Leadership and culture in combating corruption: a comparative analysis

Introduction

In reviewing the literature, Caiden (2012, p. 96) concluded that “the cultural dimension of corruption has been [neglected] for too long [and is] a poor relative of other studies”. Palmier’s 1985 pioneering comparative study of anti-corruption measures in Hong Kong, India and Indonesia ignored the role of culture in combating corruption in these countries/regions. In contrast, Lipset and Lenz (2000, pp. 114, 120) have emphasized the relationship between values and corruption and argued that “cultural variables help explain and predict levels of corruption”. Similarly, Rose-Ackerman and Palifka (2016, pp. 233-271) devoted a chapter on corruption as a cultural problem but neglected the critical role played by leadership and political will in curbing corruption (Quah, 2017, pp. 321-323). However, Rotberg (2017, pp. 223-256) focused instead on the contribution of political will in combating corruption without analysing in depth the impact of cultural factors.

In his comparative study of political leadership in Italy and Japan, Samuels (2003, pp. 2-6) describes leaders as political actors with more assets for “stretching” the “constraints of geography and natural resources, institutional legacies and international location”. Constraints limit their choices and “stretching” refers to how these actors mobilize existing resources in new ways. Using Samuels’ definition, have the political leaders in Hong Kong Special Administrative Region (SAR), Japan, Malaysia, New Zealand, Singapore and Taiwan, succeeded or failed to stretch the constraints to minimise the problem of corruption in their countries/regions?

Senior (2006, pp. 184-185) contends that political leaders play a critical role in changing the culture of corruption by making the laws and allocating the funds for enforcing these laws. However, if they have accepted bribes to fund their parties and themselves, they would not cleanse their colleagues or their nation of corruption. If the incumbent government in a country were committed to curbing corruption, it should demonstrate its political will and capacity by providing the anti-corruption agency (ACA) or other equivalent agencies with adequate legal powers, personnel and resources to enforce the anti-corruption laws impartially, without political interference.

Furthermore, Senior (2006, p. 187) also observes that corrupt political leaders are unlikely to demonstrate the required political will to curb corruption because they would be “killing the goose that lays the golden eggs”. Since they “control and exploit everyone and everything for personal gain”, corruption enables them to transform the economy into “an instrument of leader wealth creation” and claim as their own “the fruits of the nation’s labor” (Ben-Ghiat, 2020, pp. 12, 144). Similarly, Kellerman (2004, pp. 38, 44) describes corrupt leaders as bad leaders who advance their self-interests above the public interest and “lie, cheat, or steal” to acquire more of scarce resources by bending the rules and breaking the law.

As both leadership and culture are important in combating corruption, the six articles in this special issue of Public Administration and Policy focus on how these variables explain the success of New Zealand, Singapore and Hong Kong in minimising corruption on the one hand, and the failure of Japan, Malaysia, and Taiwan, on the other hand. After selecting the six countries/regions to analyse their effectiveness in combating corruption, Quah invited scholars who have published on this topic to contribute articles for this special issue (see Johnston, 1999; Carlson and Reed, 2018; Jones, 2020; Gregory and Zirker, 2013; Quah, 2020a; Ko et al., 2015). This article analyses the contribution of leadership and culture in minimising corruption in these countries/regions.

Perceived extent of corruption and contextual differences

Table 1 shows that New Zealand, Singapore and Hong Kong have much higher Corruption Perceptions Index (CPI) scores and percentile ranks for the control of corruption than Japan, Taiwan and Malaysia. New Zealand has retained its joint first position with Denmark and Finland on the CPI in 2021. Singapore is ranked fourth jointly with Norway and Sweden. Hong Kong is ranked 12^th, followed by Japan (ranked 18^th) and Taiwan (ranked 25^th). Not surprisingly, Malaysia’s performance on the CPI in 2021 has deteriorated in the wake of the 1Malaysia Development Berhad (1MDB) scandal as its rank has plummeted from 51^st to 62^th position, with its score declining from 51 to 48.

Apart from their perceived extent of public sector corruption, Table 2 describes the five significant contextual differences among the six countries/regions which affect the effectiveness of their implementation of anti-corruption measures.

First, in terms of land area, Singapore and Hong Kong are city-states of 709 sq. km and 1,050 sq. km in size, respectively. Second, both territories also have small respective populations of 5.68 million and 7.48 million. Only New Zealand has a smaller population, with 5.08 million persons inhabiting the third largest country of 263,310 sq. km. Third, except for Japan, which was not colonised, the British colonised Hong Kong, Malaysia, New Zealand and Singapore, and Taiwan was a Japanese colony for 50 years (1895-1945). Fourth, except for Malaysia, which has the lowest GDP per capita of US$10,412, the other four countries/regions are highly affluent with GDP per capita incomes ranging from US$59,797 for Singapore to US$28,383 for Taiwan. Fifth, Japan and Malaysia are constitutional monarchies, New Zealand and Singapore are parliamentary democracies, Taiwan has a presidential democracy, and Hong Kong is a SAR of China since July 1997.

Table 3 also shows that New Zealand, Singapore, Japan and Taiwan are more politically stable than Malaysia and Hong Kong. The World Bank’s indicator on political stability and absence of violence indicates in 2020 that New Zealand and Singapore have the highest percentile ranks (97.6 and 97.2), followed by Japan (87.3) and Taiwan (72.2). The lower percentile rank for political stability in Malaysia reflects its frequent changes of government during 2018-2021 and Hong Kong’s lowest percentile rank for political stability is the result of its political unrest in recent years. Furthermore, New Zealand, Singapore, Japan and Taiwan also have much higher total percentile ranks for governance than Hong Kong and Malaysia.

In sum, the policy contexts of New Zealand, Singapore and Hong Kong (small land area or population, with high GDP per capita) are more favourable than the policy contexts of Taiwan, Japan and Malaysia (larger territories and populations with lower GDP per capita) for combating corruption.

Effectiveness of anti-corruption measures in six countries/regions

There are three patterns of corruption control in the Asia Pacific countries/regions, depending on the anti-corruption measures employed, as shown in Table 4. The first pattern of combating corruption that relies on other agencies instead of ACAs is practised in Japan and New Zealand. New Zealand relies on the Ombudsman and Serious Fraud Office (SFO) to enforce the anti-corruption laws. Japan depends on the Special Investigation Departments (SIDs) of the Public Prosecutors Office to investigate corruption offences.

The second pattern of relying on more than one ACA is found in Taiwan, which depends on the Ministry of Justice Investigation Bureau (MJIB) and the Agency Against Corruption (AAC). The other eight countries which rely on several ACAs are Afghanistan, Australia, China, India, Pakistan, Philippines, South Korea and Vietnam.

The third pattern was pioneered by Singapore when it formed the Corrupt Practices Investigation Bureau (CPIB) in September 1952 to replace its ineffective predecessor, the Anti-Corruption Branch (ACB) of the Singapore Police Force’s Criminal Investigation Department. Table 4 also shows that pattern 3 is the most popular pattern because many Asia Pacific countries/regions have been attracted by the effectiveness of the CPIB and Independent Commission Against Corruption (ICAC) in curbing corruption in Singapore and Hong Kong, respectively (Quah, 2021, p. 20). Malaysia’s Anti-Corruption Agency, which was established in 1967, was replaced by the Malaysian Anti-Corruption Commission (MACC) in 2009.

The effectiveness of these anti-corruption measures depends on two factors: (1) the adequacy of these measures in terms of their comprehensive scope and powers; and (2) the political will and capacity to minimise corruption in the country. Anti-corruption measures would be adequate and effective if they were properly designed to address the causes of corruption and be sponsored and sustained by the political leaders (Quah, 1982, p. 175). For example, Singapore’s anti-corruption measures are adequate and effective because of the CPIB’s impartial and consistent enforcement of the Prevention of Corruption Act (PCA). On the other hand, the 1MDB scandal in Malaysia reflects the MACC’s failure to enforce the anti-corruption laws impartially. Relying on these two variables, a matrix of the anti-corruption measures in the six countries/regions can be constructed, as shown in Table 5.

Among the six countries/regions, New Zealand, Singapore and Hong Kong are more effective in minimising corruption, judging from their performance on the CPI in 2021 (see Table 1). New Zealand has retained its top ranking on the CPI in 2021 because of the effectiveness of the Ombudsman and SFO in minimising corruption and its emphasis on equality and egalitarianism. As shown in the fifth article by Quah, the effective CPIB constitutes an important component of Prime Minister Lee Kuan Yew’s zero-tolerance policy toward corruption, which was initiated in June 1960 with the enactment of the PCA in Singapore. Similarly, Hong Kong has emulated Singapore in replacing the ineffective Anti-Corruption Office (ACO) of the Royal Hong Kong Police Force with the ICAC to combat corruption in February 1974. As the police in both British colonies were corrupt, the breakthrough in minimising corruption was achieved by rejecting the British colonial method of curbing corruption by preventing both corrupt police forces from controlling corruption after 1952 and 1974, respectively. Unlike Singapore and Hong Kong, the police in New Zealand were not corrupt, as indicated in the fourth article by Gregory and Zirker.

In the first article, Johnston explains why the ICAC has been effective in enforcing the Prevention of Bribery Ordinance (PBO) 1971 in Hong Kong, even after its handover to China as a SAR in July 1997. As mentioned above, Governor Sir Murray MacLehose established the ICAC in February 1974 to replace its ineffective predecessor, the ACO, in the wake of the escape of a corruption suspect, Police Superintendent Peter Godber to Britain on 8 July 1973. Governor MacLehose’s leadership was critical because he accepted Sir Alastair Blair-Kerr’s recommendation to consider public opinion and establish an independent ICAC for political and psychological reasons. Lethbridge (1985, pp. 101-102) describes MacLehose’s decision as “path-breaking” because “governor after governor, committee after committee, had deferred to the police for a variety of reasons but principally because they feared a collapse of police morale if the control of corruption was handed over to an independent body”. Even though Yep (2013, pp. 215-216) considers MacLehose to be “an accidental hero” rather than “a zealous reformer”, his “key role in sanctioning the creation of the ICAC” should be acknowledged and his “unwavering budgetary support for the ICAC in subsequent years” has enhanced its effectiveness in combating corruption. Johnston concludes that the ICAC has been effective in curbing corruption in Hong Kong because of the extensive efforts of its Community Relations Department (CRD) to enhance the population’s awareness of the adverse consequences of corruption.

Japan’s structural corruption (kozo oshoku) (Bowen, 2003, p. 3) is built into its political system and results from the prevalence of money politics, which makes it among the most expensive in the world because Japanese political parties spend an average of over ¥900 billion (about £6.5 billion) per year on elections. As their official salaries are inadequate for financing their political activities, Diet members have to rely on their political parties to raise funds from firms, associations and individuals (Bouissou, 1997, pp. 133-134). Carlson has compared the different anti-corruption approaches of Prime Minister Tanaka Kakuei (1972-1974) and his successor, Miki Takeo (1974-1976) in the second article. He shows how Tanaka capitalised on the structural corruption in Japan to enhance the fortunes of the Liberal Democratic Party (LDP), his supporters and his political survival. In contrast, Miki was honest and sincere in reforming the corrupt Japanese political system but his two-years in power did not give him sufficient time to mobilise support and resources from his party to initiate and implement the necessary anti-corruption reforms to make a difference.

Japan signed the United Nations Convention Against Corruption (UNCAC) on 9 December 2003 and accepted it on 11 July 2017 (UNODC, 2021). As Articles 6 and 36 of the UNCAC require the State Parties to establish ACAs to deal with prevention and law enforcement against corruption (UNODC, 2004, pp. 10, 26-27), Japan’s reluctance to ratify the UNCAC after more than 18 years reflects its government’s reluctance to establish an ACA to replace the ineffective and inadequately staffed SIDs in Tokyo, Nagoya and Osaka (Quah, 2015, pp. 156-157). Indeed, the entrenched structural corruption in the Japanese political system is legitimised and accepted by many citizens and foreign residents as “part of the system” (Van Wolferen, 1993, p. 179).

Unlike the other five country/region studies, Gregory and Zirker criticise existing analyses of New Zealand’s reputation of being a clean country for being biased and incomplete by ignoring the exploitation and discrimination of the Māori and their culture by the dominant European (Pakeha) New Zealanders. As the oppression of the Māori population by the Pakeha establishment is a form of corruption, they contend that relying only on New Zealand’s performance on the CPI provides an ahistorical, mono-cultural and inaccurate picture of its perceived extent of corruption.

In the sixth article, Ko compares and evaluates the different approaches to combating corruption by President Chen Shui-bian (2000-2008) and his successor, President Ma Ying-jeou (2008-2016). Chen campaigned on an anti-corruption platform in the 2000 presidential election but became perhaps the most corrupt president in Taiwan’s history. In contrast, Ma was more sincere in minimising corruption in Taiwan and established the AAC in July 2011 in response to the corruption scandal in July 2010 involving three High Court judges, a district prosecutor and a former Kuomintang (KMT) legislator (Quah, 2010, p. 89).

Taiwan’s anti-corruption strategy is ineffective because of its irrational reliance on the MJIB and the AAC. The MJIB is a Type B ACA which performs both national security and anti-corruption functions. In contrast, the AAC focuses only on anti-corruption functions and is a Type A ACA. A government’s political will in combating corruption is reflected in the budget and personnel that it allocates to the ACAs. Taiwan’s anti-corruption strategy is irrational because the MJIB has been given a larger budget and more personnel than the AAC to combat corruption. More specifically, the MJIB’s budget of US$182.9 million was nearly 13 times larger than the AAC’s budget of US$14.2 million in 2017. Similarly, the MJIB had 2,339 personnel or almost 11 times more than the AAC’s 214 personnel in 2017 (Quah, 2020b).

A comparison of the AAC’s budget and personnel in 2014 with the budgets and personnel of the Hong Kong’s ICAC and Singapore’s CPIB, shows that the AAC’s per capita expenditure of US$0.59 is much lower than the ICAC’s per capita expenditure of US$16.59 and the CPIB’s per capita expenditure of US$5.36. This means that the per capita expenditures of the ICAC and CPIB are respectively, 28 times and 9 times larger than the AAC’s per capita expenditure in 2014. In the same vein, the AAC’s staff shortage is reflected in its highly unfavourable staff-population ratio of 1:117,150 compared to the more favourable staff-population ratios of the ICAC (1:5,333) and the CPIB (1:26,682) (Quah, 2020b). In other words, unlike the CPIB and ICAC, which are independent watchdogs that investigate all corruption cases impartially, the AAC is a paper tiger that lacks the necessary budget and personnel to perform its anti-corruption functions effectively.

Malaysia’s failure to curb corruption is manifested clearly in the 1MDB scandal involving Prime Minister Najib Rajak, who received US$681 million in his private bank accounts in March 2013 (Wright and Hope, 2019, pp. 341-342). Malaysia during Najib’s kleptocratic administration remains the poster child for rampant grand corruption among the six countries/regions, judging from its declining CPI scores in recent years. In the third article, Jones evaluates the anti-corruption measures introduced by Prime Minister Abdullah Badawi (2004-2009) and Najib and attributes their ineffectiveness to weak enforcement, the emphasis on prosecuting minor corruption offences, the obstacles in prosecuting major corruption offences, the culture of political interference in high profile corruption cases, and the close ties between ministers, political party leaders and their business cronies and associates.

In sum, the above analysis of the effectiveness of the anti-corruption measures in the six countries/regions is summarised in Table 5. First, the anti-corruption measures adopted in Singapore, New Zealand and Hong Kong SAR are effective because they are adequate and supported by the strong political will of their governments. In contrast, Malaysia’s anti-corruption measures are adequate but are not enforced impartially because of the weak political will of its political leaders, especially during Najib’s kleptocratic rule. Finally, the anti-corruption strategies in Japan and Taiwan are “hopeless” because the weak political will of Prime Minister Tanaka and President Chen is reflected in their reliance on inadequate and ineffective anti-corruption measures and their failure to address the causes of structural corruption in both countries/regions. Japan and Taiwan will continue to pursue their “hopeless” anti-corruption strategies until and unless their political leaders demonstrate strong political will to initiate more effective measures to address the causes of corruption.

Adverse consequences of corrupt political leaders

The analysis of how the six countries/regions have succeeded or failed in minimising corruption demonstrates clearly the important role of their political leaders in promoting a zero-tolerance policy toward corruption by Lee Kuan Yew in Singapore and Sir Murray MacLehose in Hong Kong. In contrast, leadership has played a less important role in New Zealand because of its emphasis on equality and egalitarianism among its population.

Prime Minister Badawi of Malaysia and President Ma of Taiwan were incorrupt themselves but they lacked the political will to implement the required reforms to address the causes of corruption in their countries/regions. Badawi introduced in 2004 the National Integrity Plan, which included the formation of the Malaysian Institute of Integrity (MII) to promote corruption prevention through education and training in both the public and private sectors in Malaysia. However, according to Jones, Badawi’s anti-corruption reforms were not implemented effectively because of his weak base in the United Malays National Organisation (UMNO) and resistance from his party elite.

Ma campaigned the 2008 presidential election on an anti-corruption platform and introduced several reforms. However, he was initially reluctant to establish an independent ACA because he believed that the existing agencies were effective. However, he reversed his decision when three Taiwan High Court judges and a district prosecutor were arrested for accepting bribes from a former KMT legislator in July 2010. Consequently, on 20 July 2010, Ma explained that he changed his mind regarding the creation of an ACA to strengthen the government’s anti-corruption efforts, to respond to public expectations, and to conform with international standards. Ma’s insistence that the new ACA would not be “a carbon copy” of Hong Kong’s ICAC or Singapore’s CPIB and should not report directly to the head of government was a serious error and reflected his failure and refusal to learn from the best practices of these effective ACAs (see Quah, 2021).

The pernicious influence of corrupt political leaders like Tanaka of Japan, Chen of Taiwan and Najib of Malaysia, is reflected in the irreparable damage they have wrecked on their countries/regions and their population’s quality of life. Tanaka was indicted in August 1976 for receiving bribes of US$2.1 million from the Lockheed Aircraft Corporation in the U.S. He was released after paying ¥200 million bail. He was sentenced by the Tokyo District Court to four years jail and a fine of ¥500 million in October 1983. He filed an appeal and was re-elected to the Diet in December 1983 with a huge majority in Niigata. In July 1987, the Tokyo High Court upheld the 1983 District Court ruling. Tanaka appealed against the High Court decision and the appeal ended with his death in December 1993 (MacDougall, 1988, pp. 197-198; Mabrey, 2007, p. 176).

Tanaka was the “most corrupt of Japan’s postwar prime ministers” and was one of the “shadow shoguns” (kagemusha) who “skilfully rigged the seemingly faceless, selfless system for their own gain” (Bowen, 2003, p. 6; Schlesinger, 1999, p. 13). He used the money earned from pork barrelling to finance his faction members’ election campaigns and to give gifts to his constituents on their birthdays, relatives’ funerals, weddings and festivals. He relied on “massive government funds to move mountains, bend rivers, pave rice paddies” in his native Niigata Prefecture (Schlesinger, 1999, p. 35) and consequently, dominated Niigata politics with the best organised koenkai (local support group), the largest LDP faction, and greatest influence over the Diet (Bowen, 2003, p. 37). His constituents in rural Niigata overlooked his corrupt offences because their “appetite for rural development” increased with the Tanaka “pork” they consumed for many years. They re-elected him each time with more votes after his conviction for bribery in 1948, his tax evasion in 1974 and his arrest in the 1976 Lockheed scandal (Bowen, 2003, p. 36). However, Tanaka escaped punishment for his role in the 1976 Lockheed scandal because his appeal against his conviction ended with his death in December 1993.

President Chen’s wife was found guilty in February 2009 of money laundering and wiring US$2.2 million abroad. Chen lost his immunity from prosecution after leaving office in May 2008. In September 2009, the Taiwan District Court found Chen and his wife guilty of corruption, money laundering and embezzlement and sentenced them to life imprisonment and fined NT$200 million. In June 2010, the Taiwan High Court reduced Chen’s life sentence to 20 years imprisonment and a fine of NT$170 million fine because the amount embezzled was less than that found by the District Court. His wife’s life sentence was reduced to 20 years imprisonment and a fine of NT$200 million. In December 2010, the High Court reduced Chen’s sentence to 17.5 years and a fine of NT$154 million (Quah, 2011, pp. 153-155).

Chen campaigned on an anti-corruption platform in the 2000 presidential election but succumbed to corruption during his two terms in office. He succeeded by neutralising the issue of Taiwan’s independence and made the election a referendum on “black gold” politics (Diamond, 2001, p. 4). From its founding, the Democratic Progressive Party (DPP) had opposed corruption and viewed the KMT as “a rich party that got its money from illegitimate sources” (Copper, 2007, p. 1). In his autobiography, Chen (1999, p. 1) condemned the KMT’s corruption and praised the DPP for being free from money politics and corruption. The DPP contested the 1992 Legislative Yuan election campaign effectively on an anti-corruption platform and relied on the same strategy in subsequent elections.

Unfortunately, Chen paid only lip service to combating corruption in Taiwan because he was corrupt and had received money from the Celestial Alliance, an organised crime group, because he believed that money was needed to succeed in politics (Copper, 2008, p. 24). The former chairman of Tuntex Group, Chen Yu-hao, revealed during the 2004 presidential election campaign that he had “secretly given Chen Shui-bian money in 2000” and “funnelled” NT$20 million into the DPP-affiliated Formosa Foundation (Copper, 2009, p.12). Consequently the DPP was viewed as a corrupt party and Chen’s administration was seen as “venal and dishonest” after the 2004 presidential election because of the increase in corrupt activities. Both Chen and his wife were found guilty of corruption, embezzlement and money laundering and were sentenced to 17.5 years and 20 years’ imprisonment, respectively, and fined. Not surprisingly, Chen did not show any remorse for his corrupt behaviour and his wife’s corruption offences during his interview with Ko in the sixth article.

In July 2015, the Wall Street Journal reported US$681 million were transferred to Najib’s private bank accounts in March 2013. In May 2018, the police confiscated US$274 million in luxury items and US$28 million in cash from the Najib family’s apartments. The MACC arrested Najib in July and his wife in October 2018 to assist them in investigations. In July 2020, Najib was convicted of seven charges for misappropriating RM42 million. He was sentenced to 12 years in jail and fined RM210 million. Najib filed an appeal and is out on bail of RM2 million (Wright and Hope, 2019, pp. 341-342, 406; Straits Times, 2020, p. A18).

In 2008, UMNO, the dominant party in the ruling coalition, the Barisan Nasional (National Front), was re-elected into power and Najib became prime minister in 2009, succeeding Badawi. In September 2009, the Terengganu Investment Authority became a national investment fund known as 1MDB, which was fully owned by the government with Najib as the Chairman of its Board of Advisors (Jones, 2020, p. 60). As mentioned above, US$681 million was transferred into Najib’s personal bank accounts in March 2013, followed by the deposit of another sum of US$11.1 million into Najib’s accounts by SRC International in December 2014 (Teh, 2018, pp. 183, 249). On 1 March 2016, The Wall Street Journal reported that more than US$1 billion from the 1MDB was deposited into Najib’s personal bank accounts. On 28 March 2016, the Australian Broadcasting Corporation (ABC) News confirmed that Najib had received a total of US$1,050,795,451.58 in his personal bank accounts from January 2011 to April 2013 (Teh, 2018, pp. 251-253). ABC News was concerned that “so much money was pouring so rapidly into the Malaysian Prime Minister’s personal banking accounts that it rang internal money-laundering alarms inside AmBank, a major Malaysian institution part-owned by Australia’s ANZ (Australia New Zealand Bank)” (Teh, 2018, p. 254).

Najib covered up the 1MDB scandal by removing from office the Deputy Prime Minister, four ministers, the Attorney-General, and some junior officials during 2015-2016 to prevent them from revealing evidence of corruption or convening a public inquiry. The government also hindered investigations by withholding documents and computer files and influencing the investigators in the National Audit Department and the MACC to change their findings or abandon their investigations (Quah, 2020c, p. 12). The government’s attempts to conceal the 1MDB scandal enabled the opposition political parties to criticise the 1MDB investment policies and increase public suspicions of malpractices in its financial dealings. The adverse publicity following the exposure of the 1MDB scandal angered many Malaysians and contributed to the defeat of Najib’s government in the May 2018 general election (Weiss, 2019, pp. 144-145).

Does culture matter in fighting corruption?

In the past, culture was viewed as a “residual” factor to explain people’s attitudes toward productivity and other issues. More recently, culture is now viewed as an important factor contributing to corruption when gift-giving and family ties influence individuals to give or receive bribes. As gift-giving is an accepted social tradition in Hong Kong, Japan, Malaysia, Singapore and Taiwan, it is difficult to distinguish between a gift and a bribe in these countries/regions. Furthermore, apart from promoting reciprocity in social relations, gift-giving also encourages bribery among civil servants, who accept gifts provided by those wishing to reduce red tape or to obtain licences or permits improperly.

However, among these five countries/regions, the impartial enforcement of the regulations discouraging gift-giving among civil servants varies considerably, with the strictest enforcement in Singapore, on the one hand, and the weakest implementation in Japan, on the other. In Singapore, gift-giving is identified as a form of gratification in section 2 of the PCA and civil servants are prohibited by the staff conduct and discipline rules from receiving gifts or entertainment from members of the public (Quah, 2011, pp. 219-220). Consequently, the past practice of the giving of ang pows (small red envelopes containing money) during the Lunar New Year to postmen, deliverymen, and garbage collectors, in appreciation for their services, has been discouraged. When Lee Kuan Yew became prime minister in June 1959, he received many gifts from well-wishers. However, he refused these gifts to set an example for his colleagues, civil servants and Singaporeans.

The culture of gift-giving in Japan is manifested in the biannual practice of seasonal gifts in midsummer and end of the year, and the elaborate gifts for those attending weddings and funerals. The anthropologist, Harumi Befu, has identified 37 occasions when Japanese give ceremonial gifts (Davies and Ikeno, 2002, p. 235). He attributes the Japanese penchant for gift-giving to the customary practice during weddings and funerals and the end of the year. Furthermore, those receiving gifts at weddings and funerals are expected to reciprocate by giving gifts to the givers on future occasions. Gifts also express the receiver’s appreciation for a past favour by the giver and those who fail to reciprocate are chastised for ignoring social norms. As gift-giving is “a social lubricant” in Japan, the regulations imposed by the government and companies to prohibit gift-giving are not enforced strictly because they contradict all the social norms. Indeed, those persons who obey these regulations have to justify their behaviour as they would be viewed by many Japanese to be “a bit odd” for refusing to accept gifts (Quah, 2011, p. 51).

In Taiwan, guanxi (connections) influences vote-buying and encourages corruption among the population. As gift-giving is also an important social tradition in Taiwan, it constitutes a powerful combination with guanxi and makes it difficult for the MJIB and AAC to distinguish between gifts and bribes. Vote-buying is an important form of corruption in Taiwan as money, meals and other gifts are exchanged for votes (Wu and Huang, 2004, p. 757). Faction leaders and candidates rely on vote-brokers to influence voters to vote for them. Vote-brokers are rewarded by the candidates with money, gifts, banquets and trips during election campaigns.

Vote-buying is important in Taiwan’s local elections because it reinforces the connection between guanxi and gift-giving. Most of the votes in rural elections in Taiwan are based on guanxi as candidates cannot buy votes unless they have a close guanxi with the voters (Jacobs, 2008, p. 177). Voters accept vote-buying because their close guanxi with the candidates makes them view the money offered as a gift and not a bribe. Nevertheless, gift-giving reinforces the personal relationships between the candidates and voters, and cast “the shadow of corruption over elections” in Taiwan (Rigger, 1999, p. 88).

However, vote-buying remains a chronic problem in Taiwan because 6,775 persons were prosecuted for vote-buying during 2011-2020, with the highest number prosecuted in 2011 (1,259 cases), 2015 (1,725 cases) and 2019 (1,710 cases) (MJIB, 2021, p. 167, Table 2-18). In 2020, 212 persons were prosecuted for vote-buying, with 15 persons violating the Presidential and Vice-Presidential Election and Recall Act, 60 persons breaking the Civil Servants Election and Recall Act, 135 persons charged under the Criminal Code, and two persons were prosecuted for bribery under the Farmers Association Act (MJIB, 2021, p. 171, Table 2-19). In sum, as the powerful combination of guanxi, gift-giving and vote-buying constitutes an important cause of corruption in Taiwan, anti-corruption efforts will only succeed if the political leaders enforce impartially the regulations for controlling these three aspects.

As 92 per cent of Hong Kong’s population is Chinese, the ICAC’s CRD is concerned with enhancing the population’s awareness of the adverse effects of corruption and to discourage them from accepting those cultural values and practices which nurture corruption in Hong Kong. As the Chinese have been conditioned for many centuries to using personal connections to get things done, what was important were the moral or folk norms of an individual’s informal social network and not the legal codes. Consequently, government officials were perceived to be corrupt instead of being honest and could be bribed to get things done (Lee, 1971, pp. 80-83). For many Hong Kongers, it was acceptable to pay “tea money” or “convenience money” to government servants to obtain benefits. Bureaucratic and police corruption was widespread and working class people, including hawkers and taxi drivers, had to pay bribes to survive (Chan, 2005, p. 97).

A 1971 survey of a random sample of 1,065 respondents in the middle and lower class community of Kwun Tong found that 29.2 per cent of them viewed corruption as a serious social problem. Furthermore, the older and less educated respondents who were traditionally oriented were more likely to accept corruption as a normal practice (Lee, 1971, pp. 77, 87). Apart from convincing the older, less educated and more traditionally oriented Hong Kongers of the adverse consequences of corruption, the other important challenge facing the ICAC’s CRD was the giving and taking of commissions by employers and employees in the business sector for more than a century in Hong Kong. According to the Prevention of Corruption Ordinance 1948 and the PBO 1971, the payment or receipt of business commissions without the approval of the principals or employers of both the payer and payee is prohibited (Lee, 1971, pp. 92-93).

The business community in Hong Kong was initially apprehensive with how the CRD would deal with the common practice of paying commissions by firms for services rendered. With the control of public sector corruption, the ICAC focused its attention on private sector corruption when the number of such cases increased to 1,153 in 1988. The investigation of several high profile private sector fraud cases by the ICAC during 1984 to 1994 reinforced the importance of the contacts established by the CRD with the industrial and commercial sectors. The CRD’s extensive liaison with diverse private sector companies resulted in the establishment in 1995 of the Hong Kong Ethics Development Centre to handle liaison work with the professional and commercial organisations (Scott, 2013, pp. 95-96).

In Malaysia, the culture of corruption is linked to “money politics” i.e., the reliance on vote-buying by the political parties to secure their electoral victories. The “spectre of money politics in Malaysia” is reflected in the “lavish campaign spending, vote-buying or the award of contracts to vested interests”. Former Prime Minister Mahathir Mohammad, who was the UMNO president from 1981-2003, admitted that “practically everyone who was elected to the [UMNO] Supreme Council in 2009 won because they used money. So you can say that [the] UMNO central committee is actually made up of corrupt people” (Transparency International Malaysia, 2010, pp. 65-66).

Political parties in Malaysia require funding for administering their machinery, voter education, policy analysis and training of candidates. During election campaigns, the parties and their candidates manage the operations centres, and advertise and communicate their messages to voters. These activities are financed by the collection of membership fees, donations from businesses and individuals, contributions in kind, fund-raising dinners, publications sales, and the candidates’ personal funds. In addition to the distribution of money for buying votes and support during elections, money politics in Malaysia also includes the involvement of political parties and politicians in corporate business activities (Transparency International Malaysia, 2010, pp. 70-71).

The origin of money politics in UMNO can be traced to the 1984 contest for the deputy presidency of UMNO between Musa Hitam, the UMNO Vice-President, and Tengku Razaleigh Hamzah, the Finance Minister. Their campaign was the “dirtiest to date” and involved the offer of free meals, death threats and massive vote-buying. It was estimated that the amount spent on vote-buying exceeded US$20 million (Transparency International Malaysia, 2010, pp. 75-76). In the 1MDB scandal, the huge amounts of money deposited in Najib’s personal bank accounts were ostensibly donations for the UMNO to use in its electoral campaigns. In reality, Najib and his wife had used these funds for their personal purposes as the police had confiscated US$274 million worth of luxury items and US$28 million in cash during their raid of Najib family’s apartments in May 2018.

In sum, culture constitutes a serious obstacle to curbing corruption if the political leaders are corrupt (like Prime Minister Tanaka, President Chen and Prime Minister Najib) and lack the political will to enforce impartially the regulations prohibiting gift-giving, vote-buying and money politics in Japan, Taiwan and Malaysia. On the other hand, Lee Kuan Yew’s zero-tolerance policy toward corruption in Singapore is effective because it addresses the causes of corruption and provides the CPIB with the necessary legal powers and resources to minimise corruption without political interference and regardless of the offenders’ position, status or political affiliation. Similarly, Hong Kong’s three-pronged strategy adopted by the ICAC is also effective in curbing corruption in both the public and private sectors.

Conclusion

What is the role of leadership in combating corruption in the six countries/regions selected for this Public Administration and Policy special issue? The comparative analysis shows that these six countries/regions can be divided into three groups. First, the experiences of Singapore and Hong Kong show that leadership plays a critical role in minimising corruption in both city-states. Second, in New Zealand, leadership does not play an important role in combating corruption because its top ranking on the CPI can be attributed to the importance of the values of equality and egalitarianism and its effective Ombudsman and SFO. However, Gregory and Zirker contend in their article that this view of New Zealand’s effectiveness in curbing corruption is biased and ignores the discrimination of its government toward the Māori population, which constitutes a form of corruption too.

Third, the situation is “hopeless” if the political leaders themselves are corrupt and exacerbate the situation by perpetuating their corrupt behaviour with impunity. In Japan, the late Prime Minister Tanaka Kakuei is surprisingly viewed as a “folk hero” by many Japanese in spite of his corrupt behaviour and lack of accountability for his corruption offences. President Chen Shui-bian of Taiwan broke his campaign promise to fight corruption after winning the 2000 presidential election and continued his corrupt behaviour until the end of his second term in May 2008. Even though he was imprisoned for his offences, Chen has not apologised or shown remorse for his corrupt behaviour.

However, the corruption offences of Tanaka and Chen pale in comparison with the much larger amounts of money embezzled and laundered by Prime Minister Najib Razak of Malaysia through his involvement in the 1MDB scandal. Like Tanaka and Chen, Najib is also not remorseful and claims instead that he is innocent and the charges against him are politically motivated. He was found guilty of misappropriating RM42 million in July 2020 and sentenced to 12 years imprisonment and fined RM210 million. Instead of spending his days behind bars, Najib is free to campaign with impunity for his UMNO colleagues in the recent state elections in Malacca and Johor because he filed an appeal and is out on bail of RM2 million.

In the final analysis, kleptocratic leaders like Tanaka, Chen and Najib are the bane of their countries/regions because the lack of accountability for their corrupt behaviour shows that corruption pays and that their beneficiaries would also be unwilling to implement the necessary reforms to eliminate the “structural corruption” in Japan, Taiwan and Malaysia. Without a strong dose of political will, no country/region, including Singapore and Hong Kong SAR, can succeed in minimising corruption, which remains an impossible dream.