TESTING INTEGRITY – a tool to reduce the risks of corruption
Note by Denis Osborne, 2005, revised 2007
In integrity tests, a ‘pretend criminal’ or ‘agent provocateur’ offers the temptation of
a bribe1. These methods have been found necessary and effective in the New
York City Police Department and the Metropolitan Police in London. The objective
is to deter people from corrupt actions in future by giving advance publicity to the
introduction of such tests.
NEW YORK – the New York City Police
The New York City Police Department (NYPD) is the largest police department in
the United States. In the 1980s the NYPD had a poor reputation and was thought
very corrupt, and New York had a very high level of crime. In 1994 a new mayor
brought great improvements and a remarkable decrease in crime.
The
programme included the use of integrity tests.
In the tests agents were employed to act as members of the public offering bribes,
but with hidden cameras to record the police officer’s response. Officers who took
the bribe were dismissed and prosecuted. Officers who did not take the bribe but
failed to report the offer were dismissed or disciplined in other ways (the failure to
report being a breach of the police force regulations). The police were told that the
tests would be introduced. There were some 1,500 to 2,000 tests a year for a
police force of over 40,000, but rumours went round that there were very many
agents. Many officers were afraid that they might get caught, and stopped taking
bribes. That was the objective – to stop police from taking bribes, not to catch
them. It is claimed that the action was cost effective.
Careful arrangements were made for the tests, with legal advice to ensure that the
level of entrapment would not prejudice prosecution in court. Support was at hand
nearby to help if an agent felt threatened. Informing the police and public about
the tests made it clear that the objective of the testing was not to catch offenders
for corruption, but to prove integrity or to help officers who might be tempted to
take bribes. Agents were used with care so that they would not become known
too easily and put at risk.
In random tests in New York about 1% of police officers accepted bribes, despite
having been warned of the tests. In tests targeted on police about whom there
had been allegations of corruption, about 25% took bribes. Officers were required
to report any bribes offered to them and the number of such reports increased by
300% when the test was introduced. The statistics suggest that:
with the test in place not many officers were acting corruptly;
several now reported bribes when they were offered, but had not done so
before the tests began;
Integrity Tests: a short note by Denis Osborne
intelligence used for targeting suspects was good;
police did not detect which bribes were offered by undercover agents.
A personal interpretation of the increased number of reports of offered bribes is
that the police may have taken such bribes in the past, but that when they feared
integrity testing they refused them and reported the offers. That suggests that
integrity tests cut bribe-taking by police by 75%, or more if members of the public
(who knew of the tests) offered bribes less frequently.
LONDON – the Metropolitan Police
In 1997, when evidence came to light of substantial corruption in parts of the
Metropolitan Police in London, similar tests were introduced. These included
targeted tests on suspected officers. In London the tests were known as ‘quality
assurance’. Tests for quality assurance covered not only possible corruption but
also fair treatment of racial minorities and other standards of service. Staff from
other police forces 'acted' as citizens needing police assistance.
INDIA – defence contracts
Private initiatives on these lines may also expose corruption. That happened, for
example, in India in March 2001. An internet company showed video-film on a
website giving evidence of corruption.
To get this evidence2 … the company disguised its reporters as weapons dealers,
gave them piles of cash and dispatched them to expose corruption in India’s
political and military establishment. The … journalists, posing as slick arms
merchants from London, started at the bottom of the corruption chain, working
their way up into a network of military officers, politicians, bureaucrats and fixers –
many of whom seemed interested in making money on the side for themselves or
their parties. The result was hours of videotape that captures defence officials
accepting bribes for arms contracts – an exposé leading to the resignations of two
cabinet ministers and calls for the government to step down. However such
results may not be sustainable. It is said that one of the two cabinet ministers
dismissed because of the scandal has since been reappointed to the cabinet.
Such initiatives may be applauded, but there is a risk that journalists, looking for a
story, may jump to conclusions and destroy reputations with insufficient evidence.
It is helpful if staff recognise that integrity tests arranged by the government or the
management could help protect them from malicious and false reports. When an
organisation is believed by the public to suffer from widespread corruption the
allegations of corrupt practice may be exaggerated. Integrity tests enable top
managers to declare the proven integrity of the organisation and can help win back
good reputations and restore public confidence. Official tests may make
2
Notes prepared originally for seminars, © Denis Osborne, 2005
Integrity Tests: a short note by Denis Osborne
journalists and others think their efforts less necessary, and make it easier to
refute untrue claims.
Integrity tests are tough. Some object to them as a challenge to individual human
rights. In some countries the results of such tests are not allowed as evidence in a
court. Even so such tests may be used to find which officers are most likely to
take bribes in a ‘real life’ situation and then to target the resources of further
intelligence and investigation to get valid evidence.
THE RELEVANCE FOR MANAGERS
Intelligence tests may be necessary conditions of service for the police, the
judiciary and others in sensitive positions in order to protect society from the
ravages of corruption. Every effort should be made to win the support of staff –
the police officers – and of the public for such tests, explaining that they are aimed
at proving the integrity of police behaviour and winning back public trust.
Where it is said that foreign business representatives have to pay massive bribes
to win government contracts, an anti-corruption agency may seek the co-operation
of some representatives and their companies to offer bribes as integrity tests, the
offers and the responses of officials or political leaders being recorded.
Similar methods may lie within the discretion of managers, but need to be handled
with care. Lawyers should be asked to for advice to ensure that cases will not fail
in court through allegations of unsafe evidence or unfair entrapment. The staff
needs to be consulted and convinced that such measures will help to protect them
and the department from unfair suspicion or scandal.
Managers may initiate similar programmes on less controversial aspects of quality
assurance, with members of the public paid to seek the services provided by a
department and report on the quality, speed, friendliness and competence of the
staff with whom they deal. Such measures are similar to the monitoring of
telephone calls to ensure quality of service. They need not be directed specifically
at corruption but could provide evidence of corruption if it occurs as well as other
failings in management. Again, such measures are likely to succeed best if
employees are consulted first. Employees must be told if the introduction of such
tests is to help them change past patterns of behaviour and prove any new-found
integrity.
1
This note on integrity tests incorporates information given in seminars at RIPA International, London,
between 2001and 2003 by Kevin Ford, of Goldman Sachs, formerly of the New York City Police Department,
and Michael Taylor and Max Irwing of the Metropolitan Police in London.
2
For example, The Bangkok Post, March 17, 2001, page 9 and March 18, page 5
Notes prepared originally for seminars, © Denis Osborne, 2005
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