Terms and Definitions

Accountability:
Accountability is the responsibility of an individual or an organisation, whether in the public or private sector, to acknowledge and make transparent their actions. This includes being answerable for decision-making processes and the management of funds or other entrusted assets. Accountability can be expressed at two main levels: answerability (the duty of an individual or organisation to answer to their decisions and actions) and sanctions (the power to sanction misdemeanours and malpractice).

Active bribery:
Active bribery is the act of offering or giving a bribe, as opposed to the act of receiving one (passive bribery). It is important to note that the active briber may not necessarily initiate the bribe, as it can be demanded by the receiving party (engaging in passive bribery). An example of active bribery is when a citizen reluctantly makes an informal payment to receive a service, like medical care, which would otherwise be denied. The distinction between active and passive bribery is primarily made in legal definitions to facilitate precise sanctions on either side of the transaction, as required. This classification is similar to the differentiation between supply-side and demand-side corruption, used to analyse the incentives and drivers of corrupt practices.

Administrative corruption:
Administrative corruption occurs at the interface between the state, represented by public officials or bureaucrats in decision-making roles, and the public or citizens when they require a service. For instance, when a citizen is provided a service like obtaining an ID card only after making an unofficial payment to the bureaucrat in addition to the official fee.

Anti-corruption:
Anti-corruption is a term used to encompass various strategies and approaches aimed at combating and remedying corruption. Many broader initiatives related to good governance and the promotion of democracy may achieve similar results, even if they are not explicitly labelled as ‘anti-corruption.’

Asset forfeiture:
The act of restraining, taking possession and permanently seizing assets that are the proceeds of crime, typically because they were used in committing the crime or gained from it.

Asset recovery:
The procedure through which funds obtained through corrupt practices are recovered and returned to individuals, governments, or organisations.

Auditing:
A formal examination of an entity’s (whether in the public or private sector) financial records to ensure that funds are expended and reported correctly.

B

Base erosion and profit shifting:
Tax planning strategies that exploit gaps and mismatches in tax rules to make profits ‘disappear’ for tax purposes or to shift profits to locations where there is little or no real activity but the taxes are low resulting in little or no overall corporate tax being paid.

A beneficial owner is the real person who ultimately owns, controls or benefits from a company or trust fund and the income it generates. The term is used to contrast with the legal or nominee company owners and with trustees, all of whom might be registered the legal owners of an asset without actually possessing the right to enjoy its benefits. Complex and opaque corporate structures set up across different jurisdictions make it easy to hide the beneficial owner, especially when nominees are used in their place and part of the structure is in a secret jurisdiction.

Bribery:
The act of offering or exchanging money, services, or other valuable items to influence the judgment or behavior of an individual holding a position of trust or authority. The advantage may not necessarily be given directly to the concerned official; it can also extend to their spouse, child, another family member, a friend, or even to the official’s political party as a contribution. Sometimes, bribes are paid subsequently, such as in periodic installments to officials granting permissions to street vendors in exchange for allowing them to operate. This type of bribery is known as a kickback. Bribery is broadly illegal, and both the person giving the bribe and the person receiving it can be held accountable (refer to active bribery/passive bribery). However, in practice, certain forms of bribery may be exempt from prosecution (see facilitation payments).

C

Cool Drink Money (in the South African context):
In South Africa, ‘cool drink money’ refers to a bribe or payment made to secure a desired outcome, such as waiving a traffic fine or obtaining a driver’s license without passing the required test.

Conflict of interest:
A conflict of interest arises when a person’s entrusted responsibilities clash with their personal interests. For instance, a legislator participating in a healthcare reform committee may own stocks in a major pharmaceutical company. The presence of this personal interest could inappropriately influence the execution of their entrusted duties. Because conflicts of interest can create opportunities for corrupt practices, they should be either avoided or effectively managed.

Corruption:
Corruption is the misuse of authorised power for personal benefit. While this is the most common definition, other variations exist. For instance, the World Bank defines corruption more narrowly as the “misuse of public office for private gain.” Nonetheless, all expert interpretations share three common elements: the abuse (misuse or violation) of entrusted power (duty, office, etc.) for personal advantage. In everyday language, the term is used more broadly to encompass a wide range of objectionable or unethical actions, not limited to those associated with formal duties.

Corruption (legal):
Corruption, as defined by the Prevention and Combating of Corrupt Activities Act, occurs when one party provides something of value to another party with the intent of influencing them to misuse their authority. A broader definition, as used by Transparency International, is the abuse of entrusted power for personal gain. Corruption Watch’s definition is similar, describing it as “the abuse of entrusted power for personal gain.”

Corruption indices:
Corruption indices are tables databases? encompassing multiple countries, featuring scores or grades that indicate levels of corruption or related aspects, such as the effectiveness of systems in place to combat corruption. The underlying assumption is that the strength of corruption-control systems directly reflects corruption risks and, consequently, the potential levels of corruption.

Conventions:
Conventions are international and regional agreements that are formally adopted, often through ratification by multiple states. They establish rules, laws, and standards on matters that typically have cross-border implications and require a coordinated, multilateral approach for effective cooperation.

Cronyism (also referred to as clientelism and patronage):
Cronyism involves showing preferential treatment to friends and acquaintances when allocating resources and positions. This concept is closely connected to nepotism, where such favourable treatment extends to family members. (Refer also to patronage).

D

Debarment:
Debarment is the official action taken to prohibit an individual or company from participating in the bidding process for a project funded or supported by the government. Companies are subject to debarment when an inquiry or investigation reveals their involvement in fraudulent activities, mismanagement, or corruption.

Demand side (of bribery):
The demand side of a bribe, also known as ‘passive’ bribery, pertains to the individual or entity that seeks or receives the bribe.

Democratic accountability:
Democratic accountability is the concept that allows citizens to provide feedback to the individuals and entities responsible for policymaking and decision-making, such as political parties, parliaments, and public officials. This feedback enables citizens to influence policies and decisions in a democratic system.

E

Embezzlement:
Embezzlement refers to the unauthorised misappropriation of property or funds that have been legally entrusted to an individual in their official capacity as an agent or guardian. Professionals like accountants and financial managers, who have access to an organisation’s funds, are often in a position to embezzle them. Embezzlement can also involve theft of supplies, equipment, and other assets.

Endemic corruption:
Endemic corruption is a type of corruption primarily stemming from organisational vulnerabilities. In these situations, corruption is not an uncommon occurrence; instead, it becomes the prevailing norm rather than an exception.

Ethics:
Ethics are the moral principles that guide the behaviour of individuals in government, companies, and society, influencing how they conduct their activities and make decisions.

‘Based on core values and norms, a set of standards for conduct in government, companies and society that guides decisions, choices and actions.’

Extortion:
Extortion is the act of acquiring something, whether it be money, favours, property, or other valuables, by employing threats or coercion. For instance, extortion occurs when armed individuals demand money in exchange for safe passage through a roadblock. Another example of extortion involves withholding life-saving medical treatment unless a bribe is paid. It is worth noting that sextortion is a related term involving threats or coercion to obtain sexual favours.

F

Facilitation payments:
Facilitation payments refer to relatively small sums of money paid in addition to official fees to expedite services like customs clearance, work permits, or border crossings. Technically, these payments qualify as bribes. However, in many countries, companies engaged in foreign business activities are not subject to prosecution for bribery in their home countries when these payments are made to speed up legal processes rather than circumvent regulations. This exception recognises the reality that in certain settings, it is practically impossible to conduct business without making such payments.

Favouritism:
Favouritism is the biased allocation of resources based on personal preferences. For instance, it involves granting offices or benefits to friends and family members irrespective of their qualifications. The unfair distribution of positions and resources is also known as cronyism or nepotism, which can be a form of corruption.

Fiduciary risk:
In the context of development aid, fiduciary risk is the risk that aid funds are used improperly, including situations where they fail to achieve value for money or are not adequately accounted for. Fiduciary risk is a significant concern, particularly when donors provide direct budget support, as the public financial management systems of partner governments are often relatively weak.

Financial Intelligence Unit (FIU):
A Financial Intelligence Unit (FIU) is a centralised national agency tasked with the receipt (and, where allowed, solicitation), analysis, and distribution of financial disclosures. These disclosures encompass information related to suspected proceeds of crime and potential funding of terrorism or information mandated by national laws and regulations. The primary objective of an FIU is to combat money laundering and the financing of terrorism.

Fraud:
Fraud is an economic crime that involves deceit, trickery, or false pretences through which individuals gain unlawfully. Fraud is often associated with corrupt activities, particularly embezzlement, where it is commonly used to falsify records to conceal stolen resources.

‘To cheat. The offence of intentionally deceiving someone in order to gain an unfair or illegal advantage (financial, political or otherwise). Countries consider such offences to be criminal or a violation of civil law’.

G

Ghost workers:
Ghost workers are individuals who appear on a payroll but do not actually work for the company or public institution in question. Paychecks are issued and disbursed to someone who either does not exist or exists but does not perform any duties for the organisation.

Gift giving:
Gift giving is a cultural practice in many societies where people offer presents and favours in various situations. Issues arise when gift-giving to or by public officials undermines impartiality, professionalism, and meritocracy. When a gift is given in exchange for preferential treatment by the official, it can be considered a form of bribery.

Governance:
Governance extends beyond traditional concepts of government and focuses on the relationships between leaders, public institutions, and citizens. It encompasses decision-making and implementation processes and can also apply to companies and non-governmental organisations (NGOs). ‘Good’ governance is characterised as being participatory, accountable, transparent, efficient, responsive and inclusive, respecting the rule of law and minimising opportunities for corruption.

Graft:
As a verb, ‘graft’ denotes the act of dishonestly obtaining money by leveraging one’s position of power, particularly political authority. Graft is typically associated with political corruption and often carries an element of greediness.
As a noun, ‘graft’ represents the rewards or gains acquired through corruption, including loot, booty, payoffs, or spoils obtained through illicit means.

Grand corruption:
In contrast to ‘petty corruption’, grand corruption occurs at the highest levels of government. It often involves substantial benefits for the involved officials, resulting in significant losses for the state and its citizens. It can encompass specific acts, such as ministers receiving multi-million dollar bribes to award lucrative government concessions or embezzling millions from state funds into secret bank accounts. However, it can also involve illicit exchanges in the realm of policy formation. While large sums of money may be involved, other benefits like high-level appointments, access to inside information, and influence over policy can serve as forms of currency in grand corruption. Corruption at this level is sometimes referred to as political corruption.

Grease money:
Grease money refers to bribes from the perspective of the one offering the bribe. The term alludes to the idea of providing a ‘drop of oil’ to lubricate a squeaky bureaucratic wheel, enabling things to move smoothly again. Grease money is also known as a softener, sweetener, or gift.

H

Holistic Approach:
To combat corruption effectively, conventional wisdom suggests the necessity of a ‘holistic approach’. This approach entails a comprehensive examination of all relevant institutions and practices within a specific country that contribute to promoting transparency and integrity. These encompass the executive, legislature, and judiciary branches, as well as businesses, the media, civil society organisations, and other entities that play a role in maintaining honest government and private sector institutions.

I

Illicit financial flows (IFFs):
Illicit financial flows (IFFs) are money that is illegally earned, transferred or utilized. These funds typically originate from three sources: commercial tax evasion, trade misinvoicing and abusive transfer pricing; criminal activities, including the drug trade, human trafficking, illegal arms dealing, and smuggling of contraband; and bribery and theft by corrupt government officials.

Incentive:
An incentive is a motivating factor or stimulus, which can be either a reward (the ‘carrot’) or a penalty (the ‘stick’), designed to encourage someone to take a specific action or make particular choices. Incentive theory offers a conceptual framework for analysing the role and potential impact of various factors, including recruitment and promotion methods, detection and punishment systems, and different wage structures in enhancing the efficiency of public agencies. It challenges simplistic assumptions, such as the notion that pay increases will invariably reduce corruption in public administration. It is important to note that an incentive can also take the form of a bribe, used to persuade officials to provide undue favours in return for the briber’s benefits.

Integrity:
Integrity means a set of moral or ethical principles.
‘Behaviours and actions consistent with a set of moral or ethical principles and standards that is embraced by individuals as well as institutions. Integrity creates a barrier to corruption.

Integrity pact:
An integrity pact is a pact designed to prevent corruption in public contracting. One party typically represents a government entity, such as central, local, municipal government, or a state-owned enterprise. In contrast, the other party is usually a private company seeking to secure or execute a contract. Both parties commit to refraining from bribery and agree to penalties if this commitment is breached.

K

Kickback:
A kickback is a bribe paid after the fact in return for an undeserved favour or service. For example, a company that secures a government contract might make regular payoffs to the responsible official for the duration of the contract. Street vendors may pay a small sum each month to the authority permitting them to operate.

Kleptocracy:
Kleptocracy, derived from a Greek word meaning ‘rule by thieves’, refers to a system of governance in which leaders exploit their positions for personal gain at the expense of the governed. It is often associated with autocratic regimes lacking meaningful accountability mechanisms, allowing leaders to plunder state resources and citizens for personal enrichment while consolidating their power. Prominent former kleptocrats include François Duvalier (‘Papa Doc’) of Haiti, Mobutu of Zaire, and Suharto of Indonesia.

L

Lobbying:
Lobbying encompasses any activity carried out to influence the policies and decisions of a government or institution in favour of a particular cause or outcome. It serves as a crucial tool for stakeholders to make their voices heard by politicians and public officials. Lobbying can take various forms, from citizens writing to their elected representatives to joining protests. Professional lobbyists, in contrast, are paid to advocate for the specific interests of their clients before relevant public officials. They may include former officials hired for their expertise and industry contacts. The terms of engagement for former public officials are typically well-defined and limited to distinguish permissible lobbying from illegal trading in influence.

‘Any activity carried out to influence a government or institution’s policies and decisions in favour of a specific cause or outcome. Even when allowed by law, these acts can become distortive if disproportionate levels of influence exist – by companies, associations, organisations and individuals.’

M

Measurement of corruption:
Two main approaches are employed to assess corruption. One is measurement, which quantifies the extent of corruption, while the other is assessment, which identifies the factors enabling corruption to occur.

Money laundering:
Money laundering involves any act or attempt to conceal the source of funds or assets obtained from criminal activities. This includes concealing the origins and the use of illicit assets, making it challenging to trace the proceeds of corruption. Money laundering is frequently employed to hide the gains of corrupt activities. It is practised by a range of actors, from drug traffickers and human traffickers to kleptocrats and white-collar criminals. The practice is further complicated by bank secrecy, making it particularly challenging to track laundered money.

Mutual Legal Assistance:
Mutual Legal Assistance (MLA) is the official procedure for cooperation and collaboration between two or more legal jurisdictions, often employed in cases involving cross-border issues such as money laundering, asset recovery, and tax evasion. It allows these jurisdictions to work together to exchange information, gather evidence, and provide legal assistance in support of investigations and legal proceedings.

N

Nepotism:
Nepotism refers to a type of favouritism that revolves around family connections, where an individual leverages their position of authority to secure jobs or other advantages for their relatives. When this preferential treatment extends to friends and acquaintances, it is typically called cronyism.

Nyoba:
Nyoba is an isiXhosa term that translates to ‘bribe’. To bribe someone is expressed as “ukunyoba” in isiXhosa.

O

Off-shore financial centre (OFC):
An offshore financial centre (OFC) is a jurisdiction that offers tax and regulatory advantages, typically to entities such as companies, trusts, and bank account holders. These account holders receive these benefits under the condition that they do not engage in active business within the jurisdiction. Off-shore financial centres often serve as operational financial service hubs, representing the commercial response to the offerings provided by tax havens.

P

Passive bribery:
Passive bribery refers to the act of receiving a bribe. It should be noted that the passive briber is not necessarily passive in the sense of having taken no initiative; in many cases, they may have initiated or demanded the bribe in the first place.

Patronage:
Patronage involves the support or sponsorship of a patron, often a wealthy or influential guardian. It is used to appoint government positions, facilitate promotions, award contracts for work, and more. Most patrons are motivated by the desire to attain power, wealth, and status through their actions. Patronage often infringes upon the boundaries of legitimate political influence and the principles of merit.

‘Form of favouritism in which a person is selected, regardless of qualifications or entitlement, for a job or government benefit because of affiliations or connections.’

Perception surveys:
Perception surveys are questionnaires designed to gather the opinions and views of respondents regarding the levels of corruption in a country, sector, or institution. These surveys may also inquire about the respondents’ impressions of whether the corruption situation is improving or worsening.

Petty corruption:
Petty corruption, alternatively known as ‘administrative’ or ‘bureaucratic’ corruption, pertains to the everyday corrupt practices that occur when individuals interact with public officials. Although the sums of money involved are typically small, they are far from ‘petty’ for the individuals affected. Examples of petty corruption include paying bribes to obtain identification documents, enrol in school, or have a phone line installed.

Political corruption:
The term ‘political corruption’ can be used narrowly to refer to the manipulation of policies, institutions, and rules in the financing of political parties and during electoral campaigns. It can also be used more broadly as a synonym for ‘grand corruption’, signifying corruption taking place at the highest levels of government, where policies and rules are formulated and executive decisions are made.

Political will:
‘Demonstration and commitment by political leaders to address the challenges facing society or to fulfil a political pledge, such as fighting corruption or increasing political participation, by pursuing the appropriate policy responses, including wide-spread reforms.’ ‘Anti-corruption laws and institutions are not reliable indicators of political will.’

Politically Exposed Persons (PEP):
Politically Exposed Persons (PEPs) are individuals who currently hold or have previously held prominent public positions in a foreign country. This may include heads of state or government, senior politicians, high-ranking government officials, judicial or military figures, senior executives of state-owned corporations, or influential political party officials. The term often encompasses their immediate family members and close associates. Financial institutions are typically required to treat PEP clients as high-risk, subjecting them to enhanced due diligence procedures at the beginning of the business relationship and on an ongoing basis. This helps ensure that the funds in their bank accounts are not the result of criminal activities or corruption.

Private Sector:
The private sector comprises entities such as companies, households, and institutions that are not under public sector control and are operated for private profit.

Private sector corruption:
Private sector corruption involves groups from this sector exerting influence on decisions and actions that lead to the abuse of entrusted power.

Procurement:
Procurement is a multi-stage process involving established procedures for acquiring goods and services by individuals, companies, or organisations. It spans from the initial assessment of needs to the awarding of contracts and the delivery of services.

Protected Disclosure (see Whistleblower):
A protected disclosure, often referred to as a whistleblower report, involves the reporting of serious wrongdoing, such as corrupt conduct, maladministration, or substantial waste of public funds. It is a disclosure or revelation that, when meeting specific requirements, grants the person making the disclosure support and protection against retaliation, victimisation, or legal action. Protected disclosures can be made within the organisation, to an ombudsman, or to someone with the authority to prevent reprisals against the whistleblower.

Public Sector:
The public sector encompasses the government and its decentralised units, which include entities such as the police, military, public transportation authorities, primary schools, and healthcare systems. These entities use public funds to provide services with the primary aim of improving the lives of citizens rather than seeking to generate profits.

R

Rent-seeking:
Rent-seeking involves lobbying the government for protection, subsidies, and preferential policies to benefit a business. The objective is to avoid competition in the free market, establish near-monopoly conditions, and secure excessive profits (known as ‘rents’). Rent-seeking leads to reduced economic efficiency due to the misallocation of resources decreased wealth creation, lost government revenue, and increased income inequality. Unlike profit-seeking through market competition, rent-seeking through political means does not generate wealth but transfers privileges from one party to another. The lobbying efforts in rent-seeking often encompass the unethical practice of buying public officials and politicians, constituting corrupt practices.

Risk assessment:
Risk assessment is a systematic process of evaluating potential risks or hazards associated with a particular activity or project. In the context of corruption, a corruption risk assessment involves a comprehensive examination of how specific governance mechanisms operate, achieved through a detailed mapping of all relevant sub-processes. Each element is then analysed to identify opportunities for corruption. The identified risks are subsequently assessed for the probability of occurrence and the expected impact, enabling the identification and implementation of suitable mitigation measures. These steps collectively form a risk management system.

Rule of Law:
The rule of law encompasses the legal and political systems, structures, and practices that shape a government’s actions to safeguard the rights and freedoms of its citizens, maintain law and order, and foster the effective operation of the country. It ensures that government authority is exercised in accordance with established laws and regulations and that the principles of justice, fairness, and accountability are upheld.

S

Secrecy jurisdiction:
Secrecy jurisdictions are also known as ‘tax havens’. As defined by the Tax Justice Network, secrecy jurisdictions are places that intentionally create regulatory frameworks primarily for the benefit and use of individuals or entities not residing within their geographical domain. This regulatory environment is designed to undermine the legislation or regulation of other jurisdictions. Secrecy jurisdictions also establish a legally supported veil of secrecy, ensuring that those external to the jurisdiction who utilise its regulations cannot be identified as doing so. These jurisdictions promote the relocation of economic transactions to their domain, often featuring low or minimal tax rates for non-residents and hosting various financial service providers.

Sextortion:
Sextortion involves the misuse of power to obtain a sexual benefit or advantage. It is related to the concept of extortion.

Shell companies:
Shell companies are non-trading entities used as vehicles for various financial manoeuvres, illicit purposes, or kept dormant for future use in other capacities. Typically, shell companies are incorporated in jurisdictions where they have no physical presence and are not affiliated with a regulated group.

Solicitation:
Solicitation refers to the action of one person asking, ordering, or enticing another individual to commit bribery or another criminal offence. It involves the act of seeking or encouraging the commission of such acts.

Spoliation:
Spoliation pertains to the deliberate destruction or alteration of a document that is required as evidence. More broadly, it includes the destruction or plunder of something valuable. In the context of political corruption, spoliation occurs when high-ranking officials plunder their state’s wealth, and the gains they derive from these actions are referred to as spoils, rewards, or profits from corrupt acts.

Sporadic corruption:
Sporadic corruption is the opposite of systemic corruption. It occurs irregularly and does not pose a threat to the control mechanisms or the economy as a whole. While not necessarily debilitating, it can seriously undermine morale and drain economic resources.

State capture:
Coined by the World Bank in the early 2000s, state capture refers to a form of systemic political corruption in which private interests significantly influence a state’s decision-making processes to their own advantage. For example, businesses may improperly influence legislators to pass favourable laws. The power to appoint Cabinet ministers and the boards of state-owned enterprises comes standard.

In South Africa, state capture is exemplified through the actions of members of the Gupta family. Whose activities have been widely documented in the news, indicating that they have accumulated substantial wealth by engaging in businesses that have, at various points, intertwined with state affairs. For instance, their involvement has been linked to actions that have detrimentally impacted the state-owned power utility, Eskom, through a series of deals primarily designed to directly and indirectly benefit the Gupta family and their associates.

Supply side (of bribery):
The supply side refers to individuals or entities offering illicit benefits in corrupt transactions.

Systemic corruption:
Perpetrated by networks that act according to stable practices and norms (institutionalised), and that serve political or social functions that emerge through design or dysfunction’.

T

Tax Evasion:
Tax evasion is the illegal act of not paying or underpaying taxes, typically achieved by deliberately providing false information or making no declaration to tax authorities. This may involve reporting lower income, profits, or gains than the actual amounts earned or exaggerating deductions. Tax evasion can result in both criminal and civil legal penalties.

Tax Avoidance:
Tax avoidance is the legal practice of minimising a tax liability by exploiting a legal loophole or exception to the tax rules or by adopting an interpretation of the tax code that may not have been the intended use. Aggressive tax avoidance involves attempting to reduce tax payments while adhering to the letter of the law but not the spirit of the law.

Tax Havens:
Tax havens, also known as secrecy jurisdictions, are locations with specific legislative, judicial, fiscal, and regulatory provisions designed to attract economic transactions to their jurisdiction. They may offer low or minimal tax rates to non-residents and may or may not host a range of financial service providers. These jurisdictions are characterised by the tax advantages they provide and, in the case of individuals seeking to conceal their assets, by the secrecy that ensures the anonymity of those utilising their regulations.

TJOTJO:
‘Tjotjo’ is a South African term referring to a bribe paid, typically to a police or traffic officer. It represents an illegal or unethical payment made to influence or circumvent the law, often in exchange for preferential treatment or the avoidance of legal consequences.

Transparency:
Transparency is a characteristic of being open, communicative, and accountable. It suggests that governments and other organisations have an obligation to conduct their activities in a manner that is easily understood and visible to the public. Transparency can result in more effective resource allocation, increased efficiency, and greater potential for economic growth. It involves providing information and making decisions in a manner that is accessible and comprehensible to the public.

W

Whistleblower:
Whistleblowers are individuals who disclose corrupt transactions and/or other unlawful or unethical behaviour they have observed or uncovered to the public or relevant authorities. These individuals often need protection from potential retaliation. Whistleblower protection encompasses the act of safeguarding the informant from reprisals or harm.

Z

Zero Tolerance:
Zero tolerance is a policy that involves thoroughly investigating, prosecuting, and penalising all instances of corruption, regardless of their scale or significance. This approach aims to demonstrate a steadfast commitment to addressing corruption and sending a clear message that it will not be tolerated in any form. It is sometimes criticised as being unrealistic.