Transparency International UK Annual Plan FY 2018-19

Transparency International UK (TI-UK) Annual Plan FY 2018-19

Registered Charity 1115842

Contents

1. Introduction

Section A: Programmes 2. UK Anti-Corruption Programme (UKACP) 3. Business Integrity Programme (BIP)

Section B: TI Global Programmes 4. Pharmaceuticals & Healthcare Programme (PHP) 5. Defence & Security Programme (DSP)

Section C: Support & Resources 6. Fundraising & Communications 7. Finance & Resources

Section D: Directorate & Governance 8. Directorate 9. Governance

Annex I Budget summary Annex II Strategy 2017-20: progress against three-year forecasts Annex III Organisational chart 2

1. Introduction

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1. Introduction 1.1 Overview 1.1.1 Outlook for FY 18/19 We enter the new year with a high-quality staff in place, each of our four programme teams wellfinanced and each having or developing a high-impact strategy. We have both a long-term and a recent track-record of success. The top-line numbers are more or less in line with our three-year strategy, approved by the Board in March 2017 (see Annex II). The wider environment in which we operate remains challenging, both in the UK and beyond, but at the same time there are still substantial opportunities for us to pursue our mission effectively. Awareness of corruption is stronger than ever before; there are always pockets of political, corporate and institutional will to support our work, notwithstanding the strong counter-vailing forces; the transparency revolution has given us more material to work with; and after twenty-five years, our institutional expertise and brand represent considerable assets.

1.1.2 Summary of previous year FY17/18 FY17/18 was a mixed year for Transparency International UK (TI-UK). We have had some spectacular successes in our mission impact, with a research and advocacy capability that is unmatched by any comparable NGO in the UK. But we have also had a period of austerity, with a freeze on all discretionary expenditure, including replacement staff, while we fell short on income projections in several areas. This was most noticeable in the two global programmes that we host on behalf of the TI movement, known as Global Thematic Network Initiatives (GTNIs), where large grants from institutional donors took longer than expected to finalise. Despite this financial uncertainty, we finished the year strongly, and managed throughout to maintain a high staff capability which enabled us to deliver outputs and impact in all of our key areas of activity.

1.1.3 Mission successes Our mission delivery remains structured around four key teams, two of which are primarily UKfocussed, and two of which are GTNIs. All of the programmes operate in line with the mission objectives in our Strategy: 1. To achieve a significant reduction in corruption and corruption risk, especially through our global programmes and in areas influenced by the UK 2. To promote greater transparency in the public and private sectors 3. To improve accountability so that people and institutions act with integrity and there are strong defences against corruption 4. To sustain global anti-corruption standards for governments, companies and international institutions 5. To help ensure there is no impunity for corrupt individuals and institutions, through promoting enforcement and the rule of law 6. To ensure that corruption is at the heart of the national and international debate.

Among the key success for the year in terms of outputs, outcomes and impact were:  Business Integrity (BIP)  Anti-Bribery Guidance: the team continues to set the standard for providing free, independent guidance, that sets the standard for companies and regulators; for example, this year saw the development of an online Anti-Corruption Portal, providing extensive resources for companies aiming to reduce corruption risks 4

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Independent and well-funded UK prosecutor: we have been publicly and strongly supportive of the need for a well-funded and independent prosecutor for the Bribery Act, especially while the Serious Fraud Office lay under threat of abolition – as announced in the Conservative Party election manifesto. TI-UK combined public pressure with private interventions at the highest level, and the SFO’s immediate future as an independent prosecutor is now secure, and its funding has been increased.

Defence & Security (DS)  NAKO committee: working with TI Ukraine, we have created a high-level independent anti-corruption committee for the defence sector, NAKO, chaired by Drago Kos. This is already having an impact in pressing for legislation and providing external scrutiny for areas of high corruption risk such as state-owned defence company Ukroboronprom.  Global Standards: we embarked on an ambitious projects to persuade governments to adopt Global Standards for the defence sector, and secured the first commitment from a government to be part of a leadership group.

Pharmaceuticals & Healthcare (PHP)  Latin American Principles: we developed and launched a set of common anti-corruption principles for the pharmaceutical sector in Latin America, and are now working to have them adopted by both public and private sector  Cameroon whistleblowing: through our Health Action Fund, we supported an innovative project in Cameroon to provide No Sissia whistleblowing platforms at healthcare facilities.

The platform logged over 200 reports from victims of corruption during the 3-month implementation phase which were passed for action to the Ministry of Health.

UK Anti-Corruption (UKAC)  Unexplained Wealth Orders (UWOs) were passed into law, and the first UWOs were served; this was an idea conceived and researched by a TI-UK taskforce; our follow up advocacy brought the concept to the attention of the government, persuaded ministers to accept it, helped ensure a smooth cross-party passage through parliament, and created a clear public and media expectation on law enforcement agencies that UWOs should be used.  UK Anti-Corruption Strategy: TI-UK proposed to the government that the UK should have a Strategy, secured the commitment for it, strongly and consistently advocated for its introduction, and substantially shaped the content.

1.1.4 Key figures for FY 2018/19 FY Revenue Surplus (unrestricted) Staff at year end

2017/18 £3.210m -£120,000 44

2018/19 £4.910m £1,000 50

The charity’s income profile is changing substantially, towards large, restricted grants from institutional donors. Our deficit on unrestricted funds last year principally reflects the decision to carry our global programmes in anticipation of their receiving new grants; our conservative forecast surplus for the year includes a prudent provision for slower than anticipated expenditure rates on the restricted grants. The business plan discretionary expenditure is phased to ensure that additional cost will not be taken on until unsecured income is confirmed. Although we have a high proportion of secured income – around 80% of the budget – the balance is represented principally by unrestricted funds from the Business Integrity Programme and the fundraising department, whose progress will be closely tracked and aligned to expenditure.

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1.2 TI-UK’s 3-year Strategy This annual plan represents the second year of a new Strategy approved by the TI-UK Board in March 2017. The full Strategy is available on our website www.transparency.org.uk; it is designed to operate alongside the TI global Strategy 2020.

Six key themes in the strategy are:  A changing world - the world’s small but effective anti-corruption community is needed more than ever. A flourishing Transparency International will be required to play a key role in world affairs in the coming years; we acknowledge the need and our strategy is a declaration of intent that we expect to rise to the challenge.  Leveraging the UK’s global role – we will mobilise resources and expertise from the UK to help the global fight against corruption, leveraging the UK’s international role and acknowledging the UK’s role in facilitating international corruption.  Innovation - in areas such as research and advocacy, fundraising and communications, we will introduce new means of collecting, analysing and disseminating information, with a new focus on using tech-driven solutions.  Increasing impact - we will increase the impact of our activities; we will prioritise growth in impact over growth in staff numbers – with the exception of PHP, which we expect to increase towards the size of DSP.  Organisational strength – we will build a strong and sustainable organisation, putting in place the necessary measures to manage our growth.  Sustainable funding – we will aim for each programme to be self-sustaining according to its needs and up our game in fundraising and communications.

We have outlined strategic objectives for both our mission delivery (see 1.1.3 above) and organisation-wide. The organisational objectives, with examples of how they have been met, are: 1. To ensure that we are the UK’s turn-to organisation for corruption information, policy and opinion Example: our annual Anti-Corruption Lecture was delivered by former Prime Minister David Cameron; the Executive Director was invited by the UK’s Anti-Corruption Champion to deliver a speech at the launch of the new UK Anti-Corruption Strategy.

2. To foster a world-class research, advocacy and programme capability in order to help us achieve this.

Example: publications including Fifth Column (on corruption, security and fragile states) and Offshore in the UK (on the use of Scottish Limited partnerships as a vehicle for global moneylaundering) broke new ground; our Adequate Procedures Guidance series or companies has been downloaded nearly 100,000 times.

3. To develop our human capital, ensuring that TI-UK has a high-quality, sustainable and satisfied workforce Example: we have introduced an organisation-wide Training & Development Plan, which includes a Personal Development Allowance for all staff members; we have a number of staff members who have flexible working arrangements to pursue vocational and academic courses.

4. To develop our network capital, forming and maintaining partnerships both externally and within the TI movement, that enable us to achieve our objectives

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Example: our Head of Advocacy continues to chair the Bond Anti-Corruption Group, the UK’s primary network in our field; the Executive Director was elected by voters in the TI movement to the international Board in November 2017.

5. To achieve sustainable financing: we will put our finances on a sustainable footing, so we are not too heavily reliant on any sector or individual donor; this will require more innovative and energetic fundraising, as well as strengthened project management.

Example: we have secured long-term DFID grants for three of our programmes, and created a new position of Director of Fundraising & Communications to help diversify our funding base.

1.3 External environment This annual plan is based on a number of assumptions about our operating environment:  Within the UK, the rise in inequality, combined with the political distraction of Brexit, creates greater popular feeling against corruption and reduced political will or capacity to respond.  However, the publishing of the UK’s first-ever National Anti-Corruption Strategy creates opportunities and accountability mechanisms over a wide range of issues in the UK.  Global financial centres like the UK, and its Overseas Territories and Crown Dependencies, remain a key nexus for the global proceeds of corruption.  Globally, there is a vacuum of political leadership on anti-corruption issues; several key countries have deteriorated in both corruption scores and political will; civil society is under pressure in many areas of the world.  The business community increasingly views anti-corruption measures as within its interest, although corruption scandals persist at major companies.  Corruption is a transnational phenomenon, and an important way to address this is to take transnational approaches such as sectoral initiatives.  TI’s global network of National Chapters (NCs) is a significant asset to tackling corruption on a transnational basis, but some NCs remain under-resourced and as a whole TI is undercapitalised.

1.4 Key risks for 2018/19 TI-UK’s risks are assessed regularly by the Senior Management Team and board committees and mitigation measures are put into place for each risk. They are discussed regularly at the Finance & Audit Committee, and at least annually by the full Board. A rolling risk register is maintained. The following areas present key risks for the delivery of this annual plan:  Grant management. The large institutional grants we have taken on require a level of sophistication in grant management, financial management, reporting and M&E that we have not previously had - our previous such grants were sufficiently unrestricted that such systems were not fully required; and we now both need the systems, and need them to be compatible across the teams.  Overseas operations. Three of our teams will be delivering projects overseas, often through individuals specifically employed on behalf of our projects by other TI National Chapters (NCs); we had anticipated this happening but with much lower numbers. This means our business model is changing, and we need the skills and training in place to support this change.  Building sustainable financing. We aim to generate more unrestricted income, particularly focussing on high net worth individuals and trusts, through enhancing our fundraising

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capabilities. This represents a trial year for new fundraising approaches, which creates some uncertainty of outcome.

GTNI operations. GTNIs can struggle for an identity as a global programme hosted by a national chapter, which can cause confusion for staff about reporting lines and accountability, as well as lead to a loss of coordination. We have established new operational guidelines for the GTNIs, which need to bed in.

Senior staff. We have three new Directors who are settling into their departments. While they are all capable and experienced and have been carefully recruited, this represents a considerable change at senior level; each Director will be presenting a strategy to the Board within the first quarter.

Staff (headcount and salary) pressure exceeds financing capacity. At a time of growth, we are wary of building an over-large establishment which becomes self-perpetuating in the need to generate funds. This relates both to the core/support staff, and the programme delivery staff. While it is easy to add staff and ratchet up salaries and other costs when contracts are secured we need to ensure we continue to take into account our obligations to spend money responsibly and are planning for financial sustainability in the long term.

Aggregate complexity. Overall, our operations are becoming much more complex; we are nearly doubling in size; we have four high-performing operating units supported by a very small support team; our delivery model is more dependent on third parties overseas; and we have onerous commitments to reporting, particularly to DFID. While each risk is appropriately managed, we are carrying a higher degree of aggregate complexity than before.

1.5 What is new?

Significant changes in this plan compared to previous years include:  Size and stability: we are increasing substantially in size, and this will lead to a greater focus on systems and procedures, as well as bring a period of financial stability. As an entrepreneurial organisation, we have placed a premium on being lean and unbureaucratic; however, more sophisticated and coordinated systems and procedures are required for our large grants and larger size.  PHP becoming fully operational: after an investment and development period of three years, this GTNI will be fully operational this year.  BIP Strategy: our business programme has a revised strategy and will be playing a more prominent role in advocacy and policy, in addition to providing best practice guidance for companies.  DS model: the Defence & Security team will enter a year in which they are financially supporting almost as many staff positions overseas as there are in London, as will PHP. This gives a genuinely global reach to the GTNIs, while at the same time offering some challenges to an NC-based model which we hope to resolve via TI’s global governance review. A number of the programme’s strategic initiatives are expected to make a significant impact with additional resourcing.  UK corruption: new opportunities are created by the existence for the first time of a UK Government Anti-Corruption Strategy, and our UK team will aim to build on its work on luxury housing to examine more deeply housing-related issues in the UK.  Fundraising: we have invested in a more senior fundraising capability and have combined the function with Communications.

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Section A: Programmes

UK Anti-Corruption Programme (UKACP) Business Integrity Programme (BIP)

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2. UK Anti-Corruption Programme (UKACP) Programme Director: Duncan Hames

Programme goal/objectives Our goal is to prevent corruption in the UK, and the UK from contributing to corruption elsewhere.

We aim to do this by improving the resilience of public institutions, increasing accountability, and ending the UK’s role in providing a safe haven to the corrupt and their illicit wealth.

2.1 Background The team achieved some major successes in 2017, including the introduction of Unexplained Wealth Orders into law and the publication of the UK Government’s Anti-Corruption Strategy. We built on our reputation as trusted, independent experts with research which was well received both within and outside of government.

The challenge ahead lies in pushing through existing commitments, ensuring effective implementation of new legal powers, and advocating for further change in an environment which is Brexit-focused and more resistant than usual to legislative change.

2.2 Focus areas Our UK Anti-Corruption Programme will advance three themes of work: 1) Promote integrity standards in UK sectors and institutions, and influence public policy to secure these through system change.

2) Leverage UK leadership to improve the global approach to tackling corruption, by pursuing effective implementation of the commitments made at the Anti-Corruption Summit and in the UK Anti-Corruption Strategy.

3) Work towards ending impunity by restricting the freedom of corrupt individuals and regimes, and the means available to them to launder and shelter the proceeds of corruption in the UK. The theme of open governance – specifically, improving the UK’s information infrastructure and the use of open data to fight corruption – will be embedded within all three focus areas. UK-ACP will take a leadership role throughout the development of the UK’s fourth OGP National Action Plan, and seek to feed in recommendations related to our key themes of work.

2.3 Activities and Outputs 2.3.1 Summary of outputs  Two major research projects  Six smaller research projects  Four tech-based advocacy tools  Regular, direct engagement with government officials  New advocacy and/or research partnerships with external organisations  Briefings (oral and written): parliamentary briefings, consultation submissions, government briefings  Monitor, influence debate, and galvanise amendments for two parliamentary bills  Reactive advocacy 10

2.3.2 Ensure integrity in UK sectors There are significant corruption risks within many of the UK’s sectors and institutions. We will explore opportunities to expand our work in key sectors, particularly those highlighted by the recent Anti-Corruption Strategy. We will consider the role of money in politics before, during and after individuals hold elected office, by examining data and practice in: political party funding, lobbying transparency, and the revolving door. We will develop a new project on housing to further explore the associated corruption risks in local government.

Outputs:  A major new research piece on corruption risk in housing, exploring: planning and development at local government level, examining corruption in housing maintenance and major works, and investigating the corruption risks in the development of UK housing.  A small piece of research on the revolving door, and continued advocacy on this and the risks associated with political party funding and a lack of lobbying transparency.  IntegrityWatch online tool: interrogating transparency data on money in politics and access to power. We will ensure data is processed and updated, and promoted to journalists and other stakeholders.  Work with Parliament Digital Services to improve data quality on members’ financial interests.  Joint research and advocacy with the Open Contracting Partnership and Spend Network on UK open contracting data.

2.3.3 Leverage UK leadership on corruption We will leverage the role of the UK as a global leader on anti-corruption, and encourage implementation of the Anti-Corruption Summit outcomes to substantially improve the global approach to tackling corruption. We will promote anti-corruption measures in UK trade policy, and hold the UK Government to account on commitments made in the UK Government’s AntiCorruption Strategy.

Outputs:  Leadership, coordination and galvanisation of civil society coalitions to hold the UK Government to account on its anti-corruption promises and its role as a global leader on anticorruption.  Planned advocacy around the UK’s anti-corruption commitments  Four new national pledge-trackers, five TI chapter-led advocacy projects, and a new report/tool advocating progress on Summit commitments.  Three global events, drawing TI chapters together to plan joint activity strategically on three key issues featured at the Summit: beneficial ownership, asset recovery, and law enforcement.  Continued advocacy directly to the UK Government, and strategic third party pressure through avenues such as parliament, business, tech tools, and the media.

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2.3.4 End the UK’s role as a safe haven for corrupt individuals and their assets Since 2014, this campaign has explored the role of the UK and its network of offshore financial centres as a safe haven for corrupt money and individuals from across the world, and advocated for an end to this behaviour.

Our current focus is on: an inadequate, fragmented anti-money laundering system, lack of transparency over the true ‘beneficial’ owners of UK assets such as property, an ineffective asset recovery regime, golden visas, and the role of UK businesses and other organisations in ‘reputation laundering’. Priority subjects for research projects include: civil recovery, the role of UK companies, golden visas, and professional enablers.

Outputs:  Scoping potential research project on the role of professional enablers in facilitating global corruption;  Research partnership with legal experts to explore existing options and legislative change required for citizens seeking civil recovery proceedings in the UK;  Smaller research projects: Analysis of data on suspicious networks; analysis exploring the potential role of UK companies laundering the proceeds of corruption into UK property; research on UK golden visas;  Advocacy on the register of beneficial owners of overseas companies owning UK property and bidding for government contracts, specifically on the draft legislation which is expected to land in parliament by July  Advocacy on the Sanctions & Anti-Money Laundering Bill, focusing on the abuse of UK companies, supervision of Trust & Company Service Providers, the property register, and a timetable for moving to public registers of beneficial ownership in British overseas territories.  Working with partners, such as Global Witness, on improving the capacity of Companies House to verify data and improve the usefulness of the UK’s PSC register.

2.4 Resource requirements 2.4.1 Staff numbers  In place at the start of the financial year: Director of Policy, Head of Advocacy, Research Manager, Project Manager – Commitments, Grant Manager (in the TI Secretariat), Senior Research Officer, Senior Policy Officer, Carlo Schmidt intern  To put in place during the course of the year: PHD student (ESRC funded), FCA Secondee (free resource), Housing Research Officer (only if we find a funder to establish this project).

We will explore the possibility of co-funding part of a Data Lead/consultant’s time (funded by the innovation line in the ON grant) in order to expand our data analytics capability.  The Director of Policy will be absent for two periods each of two months during the year. UKACP plan to hire a Project Assistant on a short fixed term contract to provide capacity to back-fill responsibilities through the team.

2.4.2 Fundraising priorities  Secure a government research contract with a UK corruption focus  Secure funds for a new programme of work on corruption in housing  Make significant progress towards sustainable funding for UK-ACP post the Omidyar grant  Secure funds for the PHD placement (£50K over 4 years)  Submit joint Research Councils UK bid with academic partners to produce a rich analysis of corruption risks and challenges in the UK. 12

3. Business integrity Programme (BIP) Programme Director: Kathryn Higgs

Programme goal/objectives We believe companies can be a force for good in the fight against corruption and it is in the interests of businesses to support a corruption-free operating environment and a level playing field. In collaboration with like-minded businesses and challenging organisations where appropriate, our goal is to improve anti-corruption standards in UK business and by extrapolation business standards globally by:  Leading the debate on and facilitating leading edge thinking on measures to fight corruption in business;  Raising awareness & providing guidance to the private sector on how to address corruption risk by interacting with a breadth of company types, industries and functions within those companies; and  Advocating for change within the private sector by engaging with companies directly, influencing public opinion and driving change in the enforcement environment in which they operate.

3.1 Background TI has a longstanding reputation as thought leaders in the fight against corruption and the Business Integrity Programme has historically been at the forefront of driving change and progress in business integrity standards – particularly through its involvement in the introduction of the Bribery Act UK. For several years now, the programme has played a crucial role in generating surplus revenues. However, it is important to stay mindful that its core purpose is not to be a fundraising programme, but a programme with a mission to harness corporates in the fight against corruption, providing them with insights and tools based on TI-UK’s expertise and experience.

In recent years, the programme has focused primarily on providing guidance on implementation of corporate anti-bribery programmes and related topics. However, it is now eight years since the introduction of the Bribery Act and many of our corporate stakeholders are well advanced in their implementation of such measures and do not need such guidance. To progress our work in this area, TI now needs to focus on pushing corporate standards further and encouraging companies to avoid complacency. Several of our stakeholders have indicated that they look to TI for guidance on how to continue to improve their response to the issue of corruption as well assisting them in horizon scanning.

As the Programme has focused extensively on the Business Integrity Forum and Corporate AntiCorruption Benchmark over the past few years and as adequate procedures under the Bribery Act have become a largely accepted part of business – the range and scope of engagement with the private sector has consequently narrowed to a relatively small group of stakeholders – being those involved in those two programmes. BIP needs to broaden the audience it speaks to in the private sector both in terms of the number of companies as well as the functions within companies. Additionally, another powerful way to influence companies, is by influencing the environment within which they operate – through media, public opinion and encouraging a robust legislative, regulatory and prosecutorial environment. BIP has not placed as much emphasis on these methods to date. As the programme develops over 2018/2019 we will increase our 13

involvement in this space.

3.2 Focus areas To ensure BIP achieves the objectives of driving standards forward and engaging with a wider private sector audience, all activities conducted under BIP must be referable to 3 core principles:  Thought Leadership: Developing the policy agenda to drive business integrity standards forward, both directly and indirectly through facilitation of others’ thought leadership.  Guidance: Providing guidance and practical materials to businesses about achieving current thresholds and working towards best practice business integrity standards.  Advocacy: Advocating for improved business integrity standards both through public commentary and direct advocacy with specific organisations and industries.

For the purpose of BIP activities, business integrity refers to activities directed towards tackling corruption and promoting transparency and, in limited circumstances, business ethics matters which arise in conjunction with corruption.

3.3 Activities and Outputs 3.3.1 Summary of outputs  Update and re-launch Corporate Anti-Corruption Benchmark with target of 17 participants in 2018 (with a longer term target of 50 over 3 years)  Develop and enhance the Business Integrity Forum, including exploring a new tiered structure of memberships and introducing a leaders forum tier (target of 35-40 members for 2018/19 and three year target of 50-60)  Develop a public and corporate communications strategy (incorporating direct advocacy with corporates and regulators, and indirect advocacy via other channels)  Publish Corporate Political Engagement Index of 106 companies and undertake follow up engagement  Maintain and further develop the Global Anti Bribery Guidance portal  Publish two new thought leadership corporate guidance projects  Ad-hoc training, lectures and speaking events 3.3.2 Corporate Anti-Corruption Benchmark This product is currently offered to participants primarily as a part of a premium BIF membership, with a small number of participants taking it as a freestanding product. We consider the Benchmark tool combined with the deep dive meetings into key topics to be a hugely valuable tool for corporate stakeholders – enabling participants to benchmark their ABC programmes against both TI’s recommended best practice as well as other participants’ programmes.

For the Benchmark to be truly impactful, it needs to achieve a significant number of participants and in this regard we are targeting 50 participants within three years. In order to drive significant take-up and to retain current participants, the product needs to be of the highest standard and offered in a form which is attractive and user friendly for corporate participants. Accordingly, during 2017 and 2018 we have conducted a review of the Benchmark and identified a number of important improvements to help drive take up by future participants and to retain current participants. The majority of these improvements will be implemented during 2018, including an overhauled question set and significant enhancements to the technological platform through which the results are provided to participants.

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Scaling the Benchmark to 50 plus participants requires considerable additional resources which TI-UK does not currently have. Nor would we want to carry the risk of fluctuations in subscriptions at this level. Therefore, in order to achieve scale, we intend to seek an external partner to work with us on delivery of the Benchmark, providing a technology platform, assisting in verification and data analysis, and helping with sales and marketing. We will either put that partnership out to tender during 2018 or look to incorporate the Benchmark within a more detailed strategic partnership. Suitable partner organisations are likely to be professional services or risk advisory firms. Ultimately, we see the potential for the Benchmark to become a global product which could be offered in collaboration with other chapters.

3.3.3 Business Integrity Forum Membership of the Business Integrity Forum (BIF) has remained relatively consistent in 2017 at 35 members, with 2-4 companies leaving and joining each year, and a core of around 15-20 longstanding members. Attempts to achieve greater growth in membership numbers has been unsuccessful historically. There are a number of perceived reasons for this lack of growth. BIF has become increasingly focused on corporate compliance departments - these departments face ever increasing budgetary constraints and many other forums and seminars are offered to the compliance community free of charge. In focusing on corporate compliance departments, the forum has also tended to focus its content on compliance standards.

In 2018/19 we will develop the content and format of our forum to attract the interest and engagement from a wider range of stakeholders within corporates. Accordingly, the content of our events will shift to focus more on thought leadership, horizon scanning and emerging trends in business integrity issues. It is important that TI is clearly seen to be setting the agenda of the forum in a proactive manner, whilst ascertaining that our content resonates with stakeholders – rather than merely offering content on demand. Additionally, TI around the world has an unparalleled wealth of expertise in this area, and there is an opportunity to capture it and convey it to members. For example, BIF makes little use of the annual CPI launch despite the CPI being a widely-used tool by the business community. We will also explore a new tiered structure for our corporate memberships – to enable organisations to engage with us on a variety of different projects.

New tier - Leaders Forum As part of our strategy to position BIP as the thought leader in corporate anti-corruption standards in the UK, we believe there is an opportunity to collaborate with leading CEOs and executive teams in UK and UK based companies who have progressive attitudes to business integrity standards. As such we are exploring a plan to establish a new top tier to our forum (a “leaders forum”). The purpose of this group would be to drive advancements in business integrity standards at the leading edge.

Details of a leaders forum tier are high level at this stage. However, we have taken general soundings on the concept with a number of likely invitees and the concept has been received very favourably. We will begin in earnest to scope out and plan the set up of this forum in Q1 FY18/19.

Membership of the leaders forum would be by invitation only. It is our hope that we will be able to attract the attention of CEOs of these organisations for the launch of the group and thereafter they will field members of their senior leadership team for ongoing meetings throughout the year.

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To identify suitable participants, BIP will compile a list of potential corporate members taken from the FTSE 100, the top 100 private UK companies and other private sector organisations which play a significant role in driving the business integrity agenda. We will conduct due diligence on all potential participants before finalising the list and will look to create a group which has a balanced representation of industries and is ultimately made up of approximately 30 members.

Strategic Partnerships Potential As an associated upside to building closer interaction between leading corporates and BIP, we anticipate that there is the potential to cultivate some significant strategic partnerships with a small number of corporate members. Suitable partners for this type of relationship would be firms which can demonstrate a genuine desire to progress the overall anti-corruption landscape in their industry, in certain jurisdictions or amongst corporate peers and which are willing to make a significant investment in key projects. As the potential for any such partnership develops, we will bring a detailed proposal about how such a partnership would work to the private sector committee for review and approval.

3.3.4 Communications & Advocacy Strategy Whilst TI-UK plays a role in public commentary generally, in recent years the BIP message has not had a high profile in public commentary, particularly via the media, about the role businesses should play in the fight against corruption and the standards which we expect businesses to be working towards. Additionally, whilst BIP has engaged with members of the BIF which have been involved in corruption incidents and allegations, it has not typically engaged directly with companies outside the forum to advocate change. Over the coming year we will work with our new Director of Fundraising & Communications to draw up and implement a comprehensive media and communications strategy to raise the profile of the Business Integrity Programme publicly to ensure our key policy positions are well publicised. This change in approach by BIP will involve a high level of collaboration between all the programmes within TI-UK and the GTNIs to ensure that a consistent messaging between programmes on corporate standards. We will also work closely with UKACP which has a strong advocacy approach to help develop our corporate advocacy programme. Our corporate advocacy programme will include advocacy both directly to companies as well as with regulators, law enforcement agencies, governments and intergovernmental agencies.

3.3.5 Corporate Political Engagement Index We will publish a 2018 CPEI, the work for which is funded by Friends Provident. The 2018 CPEI involves a significantly increased number of subject companies (approximately 100 as compared with 40 in the 2015/16 index). The phasing of the project is structured to allow subject companies a significant lead time to enhance their level of transparency in reporting of political engagement before their final scores are published. A report on standards will be published in the second half of 2018 and we will engage with both corporates and the UK government (through the UKACP team) to discuss the results and how standards can continue to be improved.

3.3.6 Global Anti-Bribery Guidance portal The Global Anti-Bribery Guidance portal was launched in October 2017 and supersedes our 2010 publication ‘Adequate Procedures Guidance: the UK Bribery Act’. The portal was also launched in Singapore, Hong Kong and Shanghai, with events held by its supporters and local TI chapters where available. As of February 2018 the site has had 17,458 unique visitors and 1,586 downloads. In 2018, funding from our corporate supporters is arranged to provide enhancements

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to the functionality and content of the site, including alignment with the Corporate Benchmark framework and inclusion of legislative guidance on the Bribery Act, FCPA and Sapin II. 3.3.7 Thought Leadership & corporate guidance projects In line with our objectives of driving business integrity standards forward and engaging with a wider corporate audience, we will deliver at least two additional projects during 2018. Those purpose of those projects will be to provide practical guidance to the wider private sector on how to tackle corruption risk in their business or to promote improved and forward thinking business integrity standards. We have funding for one such project already committed by a private sector donor – as indicated in the budget, and will look to fund the second with assistance from other donor(s) or from any increased funding received from our Benchmark, BIF or BILF. 3.3.8 Training and speaking events BIP has a solid reputation for training and public speaking on issues related to business integrity and anti-corruption standards for organisations. We will continue to provide ad-hoc training when approached by organisations to do so through our consultants and, where workloads permit, our in-house staff. We maintain a relationship with the London School of Economics and will deliver guest lectures for the University where appropriate. BIP and other TI-UK staff will continue to present our work and our views to the business community through leading conferences and TI events.

3.4 Resource requirements BIP is currently composed of 3 full time employees, a paid intern and a secondee from a BIF member. At the time of this report, one of the full time roles is vacant but the major project work for this role (CPEI index) is being covered by a temporary part-time consultant.

In order to achieve an ambitious plan of programmes for 2018, we require a modest increase in staffing in the immediate term. As such, we intend to upgrade the intern position in our team to a permanent junior role within the team in April. Additionally, the current vacancy in the team has led to a skills gap which results in escalating operational matters involving subject matter expertise unnecessarily to the programme director. Accordingly, we are look to fill the vacancy with an individual who has both direct anti-corruption experience and experience working in the corporate world. These changes to our team will allow us to deliver the 2018 plans as the programme develops and grows. Finally, if our proposed leaders forum gains traction amongst corporate stakeholders, we anticipate hiring a relationship manager to oversee the administration of this forum at a level which will be expected by the senior members of business who participate in this forum.

The net result will be a full-time permanent team of 5 staff, subject to revenues, supplemented from time to time by interns and secondees. We anticipate this will be the appropriate team size for FY2019/20, unless there is a substantial increase in activity from one of the areas outlined above, such as the Corporate Anti-Corruption Benchmark.

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Section B: TI Global Programmes (Global Thematic Network Initiatives – GTNIs)

Pharmaceuticals & Healthcare Programme (PHP) Defence & Security Programme (DS)

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4. Pharmaceuticals & Healthcare Programme (PHP) Programme Director: Rachel Cooper

Programme goal/objectives To reduce corruption in the global Pharmaceutical & Healthcare sectors

4.1 Background 2017/18 was a consolidation year for the Pharmaceuticals & Healthcare Programme (PHP).

Operating with minimal human and financial resources for much of the year, the Programme maintained excellent networks with a broad range of stakeholders across government, the private sector and civil society; successfully rolled out a second round of grants under the Health Action Fund; delivered the Programme’s first substantive input into the Research and Development space with the publication of the Clinical Trial Transparency Report; and successfully concluded negotiations for a £2.6M grant to support the Open Contracting for Health Initiative.

Following signature of the Open Contracting for Health (OC4H) grant contract, 2018/19 will see the PHP scale up significantly. Alongside the Inception and Year 1 phases of the OC4H project, we will review the 2016 Strategy to align more closely with the TI-UK Strategy for 2017-2020 and to define specific focus areas and fundraising opportunities triggered from the relationships and associated opportunities cultivated during the Programme’s start-up phase.

4.2 Focus Areas During 2018/19 our Pharmaceuticals & Healthcare Programme will prioritise four areas of work: i.

Proving the concepts underlying the OC4H approach through comprehensive implementation and evaluation of the initial stages of the grant ii.

Developing and pitching a robust case for an OC4H-scale intervention in another of the key priorities identified in the strategy review iii.

Establishing PHP as a repository of knowledge with and for TI Chapters and the broader TI Movement iv.

Building our network capital across the golden triangle of private sector, government and NGOs.

4.3 Activities and Outputs 4.3.1 Summary of Outputs  Updated PHP Strategy, aligning with the TI-UK Strategy 2017-2020  Open Contracting for the Health Sector (OC4H) Toolkit, providing governments and procurement staff with the skills and resources necessary to establish open contracting as the default in public procurement  Showcase data facilitating and signposting TI Chapters looking to scale up pharma/healthcare initiatives  Regular (monthly) blog contributions raising awareness and promoting discussion of corruption in the pharma and healthcare sector  Two smaller research projects  Recommendations on research methodologies and application for indices for the pharmaceutical and healthcare sectors

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Confirmation of Non-State Actor Status and application pending for Official Relations with the WHO.

4.3.2 TI Chapter Engagement The OC4H project will be substantially delivered by National Chapters. In Year 1 (to March 2019) we anticipate awarding grants totalling c£190k to 3 Phase 1 countries. Aside from our OC4H Chapter investment, we know that over 30 TI Chapters are or have been active in the pharmaceutical and healthcare sectors. We have begun to map this activity. In 2018, using a combination of electronic and hard media, we will capture this in a rolling ‘showcase’. We will ensure the showcase is of mutual value to active and non-active Chapters and to PHP, through sharing experiences and challenges, highlighting best practice and opportunities for peer collaboration and acting as a capacity statement for potential funders at national and PHP programme level. Funding permitting, PHP will use the launch of the showcase to deliver a third round of the Health Action Fund and to establish a process for handling TI Chapters looking for PHP’s support.

4.3.3 Private Sector Engagement The Latin American Business Principles for Promoting Integrity in the Pharmaceutical Sector (“Pharma Integrity Principles”) were launched in May 2017 with the ultimate objective of strengthening standards across the region and contributing to the goals of good governance and ultimately improved health care outcomes. FIFARMA are keen to move to implementation but have identified the need for an interim phase focused on consensus building in two prospective country pilots (for Mexico and Argentina) and development of an appropriate oversight mechanism for signatories to the Pharma Principles. Working with known consultants from the region and with logistical support from relevant TI Chapters, we will look at supporting this ‘strategic design’ phase for implementation of the Principles.

4.3.4 Pharmaceutical & Healthcare Index/Indices There are already a range of benchmarks/scorecards in the pharmaceutical and healthcare sectors, including e.g. national governance, performance and outcome data, the Access to Medicines Index, Gates’ Primary Health Care scorecard. To ensure that an index created by PHP adds maximum value and helps highlight and tackle corruption vulnerabilities in the healthcare value chain, in 2018 we will: i. assess how TI’s expertise in benchmarking might be adapted to the pharmaceutical and/or healthcare sectors; ii. research pre-existing benchmarks, their methodologies, and how they are produced and used; iii. assess whether PHP could add value by inserting transparency and corruption related questions into others’ indices which can then be normalised and aggregated

by PHP (i.e. extension of the CPI model) iv. make recommendations (and where appropriate develop implementation plans) for the production of pharmaceutical and/or healthcare sectors indices.

4.3.5 Open Contracting for Health (OC4H) During the initial 6-month Inception phase (to end March 2018) we have been establishing the core UK OC4H team and developing methodologies and processes for Year 1 of project implementation. Early scoping studies in up to four short-listed countries will inform the choice and ‘use case’ in up to three DFID priority countries. During the remainder of 2018, the OC4H team will work to: 20

i. ii. iii. iv. v. vi. vii.

establish local OC4H teams in relevant TI Chapters; define the nationally-tailored ‘use case’ for open contracting; harness the expertise and contribution of partners (especially the Open Contracting Partnership, the Open Government Partnership, the World Health Organization); develop the OC4H Toolkit to guide implementation of open contracting in the health sector at national level; provide priority countries with the skills and resources needed to start establishing open contracting; conduct scoping studies in potential year 2 countries; and consolidate relationships with DFID representatives and develop robust monitoring, evaluation and learning frameworks to facilitate high-quality and prompt reporting.

4.3.6 ‘Intractable Challenges’ (uncovering & tackling the most difficult corruption challenges) If PHP is to add real value to government-civil society-private sector interaction across the healthcare value chain, it needs to contribute to the identification of and solutions focused on the most intractable challenges in the prevention of corruption in the health sector. Some corruption types are symptomatic of absence, failures or breaches of process, regulation or registration.

Others are more symptomatic of entrenched practice, lack of accountability and cumulative impact. In 2018 we will continue to work on individual touch points and cross-cutting issues in the value chain. In particular we will cement our position as a ‘go to’ player including: i.

Within the TI Movement so TI Chapters and the Secretariat appreciate and use the GTNI as a centre of excellence for health-related enquiries; ii.

Through sustained and systematic engagement with the World Health Organization (WHO) to strengthen our application for non-state actor (and ultimately ‘official relations’) status; iii.

By regular exchange with key partners and potential donors; iv.

By the promotion of fora for ‘safe’ ethical debate and robust challenge of defensive and opaque practices.

And we will consider the role that PHP can play in defining, quantifying and contributing to the most difficult questions, including: i. how instances of corruption are prevented/treated by donor agencies, implementing organisations and beneficiaries; ii. the discourse on marketing ethics; iii. demonstrating the true costs of corruption at the interaction of patient and healthcare professional.

4.3.7 Corruption in the NHS As a Global Thematic Network Initiative (GTNI) PHP will also seek to complement the work of TIUK. Subject to funding, we will begin researching specific vulnerabilities in the NHS system, most probably, initially, how greater transparency in the work of clinical commissioning groups might improve integrity in public service and potential instances of corruption with the value-added of improved efficiency.

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The core PHP team has been supplemented with a four-person UK OC4H team.

PHP will also contribute funding for up to 2 staff positions per National Chapter for those involved in delivering OC4H; these staff will be answerable to or working under very close guidance of the PHP team.

Taking into account the confirmed sources of income from DFID (£775k – with contribution to support costs being made via the OC4H grant) and corporate (£80k), for the ‘base case’ financial planning, it is anticipated that PHP will require an additional £15k to break even.

The trust & foundation target for PHP to be delivered jointly with the central fundraising team is £40k (£15k net of costs); this also therefore forms part of the ‘base case’.

However, it is possible that the fundraising efforts will start to bring additional income during the course of the year, and we will take on interns and new staff as necessary to meet the Programme’s commitments. It is anticipated that this will include one paid intern and between two and four additional full-time staff if the funding is received at that level.

We will also explore the options for secondments from the Programme’s partners.

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5. Defence & Security Programme (DS) Programme Director: Katherine Dixon

Programme goal/objectives To increase transparency and reduce corruption in the defence & security sector internationally.

5.1 Background DS will continue to implement the 2016 Strategy. We now have the funding and human resources to deliver significant impact against all three programmatic goals. In 18/19 the programme will be employing Regional Programme Managers in Brussels, Beirut, Abuja and Lebanon, a Global Advocacy Manager in Washington, as well as seven person strong NAKO secretariat in Ukraine.

In total almost half the TI DS staff will be located outside the UK. At the same time we will be upgrading our internal support functions including through the arrival of a new Deputy Director and Operations Manager. This international team will be supported by a strong cadre of consultants and will be focussed on campaigning for more responsible defence governance, a greater focus on corruption as a source of conflict and insecurity, and a cleaner arms trade, underpinned by strong country programmes and our two indices the Government and Companies Index.

5.2 Focus areas Responsible Defence Governance With the official commitment of Colombia to joining a founding group of states, the global standards has the potential to take off next year. The priority will be securing other credible founding nations, ideally at least one leading regional power from Europe, Africa, and Asia, as well as fundraising to ensure we have the capacity to influence and shape this work properly.

Underpinning our work on the global standards is the Government Defence Anti-Corruption Index (GI), which will be updated and rolled out on a regional basis using an updated and much improved methodology.

Industry Integrity Team capacity will grow to five staff from April 2018, including one member of staff based in Washington. This will allow expansion into previously untouched areas relating to corruption in the arms trade and the defence industry; with two major new projects focussed on the Global North. While company conduct will continue to be an important element of the team’s work, there will also be a focus on exporting and importing governments in terms of procurement, enforcement and undue industry influence upon policymaking.

Conflict & Insecurity 2018 will be a year of growth for the C&I team. We now have well-established country programmes in Ukraine and Nigeria, and are in the process of establishing programmes in Tunisia and Mali, and a regional hub for MENA in Lebanon, with the appointment of permanent TI DS Regional Programme Manager.

We will be upping our game on shaping security policy debates through the appointment of a new Global Advocacy Manager based in DC, and will continue to work at a practical level with states providing security assistance and participating in military operations, from UN peacekeeping to 23

stabilisation missions. An interventions integrity toolkit, currently being developed, will provide analysis and guidance on mitigating corruption risks in military operations and security assistance and we will leverage the strong relationship with the British Army through the 77th Brigade, with a full-time secondee to support this.

Finally, we are currently developing a new line of work on the use of corruption as a tool of foreign policy enabling malign influence on state decisions and elite behaviour. This will enable us to address a crucial challenge to international security and stability.

5.3 Activities and Outputs 5.3.1 Responsible Defence Governance  We will be securing additional founding states beyond Colombia. We are testing interest in South Korea, Ghana and a number of European states.  We will continue to identify early adopters of the initiative and start to build more international momentum. We have already had useful scoping discussions with countries such as Australia, Japan, the UK, the U.S. as well as international organisations, such as NATO with whom we already work very closely.  Supporting all of the above, and subject to funding, will be two new regional TI-DS representatives in South America and Asia.  GI - We will carry out research for and deliver the results of TI Defence & Security’s largest project, the GI. Results will be launched in regional and thematic batches, starting with West Africa in mid-2018, to be followed by Eastern Europe. Our two-person GI team will lead on quality control, methodology, and content comparability, and our network of regional programme managers will work with chapters to ensure that for selected priority countries, the assessments are accompanied by dedicated advocacy strategies.

5.3.2 Industry Integrity  Defence Procurement Toolkit – This multistage piece of research will seek to address the highest risk areas within the defence procurement cycle through identifying global best practice and then applying it to fragile and conflict affected states.  The toolkit will aim to improve access to information focussing on Nigeria, Tunisia and Ukraine. Once complete, country specific recommendations will be made and capacity building and training offered for CSOs and government agencies. Module two will address how to mitigate the corruption risks from undue influence on the defence procurement cycle. Module three will address supplier selection, single source acquisition and monitoring contract implementation.  Defence Companies Anti-Corruption Index – The methodology for the next edition of the DCI has been revised to push the boundaries of expectation for companies. Those working on similar exercises from across TI have been consulted to align thinking and methodologies across the movement with the team closely working with TI-UK BIP on their corporate benchmark.  An initial pre-research advocacy exercise for the DCI will take place at the start of the FY, with research commencing in August. There will be an increased focus on transparency, public disclosure of information (such as beneficial ownership), incident response and implementation of anti-bribery programmes. Publication and advocacy for the index is planned for the beginning of 2019.

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Suspension and debarment – Using civil enforcement as a method of anticorruption is an underused tactic globally. The defence sector is particularly immune for a range of reasons, not least misplaced “national security” arguments. TI DS will identify best practice in civil enforcement, beginning with suspension and debarment; and then advocate for its use when cases arise.

Country programme – Using funding from DfID, TI DS will identify a country at high risk of arms trade corruption or diversion to conduct a bespoke advocacy campaign. TI DS will seek to work and build capacity of a national chapter in the area of defence corruption in the selected country.

Defence industry influence on US Middle Eastern foreign policy – This eighteen month Carnegie funded project will focus on the potential impacts of foreign policy making which is influenced by the defence industry. Revolving Door, campaign financing and lobbying will all feature in this study.

Defence industry influence on policy making (Europe) – This eighteen month project funded by the Open Society Initiative for Europe will address how the defence industry influences policy making in two European states. Research is about to commence on the first of these states – Italy. TI DS will work alongside the national chapters during the advocacy phase of the project. The Carnegie and Open Society Initiative projects will be complementary pieces of work.

5.3.3 Conflict & Insecurity  In the first half of 2018, we will complete and publish our integrity interventions toolkit, while socialising its content and recommendations with civilian and military intervention planners in Europe and the United States.  We will complete a pilot project analysing the use of corruption as a tool of foreign policy.

We plan to publish the paper later in 2018, and to use it to design and secure funding for a larger project analysing the ‘corruption as a tool of statecraft’ challenges stemming from Russian, Chinese and Saudi Arabian activities in Europe, south-east Asia and Africa.  We’ll also be stepping up our work in Nigeria with CSSF funding. Work this year will focus firstly on supporting the Air Force to develop and implement an institution-wide anticorruption action plan, and on winning similar commitments from the other defence institutions. We will also work with Nigerian civil society, researchers and journalists to push the government for much-needed changes in the oversight of defence spending.  In Africa, we plan to kick-start our work in Mali with an 18 month UNDEF-funded project helping national civil society organizations to build a platform that can constructively work with the government. We will also be looking at ways to persuade donors and intervening forces to address the links between corruption and conflict in the Sahel. We will begin with a series of research papers exploring the links between corruption in the Malian security forces, the government, and transnational trafficking in the Sahel, to demonstrate how this has fuelled the conflict.  In Ukraine, we’ll be working to support the success of NAKO now we have a fantastic new Secretary General in place, including research, fundraising and international advocacy.  In the MENA region, we’ll be collaborating with our chapter in Lebanon to launch a regional hub for work on defence corruption across the region. The new Regional Programme Manager will work to identify opportunities, develop and implement country strategies with chapters in the region (initially Lebanon and potentially also Jordan and Palestine) and to develop plans for regional advocacy, starting with the launch of the 25

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Arabic version of our report on corruption and conflict. They will also be supporting the development of a country programme in Lebanon.

We will be consolidating our work in Tunisia, building on relations already established with the government and our local chapter. Work this year will focus on holding a leadership day with the Ministry of Defence and providing guidance and technical support for the development of a code of conduct for the defence sector and support to the parliamentary defence committee.

In terms of military engagement, we will continue our work with the British Army’s 77 th Brigade through two more secondees, who will lead the work on counteracting corruption risks in the Army’s medical supply chains during interventions and on helping the Army take up the toolkit recommendations, especially in its planning processes and expertise generation.

And we also have big plans to develop our work on United Nations Peacekeeping. We have started to conduct an assessment of corruption risks related to United Nations Peacekeeping missions at the headquarters level, which will form the basis for high level advocacy to create the political will for reform in the UN and will allow us to make concrete recommendations for what reform should look like. We will build on this piece of work to plan for a subsequent assessment of corruption risks at an individual mission.

5.4 Resource requirements The programme is fully-funded with grants from, among others DFID, Dutch MFA, UNDEF, and Carnegie Foundation. The staff requirements for the year will be:  15 permanent staff in the UK by the year end  1 full-time secondment from the British Army  7 full-time posts in Ukraine, employed via TI Ukraine  1 full-time post in the Middle East employed via LTA (TI Lebanon)  1 full time staff in Nigeria employed via CISLAC (TI NC in formation)  1 full time staff in Brussels employed via TI EU (subject to their agreement)  2 full time staff in Washington employed via the Fund for Constitutional Government (migrating to TI-US if formed).

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Section C: Support & Resources Fundraising & Communications Finance & Resources

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6. Fundraising & Communications Director: Boris Pomroy

Goal (interim) To engage, educate and inspire TI’s target audiences in the UK in order to drive long-term engagement in our work and to match our income with our strategic ambitions

6.1 Background Forged from two previously distinct teams, the Fundraising & Communications team are brand new for 2018/19. Perhaps understandably then, the next 12 months will be focussed around the theme of “building the foundations for the future.”

6.2 Focus areas 6.2.1 Strategy and Team Development A significant thrust of the first half of the year will be in the development and approval of a whole organisation fundraising and communications strategy to take us up to, and beyond, the lifespan of the current TI-UK strategy. This will cover unrestricted fundraising and restricted fundraising for programmes, reflecting the operational protocol on coordination and responsibilities recently agreed around the GTNIs. In addition to the fundraising and communications team, the strategy will incorporate input from across the organisation, as well as close supporters and other key stakeholders.

Key aspects of the strategy will be to develop a sustainable funding base for the organisation, so that we re-balance our income from different areas, and do not suffer from sudden shocks when large grants for specific programmes come to an end.

There has been a lot of change within both the fundraising and communications teams over the last 12-24 months. With the Fundraising & Communications Director now in place and the teams amalgamated, there will be a focus throughout the year in building team identity, developing a shared identity and strengthening our core capabilities, systems and processes.

6.2.2 Fundraising The development of the new strategy will set the long-term course for fundraising across TI-UK. However, there is much that can and should be done ahead of its implementation to ensure that we capitalise on existing opportunities – particularly the low-hanging fruit – and maintain a steady revenue stream while developing the longer-term strategy. This starts with ensuring our fundamentals are in order – we will collect, process and analyse data in a way that is both GDPR compliant and supportive of our increasing impact; we will actively monitor and manage income and pipeline, creating a clear picture of potential future growth and allowing us to be proactive in our work; we will become donor-centric in the way we approach our fundraising.

In addition to supporting fundraising priorities across TI-UK’s programme areas, including our global programmes, there will be a particular focus on stabilising and then growing unrestricted income through the development of a major donor fundraising programme.

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The primary role this year is to generate unrestricted income for the organisation. 85% of the team’s revenue-generating capacity will be spent on this. It is anticipated that during each planning cycle, teams will plan with the central fundraising unit what support they will need to raise funds in the coming year; in FY18-19, the primary need is support for PHP, and therefore the fundraising unit has a target to raise £62k of restricted income in support of PHP, which will absorb 15% [tbc] of the team’s revenue-generating capacity, working closely with the PHP team.

In addition, a key activity will be stewardship of existing restricted and unrestricted noninstitutional donors, who are principally supporting UKAC. 6.2.3 Communications The fundraising and communications strategy will be central in developing a strategic communications platform, identifying our target audiences, putting together a coherent brand framework and starting to formulate key organisational messaging. Whilst continuing to generate high-quality opportunities to engage with our audiences and the wider public through the UK and global media, we will use the first half of the year to ensure we are delivering our basics well, focussing on: content planning, internal stakeholder engagement, our social footprint, and excellence and consistency in design.

We will look to launch the refreshed TI-UK website in the first quarter of FY18/19. It is envisaged this will lead to wider review of how we use and resource our digital platforms, particularly our social channels, and that we will use an external expert consultant to assist this review.

We will continue to offer support to our global programmes across all aspects of communications, in line with the operational protocol. We are also keen to do more to support our colleagues in TIS and across chapters and will be investing time to shape how this might look.

6.2.4 Events The Fundraising and Communications team will lead on the creation, development and delivery of TI-UK’s external facing events, including the annual lecture. We will use the development of the new strategy to review our current event output and put in place a long-term events plan for the organisation.

6.3 Activities and Outputs 6.3.1 Develop a Fundraising & Communications Strategy We will work alongside colleagues, the board, supporters and other relevant individuals to:  Identify and agree key audiences  Develop coherent brand identity for TI in the UK (recognising TI-UK’s relationship with TI-S and the wider TI movement)  Develop key messaging and campaign platform  Articulate scale of fundraising ambition  Identify fundraising pillars and potential sources of incomes (e.g. HNWI, Consumer etc.).

6.3.2 Developing a high-performing team We will:  Define roles and responsibilities of the newly formed team  Identify ways of working and expectations within the team, across TI-UK and with the TI-S and the wider movement 29

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Foster a sense of team identity and begin to develop a high-support, high-challenge culture Look at potential skills and bandwidth gaps and seek to fill through combination of individual development and recruitment.

6.3.3 Getting our basics right We will:  Invest time in ensuring we are collecting, processing and using data in a way that is GDPR compliant.  Embrace Salesforce to not only store data, but to analyse and utilize it in a way that maximizes our fundraising efforts.  Work with our colleagues across the organisation to ensure we are actively monitoring and managing income.  Develop a pipeline process that allows us to effectively manage progress against prospective donors and better forecast future income.  Put the processes, systems and training in place in order to begin to develop a ‘donor-centric’ culture for the organisation.  Begin to develop a more strategic view of our communications through the creation of a content calendar and message grid for the organisation.  Analyse our current social footprint to better understand our online audiences and how effectively we are in engaging them. This will feed into the wider fundraising and communications strategy.  Review our current design and creative output in order to better understand what is working and what isn’t, particularly beyond standard publications. We will use the results of this to inform the development of the fundraising and communications strategy.

6.3.4 Income Generation We will:  Support the realisation of £282k total net unrestricted income for TI-UK across 2018/19, plus £40,000 in restricted income for PHP  Use the occasion of TI-25 to support develop a fledgling major donor cultivation and fundraising programme, beginning with a thorough assessment of current external stakeholders, contacts and potential donors.  Review and, where necessary, update our due diligence process relating to potential donors to ensure it remains fit for purpose.  Work with each of the programme areas, including GTNIs, to evaluate how we best support and enhance programme specific fundraising, reduce duplication and exploit opportunities to fundraise across teams where appropriate  Review the value and impact of trust and foundation fundraising both to TI-UK programmes and to core fundraising, particularly in regard to the added-value from the fundraising team 6.3.5 Communications We will:  Continue to generate high-quality opportunities to engage with our audiences and the wider public via digital, print and broadcast media.  Generate opportunities for TI-UK colleagues to provide thought-leadership across a range of media and events.

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Launch the refreshed TI-UK website in the first quarter of the business year and continue to update and provide/co-ordinate ongoing content, design and maintenance support for all TIUK digital channels Develop our digital and social presence in line with recommendations coming from our internal review and the development of the fundraising and communications strategy Review with individual teams how best to support our global programmes across all areas of their communications and implement the recommendations Invest time in identifying how we might best support our colleagues in TI-S and across national chapters so they can better access the global media market operation out of London to amplify their messages.

6.3.6 Events We will:  Use the development of the Fundraising & Communications strategy as an opportunity to review TI-UK’s current event output and put in place a new long-term plan for events that is aligned to our organizational strategy.  We will deliver a high-quality Annual Lecture that takes into account the added opportunity of TI’s 25th anniversary.  We will look into the potential of hosting one or more fundraising, cultivation and/or thoughtleadership events specifically to celebrate TI’s 25th anniversary.  We will support and build on the Transparency International Supporters Network (TIPS).

6.4 Resource requirements Human resources - current  1 x FCD (New role in Q4 FY17/18, partially replaced approved headcount of Events Officer and Head of Development in FY 17/18 plan. It is envisaged in FY18/19 the FCD will spend approximately 65% of their time on fundraising and 35% on communications).  1 x Communications Manager with a focus on Press  1 x Communications Officer with a focus on design and content  1 x Head of Development part-time – Trusts and Foundations  1 x Fundraising Assistant (Fixed-term contract, headcount approved for Development Officer role in FY17/18 plan) Human resources - new  1 x Fundraising Manager – Major Donors (to be recruited Q3 subject to revenues permitting).

Rationale: During the first half of FY18/19 we will focus on: getting our fundamentals right; the development of a new fundraising & communications strategy; new income generation through identifying and converting ‘low-hanging fruit’; and the building of a major-donor prospect-pool for longer-term engagement. Once these activities are complete we will seek to recruit a new major donor manager to cultivate this prospect-pool and significantly build our capacity to secure significant unrestricted income in the future. As in all major-donor roles, this should be seen as an investment for the future, with significant returns only being realised after 12-24months of being in place.  1 x Communications Officer/Manager with a focus on digital and social (be recruited Q4 subject to revenues permitting).

Rationale: Whilst we certainly punch above our weight in generating high quality and high reach media opportunities, our wider communications platforms are more lightly resourced 31

and as a result, have perhaps less impact for the organisation than they could. None more so than in the digital space. Post the launch of the refreshed website and as part of the development of the fundraising & communications strategy we will be looking in depth at our digital and social footprint and bringing forward a series of recommendations of how we increase our impact. Subject to those recommendations it is our intention to recruit a new specialist digital communications resource to support our development.

Other significant resources  Digital media consultant (c £10,000) Digital media, including social, continues to grow in both scale and influence across the UK and beyond. Our own digital and social channels have been built and resourced in a piecemeal way to date – with only limited thought to how they interact with one another and in a way that increases our impact and moves us towards delivering on our mission. As part of the development of the fundraising & communications we will look to use external expertise and support to thoroughly review our current approach to digital and make recommendations on how we maximise our digital output into the medium term.

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7. Finance & Resources Director: Joe Ghandhi

7.1 Finance The finance team will need to respond to the challenge of managing large institutional grants, with the staff changes put into place at the end of FY17/18 becoming fully operational. The volume of financial transactions has grown in the last few months, with increased complexity and growth to continue through into 2018/19 and future years.

Given the increasingly onerous conditions DFID are imposing on grant reporting ensuring, we need to ensure that contracts are properly set up and capacity is in place for financial reporting and grant management. This is primarily the responsibility of the Finance Manager, a new position created in Q3 2017/18, working closely with the liaison points in each programme area.

The key objectives of the finance team will be to ensure that there is a framework for robust and timely financial monitoring and reporting to the Board, donors and the SMT. We achieve this we will need to:1. Ensure the structure, skills and systems of the Finance team are equipped to deal with the larger scale and greater complexity of transactions 2. Support programme teams in TI-UK on the financial management of the grants 3. Ensure that there is a consistent reporting framework for chapters for grant reporting, and that chapters are aware of donor reporting requirements 4. Ensure that the financial monitoring of projects is done on a timely, accurate and consistent basis.

7.2 Human Resources Our staff are our most important resource, and we need to ensure that we take all necessary measures to ensure that we give our staff the working environment, induction, skills and training they need to be effective in delivering programmes.

7.2.1 Training & development To ensure we meet the above objective, we intend to recruit a short-term (6-month consultancy) 40% FTE additional HR resource, who will focus on training and development to help us clear a backlog of planned training. This training and development resource will be on an initial 6 month contract, to be reviewed at the end of the period to determine whether the role should continue for a further period.

We will develop a training plan at the start of the year. There is a central pool of training funds which will be used for a) any compulsory all-staff/SMT training (e.g. mental health, GDPR), b) centrally-provided courses (e.g. project management) c) all-staff activities such as an off-site day. Each team will additionally provide for its specific needs, e.g. programme off-sites, personal training allowances for staff, team-specific training, etc.

7.2.2 HR systems and policies A further HR priority will be to obtain an HR system and database. We have undertaken the research over the last year, and have shortlisted two systems.

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We will also need to ensure our HR policies are updated, and to make any necessary adjustments to reflect the shift of staff to non-UK locations.

7.2.3 HR for overseas partners and staff Our 3-day PW HR provision covers the standard HR needs of the 40-50 UK-based staff. It does not have the capacity or expertise to advise on overseas staff, MoUs with National Chapters, overseas consultant contracts, etc. However, our model is changing, such that we now have more direct contact with overseas staff employed by other national chapters and related entities, but funded by TI-UK and its GTNIs. At present, the need for additional specialist HR advice is primarily felt in DSP, but over time it may well be required by other programmes. In Q1 we will assess how to provide for these additional needs within the parameters of the restricted project budgets.

7.2.4 Safeguarding The safeguarding incidents that have recently been brought to public attention about the culture and operations in other organisations within the UK and beyond, have naturally caused us to reflect deeply on our own organisation, and whether our existing policies, procedures, culture and awareness could be enhanced. We will be taking a number of steps to strengthen our procedures and approach, including consideration of whether a separate safeguarding policy is now required or if it remains appropriate to embed safeguarding within other policies and procedures as we do now.

As part of our review of safeguarding risks, we will look at the changing nature of TI-UK, which now has more overseas relationships with national chapters, consultants and contractors. We will also be working with the TI Secretariat to ensure that TI national chapters that are in receipt of grants from us or are significant delivery partners in our work also have in place appropriate processes.

7.3 Information Technology In 2017-18 we took steps to make our IT systems more resilient. However, we need to build on that. The absence of a dedicated IT resource in the organisation has meant we have been heavily dependent on an external consultant and our approach has been more reactive than proactive.

Whereas this has been a cost effective solution in the past, with staff based in non-UK locations, we will need a level of connectivity that we have not required to date, and our IT needs are growing more complex as we grow in size and our research and advocacy teams use more sophisticated tools and approaches.

Our first IT priority is to review what type of provision will give TI-UK a robust and continuous IT solution. This support might typically include helpdesk support as well as the server monitoring and overall control of the IT environment.

The next IT priority will to form an IT strategy to meet the anticipated needs of the organisation, which is likely to include the transition to O365 during 2018/19.

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7.4 CRM – Salesforce database We have commenced work in migrating a number of databases to Salesforce.

Our priority in 2018/19 is to continue this work and ensure that the organisation has a single database for all stakeholder engagement. Use of one database will make for effective stakeholder interaction and will also make it much simpler to comply with the requirements of GDPR.

7.5 GDPR A key task for the year will be implementation of the new GDPR regime. The organisation’s Data Officer is the Director of Finance & Resources, who therefore has primary responsibility for GDPR compliance. In implementing the GDPR regime he will work closely with the Director of Fundraising & Communications, to ensure that we have a Comms plan for existing stakeholders whose details we hold, and a plan for how we collect new data. All staff will receive training in GDPR requirements.

7.6 Office Environment   

Our current office environment is deteriorating, which is of concern to the staff and provides an unsatisfactory working environment.

This deterioration is in context of a large growth in staff numbers, putting considerable additional pressure on the existing space in the office.

Given this scenario, our priority in 2018/19 is to explore options, including refurbishing our existing space, hot-desking arrangements and moving offices. Our licence requires we give 6 months’ notice to vacate.

7.7 Resources The department has a total of six permanent staff, 5.2 FTE:  Director of Finance & Resources  Three finance positions (one part-time)  One Office Administrator  One part-time HR Manager These will be supplemented by:  One part-time, temporary HR Manager (training consultant, six month contract)  External IT consultancy.

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Section D: Directorate & Governance

Directorate Governance

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8. Directorate Executive Director: Robert Barrington

8.1 Key areas of focus The ED’s primary responsibility will be to oversee the delivery of all areas of this operational plan.

The ED is also primarily responsible for ensuring that the five organisational objectives in the Strategy are met:  To ensure that we are the UK’s turn-to organisation for corruption information, policy and opinion  To foster a world-class research, advocacy and programme capability in order to help us achieve this  To develop our human capital, ensuring that TI-UK has a high-quality, sustainable and satisfied workforce  To develop our network capital, forming and maintaining partnerships both externally and within the TI movement, that enable us to achieve our objectives  To achieve sustainable financing: we will put our finances on a sustainable footing, so we are not too heavily reliant on any sector or individual donor; this will require more innovative and energetic fundraising, as well as strengthened project management.

Among the focus areas for the year to contribute to these objectives over and above the oversight of the annual plan will be:  External representation, including fundraising and speaking at high-level events  Liaising with global TI movement: as TI-UK has grown, and the GTNIs it hosts have extended their relationships with other NCs, the relationship management between TI-UK and the rest of the TI movement has become an increasingly important feature of the Directorate’s work.  Building network capital, though high-level external meetings, with international groups and individuals who come through London, and UK-based stakeholders including politicians, donors, corporates, regulators, academics and others.  Internal coordination to ensure that TI-UK capitalises on being the home to four programmes to ensure there is an environment of learning and collaboration which enables TI-UK to be more than the sum of the parts. Implementing the newly-agreed GTNI operating procedures will be an important component to this.  Thought leadership and policy development. The ED plays a role in developing TI-UK policy positions, notably when we are faced by a new issue or an issue cuts across more than one programme. Likewise, the ED plays a role in long-term strategic thinking about the challenges of corruption that are not captured with in our existing plans and activities.

8.2 Areas for future development Three important areas which need further consideration within TI-UK and will form part of this year’s agenda are:  M&E: our approach to M&E has been reasonably effective, but we have an opportunity with the M&E requirements of the institutional grants to take a step forward in this area and combine it with a full life-cycle planning in which we learn from successes in our projects and build in the learning to new projects to achieve maximum impact.

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



Tech: one of our teams (UKAC) has a greater understanding than others of the impact of tech on facilitating and enabling corruption and the opportunities created by tech and open data for research, enforcement and accountability. However, we need both to increase the sophistication of our approach and to spread this across the organisation.

New issues: one of the drawbacks of our otherwise highly effective four-programme structure is that new issues that arise – such as corruption in overseas development – have no obvious home, even though many externally will look to TI-UK for views, comment and expertise.

This gap is already filled partially by the ED, but we require further internal discussion about how best to deal with this eventuality.

8.3 Resources The Directorate consists of two staff:  Executive Director  Executive Assistant.

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9. Governance Chair: Fiona Thompson

9.1 Background TI-UK often comments on the need for good governance, and therefore aims to have in place governance procedures that are both appropriate for an organisation of 40 staff, and represent best practice. This applies to the way in which we manage the board, the formal procedures such as the AGM and transparency about areas such as donations and our own advocacy. We received a 5* rating from Transparify for our website transparency, and aim to continue to operate to those levels.

9.2 Board recruitment The maximum number of Board members is twelve, and there are currently seven members.

Vacancies over the past twelve months have not been filled as the Board wished the incoming Chair to be an integral part of the selection process. Board members are typically recruited through an open recruitment process, overseen by the Nominations Committee with admin support from the staff. It is anticipated that new Board members will be recruited in the coming financial year.

9.3 Membership Membership numbers are around 85, which is below the Board’s preferred threshold of a minimum of one hundred members. Members play an important role in governance, through their voting rights at the AMM, and we will make a push on membership once we have in place our updated website which will have provision for easier application and payment.

9.4 Global governance As TI-UK has increased in size as a chapter, and given that it hosts two GTNIs and is based in a global hub, the management of TI-S and global governance of TI have taken on an increased importance. Relevant to this:  The Executive Director has been elected to the international Board for the period 2017-2020, and sits on the Board’s Governance Committee and Trends & Vision Committee  A TI-wide Governance Review, in two phases, is underway; the TI-UK Board expects to play an active role in feeding into this Review  The Chair remains the Official Chapter Representative (OCR) and will represent TI-UK at the Annual members Meeting.

9.5 Resources The Board is assisted by a qualified Company Secretary, who provides a greatly-valued additional resource to the Chair, and is remunerated through an honorarium.

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Annex I Budget summary

Budget 2018/19 Unrestricted Funds £

Designated & Restricted Funds £

Total Funds £

Total Income

863,341

4,048,526

4,911,867

Expenditure Direct Project costs Staff costs Premises Grants to local chapters & partners

22,919 776,088 64,152 0

1,532,305 1,510,350 119,256 873,603

1,555,224 2,286,438 183,408 873,603

Total Expenditure

863,159

4,035,515

4,898,673

182

13,012

13,194

205,459 205,641

1,150,000 1,163,012

1,355,459 1,368,653

Net Income / Expenditure Funds brought forward Funds carried forward

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Annex II Three-year outline financial plan Extract from the TI-UK Strategic Framework (updated with latest available numbers)

Area

2017-18 Budget/ 3-year Strategy

2017-18 Forecast

2018-19 3-year Strategy

2018-19 Budget

2019-20 3-year Strategy

442 508 1,340 477 155 2,922

540 416 2,000 167 87 3,210

500 600 1,900 1,200 200 4,400

961 581 2,170 917 282 4,910

500 700 1,700 1,500 300 4,700

380

205

450

205

500

6 6 6 3 6 15* 42 *plus staff wholly paid for by TI-UK but located in other chapters:, DSP-3

8 (3 p-t) 4 (1 p-t) 6 3 6 17* 44 *plus staff wholly paid for by TIUK but located in other chapters:, DSP8

7 8 6 4 8* 18* 51 *plus staff wholly paid for by TIUK but located in other chapters: PHP4, DSP- 5

8 (2 p-t) 8 (1 p-t) 6* 4 6* 15* 47 *plus staff wholly paid for by TIUK but located in other chapters: PHP8, DSP- 12, UKAC-4

7 8 6 4 8* 18* 51 *plus staff wholly paid for by TIUK but located in other chapters: PHP4, DSP- 5

TI-UK Members

120

85

145

100

170

Social media followers Inc. ED, DSP, PHP

25,000

21,000

35,000

?

50,000

40 16

35 15

40 20

36 17

40 25

Annual income £000s UKACP BIP DSP PHP Other TI-UK total Unrestricted reserves £000s Staff (permanent but not all FTE) Dir/Finance/HR (core) Comms/F’raising/M&E UKACP BIP PHP DSP/DS TI-UK total

BIP BIF/BILF members Corporate benchmark

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Annex III Organisational chart as of 31/3/18

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