do so. Those pr ocesses will notb e n e a t a n d s t r a i g h t f o r w a r d , a n d i n f a c t t h e y m a y f e a t u r econsidera ble con t ent ion . But t he politica l found a t ions for r eform,an d th e sett lement s limit ing official power, tha t can em erge in t he

middle to long term r eplica t e th e sor t s of limits on power devisedby other formerly-corrupt societies as they have thrashed outquestions of who should govern society, how and on what basis.Pu nish men t-an d-deter ren ce ta ctics can be effective when th ey ar epart of, and are backed up by, such political settlements; othermea sur es might be a imed at redu cing opport un ities for corr upt ion,ma king its effects m ore a ppa ren t, an d ma king it less profita ble

in effect , not a t bu ilding a corr upt ion-proof syst em bu t one t ha t ista mper-evident an d rewar ds better govern an ce.


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Those sorts of strategies, broadly defined, are the point of thispa per . A nu mber of ideas will be offered t ha t I believe can a id th epo l i t i c a l p roces se s and changes t ha t a r e needed . Bu t l aws ,e n f o r c e m e n t , a d m i n i s t r a t i v e i m p r o v e m e n t s , t r a n s p a r e n c ymea sur es a nd civil society initia tives will have th e great est cha nceof success when they engage the in teres ts and fe l t needs of Philippine citizens (for a comparative study of how those issuesa ffect civil society-bu ilding e ffor t s, see Mavrikos-Ada mou, 2010),and t he form idable en ergies of society its elf.

II. Co rru p t io n i n t h e P h i li p pi n e s : Ol ig a rc h s a n dClans

What makes corruption in the Phil ippines so resistant to thenu mer ous r eform effort s th at ha ve been un derwa y for year s? ThePhil ippine case fal ls squarely within what I have termed theOligar chs and Clan s syndr ome of corr up t ion (for a st a tist ica l an dcase-study development of that argument, see Johnston, 2005a,par t i cu la r ly Ch . 6 which inc ludes a shor t case s tudy of thePh ilippines). Tha t syndr ome, one of four 3 identified in my earlierwork, should be understood as an ideal type (on that classicWeberia n notion, s ee Coser, 1977) t ha t is, a simp lifying cons tr uctmeant to emphasize and interpret elements common to a largernumber of cases that are by no means identical but do share

important characteristics. Essentially, it refers to a situation inwhich significan t a nd growing politica l and economic opport un itiesabound in a sett ing of weak inst itu tions. Corr upt ion, un der t hosecircum stan ces, tends to be dominat ed by the dea lings of a relat ivelysmall number of powerful figures and their personal followings.Ol igarchs and Clans fos ter par t icular ly worr isome forms of corruption and their deep roots in Philippine geography, history

_____________________________3 The oth er th ree are Influence Markets (e.g. th e United Stat es, Germa n, and J apa n),

Elite Ca rt els (South Korea , Ita ly, Botswa na ), an d Official Moguls (China , Indonesia,Kenya). See Johnston, 2005a.


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an d society crea te st rong const ituencies with a sta ke in t he st at usquo. That overal l characterizat ion was echoed (and, at t imes,an ticipat ed) by ma ny of th e people I met a nd in ter viewed in Ma nila.

Oligarch-and-Clan corruption, as seen in a variety of societiesra nging from Ru ssia a nd Mexico to Nigeria an d Venezuela, a s wella s t he P hilippines, is cont ent ious, disorder ly (oft en in a zero-su m 4

pa tt ern ), and can be linked t o a clima te of pervasive insecurit y aswell as to violence (this discussion is based on Johnston, 2005a:Ch 6). The oligar chs ma y ha ve long-sta ndin g power a nd prest ige,or be arrivistes . Their clans vary in size and composition, buttypically opera te in both th e public a nd privat e sectors; indeed, insome oligar ch-and-class societies th at is a distinction without mu chof a differen ce. Such clans a re u sefu l as ways t o pr oject influen cean d see off rivals, but th ey gener ally mu st be rewa rded a gain a ndagain in ma ter ial terms a s followers ha ve several pot ent ial options .Oft en pu blic agencies and policiesincluding law en forcemen t a nd

reformsare owned by one el i te fact ion or another, or areperceived in such ter ms , an ti-corr upt ion effort s m ay well have litt lecredibi l i ty as a result . Where ol igarch-and-clan corruption isser ious , people a t ma ny levels of society live in a set tin g of pervasiveinsecur ity ma rked by economic un cert ain ties, weak propert y right s,shaky civil libert ies and polit ica l right s, powerful but un accoun tableel i tes in poli t ics and the economy and, al l too often, al l - too-

imm inent th rea ts of violence.

Many corrupt oligarchs in Russia and Mexico, for example, havecome to the fore relatively recently as political transformationsan d economic libera lizat ion ha ve injected lar ge sta kes int o a gam ewith few inst itu tiona lized ru les. The Oligar chs of the Ph ilippines,

_____________________________

4 Zero-sum situa tions arise when one par tys gain s are an oth er par tys losses. In suchsett ings an yth ing resem bling the pu blic int erest is likely to lose out t o conflict a mongfactions who see any gains made by others as coming at their own expense. Suchconflicts often become bitter , resist efforts a t compromise, and ma ke it ext rem elydifficult to build mutual trust. A more desirable pattern would be non-zero-sum,par t icular ly if al l par t ies can gain.


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can ta ke on th e bitt erness an d zero-sum cha ra cter of factiona l feuds,fueling vote-buying, electoral fraud, and grassroots intimidationt act ics (Sidel, 2000) an d, as tr agically witn essed in t he pa st year,violence. Prominent families have used political connections tocarve ou t n iches in the s ta te admin is t ra t ive and regu la to ryapparatus, and to parlay such resources into virtual monopoliesover some sectors of the economy (for a classic case study seeMcCoy, 1993b). Meanwhile, I was t old by severa l in terview subject s,citizens and small businesses suffer from ineffective governmentan d policy implement at ion, an d from un cert ain ties regar ding th eeconomic and lega l clima te, pr oper ty right s, an d (for some) persona lsa fety. Middlemen and fixers abound (Amorado, 2007); while su chopera tors ma y redu ce some sh ort -t erm t ra nsa ction cost s th ey alsoha ve an int erest in preserving perceptions of govern men t a s rem oteand unresponsive (Khanna and Johnston, 2007), thus adding tothe overall sense of insecurity. Worse yet, a seemingly helpfulmidd leman migh t func t ion more as an in f luence pedd le r o r

extort ionist in cas es where t he st ak es ar e larger (Amora do, 2007).Int erna tiona l investors find ma ny projects riskier t ha n th ey mightbe elsewhere, a pa tt ern th at encour ages th em t o keep their eye onth e short term (th at genera l tenden cy ha s been demonst ra ted byKeefer, 1996; Cam pos, Lien, a nd Pr a dha n, 1999) . The domesticeconomic elite was described t o me a s inwa rd-lookin g, hiving off hegemonic positions and rent-producing monopolies rather than

developing a competitive economy. High-profile anti-corruptioninstitutions such as the Ombudsman and the Presidential Anti-Graft Commission, I was told, are viewed by many (rightly orwrongly) as protect ing the personal in teres ts of var ious toppolitician s. Even t he m ost s cru pu lous occup ant s of su ch positionsha ve foun d t hem selves th e focus of int ense su spicion a nd distr ust .For all of these and other reasons, economic development, the

consolidation of democracy, and the overall well-being of societyhave suffered (Hutchcroft, 1991; McCoy, 1993; Wedeman, 1997;Coronel a nd Balgos, 1998; Hu tchcroft , 1998; Mora n , 1999; Kan g,2002) .


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I n s u c h a s e t t i n g t h e l a w - e n f o r c e m e n t , a d m i n i s t r a t i v eimpr ovement , an d civil-society-orient ed mea sur es t ha t domina tean t i-corr upt ion t hin kin g in most s ocieties will la ck cred ibility an dbroad-based political support. They will thus, by themselves,accomplish l i t t le . I t is not that such measures are bad ideas;instead, they are premature, because the political support theyrequire ha s yet to emerge. Thus t he st ra tegies proposed here a im,via enhanced poli t ical accountabil i ty, poverty reduction, andimprovements to democrat ic processes to strengthen ci t izenscap acity, incent ives, an d willingness t o ta ke issu e with corr upt ion,and to enhance political incentives for leaders to address thosedemands and expectations. In no way do I suggest that soundlegis la t ion and i t s enforcement , or improved adminis t ra t ivepra ctices in both th e public an d th e privat e sectors, ar e not wort hpur suin g. Rat her , th e longer-term cha llenge is to:

Link reform to the provision of services th at both addr ess

th e immedia te n eeds of th e popula tion an d, via effective an deven-handed provision, reduce distrust among citizens andin government, and ease collective-action problems (to bediscussed below);

Demonstr at e that improvements are taking place, and th atthe scope and profitability of corruption are being reduced,

by gathering and publishing indicators and benchmarks of governm ent perform an ce;

En able citizens to support leaders who succeed at su ch t asks,and t o resist abu ses of power, th rough politica l processes t ha ta r e m o r e o p e n , s t r u c t u r e d , a n d c o m p e t i t i v e , a n d l e s spersonalized and factionalized, that work from the bottom

upwa rds, an d produce decisive results; an d

Sust ain t he whole virtu ous cycle over t ime.


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From d em ok rasya to dem ocracy

Such cha nges will be difficult not leas t becau se corr upt segment sof th e oligarchy ha ve a st ak e in t he status quo . But broader forcesand processes are challenging too. Electoral competition has notchecked corruptiona problem found in other democracies, suchas India , where democra cy cont ends with pervasive povert y (Sunand J ohns ton , 2010). Grea t h opes oft en a ccompany the elect ion of a new president , and Sena tors frequent ly port ra y them selves a sagent s of cha nge; yet even t he lat e Pr esident Cora zon Aquino, whorose to power on a wave of ma ss r esent men t of a buses (includin gbut by no means limited to corruption) during the Marcos era,cou l d n o t fu n d a m e n t a l l y a l t e r t h e s i t u a t i on . D e m ocr a t i cinstitutions and processes were restored, but corruption was notchecked; indeed it would be m ore a ccur at e t o say t ha t Mar cos-eradea lings favorin g some oliga r chs gave way to new schemes , or t heresumption of older ones, favoring other families and factions

(McCoy, 1993b). 6 Electoral politics has historically been plaguedby vote-buying and rivalries among elite factions who fear beingshut out of power. Influence has tended to run from top-down,accoun ta bility t o flow up war d, an d politica l support to be bar ter edfor short -ter m benefits.

Indeed, th e domina nt impression, to one out side observer at least,

is of a s ta te a nd s ociety th at ma y be extensively int erm ingled interms of personal connections, yet all too often disconnected int erm s of official du t ies a nd a ccoun tability. On a da y-to-da y level,part icularly during elect ion campaigns, interact ions betweencitizens, polit ician s, an d officials can be int ense yet sh aped by short -

_____________________________6 I t is tempt ing to speculat e tha t for a l l but t he str ongest presidential personali t ies,

th e hyper-presidential pat tern of polit ics an d government , and t he more generalpower of oligarchs, might h ave developed in symbiotic fash ion. Pr esident ial power,in su ch a s cena rio, would be a fun ction of the in cumbent s willingness to go alongwith, and/or t o exploit , the sta tu s quo, ra th er th an to cha llenge it in funda ment always, an d of th e condit iona l acquiescence of competing oligar chs who hope th at th eyor th eir allies might one da y hold such a dominan t office.


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term, what-can-you-do-for-me expectations. At that level i t isdifficult to say exactly where th e st at e ends an d pr ivat e doma insb e g i n a n d t h u s , t o s a y w h a t s t a n d a r d s o f b e h a v i o r a n dper formance shou ld app lysince persona l connec t ions anddeal ings are so dominant . 7 With respect to the formal publicprocesses of development and governance the country finds itself in an expecta t ions t rap in which governing e l i tes demandre la t ive ly l i t t l e o f c i t i zens , and c i t i zens expec t l i t t l e f romgovernment (the idea draws upon Rose and Chin, 2001). Suchdynamics not only hinder nation-building; they sustain corruptdea lings t oo, as officials wh o accomplish litt le ar e not on ly tolera tedbut effectively left free t o pur sue th eir own schemes. F am ilies an dindividua ls, for th eir pa rt , find it easier to deal with problems viapersonal connections and fixers rather than to demand, bypolitical or bureaucratic means, those officials to do their formaldu t ies and t hose a gencies t o deliver services effect ively.

Those ways of doing things are not just situational adaptations,but a lso a re link ed to deeper elemen t s of politica l cult u rein effect ,t o a pa r t icula r k in d of socia l cont ra ct . Man y ci t izens bas icun derst a nding of ideas like demokrasya rest n ot u pon t he values,inst itu tions, a nd processes of popula r self-govern men t, but ra th erupon help with personal problems. Schaffer, for example, foundout in h is int erview of citizens in a bar an gay in Quezon City t ha t

many thought the Marcos presidency was a good example of demokrasya: dur ing t hose year s t he int ervent ion of officials a ndpat rons m ade it easier to ar ra nge for lenient persona l treat mentfrom ba nk s, governm ent offices, an d other s wh ose h elp was needed.Tha t such he lp o f t en r equ i r ed paymen t s , and t ha t bo th t hepayments and the help had a large long-term price, was lessimporta nt tha n t hat it was available. Demokrasya, Scha ffer ar gues,

is link ed t o th e idea of kalayaan, a compound word with its own

_____________________________7 Thanks to Steven Rood and Frederic Schaffer for their perceptive comments on these

points.


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complex history, evolving out of family relationships and firstat ta ched t o politics t owar d t he en d of th e colonia l era . The ter mconveys a s ense both of freedom from cru el ru lers (or pa ren t s) anda kind of mu tu al care an d u nit y an alogous to a childs experiencein a close and indulgent family (Schaffer, 2009)a notion withobvious appea l to people for wh om povert y, da nger, an d insecur itya r e fact s of everyday life, but not a promisin g model of citizensh ipin t erm s of holding officials a ccoun ta ble an d checking th eir a busesof power .

N o wa y out of it but t hrough it

I t wi l l be sa id that such chal lenges are immensely d i ff icul t ,amounting to a fundamental rewiring of politics, society, andimport an t a spects of cultu re, over a span of a gener at ion a nd m ore.Those views will be exactly right. But as in t he hist orical exam plesno t ed ea r l i e r, t he na t i on w i l l be a t t a ck ing co r rup t i on a t a

fun dam ent a l level, giving more ta rgeted a nt i-corr upt ion m easu resthe political backing they need, and building a broader, deeperan d more genuine dem ocra cy.

Impr oving th is stat e of affair s am oun ts, in importa nt respects, toa process of nation building a thought echoed by a number of well-placed observers during my visitsand of supplanting the

persona l links a nd r ewards of demokrasya with a more open, publicand broadly accountable democracy. The scope of that challengecannot be overstated: in the United Kingdom the emergence of genu ine democra cy took t hr ee cent ur ies, while in th e Un ited Sta tesit t ook t wo. Moreover, both of t hose societies h ad a key advan t age:th ey become na tions, in th e sense of developing a str ong sh ar ediden t i ty and a sense o f common des t iny, be fore o r as they

implemented key democrat ic procedures. The Phil ippines, bycont ra st , becam e a democra cy in a procedur a l sense before it ha drea lly become a na tion, a nd did so with great speed. Moreover, itssta te h as not shown a n ability to creat e an environm ent favora ble


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III. An Agenda fo r t he New P re s iden t

Cont rolling corr upt ion in t he Ph ilippines over th e long t erm willengage diverse constituencies, motivated by the defense of theirown interests, in a process of redefining accountability, and of redrawing the l imits around acceptable uses and connectionsbetween wealt h an d power. Those sett lement s will be political a ndeconomic a s well a s legal a nd bur eau cra tic and , as in oth er societieswhere corruption has been brought under control, they will winbroad support because they work.

At t he sa me t ime, however, na tiona l leader ship ha s a special roleto play. Focused a nd cred ible a ct ion again st corr up t ion, followedu p b y c l e a r e v i d e n c e o f b e n e f i c i a l e f f e c t s , c a n p e r s u a d econstituencies both domestic and internationalnot only thoseseeking reform , but also th ose with a st ak e in t he cur ren t wa ys of d o i n g t h i n g s t h a t p o s i t i v e c h a n g e s a r e u n d e r w a y i n t h e

Ph ilippines . Moreover, ear ly and effect ive action can increa se th epolitical feasibility of longer-term measures, opening the door tonew ideas a nd reducing opposit ion t o older ones.

Wh at not to do

Let u s begin with some pr opositions about wha t a new P resident s

anti-corruption agenda should not be. First, waiting for an anti-cor ru pt ion champ ion t o do t he hea vy lift ing ma y well tu rn ou t t obe self-defea t ing. Even if a n ew leader wer e to supp res s corr up t ionby sheer force of persona lity, the h yper-president ial politica l systemwould rem ain just as vulnera ble to abuses by succeeding president san d th eir cronies. The more fun dam ent a l cha llenge at t he level of th e political system t ha t br ings leader s to the fore: th ere, the n at ion

needs politica l processes in wh ich power is won, u sed, an d handedon in accountable ways, and (a lesson it took American urbanreform ers m a ny years to lear n) in which voting t he scoun drels outdoes not necessa rily mean vot ing a n ew set of scoundrels in.


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Second, most people hold a highly per sona lized view of corr upt ionnot an inaccurate view, given the central roles of oligarchs andother prominent figures. But the most popular anti-corruptionremedy suggested by that viewfrying a big f ishis alsounlikely, by itself, to produce lasting reform. Throwing a fewcor rup t ion k ingp ins i n to j a i l m igh t open t he doo r t o moresu st a ina ble reform s by serving as p roof of t op-level comm itm ent .Precedent makes it clear that doing nothing about such figuresquickly arouses suspicion. But without accompanying systemiccha nges a ny deter ren t effects ar e likely to be short -lived and ma ylead to bett er-concealed corr upt ion r at her th an to less of it. Fur th er,a fish fry will not make citizens any more able to demand andreward accoun ta ble govern ment , nor to resist abuses t ha t th reat enth eir inter ests a nd divide th eir political st ren gth . There is also arisk t ha t high-profile tr ials an d convictions ma y be seen by ma nyas just an oth er r oun d in th e long-ter m cont ent ion a mong powerfulfamilies and factions. If a new administration can fry some big

fish, more power to it, but beyond the clear value of punishingspecific wrongdoers s uch a n appr oach sh ould be seen a s a way toopen the door for more basic reforms, not as a solution to thecorr upt ion problem in it s own right .

Fin ally, it is equa lly importa nt not to gear up t o fight th e la st wa r.A focus on prevent ing sequels to ma jor scan dals t ha t h ave alrea dy

occur r edwha t can we do abou t ca ses like t he so-and-so affa irra th er t ha n looking at chr onic system ic problems, is not pr omising.Obviously, institutional and procedural vulnerabilities revealedby such cases need to be addressed. Some continuing corruptprocessesnotably, in electoral processes, as well as abuses inCustoms agencies and publ icworksneed a t tent ion too. Butheadline-making top-level scandals often have unique elements,

an d corr upt ion a s a genera l problem can cha nge and ada pt m orerapidly than we often imagine. The clandestine nature of mostcorr upt ion compoun ds t ha t logic: even if mea sur es a re in place toprevent a recurrence of The Great X Scandal, we may not know


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where t o look for it or even be a war e it is being r epeat ed un til th enext m ajor scan da l comes t o th e sur fa ce. In a lat er section I willsuggest th at th e crea tive inter pret at ion of governm ent perform an ceindicat ors can tell us m uch m ore a bout vulnera bilities t o corr upt ion,even if th ey do not hint at all of th e details tha t ma ke some pa stscandals notable.

Early initiatives

Ea rly init iat ives should be aimed both a t corr upt ion itself an d atperceptions, both domest ic an d int ern at iona l. I su ggest a few ideashere that would represent constructive, visible commitments onthe part of a new administration. These proposals will not, bythemselves, end corruption, even though they are worthwhilereform ideas. They ar e int ended inst ead t o demonstr a te t op-levelcomm itment an d a willingness to shake u p th e status quo . Mostam oun t to ta rgets by which effort s can be judged a fter a year or

two; all are only the opening moves of a long and demandingstruggle.

An early action agenda for a new President might include thefollowing:

Relent lessly fra me corr upt ion cont rol in ter ms of fight ing poverty

and impr oving th e qua lity of life for citizens; th en (as suggest edbelow), ga ther a nd publish evidence of per form ance on a r egularbasis.

This suggestion emph a sizes essentia l conn ections t ha t m ustbe ma de between r eform and citizens own int er est s. Overtime, the effective and fair allocation of resources can ease

d i s t ru s t among c i t i z ens , and i n gove rnmen t , and he lpm i n i m i z e c o l l e c t i v e a c t i o n p r o b l e m s ( m o r e o n t h e s econs idera t ions below). Pr esident ial initia t ives can laun ch bothelemen ts of this su ggestion; in t ha t conn ection it is importa nt


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to remember that both also line up with some of the mosti m p o r t a n t a p p e a l s a n d c o m m i t m e n t s o f t h e A q u i n opresidential cam paign.

Consolidat e an ti-corr upt ion responsibilities now scat ter ed am ongth e Ombuds ma n, P AGC, blue-ribbon bodies, an d oth ers:

The consolidat ed agency should be th e clear int ak e/citizenfocus point for in vestigat ory an d pr osecut or ial pr ocesses.

The consolidat ed an ti-corr upt ion office should ha ve ar rest an dsubpoena powers, and should either possess the power toprosecute or be able to compel prosecution of cases uponappeal to th e President .

The consolidat ed agency should minimize its involvemen t indonor-driven anti-corruption projects.

The consolidat ed agency mu st h ave sufficient s t aff an dresources to follow up complaints effectively, guaranteeingsecurit y an d confident iality for citizens.

A t p r e s e n t a n t i - c o r r u p t i o n p r o j e c t s p r o l i f e r a t e w h i l eres pons ibility for corr up t ion con t rol is divided am ong severa l

agencies. As a resu lt t he projects ha ve litt le public credibilit y:even t hough mos t a r e p robab ly wor thwh i l e e f fo r t s i nthemselves, citizens do not have a clear picture of what isbeing done and any progress becomes difficult to publicizea b o v e t h e n o i s e . M e a n w h i l e , a g e n c i e s s u c h a s t h eOmbudsman, PAGC, and the Sandiganbayan ar e regar dedas ineffective or as underperforming. Where projects and

agencies work at cross-pur poses r esour ces a nd opport un itiescan be wast ed, effort s m ay overla p a nd cont ra dict each oth er,an d t her e a re r eal r isks, after a tim e, of project fat igue. TheHong Kong a nd Singapore a pproaches, by cont ra st , show th e


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value of a s ingle un ified reform lea der sh ip, coord ina t ed andconsistent anti-corruption strategies, and a clear focus forcitizen activity and corruption complaints. Further, whereprolifera ting ant i-corr upt ion projects reflect only t he int erest sand views of external donorsor, where they are perceivedas doing sothey may miss the mark in terms of socialrealities and popular expectations. At an extreme, reformitself ma y seem t o be a smokescreen for exter na l inter vent ionin t he life of people an d th e na t ion . As noted ea r lier, cha ngesat this level wil l require legislat ion, at a minimum, andconst itu t iona l cha nges too if th e Office of t he Ombu dsm an isto be replaced by the new consolidated agency. In thoseconn ections, it m ay be necessa ry t o rea ssu re legislat ors t ha tthe results of such changes will complement and enhance,not pr e-empt , th eir own oversight an d investigatory functions.

Recruit a n Eminent Persons Group (EPG) from ma ny segments

of society t o a dvise on and oversee evalu a t ion of reforms , reportto th e pu blic, an d t o a ppoint /rem ove th e h ead of th e consolidat edan ti-corr upt ion a gency.

An overs ight body made of up wel l -known, pres t ig iousind ividu a lsand a s fa r a s possible, ma de up of people of clearindependence and in tegr i tycan serve as an important

gua ra nt or for a new P residen ts a nt i-corr up t ion effort s. If empowered to appoint and remove the head of the newconsolidat ed an ti-corr upt ion a ut hority, th at agency ma de befreed from ma ny of th e su spicions an d n egative perceptionst h a t h a v e p l a g u e d o f f i c i a l s s u c h a s t h e O m b u d s m a n .Maint a ining th a t posit ive image will be a challenge over time,however, but if th e new a gency an d its h ead en joy th e support

of an EP G which h as t he power to remove the hea d, tha t canbe a powerful continuing endorsement. In a sense the EPGcan exercise oversight of sorts of the new President too, atleast with respect to cont inuing a nt i-corr upt ion comm itmen ts.


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The EPG could review and comment upon anti-corruptionau dits , ann ual reports from the P resident a nd t he new an ti-corruption agency, and others, interpret ing them for thecitizens a t la rge an d evalua ting the credibility of such r eport s,much as international observers in some societies evaluatethe qua lity of elect ion p rocesses. The E PG would n ot be t hena tions chief ant i-corr upt ion cru sader s, but ra th er would playth e role of guar an tor, honest broker, and t ru st-builder.

Speed up th e Sandigan bayan, in par t by restr icting its case load

to large or particularly high-profile cases, but also through fullst affing an d r esour ces.

The Sandiganbayan fa res m odera t ely well in Social Weat herSt a t ions (SWS) Tra ns pa ren t Account a ble Govern ance (TAG)evalua tions of a nt i-corr upt ion comm itm ent , but it h as beench ronica lly sh ort of st a ff and resour ces while saddled with a

very heavy cas eload. The r esultin g delays in ha ndling cas es,o f t e n i n t h e r a n g e o f s e v e n y e a r s o r m o r e , s e r i o u s l yun dermines the credibility of ant i-corr up t ion effort s genera lly,an d of th e Sandiganbayan specifica lly. By pr oviding a ma jorin f lux o f funds , aggress ive ly rec ru i t ing and t ra in ing asufficiently large, high-quali ty staff , and adjust ing caseparameters to restrict the caseload to major cases or cases

posing import ant an t i-corr up tion policy an d law-enforcemen tissues, a n ew administra tion can m ak e the cour t a far morecredible an ti-corr up t ion force. This is not necessa r ily the sa methin g as frying big fish: a Sandiganbayan th at expeditiouslydea ls with a collusive ring of m iddle-level figu res , or a t t a cksa pervasive corr upt pra ctice like vote-buying a t ma ny levelsand, where justified, produces convictionswill accomplish

mu ch more in t erm s of deter ren ce an d public credibility t ha nwill a few sensational big fish convictions followed by aretu rn to inaction-as-usu al.


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Est ablish a Citizen Advocat e with in each Cabinet-level Pu blicService Depart ment .

Citizen Advoca tes can help people dema nd accoun ta bility an dgain redress of grievances within the major public servicedepart ment s of govern ment th at is, th ose th at deal directlywith ci t izens on a regular basis and those charged withdeliverin g ser vices. The Advoca tes should be given significan tsta ffing and fun ding, and be gran ted powers t o ma inta in th ean onymit y of citizens filing compla int s a bout th e ways t heagencies have acted. Where su ch compla int s involve appa ren tcorr upt ion th e Advocat es would be r equired t o report cas esto the n ew ant i-corr upt ion a gency, an d gua ra nt eed access toinform at ion a bout how such cas es ha ve been ha ndled so th atthey can repor t back to the compla inan ts . The Ci t i zenAdvocates should f i le public reports on an annual basisevaluating the quality of services within their respective

agencies, summarizing the flow of citizen complaints, andrecomm ending improvemen ts with in th eir agencies.

Choose one or t wo sectors with direct impact on the quality of lifesuch as the Department of Education and BIR or othert axat ion bodiesin order t o:

Regular ly gath er and publish dat a on perform an ce, such a st h e t i m e a n d n u m b e r o f s t e p s r e q u i r e d f o r r e g u l a radministrative functions.

Regular ly gath er and publish dat a on th e quality an d costsof services.

Compar e the dat a a bove to appropriat e benchma rks, againpublishing results; ma ke clear th at th e results da ta receivetop-level r eview.


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Condu ct a nd publish regular t op-down perform an ce-an d-int egrit y reviews of t hose sectors ; involve citizens and NGOsin t hose reviews.

Pu blicly cite a nd rewa rd officials r esponsible for improvedperformance; require unsuccessful officials to account forresults .

Al locat e resour ces to rewa rd a gencies an d jur isdict ionsshowing impr ovement .

Over time, expan d such a ssessments t o include oth er sectorsResponsibility for gathering and reporting data should bevested, by presidential mandate, in the relevant executive-branch agencies themselves, with reports being made on aregular schedule to th e Pr esident a nd t o th e Eminent PersonsGroup, th e latt er serving as a guar an tor of th e integrity of

t he process. Coopera t ion with citizen groups, ma ny of whichar e already gat hering useful dat a a nd which can aid in t heinterpretation of results, should be an integral part of themandate. This data-and-benchmark process is discussed inmore detail in the next section of the memo; for now it isenough to point out that these processes offer citizens theopport unit y to evalua t e how well services a re being pr ovided,

t a r g e t s a r e b e i n g m e t , a n d i m p r o v e m e n t s a r e b e i n gimplement eda critical a spect of building t he new k ind of accoun ta bility emph asized elsewhere in th is report . Fu rt her,data and benchmarks allow us to locate and estimate thescale of specific vulnerabilit ies to corruption and, whereimprovement s a re being ma de, to send out import an t signa lsthat the scope for and profitability of corruption are being

r e d u c e d . W h i l e d a t a - g a t h e r i n g , b e n c h m a r k i n g , a n dpublication of results on the scales proposed are no smallun derta king, th ey offer a new adm inistr at ion t he chan ce to


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demonst ra te its successes an d t o rewar d effective leaders an dma na gers at a ll levels of govern men t.

Key a rea s for t he indicat ors a nd benchm ar ks would be thosein wh ich gove rnmen t i n t e r ac t s d i r ec t l y w i th c i t i z ens ,providing an import an t ser vice in which a ll sha re a n int erest ,and in which services can be provided in a non-zero-summanner. Educat ion is one such area; taxat ion might beanother. My conversat ions with a variety of individualsshowed th at a var iety of benchm ar king activities are alr eadyunderway . In some cases NGOs are gather ing data oneducat ion a nd pr ocur emen t, for exam ple; in oth er inst an ces,such as the Department of Education, a variety of types of data are likely to be available already. A key challenge willbe to win the compl iance and suppor t o f agency- leve lma na gers; emph as is should be upon t ra cking a given agencysor progra ms per form a nce over t ime, an d on rewa rdin g

improvement, not on compet itive ra nk ing or publishing an ysor t of new corr upt ion index (a ft er a ll, t ren ds in corr upt ionare far f rom the only inf luence on performance) . In a l ll ikelihood third parties will insist on interpreting data inthose ways, however, so a variety of resources and positivepublicity should be made available to cooperating agenciesan d ma na gers a s a coun terba lancing incentive.

Condu ct a nd pu blish r epeat ed lifestyle-an d-ass et disclosur es fortop-level officia ls.

These a ssessmen ts should be condu cted before a n in dividua ltakes officeelective and appointiveat regular intervalsdur ing ten ur e of office, and at th e point th e individua l leaves

public service or moves to another public position. Whiledisclosu res sh ould n ot be so oner ous a s t o dr ive good peopleou t of pu blic ser vice, th ey shou ld a lso be su fficien t ly rigorousan d deta iled to provide mea ningful inform a tion t o th e press


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an d t he pu blic. The new a dminist ra tion, sh ould it follow th isrecomm enda tion, sh ould do all it can t o persu ade in dividua lssubject t o disclosur e requirem ent s th a t t he pr ocedur e can bean opport un ity for th em t o demonst ra te th eir integrity, not

just an intr usion upon th eir privat e affairs or a par alyzingth rea t of lega l problems.

E n d lu m p -s u m b u d ge t i n g ; s h a r p l y r e d u ce or e l im i n a t epresidential discretionary funds.

At p resen t l a rge sums of pub l ic money a re spen t wi threlat ively l i t t le t ransparency or accountabil i ty, and in ase t t ing where mechanisms that can demand and rewardefficient performance are weak or lacking. Particularly inPu blic Work s, a budgeta ry process th at is defined in t erm s of specific projects and appropriations, and provides regularreports on progress, spending, and quality of performance

would be of particular benefit. Such a process would be ama jor source of useful data an d benchm ar ks in its own r ight ,both as regards corruption and the more general ability of governm ent to at ta in its st at ed goals. It would a lso provideprivat e cont ra ctors an opport un ity to distinguish t hem selvesin t he public eye in t erm s of qua lity of per form ance.

Support reform -minded burea ucra ts with bonu ses, recognition,whistleblower pr otections, a nd promotions. Su ch cha nges m aywell require new legislation or amendments to existing laws;ideally, those changes could be part of a broad-based review of compen sa tion an d incent ive systems in t he pu blic sector, th oughsuch an ambitious process would face obvious difficulties andobject ions . Help th ose who ar e comm itt ed t o r esist ing corr upt ion

build mu tu al-supp ort net work s, an d give them pr ominen t pu blicrecognition for their contributions. When corrupt officials aredismissed, roll their sa laries over int o higher pay for th ose whorem ain . It m a y be possible to separ at e th e tr uly-reform min ded


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from those who simply give lip service to the idea by closelyexamining the indicators and benchmarks described above forpositive chan ges, or by issuing incent ive-linked cha llenges k eyedto those indicators , and then observing which off icials andwork ing groups st ep forwar d an d act. For exam ple, t ax collectorswho come closer to revenu e t ar gets wh ile r educing irr egular itiescou ld be given r a ises, bonus es, pr ofessiona l r ecognit ion, and/orpositive publicity.

Severa l persons with whom I met empha sized th at significan tnu mber s of bur eau cra ts wa nt to oppose corr upt ion, an d wan tto esca pe t he pu blics per cept ions t ha t a ll or m ost of t hema r e c o r r u p t . T h o s e a n t i - c o r r u p t i o n m e m b e r s o f t h ebur eau cra cy would benefit from encour agemen t, protection,favorable publicity, an d pu blicly-visible increa ses in pa y an dstatus; they should also be encouraged to f i le reports of cor rup t ion as appropr ia te , to a id in the compi la t ion o f

perform an ce indicat ors a nd benchma rks , an d to support eachoth er th rough organ izat ions an d inform al n etworks. Man yof th ose kinds of rewar ds a re int an gible, and in m ost respectscost -free, yet ar e valued by recipient s and oth ers . With respectt o t angible incent ives a nd compensa t ion , if cor ru pt officialsar e dismissed and t heir sa lar y fun ds rolled over into higherpay for those who serve well, several important kinds of

signa ls can be sent to bur eau cra ts an d citizens, at relativelymodest cost .

In itia tives for the longer term

Longer-term reforms should also have priority status. By longerterm I do not mean that these actions should wait until some

dista nt dat e, but r at her t ha t t heir effects a re likely to be seen inth e longer t erm . Most, in fact, can be lau nched on a tr ial basis an dth en developed in par allel to th e dat a-gat her ing timeline pr oposedabove. In n o par ticula r order, th en:


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Laun ch, sust ain, an d refine an a nt i-corr upt ion cur riculum in th eschools.

Hong Kongs long-t erm an t i-corr upt ion edu ca t ion effort s a rewell known a nd ha ve paid ma jor dividends in t erm s of publicres ista nce to corr up tion an d willingn ess to file report s (Cha n ,2005). The key is starting early in the schooling process,weaving anti-corruption themescultural as well as officialan d civicth rough m ultiple aspects of th e cur riculum , an dth en su s ta in ing th e e ffor t both th roughout a s t uden t sschooling an d for su bsequen t wa ves of st uden t s. To be sur e,th e Ph ilippines is a far lar ger a nd m ore complex society th anHong Kong, and education in a democracy serves a widerra nge of pur poses a nd agenda s; for guidan ce it m ight well bewort h wa tching similar effort s n ow un derwa y in a var iety of societies (Transparency International, 2004; TransparencyInt ern at iona l, 2010).

Elect Senat ors by distr icts

The hope her e is th at Sena tors elected by distr icts m ight nothave to spend as much, legi t imate ly and otherwise , oncampaigns, and that they would have incentives to overseegovernm ent perform an ce a nd th e provision of services in th eir

dist r ict s. Sena tors with specific geogra ph ica l responsibilit ieswould a lso be less tolera nt of lum p-sum budgeting (see t hepresidential agenda, above), and more insistent on specificpublic work s agenda s an d ta rgets for t heir distr icts . Districtelection of Sena tors m ight well str ength en t he h an d of someregiona lly-based oligar chs, but th e hope is tha t t he Sen at orsthey influence would have to negotiate with, and could be

checked by, other Sena tors with differing geogra ph ica l bases,a n d w o u l d f i n d i t m o r e d i f f i c u l t a n d l e s s p o l i t i c a l l yadva nt ageous to quickly set t hem selves up a s na tiona l-levelpolitical operators.


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En ha nce t he p r ofe s s iona l ism , pol it i ca l i ndependence , an dcredibility of the judiciary, emphasizing protection of humanright s, and propert y right s

An independent judiciary can be essential to corruptioncon t ro l , and i n pa r t i cu l a r t o t he r e l i ab l e and c r ed ib l eimposition of criminal laws a nd pena lties. Indepen dence mustbe balanced by overall responsibility and accountability toth e Const itut ion, however: India is an example of a democra cywith a n indepen dent but less-th an -responsible judiciary, withthe result that judicial poli t ics and decision making canbecome ano ther a rena fo r cor rup t in f luencean a rena ,ironical ly, lying beyond the legit imate reach of electedofficials.

Simplify th e ta x code, crea tin g broad but progressive ban ds of taxation that feature few exemptions, low rates, and uniform

tr eat men t of ta xpayers, in order t o redu ce th e discret ion of ta xcollectors/assessors

I do not claim t o kn ow much a bout ta xat ion in t he P hilippines,and in fact i t may well be that recent changes exemptingmany ord ina ry citizens from some filing procedu res h ave beena move in t his direction. The point her e, however, is to ma ke

the taxation system visibly more fair and tamper-evident,an d to reduce th e discret ion t ha t corr upt agents m ight use top u t p r e s s u r e o n c i t i z e n s a n d b u s i n e s s e s . B r o a d e raccountability is important in this connection, too, and aPr esident who uses a n indicat ors-an d-benchm ar ks st ra tegyfor taxation 8emphasizing the fairness and consistency of t he pr ocess, and highlight ing ar eas of excessive var iat ion a nd

discret ionwill be sending import an t messa ges to the BIR,business, an d citizens a like.

_____________________________8 Some promising init iat ives may a lready be underway in t he Depart ment of Fina nce.


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R e focu s p ol i t i ca l fi n a n c e p o li cy t o e n cou r a g e b ot t o m - u ppar ticipat ion a nd well-str uctu red compet ition a mong part ies withbroad an d legitima te social bases:

G e n e r ou s a n d cr e a t i v e m a t c h i n g for m u l a e for s m a l lcont ributions t o par ties, ra th er t ha n t o can didat es

Pr otection, including an onymity if desired, for citizens m ak ingsmall donations.

Pr ovision of fun ds to parties th at demonst ra te a genu ine socialbase by obtaining large numbers of small contributions insevera l sect ions of t he count ry.

Free television a nd ra dio t ime on com m ercial as well as onstate-owned broadcast channels for parties and candidatesdemonstr at ing a broad a nd genu ine social bas e.

Her e th e key idea is t o use polit ical finance rules and resourcesnot so much to police the flow of funds or t o dr ive money out of electoral politics, but rather to encourage broad-based, open,and competitive politics in which candidates have reasons tospeak for genuine social constituencies and resources areava ilable to bring a variety of such voices into the electora l ar ena

(for a more deta iled development of th at ar gumen t see J ohn ston,2005b). Those sorts of long-term developments will add politicalforce and vitality to virtually every proposal in this memo.Resource constraints will be an important challenge, in thisconnection, a s will confidence in the ways votes a re cast , coun ted,and proclaimed (in which the automation of the 2010 electionwas a good sign). It will a lso be important to devise and publicize

ru les and procedures in ways tha t emphasize their fairness a ndtransparency; here is one area in which some key arrests andtrials of possible abusers may go a long way toward buildingconfidence in t he n ew system.


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IV. Co ll ec ti ve Ac t ion and t he Soc i a l Founda t ions o f Reform

The gra nd scena rios sket ched out above, and popula r support forthe more specific mea su res pr oposed, requir e accoun tability backedup by polit ica l incent ivestha t is, a citizenr y tha t dema nds officialsuse public power and resources honestly and effectively, andofficials who see good reasons to take such demands seriously.But while a n a na lyst m ight see it a s being in peoples int erest s toact ively res ist corr up t ion, t ha t does not m ean t hey will do so. Someof th e rea sons for t ha t ar e situ at iona l: th e risks people perceive insu ch en dea vors , th e efficacy th ey do or do not a t t a ch t o t heir ownpolitical activities and choices, and the trust they do or do notplace in specific leaders, will all influence their willingness todemand and reward bet ter government. But there are genericdifficult ies in mobilizing t he pu blic behind reform a s well, two of which a re pa rt icula rly crit ica l: building social tr us t , and overcomingcollective action problem s (R oth stein , 2000; Us lan er , 2004; Teorell,2007).

If people do not t ru st each oth er, th eir leader s, or th eir institu tions,they are unlikely to act against corruption through the politicalsystem. They may rebel, with unpredictable consequences, ormore likelythey may adapt to the realities of the system by

seek ing ou t t he sor t s of fixers and per sona l connections describedearlier. A third a lterna tive is th at th ey may respond to corr upt ionwith corruption of their own (an imaginative discussion of thecalculations shaping popular responses to corruption appears inAlam, 1995).

Genuine trust must be earned, not proclaimed nor commanded.

Perhaps the most promising approach, in terms of policy, is toth ink of ways to redu ce distru stnot pr ecisely the sa me t hin g aspositive values of tr ust , but a st ep in th a t direction. The personalcondu ct of leaders is import an t in t ha t r egard, as a re ideas proposed


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being squeezed ou t of t he syst em: a city th a t is n ow paying close toa ma rk et price for basic comm odities like fuel an d concrete, r at herth an spending th irty percent too mu ch a s in years pa st, is one inwhich bribery an d kickbacks in pr ocur emen t ar e likely to be lesscommon, less profitable, and harder to conceal (a more detailedversion of th e indicat ors-and-benchma rks idea a ppear s in J ohn ston,2010).

The indicat ors an d benchm ar ks st ra tegy out lined a bove is a wayto as sess vulner abilities t o corr upt ion a t a deta iled level, to verifypr ogress (or la ck of it) in a ddr essing such problems, an d t o brin g avariety of anti-corruption forces together into a more powerfulwhole . Essent ia l ly, the idea is to moni tor vulnerabi l i t ies tocorruption by regularly gathering and publishing data on theper form ance of specific progra ms a nd agen cies, with t hose result sbenchmarked against similar indicator from comparable bodiesan d jur isdictions. Those indicat orsmeasu ring, for exa mple, th e

tim e, cost, n um ber of steps, a nd ult ima te qua lity of perform a nceof government agencies are linked to corruption in two criticalways: first , th ey reflect t he effect s of pa st corr upt ion, a mong otherinfluences, an d second t hey can tell us m uch a bout th e incent ivescurrently sustaining corruption.

Consider the process of getting a building permit in two cities: if

doing so ta kes seven weeks a nd requ ires 35 steps in City A, whileta king only four days a nd five steps in City B, it is not u nr easona blet o believe t ha t City As pr ocess involves more cor ru pt ion , eventh ough we can not mea sur e it directly. Pa st corr upt incent ives ha velikely sh own officials t ha t t hey can m ake m oney by con t riving newrequirements , bureaucra t ic s teps , and delays ; as for currentincent ives, each st ep is pot ent ially a toll gat e wher e bribes mu st

be paid, an d t ime lost is a r eal expense ma king it more t emptingto pay up. Similarly, if school lunches or water in one area costth ree t imes as mu ch a s elsewher e, or if roads a nd pu blic buildingsan noun ced or laun ched a re n ot finished (or ar e built in substa nda rd


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ways), someth ing aga in is am issor, a t lea st , respons ible agenciesmust be asked to account for ways in which local considerationsmight affect observed differen ces. Benchm ar king su ch indicat orscompa ring t hem to similar agencies or governm ent s a cross a widerar eacan both flag the out liers, demonst ra te impr ovemen ts , an dgive officials the opportunity or obligation to account for largedifferences. Demonstrable improvement is not only a good thingin itself; it also gives successful officials a chance to claim creditand makes citizens more able to support effective leaders whileopposing or pu nish ing t he ineffect ive.

A fur th er benefit of indicat ors a nd benchm ar ks h as a lready beenhinted at above. If an agency that had been paying 30 per centover market for diesel fuel is now paying, say, 5 per cent overma rket , it is a r easona ble guess tha t th ere is now less money to bema de via corr upt ion in t ha t pa rt icular ar ea. Such improvement ssus ta ined over t ime and ac ross many agenc ies and un i t s o f

government would s t rong ly sugges t tha t the scope for, and profitability of, corruption are being squeezed out of the system .Draining the incentives out of corruption is , at the least , anessent ial coun ter pa rt to investigat ions a nd pr osecut ions, an d overthe longer term may be even more effective. From an analyticals t a n d p o i n t w e w i l l n e v e r k n o w e x a c t l y h o w m u c h o f a n yimprovement is attributable to reduced corruption versus other

sort s of governance impr ovements , such a s t echn ologica l innovat ionor increa sed efficiency in t he u se of resou rces. But from a reformst an dpoint , we ma y not pa rt icula rly car e: govern an ce an d servicesar e being impr oved an d sca rce resour ces ar e going to bett er u se.Such ind ica to rs may a l so he lp the count ry b reak ou t o f i t sperception trap, in which sincere anti-corruption efforts do notmove th e needle on exist ing perception-based indices.

I n d i c a t o r s a n d b e n c h m a r k s c a n t a k e m a n y f o r m s . P u b l i cExpenditu re Tra cking Su rveys (PE TS) ha ve been used effectivelyin La t in Amer ica , for exa mple, t o impr ove educat ion s ervices and


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counteract problems ranging from theft of funds and supplies tosystema tic absent eeism (Equ ip2, 2005). Citizens can play int egralroles t oonot only th rough groups such a s Road Wat ch but alsoth rough s chemes emu lat ing successful social a udit and citizenreport car d processes in In dia (Pau l, 2002; Apa za a nd J ohn st on,2009) and Pakist an (UNDP , 2010), in wh ich a ssem blies of citizensevaluate services and consult with off icials on problems andimpr ovemen t s. Anoth er option is pa rt icipat ory budgetin g of t hesort th at ha s been r easona bly successful in Brazil an d Argent ina .In P ort o Alegre, Bra zil, for exam ple, citizens t a ke pa rt in a nn ua lmeet ings th a t evalu a t e th e perform ance of public-service agencies,an d th en set ta rgets a nd a llocat e fun ds am oun ting to over fort yper cent of the local government budget (Apaza and Johnston,2009).

Leadership

Any indicat or-and -benchm a rk process will require sust ain ed t op-leve l back ing , the jud ic ious d i s t r ibu t ion o f incen t ives , andcont inu ing pu blicity. Agency h ea ds m a y well r esist providingindicat ors a nd pa rt icipat ing in benchma rk ing, an d will be tempt edto game any data they do supply (Hood, 2006). Lower-levelf u n c t i o n a r i e s a n d t h e i r l a b o r o rg a n i z a t i o n s m a y s e e s u c hassessm ent s as th rea ts t o th eir jobs (as in s ome r espects t hey could

well be). Assessmen t s of govern ment per form ance will work bestin a n incent ive-rich environm ent where coopera tion an d impr ovedpe r fo rmance can be r ewarded w i th budge t a ry and s t a f f i ngresources; both will be problems in the Philippines, but perhapscan be applied in selective and targeted ways as demonstrationprojects. It is worth emphasizing, though, that such assessmentprocesses can offer positive incentives to elected officials and

bur eau cra ts alike: th ey allow th e successful t o ta ke credit a nd gainst at us, as n oted, an d ca n pr ovide a grea t sen se of professiona l an dpersonal satisfaction to the extent that they show public servicedoes impr ove Ph ilippine society. For a gency ma na gers in pa rt icula r


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t he process m ay, over t ime, redu ce incent ives for polit ica l meddlingor colon izat ion of agencies a nd fun ct ions by var ious elite factions(positive and negative aspects of performance assessments arediscussed in m ore det ail in J ohn ston, 2010).

As noted above, data-gathering efforts similar to that proposedabove a re a lready u nder way in a variety of locat ions an d servicesectors in the Philippines. The Philippine Public TransparencyReporting Project, 9 for example, conducts a Bridges and RoadWat ch pr oject t ha t m onit ors t he exten t a nd qua lity of road-buildingin ru ra l areas. Pr ocur ement Watch In c. gath ers dat a on educat ionser vices a nd other pu blic service fun ct ions; it s r ole in pu sh ing forthe enactment of procurement reform legislation is outlined byPimente l (2005) . One of the mos t p romis ing da ta -ga ther inginitiat ive is th e Per form an ce Governa nce System (PGS), lau nchedin 2004 by the Ins t itu t e for Solida rit y in Asia in con junct ion withthe Center for International Private Enterprise in Washington,

DC. PGS involves community consultative processes, throughwhich performance goals are defined and a locally-appropriatescorecard is agr eed upon, as well as dat a -gat her ing. While th eprocess is typically init iat ed in a comm un ity with ISA support an dadvice the goal is to have PGS become integral to routine localgoverna nce, a nd to be supp ort ed by loca l support an d owners hip(more details appear in Morrell , 2010). While these and other

s imi lar data-gather ing processes are not a imed a t present ingcompr ehen sive a ssessmen ts of corr upt ion vulnera bilities over time,th e prin ciple of gat her ing governm ent perform an ce da ta for publicanalysis, discussion, and subsequent reform efforts has gainedconsidera ble st an ding in r ecent yea rs.

_____________________________9 Online at ht tp://www.tr an spar encyreporting.net/

index.php?option=com_content&view=article&id=70:road-and-bridge-wat ch&cat id=53&Item id=77 (Viewed 22 J un e 2010).


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t ha t a lrea dy enjoy cons idera ble su pport . A fina l dist inctive fa ctoris the potential value of the indicators-and-benchmarks strategyf o r d e m o n s t r a t i n g p r o g r e s s , o r l a c k o f i t , t o c i t i z e n s a n dinternat ional observers a l ike . At present we have no way of system at ically assessing t he a ctu a l progress of reform sta cticalo r s t ra teg icat p resen t . Address ing fundamenta l causes o f cor ru pt ion, h onest ly sh owing th e effect s of our effort s, an d st ayingwith th e st ra tegy for th e long t erm offer n o gua ra nt ees of success,but it is ha rd t o see how embedded, persist ent corr upt ion can bereduced with out such m easur es.

Why would corrupt Oligarchs tolerate these activities?

Once aga in, we ha ve a sim ple answer : it m ay well be th at th ey willnot. Indicat ors a nd benchmar ks, accoun ta ble an d politica lly secur ena tiona l leaders, an d a n at tent ive citizenry a nd pr ess, however,ma y ma ke it h ar der for Oligar chs to act with im pun ity. In effect

such development s can ma ke th e system somewha t m ore ta mper-ev iden t , i n t he p roces s p rov id ing an t i - co r rup t i on and l aw-enforcement forces with clearer cues as to where to look and act.In th e long r un , a less corr upt society ma y even h ave some benefitsfor the current bad actors. To the extent that lasting reform willa id economic growtha complica ted issu e in its own righ ttoda yscorrupt oligarchs may find it easier and far less risky to make

money in a buoyant economy by honest means. The same mayhold tr ue for t heir wish t o hold power: it is n ot out of t he quest iontha t elect ions a nd govern ing could become less risky, less fra ugh twith rivalries, and less violent, t ha n in r ecent decades. And, whileI have suggested that anti-corruption champions by themselvesare not a sufficient basis for lasting reform, the time could comewhen it will be more t emp t ing for once-corr upt oliga r chs t o get out

in front an d lead, ra th er t ha n t o resist or h ide. Ju st a s organ izedcrime figur es a nd orga nizat ions seek t o go legitima te over t ime,an d in th e pr ocess t o tr a de violence a nd legal pr oblems for a quietlife, t he n a t ions cor ru pt oligar chs might well see new opport un ities


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in a reforming society. The key might well be, not so much toconfront th ose figur es directly today, but to persua de th em t hr oughreal evidence th at th e reform process is rea l and t ha t t he t ra in, ineffect , is abou t t o leave th e st a t ion .

N o m agic bullets

It will be critical that any of the strategies a new administrationchooses to pursue be sustained over the long run and be carriedout in a tr an spar ent, open, and demonst ra bly fair m an ner. As notedabove, the goals of linking reform to self-int eres t and to int ens ifyingpolitical demands for accountability and performance along thelines of those interests echoes the long-term political processesth rough wh ich m any of yester da ys highly cor ru pt societies broughtthe problem at least partially under control. They also echo thepoli t ical processes that created ou tcom es critical to checkingcorruption in those societies: sound legislation, the rule of law,

social sanctions against corruption, a free press, independent judiciary, and signif icant const i tuencies with a s take in theirpersist ence and success. Such cha nges t ook centu ries, or at leastsevera l gener a tions; th ey were n ot an order ly ma rch t owar d goodgovernm ent , but were ra th er mar ked by cont roversy an d cont ent ion(which drove t he pr ocess, after all) an d by notable scan dals a ndreversa ls a long t he way. If, however, cit izens come t o see r eform

as benefiting them in their daily lives, and see improved livingcondit ions over t ime (consider Singapores r ise from povert y toaffluence, admittedly in a far smaller society) the formidableenergies of the Phil ippine people can become a steady forcedeman ding better govern ment .


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AppendixInd ica to rs an d be nch marks : a po ss ib le t ime l ine 10

The suggested s teps below apply to two service funct ionseducation and procurement. Procurement is not a direct citizenservice a ct ivity bu t is a prim e locus of corr up t ion in m any societies.Moreover, i t f i t s in to an ind ica to rs -and-benchmarks mode lpa rt icula rly well.

F irs t s ix m on t h s:

Iden t ifica t ion of indicat ors n eeded for per forma nce asses sm ent s,e.g. :

ident ify compa ra ble comm odities (e.g. t extbooks, class roomequipment; petrol, concrete, office supplies)

prices paid for t hose comm odities s p e e d of con t r a ct i n g , d e l iv e r y p r o ce s s e s for r o u t i n e

commodities ident ify rea dily-comp a ra ble con st ru ct ion pr ocesses (e.g.

school buildings) prices pa id for labor, basic comm odities frequen cy of discret iona ry pur cha sing, cont ra ctin g qua nt ities, qua lity of goods delivered qua lity of const ru ction processes, finished projects

delays in const ru ction frequen cy, scope of cha nge requ ests, cost overru ns speed, accu ra cy of pa ying invoices

Identification of possible benchmarks pu blic-sector: compa ra ble agencies, jur isdict ions privat e firms, mar kets (if appr opriat e?)

_____________________________10 This section is based u pon a similar discussion in J ohnst on, 2008.


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Reach agreement on da ta - shar ing among publ ic agenc ies , jurisdictions

explici t ly define pur poses an d uses of dat a: measuring,reward ing im provem ent

ident ify specific rewa rds/incent ives for su ccess (budget a ryinfus ions, if possible; positive publicity; favorable tr ea tmentwith in bu dgeting pr ocesses)

Mo n t h s 7-12

First roun d of dat a-gat hering gath er sma ll am oun ts of readily-accessible dat a in a non-

disruptive fashion ad minist er first citizen/vendor/user su rveys on qua lity of

edu ca t ion ser vices, fa cilit ies, and problems in procu rem en tprocesses

follow-up int erviews with officials, individua ls, vendors t o

as sess su rvey experience review data -gat her ing process for pr oblems, resista nce,

cooperation

Benchm ar king: First roun d assemble shared benchmar king data assemble any pr ivate-market data

calculate benchma rks by alterna t ive sta t is t ical m ethods

E n d of Ye a r On e :

FIRST ROUND OF ASSE SSMEN TS: compar e performa nce an d survey data to benchma rks tentative as sessment s, based on compa risons of perform an ce

data to relevant benchma rks search for cont ra sts, cont inuities, gaps indicat ing areas t omonitor for fut ur e impr ovemen t as well as vuln era bilities


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Select ively pu blicize key sur vey r esu lts (de-empha size other da t aon indicat ors a nd benchmar ks u nt il second r oun d, so improvement scan be empha sized at t ha t point)

Del iver h ighly-publ ic ized resources , rewards , recogni t ion toagencies, ju risdictions fa rin g well in first roun d of su rveys

Month s 13-15

Evaluate and, as needed, revise al l aspects of indicator-andbe

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