ONE of Lee Kuan Yew's most significant achievements was to fight graft at all levels of society and try to weave incorruptibility into the fabric of Singapore culture.
A month after his passing, we commemorate this achievement.
The former prime minister saw a "zero tolerance" approach to corruption as a strategic comparative advantage for Singapore in attracting the investments of multinationals to a region rife with ingrained practices of bribery, kickbacks and facilitation payments - long before the term "zero tolerance" gained modern popularity in compliance parlance.
The political will behind Mr Lee's vision of a corruption-free Singapore, the importance placed upon the independence and effectiveness of the Corrupt Practices Investigation Bureau (CPIB), coupled with the aggressive enforcement of the Prevention of Corruption Act, made for a potent combination that saw Singapore ranked high in international anti-corruption surveys for many years.
The CPIB recently released statistics indicating that levels of corruption in Singapore were stable and under control despite various high-profile bribery cases involving both public servants and private enterprise that may have disproportionately skewed public perception of Singapore's pristine image.
It appears that complaints about corruption in the private sector numerically outstrip concerns in the public service, and - given the CPIB's professed intent to develop an anti-bribery package for business - the private sector could form the focus of the CPIB's prevention and enforcement activities going forward.
Efforts are reportedly underway to review the Prevention of Corruption Act, boost the manpower of the CPIB by one-fifth and establish a one-stop anti-corruption reporting centre in the coming year.
Areas of potential legal reform include establishing a clearer and simpler threshold for proving corporate liability, recognising compliance programmes as a legal defence or mitigation measure, broadening the extraterritorial effect of the laws, and imposing personal liability on senior management for lapses in oversight.
In looking ahead to Singapore's efforts to establish itself as a corruption-free centre for regional and international business, it is instructive to examine Mr Lee's thinking when setting out Singapore's firm stance on the issue at a challenging juncture of the nation's history.
In prescient remarks that are applicable to both public administration and private enterprise, the former prime minister said at a Parliamentary sitting in 1987, following the suicide of a senior minister investigated for bribery: "Sir, there is no way a minister can avoid investigations, and a trial if there is evidence to support one . . .
The effectiveness of our system to check and to punish corruption rests, first, on the law against corruption contained in the Prevention of Corruption Act; second, on a vigilant public ready to give information on all suspected corruption; and third, on a CPIB which is scrupulous, thorough, and fearless in its investigations.
"For this to be so, the CPIB has to receive the full backing of the prime minister, under whose portfolio it comes.
But the strongest deterrent is in a public opinion which censures and condemns corrupt persons - in other words, in attitudes which make corruption so unacceptable that the stigma of corruption cannot be washed away by serving a prison sentence."
On closer review, Mr Lee's statement - although delivered in the context of public governance in Singapore - portended foundational principles underlying modern compliance programmes.
These principles include those advocated by the UK Ministry of Justice in its Six Principles of Adequate Procedures designed to prevent bribery under the Bribery Act 2010 published in March 2011, and the US Department of Justice and Securities Exchange Commission in the 10 Hallmarks of Effective Compliance Programs in the Resource Guide to the US Foreign Corrupt Practices Act published in November 2012.
The similarities are uncanny.
Mr Lee's reference to the inevitable outcome of conducting investigations or prosecuting a case if there is supporting evidence points, in a corporate context, to the importance of carrying out monitoring and review, and conducting internal investigations.
His emphasis on the law of corruption is a reference to policies and procedures that should be properly articulated by companies.
The importance of a vigilant public ready to give information on all suspected corruption is clearly a reference by Mr Lee to whistleblowing, communication and reporting.
He also referred to a CPIB which is scrupulous, thorough, and fearless in its investigations, indicating that there is a parallel need for a well-resourced compliance function in companies.
He added that the CPIB had to receive the full backing of the prime minister, which is an unmistakable call for top-level commitment from any organisation to the anti-corruption cause.
Finally, he stressed that the strongest deterrent is in a public opinion which censures and condemns corruption, and creates a stigma which makes it unacceptable to all.
That, for companies, is a directive that corporate culture drives the approach towards the elimination of corruption in business practices.
Looked at almost three decades later, Mr Lee's words are more pertinent than ever.
Singapore may have lost its founding prime minister but the vision he cast for the nation's anti-corruption imperative lives on in the ever-increasing compliance efforts to maintain Singapore's reputation as a corruption-free country in this challenging region.
This article was first published on Apr 29, 2015.
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