Regulation & Governance (2012) 6, 66–82 doi:10.1111/j.1748-5991.2011.01125.x Why do anti-corruption laws fail in Central Eastern Europe? A target compliance perspective Agnes Batory Department of Public Policy, Central European University, Budapest, Hungary Abstract The Central Eastern European member states of the European Union have introduced a host of anti-corruption measures in the past two decades, yet corruption is still prevalent. Rather than asking what is wrong with the letter of the law, which has traditionally been the focus of analysis, this article identifies some of the reasons why those whose behavior the law seeks to change fail to act as expected. Drawing on theoretical insights from implementation studies and using Hungary as an illustrative example, the article finds that both incentives and normative judgments are skewed towards non-compliance with anti-bribery laws. The main policy implications are that anti-corruption interventions should pay more attention to raising awareness among target groups, take existing social norms into account, and rely on positive incentives as well as, or rather than, increasing penalties. Keywords: anti-corruption, Central Eastern Europe, compliance, implementation, target groups. 1. Introduction Corruption control has been high on the agenda in the Central Eastern European (CEE) member states of the European Union (EU) more or less continuously since the democratic transitions in 1989–90. These countries introduced a host of anti-corruption measures in the past two decades, ranging from penalizing various conducts previously not recognized as criminal, to setting up specialized anti-corruption agencies, courts, and/or prosecution services. Other legislation essential or conducive to transparency and public integrity, such as freedom of information laws (Peisakhin & Pinto 2010), were also adopted – many already in the 1990s. Efforts to reform and modernize the civil service started in some countries in the mid-1990s, and became common in preparation for EU accession (e.g. Meyer-Sahling 2004). The large-scale privatization of state assets, generally seen as a hotbed of corruption, was completed some time ago in most CEE countries. Electoral accountability is firmly entrenched, with at least five or six rounds of elections having taken place since regime change. Almost all resulted in changes of government, often as a result of voters punishing politicians seen as enriching themselves at the public’s expense. According to monitoring reports by the Council of Europe’s Group of States Against Corruption (GRECO), most of the countries in question have legislation in Correspondence: Agnes Batory, Department of Public Policy, Central European University, Nador u. 9, 1051 Budapest, Hungary. Email: [email protected] Accepted for publication 12 December 2011. © 2012 Blackwell Publishing Asia Pty Ltd Why anti-corruption laws fail A. Batory place that largely conforms to the relevant international standards (GRECO 2010; see also Wolf 2010). The international NGO Global Integrity’s expert surveys also rate the legal framework as strong in Poland, Hungary, or Romania – similarly to the longer-standing ten EU countries surveyed (Global Integrity 2010). Yet corruption – defined in the simplest terms as the abuse of public power for private gain – remains a widespread and persistent problem in the CEE member states. This is not to say that the 10 EU countries that joined the Union in 2004 and 2007 are all equally corrupt, or that they are the only ones affected among the member states – indeed, Italy and Greece, for instance, both score lower on integrity in Transparency International’s (TI) Corruption Perception Index (CPI) than the majority of the “new” EU member states (TI 2010a). Perceptions-based macro indicators of corruption are not without serious methodological limitations (see e.g. Sampford et al. 2006). However, frequent media reports featuring the disappearance of EU funds in Bulgaria or Romania, politicians embroiled in graft resigning (or refusing to resign) in Poland or Hungary, or bribes extorted by Czech traffic police, lend credibility to the indices to those familiar with CEE. Moreover, experience-based surveys strongly correlate with perceptions (TI 2007). According to the 2010 Global Corruption Barometer, conducted by Gallup for TI, an average of almost 17 percent of respondents from nine new member states reported having paid a bribe in the past year, as compared with 0 percent in Denmark, for instance, and the average was 5 percent in the EU plus Norway and Switzerland (TI 2010b). Thus, those who had expected that corruption, fed by the general chaos of the years following regime change in CEE, would be substantially reduced, have been disappointed; in spite of the wide range of control efforts, corruption remains stubbornly widespread in most countries in the region. Why is this the case? There are naturally several possible answers to this question (the relevant literature is briefly reviewed in the section below). In some ways the most obvious one is that the existing laws are insufficient – a typical reaction of policymakers all around the world, which normally, as in the CEE countries, results in more and more legislation passed and layer upon layer of controls added to existing ones (Anechiarico & Jacobs 1996). In the CEE cases, this knee-jerk reaction was reinforced by EU membership conditionality. The adoption of new laws was often the only available signal to send to Brussels that the given candidate country was committed to addressing the European Commission’s concerns in the area (see generally Schimmelfennig & Sedelmeier 2005). However, an equally likely and, for those familiar with CEE, more plausible answer is that the existing laws affect only limited change on the ground – or, put differently, that policy design problems are compounded by a very evident implementation problem. Indeed, Global Integrity’s expert surveys find that relatively strong legal frameworks in corruption control go hand in hand with serious deficiencies in practice, thereby pointing to a large (and in the case of some countries, huge) implementation gap (Global Integrity 2010). There are many things that can go wrong with policy implementation (see e.g. Mazmanian & Sabatier 1989; Hill & Hupe 2002). Among the many possible factors, this article focuses on target compliance, an aspect hitherto curiously under-utilized in the literature dealing with corruption control in CEE. Rather than asking what is wrong with the letter of the law, this article aims to identify some of the reasons why those whose behavior the law seeks to change fail to act as expected. In doing so, it draws on the implementation/compliance literature and applies some common insights to corruption control. It needs to be stressed that a target compliance perspective alone clearly does not, © 2012 Blackwell Publishing Asia Pty Ltd 67 A. Batory Why anti-corruption laws fail nor can it be expected to, provide “a solution” to reducing corruption, or fully explain cross-country variation in levels of corruption. The contention of this article is merely that compliance is a hitherto relatively neglected aspect of the problem which can nonetheless make a useful contribution to the literature and also yield new policy implications. The empirical focus is narrow: only one country, Hungary, is considered as an illustrative example, and the focus is on laws where the target group is the citizenry as a whole (rather than civil servants, or law enforcement officials, or politicians). While the usual methodological limitations arising from a single country as an illustrative case apply, Hungary as a medium-corrupt post-communist member state can be considered sufficiently similar to other CEE EU countries to expect the findings to be relevant for the region more broadly. The country is also a clear example of the paradox described above, in that although its legislative framework against corruption is rather well-developed, neither perception-based indicators such as the CPI nor survey data on citizens’ experiences with various forms of bribery in daily life show any significant improvement in the last decade. The paper proceeds from Section 2 linking the literatures on (anti-) corruption and policy implementation, and provides a framework for analyzing the empirical material on Hungary. Section 3 reviews instrumental sources of (non-) compliance and Section 4 normative sources in light of the Hungarian experience. A brief conclusion summarizes the findings and some of the most evident policy implications. 2. Why do anti-corruption efforts have limited success in Central Eastern Europe? The literature dealing with policy failure in corruption control is considerable (although the findings are rarely expressed in these terms). One common answer points to the problem of agency or, as often put, the lack of political will: effective reforms to combat corruption would need to be initiated by the very actors who are argued to benefit most from the existing, corrupt status quo, and therefore no real effort is made (see e.g. Levin & Satarov 2000, p. 130; Fritzen 2005, p. 81; Mungiu-Pippidi 2006, p. 87). Others point to the legacies of the past regimes, in particular the persistence of “bad” social capital. Informal networks inherited from communist times – initially formed as a coping strategy in what Kornai coined “the economics of shortage” (1980) – are argued to give rise to cronyism, nepotism, and patronage, and to an unhealthy symbiotic relationship between business and politics (see e.g. Ledeneva 1998; Miller et al. 2001; Karklins 2005). Yet another, and perhaps a more pertinent, answer can be distilled from the literature that looks at EU rule transfer to CEE. Although these studies do not deal with corruption specifically or with legislation of domestic origin, the observation that in CEE laws in books often fail to be translated into laws in action can be considered to be generally applicable. One line of argument to explain this, is that prior to accession laws were adopted mainly to please the EU, and, therefore, once membership conditionality no longer provides the right incentives to CEE government reforms of any kind are likely to run out of steam (Steunenberg & Dimitrova 2007; Moroff & Schmidt-Pfister 2010; Haughton 2011). Another line of argument relates to (non-)implementation more directly. Falkner and Treib’s study on the implementation of EU social policy describes CEE as “the world of dead letters” (2008). It finds that contrary to earlier expectations that following accession these countries would fall behind, on the transposition of EU legislation the new member states do no worse than the old ones (a finding Epstein & 68 © 2012 Blackwell Publishing Asia Pty Ltd Why anti-corruption laws fail A. Batory Sedelmeier (2009) concur with), but the transposed legislation has little effect. Dimitrova similarly concludes that “European rules remain empty shells” in the new member states (2010): although the new rules are formally adopted, in practice they are ignored and/or substituted with parallel informal rules. The corruption and EU rule transfer literatures provide important insights, and the intention here is not to dispute their findings. However, the conclusions tend to be rather broad brush and are not (and often not meant to be) actionable. For instance, MungiuPippidi’s (2006, p. 87) analysis asserts that “nothing short of . . . a revolution [against particularism] will succeed in curbing corruption in countries where particularism prevails”. Levin and Satarov’s study on Russia suggests that “the norms of behavior are needed to be changed so that corruption will not be viable” (2000, p. 130). As Rothstein (2007, 2011) put it, in countries characterized by systemic corruption the problem is that almost everything needs to change, and needs to change more or less simultaneously in a “big bang”. Much of this literature responds to the “governance turn” in corruption studies, that is, the idea that corruption is only one of many symptoms of the dysfunctionality of the state and of state–society relations, and therefore only a holistic approach drawing on government and non-governmental actors alike can be hoped to produce any change (see e.g. Andvig et al. 2000 for a review of the literature). In the EU rule transfer literature, Dimitrova’s (2010) main diagnosis for the general weakness of policy implementation in CEE is the weakness of the state and its institutions, which leaves space for informal networks to emerge and take over some of the state’s functions. Falkner and Treib (2008) list the weakness of civil society, the judiciary, and of human and material resources in enforcement agencies, among others, as main reasons for the (non-)implementation of transposed EU social policy legislation. While these observations would be difficult to disagree with, the policy implications are less clear. Clearly, the large-scale shifts in “soft” institutions (social norms) governance accounts call for are indeed necessary. However, they can only work in the long run – and the short time horizons even well-intended policymakers subject to electoral pressures work with make them difficult to act upon. Similarly, strengthening formal institutions or organizational responses, as the EU rule transfer literature suggests, is often not possible: severe resource constraints being the rule rather than the exception. Nor is it always sufficient: for example, setting up anti-corruption agencies is not the magic bullet many had assumed it would be (Batory forthcoming). Moreover, by focusing exclusively on the failures of governments and public administrations even the policy-oriented literature tells only part of the story. The machinery of the state that is meant to deliver particular policy outcomes is one side of the picture – the other side is that of the citizens who deal with the state. If more is known about why target groups act, or fail to act, in line with the objective of a particular policy then better policy interventions can be designed. This is the main objective of the target compliance literature. Although compliance and implementation often blur into one another, the two terms also convey distinct meanings: while the latter refers to the process in which a given norm is put into practice, the former denotes the conformity of behavior with a prescribed rule (rule conformity) and its main concern is outcome (Treib 2008, p. 4). Implementation does not necessarily result in compliance as the discussion below also illustrates (see e.g. Mazmanian & Sabatier 1989, p. 36; Treib 2008, p. 4). © 2012 Blackwell Publishing Asia Pty Ltd 69 A. Batory Why anti-corruption laws fail Target compliance is somewhat under-appreciated in the burgeoning implementation literature. Particularly in the EU context, implementation is typically studied in terms of transposition, that is, the adoption of laws, not in terms of change on the ground (Treib 2008). Even in domestic implementation studies, the focus tends to be on the state apparatus, whether on high-level decision-makers and the chain of command in “topdown” implementation studies, or front-line staff (Lipsky’s (1980) street-level bureaucrats) in “bottom-up” studies. Less attention is paid to the circumstances and perceptions of those whose behavior the implemented policies intend to change. For example, Howlett and Ramesh’s (1995) textbook on the policy cycle mentions target groups only in passing in the chapter dealing with policy implementation. Weimer and Vining (2005) discuss a case of obstruction by local government officials as an illustration of implementation problems. Only one chapter (Ingram et al. 2007) deals with target groups in Theories of the Policy Process, edited by Sabatier (2007), a key reference work in policy studies, and the focus there is on how different social constructions of target groups are reflected in policy design. Hill and Hupe’s (2002) volume, devoted entirely to implementation studies, does not deal with target groups or target compliance. This gap in the literature has led some scholars to call for a more “democratic” approach to implementation; that is, one where “the affected parties” feed into the policy process (deLeon & deLeon 2002, p. 483). Nonetheless, a body of literature dealing with target group behavior per se does exist, albeit the topic is approached from very diverse angles. Work ranges from Tyler’s (1990) classic Why People Obey the Law on procedural justice and Kelman and Hamilton’s (1989) Crimes of Obedience on the problems of unquestioning compliance, to journal articles on smoking bans in Tobacco Control. All of this work, in very different ways, deals with the question why citizens, companies, or other actors whose cooperation is required for a particular state objective, respond to obligations in particular ways. A number of studies that are especially relevant here discuss target compliance in generic terms. Feldman (2011) distinguishes five sets of assumptions about what motivates citizens’ reactions to regulation. The first is based on cost–benefit calculation; the second on “reason-driven” conviction about the wisdom of following a particular course of action; the third the conviction that the prescribed behavior is the social norm; the fourth on fairness and morality; and finally, the fifth on simply abiding by the law. Weaver (2009) identifies six sets of factors underlying program targets’ failure to act as expected by the policymaker: wrong incentives; monitoring problems; resource, autonomy, and information problems (the targets lack the resources/power/information to comply even if they want to); and attitude problems (the targets are hostile or distrustful). These partially overlapping sets of factors can be tied to instrumental and normative perspectives: the former premised on the idea that people act as dictated by self-interest and therefore their behavior can be influenced by a combination of carefully selected rewards and punishments, and the latter on the idea that people are influenced by their moral judgments (Tyler 1990, pp. 3–4). Accordingly, in the following, compliance with anti-corruption laws will be discussed as a function of incentives (including monitoring, enforcement, autonomy issues, and information effects) on the one hand, and as a function of social norms and legitimacy on the other. It is important to stress that instrumental and normative sources of (non-)compliance should not be seen as mutually exclusive; rather, target groups’ failure to “behave” as expected is a result of a mixture of 70 © 2012 Blackwell Publishing Asia Pty Ltd Why anti-corruption laws fail A. Batory both sets of considerations. Which type of motivation is stronger in any given situation is highly contextual and should therefore be seen as an empirical question. 3. Compliance with anti-corruption laws: Instrumental motivations Before the empirical material on Hungary is discussed, a few brief remarks seem to be in order about the specific properties of corruption that make acceptable levels of compliance particularly difficult to achieve. First, as with other illicit conducts, corruption takes place in secret, and corrupt officials will do their best to appear to act “normally,” which makes monitoring an obvious challenge (see e.g. Gambetta 2002). Second, corruption is often described as a victimless crime, in that the social costs (in terms of public finances, declining trust in public institutions, etc.) are so widely spread as to be unnoticeable to the individual. In contrast, in the case of a “successful” corrupt transaction, often each direct participant feels they are better off than before. For instance, a civil servant may supplement his modest salary with a little “extra,” his client, not having to go through the official (legal but cumbersome) channels, saves a lot of time and hassle, and both parties consider this a fair deal. These features mark out corruption as a classic collective action problem (Olson 1965): the social costs are high but diffuse and often no immediate personal utility can be realized from not corrupting/being corrupted, which makes the phenomenon particularly “sticky.” The typical reaction from policymakers to such social problems is deterrence, that is, to try to change the individual’s strategic calculus by increasing the costs of socially harmful behavior as well as the likelihood that those costs will indeed need to be borne (Mazmanian & Sabatier 1989, p. 37). In the anti-corruption literature some of the most influential early work follows the same logic when for instance Klitgaard (1988, p. 71) argues that the decision of an “agent” to be corrupt or not is a function of her utility from the moral satisfaction she gets from not engaging in corruption and her salary on the one hand and the size of the bribe and of the penalty and the probability of getting caught on the other. Although not mentioned in this “decision tree,” being aware of all the factors (the ability to attach a price tag) and having the freedom to decide are preconditions for the model. Accordingly, the following sections review the situation in Hungary in terms of penalties, monitoring (detection), autonomy issues, and information effects. 3.1. Penalties Looking at penalties alone, Hungary seems to be reasonably well equipped to deter corruption. Sixteen types of corruption-related conducts are penalized in the Criminal Code, in addition to crimes such as money laundering or embezzlement that are often associated with corruption (Földes 2010, pp. 4–8). Criminal law punishes bribery (domestic and foreign, active, and passive, and in the public and the private sectors) as well as trading in influence and abuse of authority. The penalties are not negligible: public officials requesting or accepting an “undue advantage” (passive bribery) commit a felony punishable by up to ten years’ imprisonment in certain circumstances. Active bribery (offering or promising an undue advantage to a public official) carries up to five years. However, the chances that anyone engaging in these practices would actually face the consequences are rather slim. Criminal statistics for 2009 show 1,237 registered investigations in corruption-related cases, or less than 0.03 percent of all investigated crimes in a country of approximately ten million (Földes 2010, pp. 19–20). According to an esti© 2012 Blackwell Publishing Asia Pty Ltd 71 A. Batory Why anti-corruption laws fail mate by a public prosecutor, indictment occurs in only about one out of a thousand corruption crimes actually committed (referred to in Papanek 2009, p. 8). Since 2005, the number of finished court proceedings and resulting convictions has varied between 200 and 500, with only 200 cases closed in 2009 – indicating both that the number of court cases overall is quite small and that proceedings often take a very long time to complete (Földes 2010, pp. 19–20). Moreover, the vast majority of the cases concern street-level corruption where only small amounts of money change hands: according to a study, in more than half the cases the value was less than 100 euros worth of Hungarian forint (K-Monitor 2010). Partly arising from this, relatively lenient penalties such as fines or suspended prison sentences are relatively common (K-Monitor 2010). This also suggests that the enforcement of the law is particularly weak with respect to the high-value, high-level corruption cases that receive most media attention. Low detection and conviction rates are undoubtedly at least partly due to the usually cited reasons such as overburdened and slow courts and under-resourced law enforcement agencies, where badly paid officers investigate corruption cases, sometimes without sufficient training and specialized expertise (Kósa & Alexa 2007). However, another, less recognized reason is equally important: the relatively limited likelihood that corrupt conduct comes to light. 3.2. Monitoring (detection) The general difficulty of uncovering corruption, as noted above, is certainly borne out by the Hungarian experience. Law enforcement agencies and policymakers also recognize that the number of cases coming to light is only the tip of the iceberg, and have accordingly tried to pursue some of the available strategies to increase detection rates – although not necessarily the appropriate ones. Common measures to improve monitoring include increasing the resources devoted to agencies charged with the task or, failing that, providing incentives to particular target groups to disclose relevant information (Weaver 2010, p. 16). With respect to the former, the police budget is tight – given general budget constraints perhaps not surprisingly – but inefficient use of existing resources is also an important problem (Kósa & Alexa 2007). With respect to incentivizing reporting, policy-makers tried to influence the behavior of those judged most likely to encounter corruption, that is, civil servants, but the instrument chosen for this is rather blunt. Public officials have a legal obligation to report corruption, and failure to do so is a felony punishable with up to three years of imprisonment (Burai 2010, p. 4). Yet criminal statistics show essentially no reporting by civil servants, and equally, no prosecutions of civil servants failing to report – that is to say, the purported policy response to addressing low detection rates falls victim to the same reasons that caused the original monitoring problem. There have also been attempts to incentivize reporting by those engaged in corruption. Similarly to strategies employed by competition agencies for cartel busting, parties to corrupt transactions are encouraged to defect by an “effective regret” provision in the Criminal Code (Section 255/A) that offers impunity to perpetrators for disclosing bribery before the investigating authorities uncover it, regardless of the motive for such disclosure (GRECO 2010, p. 23). The measure however did not result in any change in the number of registered cases of corruption crimes (Ministry of Justice 2010, p. 25), at least in part because the perpetrators in question probably judged the risk of detection fairly low in any case. Moreover, the fact that the motive for reporting is irrelevant may 72 © 2012 Blackwell Publishing Asia Pty Ltd Why anti-corruption laws fail A. Batory even be counterproductive in the case of crimes which would be revealed in some other way. Finally, whistleblower protection can also be considered as a way of influencing the cost–benefit calculus of individuals (whether public officials or ordinary citizens), to report corruption-related crimes. Here the logic is somewhat different than in the cases above in that, rather than imposing a duty to report and punishing offenders, it tries to remove, or at least ameliorate, the negative consequences that would otherwise likely follow the decision to speak out. In Hungary too, since a 2004 amendment of the criminal code “ill-treatment of a person disclosing information of public interest” is an offence, punishable with up to two years’ imprisonment (Burai 2010, p. 4). However, as a TI Hungary report puts it, the provision can only be considered as dormant: it had been applied on only one occasion, and reprisals against the courageous individuals who do disclose irregularities, particularly in the form of terminating employment, are common (Burai 2010). This situation was recognized as problematic by policymakers and comprehensive whistleblower protection legislation was introduced in 2009, which also provided for the establishment of a bureau or agency to assist whistleblowers. The bill was, however, never implemented as, following a change of government in 2010, the idea of a new agency fell out of favor. Thus, in Hungary, even the best-case scenario under the law – one in which the whistleblower is at least no worse off than prior to the disclosure of wrongdoing – is not an outcome potential whistleblowers can expect in practice, not to mention being rewarded for their courage. These factors taken together mean that a cost–benefit calculus should clearly push the rational citizen toward not reporting corrupt practices: not only is the disclosure of wrongdoing potentially dangerous, but also likely ineffective in terms of getting a perpetrator disciplined or behind bars. It is consequently not particularly surprising that according to a 2007 Gallup poll, only 6 percent of respondents reported corruption when they encountered it (Burai 2010). Low detection rates in turn weaken or remove incentives for those who engage in corruption to come forward in exchange for impunity. 3.3. Autonomy issues Autonomy problems, that is, situations where target groups are unable to comply with rules and requirements even if they want to (Weaver 2009) make the likelihood of rule conformity even lower in the case of particular practices citizens encounter in daily life. A case in point is corruption in health care. The practice of giving “gratitude payments” is widespread and widely known, to the extent that people expect to have to pay for medical services supposedly covered by national health insurance contributions. Although the term suggests patients retrospectively and voluntarily rewarding kindness or especially good service, which in earlier times was indeed the practice, what happens in contemporary hospitals and doctors’ offices is not necessarily quite so benign. Payment is sometimes requested by medical practitioners before treating patients, in circumstances that make, or appear to make, the payment a condition of receiving care of an acceptable quality or in a timely manner. A website, since then closed down on data protection grounds, for instance listed the standard “fee” individual obstetricians routinely charged in public hospitals for maternity care supposedly covered by national health insurance – the site was intended to increase price transparency in this otherwise completely illicit market. © 2012 Blackwell Publishing Asia Pty Ltd 73 A. Batory Why anti-corruption laws fail Although in theory patients can always seek an alternative service provider, in practice finding another specialist or hospital is often time-consuming or it would require travel or some other additional expense or simply information patients lack, which makes gratitude payments an almost unavoidable fact of life. These quasi-extortive situations can be considered to be common: according to the 2010 Global Corruption Barometer, 26 percent of Hungarian respondents reported that either the respondent or someone in his/her household paid a bribe in some form for health care in the past year, although obviously not all of this was a result of extortion (TI 2010b). In the same survey, almost 15 percent of all respondents said they paid a bribe of some sort for a public service they were legally entitled to. In such cases the “exchange” cannot be assumed to be entirely voluntary. With respect to this subset of the target group (i.e. the victims of extortion) regular incentive-based anti-corruption interventions cannot be expected to work. 3.4. Information effects One possible partial solution to autonomy issues may be better awareness of one’s rights or existing possibilities for seeking redress. Indeed, information deficits in target groups seem to be a common obstacle to effective implementation of anti-corruption measures more widely (see generally Peisakhin & Pinto 2010). Experience with a Hungarian anticorruption legal advice clinic suggests that many citizens are unable or unwilling to distinguish corruption from other grievances they have or irregularities they come across, and those who indeed encounter corruption often simply need directing to the relevant authorities (interview with Ádám Földes, Director, Transparency International Hungary, 10 August 2011). In a 2007 Gallup poll, 69 percent of respondents said they did not know where they should turn if encountering corruption (Burai 2010, p. 11) adding another significant reason to those discussed above, explaining why reporting is so low. Even anti-corruption measures targeting a narrower segment of the population (e.g. those routinely engaging in corruption) seem to fail to register. For instance, legal practitioners believe that very few people are aware of the “effective regret” clause in the Criminal Code annulling punishment for those coming clean about their own corrupt acts (Földes 2010, p. 14). Clearly, incentive-based anti-corruption measures have no chance of inducing the desired change in behavior if they fail to be communicated, and hence never enter the target group’s cost–benefit calculation. 4. Compliance with anti-corruption laws: Normative motivations Sticks and carrots alone cannot explain human behavior. Despite weak incentives for reporting corruption, some people do; despite low risk of losing a (normally poorly paid) job in the civil service many public officials refuse to take a bribe. As Tyler (1990, p. 4) observes, many people obey the law without even entering into a cost–benefit calculus simply because they believe “the law is just,” or because they believe that “the authority enforcing the law has the right to dictate behavior.” Kelman and Hamilton (1989) suggest that obedience – the likelihood that commands or obligations are carried out or refused or overlooked in a society – is structured by the way individuals relate to political authority. Levi’s (1997) work points to the importance of perceptions of procedural fairness for people’s willingness to consent to particular policies. Feldman’s (2011, p. 338) review of motivations for regulatory compliance refers to the perceived fairness of the 74 © 2012 Blackwell Publishing Asia Pty Ltd Why anti-corruption laws fail A. Batory content of the law as well as “the perception that the law was formulated and executed with full authority.” In other words, social norms and the legitimacy of the source of legal obligations (the policymakers and implementers) have a strong bearing on rule conforming behavior. Applying these insights to anti-corruption, one condition for compliance on normative grounds would be a commonly held conviction within the target group that corruption is wrong. A second one would be the belief that this ethical judgment is widely shared and acted upon. People are “conditional co-operators:” they comply when they expect that others do too (Feldman 2011). In other words, if corruption is seen as widespread, then people are more likely to engage in it themselves – a phenomenon Rothstein and Tegnhammar (2006) describe as the “self-fulfilling character of expectations about corruption.” Finally, people may decide to comply with anti-corruption laws if they believe that the politicians enacting them and the police and judiciary enforcing them are legitimate actors rightfully demanding rule-conforming behavior. As the sections below show, at least two of these three essential conditions are problematic in the CEE context. 4.1. Social norms Undoubtedly, the majority of citizens in Hungary condemn corruption, and at least on this count normative motivations for compliance should be in line with the policy objective. However, there is a sizeable minority for whom non-corruption is not evidently accepted as the morally desirable conduct. In 1999 (the last year from which suitable data is available from the World Values Survey) about 12 percent of respondents thought it was more or less acceptable – considerably more than the corresponding figures for the “cleaner” countries of Western Europe (only 3 percent of Germans would justify the practice, for instance) or other CEE countries (World Values Survey Association 1999). More importantly, although the majority said they themselves would never accept corruption, there is a strong indication that people believed everyone else did (World Values Survey Association 1999). The relevant question on bribery was not included in the survey, but attitudes to comparable illicit behaviors such as avoiding or cheating on taxes certainly indicated a wide perceived gap between social norms and social practices. Fifty-three percent thought paying cash to avoid taxes was never justifiable – the same as those giving this answer about corruption. But when asked whether their compatriots engaged in the practice, 76 percent of respondents thought “almost all” did. Roughly the same proportion of respondents felt that cheating on one’s taxes was never justifiable, but was at the same time convinced that almost all their countrymen did cheat on their taxes (65.5 percent and 78 percent respectively). In other words, people who believed that cheating the state was wrong and avoided engaging in the practice likely considered themselves to be in a minority – which indicates anything but a strong belief in integrity as the social norm. This creates perfect conditions for the downward spiral of selffulfilling expectations about corruption can give rise to. The perception that corrupt behavior is common must be reinforced by the fact that so many prominent members of the country’s elite have been implicated, or rumored to be involved, in various scandals, without any apparent harm to their economic or political advancement. Shady deals – even when exposed – seem to be no obstacle to “making it” in business or politics, sending a signal that “the big fish” can enjoy the fruits of their illicit labors with impunity. The exceptions (corruption charges against high-profile politicians) tend to result from the predictable but normally short-lived determination of © 2012 Blackwell Publishing Asia Pty Ltd 75 A. Batory Why anti-corruption laws fail newly elected governments to use the full force of the law – against their political opponents. Surveys show many more people in Eastern than in Western Europe believe that “connections and dishonesty are the principal factors that make people wealthy” (Rothstein & Uslaner 2005, p. 55). The message to the ordinary person is that it is the rejection of corrupt practices that is an anomaly or deviant behavior. There is further indication, with respect to particular forms of corruption, that public attitudes might be a stumbling block to control efforts. As pointed out above, gratitude payments in health care represent perhaps the most common type of petty corruption, and here, to a great extent, moral judgments align with, rather than against, the practice. According to a survey conducted in 2000, only a third of the public and a tenth of the surveyed physicians felt that “accepting gratitude money is morally reprehensible,” and the majority of the medical professionals believed that “as long as the state does not pay them properly, doctors have a right to accept gratitude money” (Kornai 2000, p. 15). Low legal salaries among medical professionals seems to be an important reason for people to be prepared to condone the practice; nonetheless, the sense that there is nothing wrong with passing on or accepting some cash in an envelope for a publicly funded medical service is clearly not conducive to corruption control efforts in the area. 4.2. Legitimacy Compliance, in its most fundamental sense, is about the cooperation of the citizen with the authorities in reaching some policy objective. Target groups often do not find the objective desirable – for instance smokers are rarely pleased about the introduction of smoking bans – but nonetheless recognize that the government has the right to determine behavioral rules binding on them. However, in the CEE countries, even for citizens who recognize that corruption is harmful and find it morally objectionable the question that often arises is: who are they, our politicians, to tell us not to bribe or accept a bribe? According to the Global Corruption Barometer, Hungarian respondents rated political parties 3.9 on a scale from 1 (not at all corrupt) to 5 (extremely corrupt), concurring with respondents from around the world in finding parties the institutions most affected by corruption in their countries (TI 2010b). Moreover, in Hungary political parties flaunt their disrespect for anti-corruption laws when they themselves form the target group. Party and campaign finance regulation is weak and evidently not complied with: for instance, the two biggest parties in the 2010 parliamentary elections were estimated to spend up to three times the legal campaign spending limits (Kepmutatas.hu 2010), a fact that does not escape voters. In spring 2011, Eurobarometer showed a large majority, 59 percent of respondents, did not trust their parliament or government, roughly on par with their fellow Europeans (European Commission 2011). Attitudes to law enforcement agencies and the courts are not much more favorable. According to a 2009 Eurobarometer on attitudes to corruption, 53 percent of respondents in the new member states believed corruption was widespread in the judiciary and the police service (the same figure was 33 percent and 35 percent, respectively, in the old member states) (European Commission 2009). In Hungary, one of the reasons people cited for not reporting corruption, apart from not knowing where to report it, was fear of the police (11 percent of respondents mentioned this) (Gallup poll in Burai 2010). According to a 2005 survey, up to 26 percent of respondents thought judicial decisions 76 © 2012 Blackwell Publishing Asia Pty Ltd Why anti-corruption laws fail A. Batory could be influenced through corruption (depending on the type of court in question), and up to 45 percent thought investigators could be bought to influence judicial proceedings (Hack & Garai 2008, p. 12). There is thus little doubt that citizens believed that those expecting, or meant to ensure, rule conformity with anti-corruption laws were themselves not above breaking those laws – clearly undermining any normative commitment to compliance citizens may have had. An overview of instrumental and normative sources of (non-)compliance in anticorruption is presented below (Table 1). Table 1 Overview of instrumental and normative sources of (non-)compliance in anti-corruption Motivation of behavior Generic sources of (non-) compliance Possible general sources of non-compliance in the anti-corruption field Examples of specific compliance issues in the anticorruption field Instrumental Positive and negative incentives Weak or no penalty for corrupt behavior and/or weak or no reward for non-corrupt behavior Monitoring Low likelihood of application of penalties due to weak detection of corrupt behavior Significant part of the target group is victim of extortion Particular forms of corruption not criminalized; legal penalties for corruption crimes weak; rewards for non-corrupt behavior (even in highly corrupt contexts) not provided Low reporting of corruption (despite legal obligation to report; impunity for self-reporting etc.) Accessing public services possible only through corrupt behavior, or non-corrupt behavior extremely costly Little or no knowledge among target group of relevant legislation, their rights, or procedures for seeking redress Forms of petty corruption commonly excused or justified; widespread perception of fellow citizens commonly engaging in corruption; perception of impunity of corruption crimes Government, political parties, or individual politicians widely seen as corrupt; police and/or judicial corruption seen as common; legislative process not transparent Autonomy issues Normative Information effects Target group unaware of relevant rule Social norms Target group condones particular corrupt practices, or believes infringement of existing social norm against corruption is widespread Low acceptance/credibility of law-makers or law enforcement agencies as source/enforcer of obligations Legitimacy Source: Weaver (2009), Feldman (2011), and others cited in the text for generic sources of non-compliance. © 2012 Blackwell Publishing Asia Pty Ltd 77 A. Batory Why anti-corruption laws fail 5. Conclusion Echoing the subtitle of Pressman and Wildavsky’s (1973) classic study (“Why it’s amazing that federal programs work at all”), one inescapable conclusion from the overview above is that it is a miracle if anti-corruption interventions have any effect in Central Eastern Europe. Citizens have a multitude of reasons not to comply with anti-graft laws, and relatively few to do comply, on either instrumental or normative grounds. With respect to incentives, while penalties are in place for a high number of corruptionrelated crimes, all the other elements of credible deterrence are weak or missing. It is rather unlikely that corruption is uncovered, and therefore that the penalties will ever be applied due mainly to weak incentives for reporting wrongdoing, either by the perpetrators themselves – which is after all not surprising – or by others not directly involved. Awareness of information that would be key for sticks and carrots, or for detection, to work, is often lacking. There is a not negligible subset of everyday corrupt practices where citizens face such strong pressure to be corrupt in order to access public services legally due to them that incentives against bribery are unlikely to have any effect. With respect to normative motivations too, several factors weaken compliance among citizens in CEE. While most people condemn corruption themselves, evidence abounds around them that their countrymen do not, or at least not sufficiently, refrain from corrupt practices – thus undermining their own resolve. This is compounded by the fact that those who make or are charged with the implementation of anti-corruption policy have only weak credibility and legitimacy for imposing binding behavioral norms on society. Thus, to answer the research question posed at the beginning of the article, anticorruption laws fail in CEE at least in part because they can be expected to elicit only limited support from the citizens whose behavior they seek to change. For the target group compliance is not particularly rewarding either materially or normatively and it is often outright costly, while the broader societal benefits from curbing corruption fail to be communicated effectively or legitimately. However, to avoid the pitfall of much of implementation research, that is, to “put the whole blame for any lack of goal achievement on implementation” (Winter 2003, p. 155), it needs to be acknowledged that target compliance is only one of the explanatory factors for the continuing prevalence of corruption, and faulty policy design also has much to do with this outcome. Indeed, as Weaver (2009, p. 9) puts it, “widespread failures of policy compliance may signal that there is something wrong with the policy, rather than that something is wrong with the targets who are being uncooperative by failing to comply with it. ” However, even if one takes a rather dim view of policymakers’ ability (or willingness) to craft “good” laws, a number of lessons are worth spelling out, assuming that at least some, if limited, change is possible. Some of these lessons are more actionable than others, but all go beyond the deterministic view that the legacies of the past make every effort futile. From the policymakers’ point of view, normative commitment is the ideal source of compliance in the sense that it does not require the involvement of the state apparatus at all (Tyler 1990, p. 4). The problem is that the target group’s normative judgments are extremely difficult, if not impossible, to manipulate within the time frame normally available to policymakers. Deeply held social norms do not change within electoral cycles and politicians have little chance to generate legitimacy for their actions, particularly if the whole of the political class is perceived by the voters to be morally lacking. These are the reasons why the default policy response is generally deterrence: cost–benefit calcula78 © 2012 Blackwell Publishing Asia Pty Ltd Why anti-corruption laws fail A. Batory tions are simply easier to influence, particularly through negative incentives, in the short term. However, the Hungarian experience shows, as many examples showed before, that simple prohibition and the escalation of penalties do not ensure compliance: for instance, criminalizing failure to report corruption crimes is at best a symbolic measure in a context where criminalizing corruption itself shows such limited results. Nonetheless, a number of common sense policy interventions that neither require large-scale resource investment nor “systemic change” are (or would be) at the policymakers disposal. First, legislation would need to be better communicated, and the targets actively informed – this should be possible particularly when the target group is relatively specific, such as civil servants or lawyers, or by involving multipliers through the media or civil society organizations. Information campaigns should be part of the process for the introduction of new rules seeking to curb corrupt practices. Second, in terms of incentives, there is a need for policymakers to move away from the almost exclusive focus on sticks and also consider the potential use of carrots. In many situations rewards for rule conforming behavior may have a greater effect than stiff, but not consistently applied, penalties for non-compliance. For instance, in the debate prior to the 2009 adoption of the (to this day, unimplemented) whistleblower-protection package in Hungary, there had been a proposal to provide a positive incentive to those disclosing information of public interest in the form of a fee or share of the value of the public assets recovered (following the logic of the US False Claims Act). Or, to take another example, the Hungarian Residents Association suggested that doctors who promise not to accept gratitude payments and by wearing a green badge signal this to patients should get higher salaries (Népszabadság 7 January 2011). Both proposals were rejected, even though this type of intervention could send a powerful signal about what should be considered as appropriate behavior. Third, and for policymakers probably most controversially, with respect to legislation that proves to be completely out of sync with social norms, policy reversal or termination should at least be considered as options. Laws that are patently ignored are worse than not having a law in the first place, because non-compliance undermines the credibility of the legal system as a whole. For instance, it should be recognized that gratitude payments are deeply ingrained and relatively widely accepted in the health care system, and therefore they will not go away in the visible future. Turning a blind eye while condemning the practice does nothing to improve the situation for patients. In line with Rose-Ackerman’s (1999, pp. 92–93) recommendation, allowing doctors to charge legal fees for particular services would at least make some of these payments transparent and taxable (a shortlived attempt in Hungary to do this did not have sufficient time to produce significant change). This overview of compliance issues in corruption control paints a dark picture of Hungary in particular. Unfortunately, there is little reason to believe that the situation is significantly better in other CEE countries, or indeed some of the longer-standing EU member states where corruption is a fact of everyday life. More comparative empirical work is clearly needed to, hopefully, disprove this pessimistic conclusion. Nonetheless, what this discussion demonstrates is that understanding why those whose behavior laws aim to change do or do not act in conformity with the rules can generate important insights for crafting more effective corruption control efforts internationally. In conceptual terms, this is also to say that an explicit target compliance perspective, applied in addition to policy design and implementation factors more commonly employed in the © 2012 Blackwell Publishing Asia Pty Ltd 79 A. Batory Why anti-corruption laws fail literature, should be seen as a promising avenue for further research on corruption control and indeed for explaining policy failure more broadly. 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