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USING THIS SHIPPING REVIEW
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Curbing corruption in Shipping: Sector reform experience & strategies. Pyman and Vidal de la Blache (2021)
Around 90% of world trade is carried out by the shipping industry today. The world fleet of over 50,000 merchant ships is registered in over 150 nations and manned by over a million seafarers of virtually every nationality (See here). Yet, while seaborne trade continues to expand, and the shipping industry is considered a highly efficient mode of transport, corruption has become one of the industry’s biggest challenges. Social extortion by officials, even of small amounts, is powerful because small delays have very high costs. In shipping, the most well-known anti-corruption initiative is an industry-led one: The Maritime Anti-Corruption Network (MACN). While in the past paying bribes to clear customs and port authorities was seen as relatively normal, stronger national anti-corruption legislation and the rise in operational costs due to corruption has triggered this collective response by the shipping industry.
A changing view of corruption is also suggested by the magazine Maritime Fairtrade, which is routinely highlighting progress and issues in addressing maritime corruption. See for example correspondent Lee Kok Leong’s 2019 interview with Mark Pyman of CurbingCorruption, here , with Alexandra Wrage of TRACE, here., and on application of new technology such as Blockchain to raise the integrity of Port operations, such as in Singapore in 2020, here.
AUTHORS AND CONTRIBUTORS
The originating author of this review is Mark Pyman, managing editor of CurbingCorruption. Additional contributions have been made by Eléonore de la Bache.
FOCUS on the specific corruption issues - Guidance summary
The corruption challenge needs first to be focused – disaggregated – into specific issues. Our experience is that there are 20-40 different issues in each sector, recognisable to those working in it. They can then be organised into an easily comprehensible format – a typology. The reforming group uses the one-page typology as the starting point for discussion and for analysing them: their scale, importance, context, avoidability and solubility. You can use this as the basis for building a shared understanding of the impact of the corruption.
Start by disaggregating the different corruption types that you are faced with. You can do this in the following way:
You can read more guidance on FOCUS here.
Shipping is seen as being more exposed to corruption and less active in tackling it than other industries: ‘It is a global industry that does not have a mature anti-corruption compliance culture. It is traditionally very opaque and has only made a slow shift to greater transparency. Fraud, bribery and other illegalities are endemic to some parts of the industry, and the world’. (Interview with Alexandra Wrage in Maritime CEO interview April 2015).
Every day, vessels and cargos enter ports and clear customs, involving numerous stakeholders across several jurisdictions. This creates huge opportunities for corruption, such as facilitation payments, one of the biggest problems by shipping companies. There are also grand corruption opportunities, such as when companies disassemble products and ship them through separate customs bureaus.
Analyses of corruption risks in the maritime industry have focused on the demand and supply of bribes in ports and customs. Most of the literature on the topic looks at what is happening when a vessel enters a port and the different obstacles it faces to clear customs. While corruption risks in ports is relatively new topic of analysis, corruption in customs is generally well documented.
Deloitte (2015) have similarly summarised the different fraud risk prone areas of the shipping industry. They use a flow diagram below to illustrate the risk-prone areas.
The World Bank has guidance on how to identify corruption risk in customs operations. See Section 4 of this review for an extract from the World Bank 2011 book on risk modelling for border corruption (Durrani et al 2011).
Specific Reform Measures - guidance summary
Reform measures will always be specific to the particular circumstances. Nonetheless, in order to get ideas and insights, it helps to learn about reforms employed elsewhere and to have a mental model of the type of what sorts of reforms are possible. We recommend you consider each of these eight categories of specific reform approaches:
Talking through with colleagues and stakeholders how each of them might work in your environment enables you to ‘circle around’ the problem, looking at different ways and combinations to tackle it. One feasible option might, for example, consist of some institutional improvement projects, plus strengthening integrity among staff, plus strengthened sanctions and discipline.
You can read more guidance on Specific Reform Measures here.
Reducing corruption in the shipping industry requires reforms on three different levels for change:
TRACE is an anti-corruption compliance organisation who have established a Shipping and Maritime Initiative with vessel owners, shipping agents and freight forwarders.
According to Lysova (2016) from TRACE ‘the most powerful tool in companies’ possession against bribe demands is their genuine commitment to clean and transparent business practices, effectively broadcast to port and customs government officials, competitors, customers and other players in the industry’. Such anti-corruption/bribery programmes include:
Another example is from Danish shipping giant Maersk, which is the shipping company that has been most active on anti-corruption. They have a strong published stance against bribery. Maersk have invested heavily in stopping facilitation payments (separate from their engagement with MACN), starting with an effective system whereby the Captains log all small facilitation requests. The trend of the number of these requests worldwide from Jan 2015 to May 2017 – shown in the Maersk data below – shows the success of their initiative (Slide given to the author by Maersk February 2018; published with permission of Maersk).
What did Maersk do in this case?
2.1.3 Other possible company-level reforms
All shipping companies to track vessel facilitation payments: This can be as powerful as Maersk’s experience: we understand that some other companies are already doing this.
Building the confidence of Captains to negotiate: As in so many sectors, the key people don’t talk about this subject. Corruption is not taught at marine school. Corruption faces the Captains daily, yet no-one says a word about it at school. The first step can be so ‘easy’ as to bring the topic into open, easy discussion. Of course, it’s not really easy, but with the right atmosphere and interpersonal skill this can open up the whole conversation. One unpublished study of Captains being asked for bribes found that 78% did pay up, 22% did not pay up. The key differentiator was whether the Captain had training in such negotiations. (Personal communication to author from Bruce Horovitz).
The Maritime Anti-Corruption Network (MACN), consisting of shipping and freight-forwarding companies, and some key ship investors, has grown over five years from around 20 members to over 70. The MACN launched its first Collective Action project in Nigeria in partnership with the UN Development Program (UNDP) in 2012. It combats corruption in major Nigerian ports, where vessels have often been met with demands for facilitation payments by port officials. Nigeria’s government and the companies involved both acknowledged the problem and their commitment to resolve it. Below is MACN’s diagrammatic representation of improvement at two levels improving corporate practices makes it easier for the individual Captains to say no to demands in ports. At the same time, working to improve the operating environment makes it easier for the whole sector to strengthen the anti-corruption environment and to change practices.
Relevant government agencies are now collaborating with the MACN to generate training, standard operating procedures covering the actions of vessel officers and port officials during port calls, a formal complaints process, and enhanced cooperation between various agencies. The UNDP has contributed funds and other resources to the project, which has also received support from the UK government, for example. The key aim of the MACN project is to achieve effective collaboration between government agencies and companies to eliminate corruption by employing simple practical tools and processes.
Shipping companies complain that they almost systematically need to bribe ports or customs officials to be able to enter ports and clear their shipment. In the port of Maputo for example, 53% of all shipments involve bribery. Reducing the demand-side for bribes and facilitation payments coming from ports and customs must therefore be addressed to reduce corruption in the industry.
Experiences from certain ports have shown that some measures can significantly reduce bribery and improve waiting times in ports and customs. These include Online processing of clearance documentation; Development and clarification of standard operating procedures (SOPs) of port stakeholders; Establishment of a port-level complaints mechanism for potential and actual acts of corruption; Introduce inspectors’ rotation in ports and terminals to hinder collusion and development of improper arrangements; Automation of customs administration.
Institutional reforms, particularly combined with increased levels of automation, have had the further effect of reducing opportunities for corrupt officials to demand bribes. The importance of automation in the context of bribery and corruption was illustrated in an investigation into bribes paid at the ports of Durban in South Africa and Maputo in Mozambique (On the Waterfront: An Empirical Study of Corruption in Ports by Sandra Sequeira and Simeon Djankov, December 2008). The study highlighted the degree to which the level of automation had an inverse correlation with propensity to demand bribes. In Maputo, 80% of bribes were paid to customs rather than port authorities. The customs service in Mozambique is an arm of government and its processes lack automation, in contrast with the privately managed port. The situation in Durban is reversed, with customs authorities run by an independent regulator that has implemented a high level of automation. (Bray 2013)
Example: Port reform in Argentina. The shipping industry operating in Argentina is facing specific challenges regarding the inspections of holds and tanks, custom declarations, and on board-practices. Data from shipping companies highlighted a systemic issue with demands for payment for unclean gran holds, including cases of extortion. New regulations were drafted to improve specific areas: approval of a vessel’s holds or tanks for the loading of agricultural products, development of new IT system for processing and registering holds/tanks inspections. The regulation more specifically: Limits inspector’s discretion by having more precise definitions and objective criteria for holds or tanks rejection; Introduces inspectors’ rotation in ports and terminals to hinder collusion and development of proper arrangements in certain ports and client interactions; Increases the timeframe allowed for remedying hold’s deficiencies; Strengthens control mechanism by creating a new Technical Appeals Tribunal, developing a risk matrix on the basis of which inspections will be supervised and establishing a trustworthy whistleblowing hotline (Business for Social Responsibility 2016).
Example: European port reform. There is very little literature regarding corruption and bribery risks in European ports, though Captains report that occasionally European ports do require payments, e.g. in Spain (Personal communication). However, some ports have taken initiatives to reduce the risk of bribery (Control Risks, European ports): In 2012, the Port of Rotterdam signed a Letter of Commitment to the UN Global Compact, one of the principles covering anti-bribery; The Hamburg Port Authority has formed an anti-corruption committee to combat bribery; Ukraine introduced an electronic cargo clearance system to reduce bribes.
More port reform examples from Cameroon, Nigeria, South Africa
One stop shop for clearance in Cameroon. The automation of customs administration and introduction of a ‘one-stop shop’ for clearance procedures at Douala port in Cameroon led to a reduction of average customs clearance time from 15 days in 2000 to just over three days in 2009, according to a 2011 World Bank working paper. (Bray 2013).
Example: Use of the ‘landlord model’ in Nigeria. any countries in sub-Saharan Africa are starting to seriously address the infrastructural and institutional deficiencies within the ports sector, in line with growing awareness of the importance of facilitating trade. Institutional reform of the ports sector, spearheaded particularly in Nigeria, has led to increasing use of the ‘landlord’ model of port management, which is widely regarded as the preferred institutional set-up for the sector. Under this model, the public-sector withdraws from cargo-handling operations, allowing these to be concessioned to the private sector. In line with these changes, many customs administrations are in the process of being reformed, with systems becoming increasingly automated and some functions subcontracted to the private sector. This has brought significant improvements in operational efficiency at certain ports. (Bray 2013)
Example: Port reform at Douala, Cameroun. In line with the landlord model described above, ports in these three countries have started to automate customs administration and subcontract some functions to the private sector. At Douala port in Cameroon ‘the automation of customs administration and introduction of a “one-stop shop” for clearance procedures led to a reduction of average customs clearance time from almost 15 days in 2000 to just over three days in 2009, according to a 2011 World Bank working paper’ (Control Risks, African ports).
Example, Port reform at Durban, South Africa. ‘The importance of automation in the context of bribery and corruption was also illustrated in a 2013 investigation into bribes paid at the ports of Durban in South Africa and Maputo in Mozambique by Seiqueira and Djankov (2013). The study highlighted the degree to which the level of automation had an inverse correlation with propensity to demand bribes. In Maputo, 80% of bribes were paid to customs rather than port authorities. The customs service in Mozambique is an arm of government and its processes lack automation, in contrast with the privately managed port. The situation in Durban is reversed, with customs authorities run by an independent regulator that has implemented a high level of automation’(Control Risks, African ports).
Example: Port reform in Nigeria. Nigeria is considered one of the most challenging countries to do business due to systemic corruption. MACN supported a pilot project run together with local authorities and UNDP. The aim was to identify and address vulnerable elements in vessel port call processes where corruption is prone to take place. This included improving and harmonising public officials’ port clearance procedures. A new complaint mechanism enabled companies to file a complaint when faced with improper demands from government officials. Anti-corruption training of selected officials was conducted, and anti-corruption policies were developed for all relevant agencies (See Maersk website).
There is some sense that enforcement action is becoming more prominent in shipping sector. Here is a report by a law firm on Bribery and corruption in the shipping industry regarding the prosecution of a Shipping Marine Surveyor in Singapore (Norton Rose Fulbright 2015).
Enforcement action in Singapore
The case in Singapore concerned bribery charges against Syed Mostofa Romel (the respondent), an associate consultant in the marine surveying business of PacMarine Services Pte Ltd. The respondent was responsible for conducting inspections of vessels seeking to enter an oil terminal, which involved ensuring vessels were sea-worthy and free of any high-risk defects; ensuring cargo was properly documented; and ensuring vessels had correct documentation. On three occasions, the respondent solicited bribes from ship masters in return for submitting false inspection reports that would allow the vessels to enter an oil terminal. The respondent was charged with three offences under Singapore’s Prevention of Corruption Act (PCA) – two charges were proceeded with and the remaining charge was taken into consideration when sentencing.’
In some waters, such as the Gulf of Guinea, there are not only corruption threats to shipping but also security issues of drug trafficking, human trafficking, oil theft and piracy. In such environments local and regional navies are taking a more active role than in the past. This, however, also has counterproductive, as those same naive become a predatory force on commercial shipping. In some regions large scale efforts are being made to tackle this. One example is in West Africa, where AFRICOM is working with the Nigerian navy, Nigerian maritime police, the Nigerian Maritime Administration and Safety Agency, the Economic Crimes Commission and others to strengthen the Rule of Law in territorial waters. A second initiative, the Africa Maritime Law Enforcement Partnership (AMLEP) has similar objectives in the same region. (For details, see Ostensen et al 2018).
Make use of national embassies to assist resolving ports disagreement. One of the lessons from Maersk’s experience is that having a local office in the country is important. They know how to peacefully resolve disagreements, such as over facilitation payments. Most shipping companies do not have such local networks. One possible alternative is to see if the national embassy can assist, or if one embassy could assist on such shipping matters on behalf of as number of different national shipping companies.
Establishment of a ‘Port Integrity Index’. Ports are often competing against each other within specific region. This is the case of the ports of Maputo and Durban for example. Creating a ‘Port Integrity Index’ aiming to identify ‘corrupt-free ports’ could encourage ports to develop appropriate mechanisms and reforms to reduce corruption. Sequeira and Djankov (2013) have demonstrated that firms travelled on average an additional 319kms (in some cases almost doubling their transport costs) just to avoid coercive corruption at a port. This is explained by the ‘extreme aversion shipping companies have to the uncertainty surrounding bribe payments at the most corrupt ports’.
Political & Tactical Approaches - Guidance summary
This is the political, judgemental, tactical part of the strategy formulation exercise. It starts with how to shape the overall approach. Would it be most effective to mainstream the anti-corruption improvements within a larger improvement initiative? Or to adopt an incremental approach, keeping the anti-corruption measures below the political radar? Or tackle just one vital aspect of the corruption problem so as to concentrate effort and have a visible result? Would the organisation’s output be better if the overall anti-corruption approach was framed as integrity-building, as confidence-building, or directly as confronting corruption? The actionable reform approach will be more political, more contextual and more time-bound than individual measures; how to build support, how to spread the benefits, how to bring opponents on board or how to outflank them.
We suggest that you – in collaboration with those who might also own the reforms with you – start out by examining these eight possible approaches: Broad approach; Narrow approach; Low-profile approach; Rapid & radical approach; Signature-issue approach; Bundling approach; Keeping-up-hope approach.
Issues to consider include:
You can read more guidance on Political & Tactical Approaches here.
In shipping, reform initiatives separate into the three scales that we mentioned in Section 2:
Transnational initiatives - Guidance summary
Review what international sector efforts are active in tackling corruption in your sector. They may be sources of knowledge, ideas, support and assistance in the development of your initiative. Sector-specific organisations include:
Non-sector-specific organisations also have sector knowledge. These include:
However, unlike many other sectors, shipping does not have strong trans-national organisations.
The most extensive and active trans-national anti-corruption initiative in shipping is MACN, already discussed above.
Besides MACN, the not for profit due diligence organisation TRACE is active in shipping. TRACE (from their website) conducts the following activities: Partner with leading shipping and freight forwarding organizations to raise anti-bribery compliance standards in the industry, Conduct specialized training and host industry webinars for global shipping and freight forwarding companies, Provide industry intelligence via articles in leading maritime, shipping & logistics magazines and public presentations at major industry events, and Facilitate knowledge sharing and benchmarking through the TRACE Anti-Bribery Customs Working Group. (TRACE maritime website). Collectively, TRACE proposes that shipping companies should develop a « whistleblowing hotline »; visual anti-bribery campaigns, for instance posters in several languages announcing, “Don’t Ask; We Don’t Bribe; We Report” displayed on vessels”; Common Anti-Corruption Principles (already developed by the MACN Network); Capacity-building/best practice/information sharing seminars; and avoidance of ports, to the extent possible, known for high levels of bribery and corruption.
The International Maritime Organisation (IMO) appears to do little in relation to corruption. They are currently being criticised for opaque decision making and an excessive level of private industry influence. For further information on this, see the reports from Transparency International (2018) and InfluenceMap (2017), and this 2021 NY Times article: “Tasked to fight climate change, a secretive UN Agency does the opposite” here.
The World Customs Organisation’s website states that it is very active on integrity and anti-corruption: ‘For more than a decade the WCO has played an active and key role in addressing the complex problem of corruption in public service and more specifically in Customs. ..
then WCO’s integrity strategy and programme has progressed. An institutional mechanism such as an Integrity Working Group, currently Integrity Sub-Committee was established and supporting instruments such as WCO Integrity Self-Assessment Guide… as well as the WCO Integrity Action Plan were developed…To assist Members in implementing the Revised Arusha Declaration, the WCO has developed the Integrity Development Guide as a comprehensive integrity tool set, and reviewed it again in 2020 (here). The World Customs Organisation WCO (2019) now has an online ‘Integrity Development Tool” available (here), including a compilation of good customs integrity practices from some 20 countries.
There are many member-based shipping industry organisations, such as Intercargo, Intertanko and ship- owners’ associations, though we are not aware of transnational action on corruption. One organisation that does connect to the topic is BIMCO, a large shipping industry membership organisation comprising shipowners, operators, managers, brokers and agents.
More about Shipping organisation BIMCO
The BIMCO Anti-Corruption Clause is designed for use in both voyage and time charters and sets out a series of steps that contracting parties can follow in co-operation to resist unlawful demands. Should these steps fail, a number of options are available through the clause, with termination by either party being the ultimate sanction. The termination option has a high threshold in order to avoid misuse such as an easy way out from an inconvenient charter. Recognising the challenges that the industry is facing from corruption, the IMO Committee, member states and organisations have decided to strengthen the work against corruption and propose ways to do so, ahead of the next IMO Facilitation Committee meeting.’ (From their website BIMCO)
Maritime Fairtrade is routinely highlighting progress and issues in addressing maritime corruption. See for example correspondent Lee Kok Leong’s 2019 interview with Mark Pyman of CurbingCorruption, here , with Alexandra Wrage of TRACE, here., and on application of new technology such as Blockchain to raise the integrity of Port operations, such as in Singapore in 2020, here. Their well-informed special correspondent for anti-corruption is Lee Kok Leong.
The Bank has been active in addressing corruption in shipping and the related topic of customs reform and border reform.
Contacting others really helps because corruption is a tough problem, with no ‘manual’ of how to go about tackling it. It is not just a ‘nice thing’ to do.
We find that others working in their sector round the world – whether it be a very public sector like health or a more private sector one like telecommunications – are open to being contacted and happy to respond. People everywhere really hate corruption, and this is why you’ll find lots of support for your reform ideas.
Professionals in each sector know that much of the corruption reform available guidance is generic, in reports or in the form of technical advice from institutions. They’ll be happy to get down to sector level actions, where the real impact of corruption issues is usually seen.
Here’s what we suggest:
Contacting others also has a second benefit. Most of us who are involved in efforts against corruption, whatever their country or sector, are nervous of whether our anti-corruption ideas are plausible. Officials are aware they have no deep knowledge of how to tackle corruption and have less time to spend on this than they would like; so they are lacking in confidence. The best way to gain confidence is to talk with other people who also understand the problems in your sector.
We suggest the Maritime Anti-Corruption Network website: http://www.maritime-acn.org/, some of their reports, e.g. the 2019 Impact report, the Deloitte 2015 report on Fighting Corruption in the Maritime Industry: what you need to do to navigate in transparent waters and the article Businesses in dilemma over corruption in African ports by John Bray (2013).
Shipping sector: Bibliography
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Bray, John (2013) Business in dilemma over corruption in African ports. Control Risks. http://africanbusinessmagazine.com/features/diplomacy/businesses-in-dilemma-over-corruption-in-african-ports
Business for Social Responsibility (2016) MACN impact report 2016. https://www.bsr.org/our-insights/report-view/macn-impact-report-2016
Business for Social Responsibility (2014) Corruption Risk Assessment in the Nigerian Port Sector: MACN Executive Summary. https://www.bsr.org/reports/BSR_MACN_Summary_Corruption_Risk_Nigerian_Ports.pdf
Deloitte (2015) Fighting Corruption in the Maritime Industry: what you need to do to navigate in transparent waters, Report by Deloitte India, July 2015. https://www2.deloitte.com/content/dam/Deloitte/in/Documents/finance/in-fa-fighting-corruption-in-maritime-industry-noexp.pdf
Durrani, Amer, Prokop, Michaela and Zarnowiecki, Michel (2011) Integrity risk modelling in the border management context. Chapter 20 in Border management modernisation, edited by McLinden et al (2011), World Bank. https://openknowledge.worldbank.org/bitstream/handle/10986/2544/588450PUB0Bord101public10BOX353816B.pdf?sequence
G20 Germany Business 20 Dialogue (2017) Promoting Integrity by Creating Opportunities for Responsible Business, B20 Cross-Thematic Group, Responsible Business Conduct and Anti-Corruption. https://www.b20germany.org/fileadmin/user_upload/documents/B20/b20-ctg-rbac-policy-paper.pdf
InfluenceMap (2017) Corporate capture of the International Maritime Organisation: how the shipping sector lobbies to stay out of the Paris Agreement.https://influencemap.org/site/data/000/302/Shipping_Report_October_2017.pdf
Lysova, Katya (2016) Commitment to Compliance: Countering Bribe Demands in Customs and Ports. Breakbulk Magazine (Issue 3, 2016). https://issuu.com/breakbulk/docs/2016_issue_3_issuu/73
McLinden, Gerard, Fanta, Enrique, Widdowson, David and Doyle, Tom (2011) Border Management Modernisation, World Bank. https://openknowledge.worldbank.org/bitstream/handle/10986/2544/588450PUB0Bord101public10BOX353816B.pdf
Norton Rose Fulbright (2015) Bribery and corruption in the shipping industry.http://www.nortonrosefulbright.com/knowledge/publications/132269/bribery-and-corruption-in-the-shipping-industry
Ostensen, Arse, Brady, Sheelagh and Schutte, Sophie (2018) Capacity building for the Nigerian navy: Eyes wide shut on corruption? U4
Pyman, Mark (2019) Winning the war against maritime corruption. Interview with Lee Kok Leong of Maritime Fairtrade, February 25, 2019. https://maritimefairtrade.org/exclusive-2-part-series-winning-the-war-against-maritime-corruption/
Pyman, Mark (2019) From Maersk, AEC, and Shell, inspiring stories about changing corporate behaviour. The FCPA blog, 23 July, 2019. Accessed April 20, 2021. http://www.fcpablog.com/blog/2019/7/23/from-maersk-aec-and-shell-inspiring-stories-about-changing-c.html
Sampson, Helen, Acejo I, Ellis N, Tang L, Turgo N (2016) The relationships between seafarers and shore-side personnel: an outline based on research undertaken in the period 2012-2016. Seafarers International Research Centre, Cardiff, UK. Cardiff: SIRC, April, ISBN: 1-900174-48-0. http://www.sirc.cf.ac.uk/Uploads/Publications/The%20relationships%20between%20seafarers%20and%20shore-side%20personnel.pdf
Sequeira & Djankov (2013) Corruption and Firm Behaviour: Evidence from African ports. The London School of Economics and Political Science
Transparency International (2018) Governance at the International Maritime Organisation: the case for reform. https://www.transparency.org/whatwedo/publication/governance_at_the_IMO_the_case_for_reform
U4 (2013 Literature review on corruption at ports and border points in Southern Africa. https://www.u4.no/publications/literature-review-on-corruption-at-ports-and-border-points-in-southern-africa/
World Customs Organisation (2015) Guide to corruption risk mapping. June 2015. http://www.wcoomd.org/-/media/wco/public/global/pdf/about-us/legal-instruments/declarations/risk_mapping_guide_june_2015.pdf?la=en
World Customs Organisation (2017) Compilation of integrity practices from WCO members. http://www.wcoomd.org/-/media/wco/public/global/pdf/topics/integrity/instruments-and-tools/compilation-of-integrity-practices-from-wco-members.pdf?la=en
World Customs Organisation (2013) Integrity development guide. Available in Spanish or Arabic. http://www.wcoomd.org/-/media/wco/public/es/pdf/topics/integrity/instruments-and-tools/integrity-development-guide-es.pdf?la=en
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