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THE UNITED NATIONS CONVENTION AGAINST CORRUPTIONOVERVIEW OF ITS CONTENTS AND FUTURE ACTION
Dimitri Vlassis*

I. INTRODUCTION
The new United Nations Convention against Corruption has enormous significance. It proves that a
destructive practice as old as history can no longer be tolerated. It manifests the realization that the world of
the 21st century needs new rules to become a better place for all peoples. It demonstrates that core values,
such as respect for the rule of law, probity, accountability, integrity and transparency must be safeguarded
and promoted as the bedrock of development for all.
People around the world, in developing and developed countries alike, have become increasingly
frustrated at witnessing and suffering from the injustice and the deprivation that corruption brings. On adaily basis, people have faced head-on the effects of corruption on areas such as the administration of justiceand the provision of adequate medical care. They have watched with awe and anger the revelations about theluxurious lifestyle and immense fortunes amassed by corrupt leaders, while their people toiled to scrape aliving and were denied the most basic of services.
And that anger becomes resignation and cynicism when people discover that the vast fortunes stolen bycorrupt leaders cannot be recovered because they have been transferred abroad. To these people, diatribes
about good governance, sustainable development, the benefits of a free market and the liberalization of tradering hollow.
It is there that lies one of the gravest dangers, one of the most serious threats posed by corruption. The
loss of confidence in institutions and the de-legitimization of government have destructive consequencesthat can span generations. The best and brightest will eschew local political and economic life or even flee
abroad.
The new Convention offers good reason to look at the future with optimism. It is itself an act of faith.
Only a few years ago, speaking of the possibility of such an instrument, and saying it would be negotiated insuch a short time, would have brought ironic smiles to the faces of most people. Yet, it is a reality and aremarkable achievement.
It became a reality because of the vision, determination and commitment that all Governments displayed
throughout the negotiation process. And it is a remarkable achievement because it is innovative, balanced,
strong and pragmatic. These qualities, together with its universality and functionality, make the newConvention a unique platform for effective action and an essential framework for genuine international
cooperation.
The Convention offers all countries a comprehensive set of standards, measures and rules that they canapply to strengthen their legal and regulatory regimes to prevent and control corruption.
Negotiating the Convention was not an easy undertaking. There were many complex issues and concerns
from different quarters that the negotiators had to tackle. It was a formidable challenge to maintain thequality of the new Convention while making sure that all of these concerns were properly reflected in the
final text. Very often compromise was not easy and all countries made concessions. But the result is asource of pride. This result was made possible by the flexibility, sensitivity, understanding, and above allstrong political will that all countries displayed.
* Chief, Crime Conventions Section, Division for Treaty Affairs; Secretary, Ad Hoc Committee for the Negotiation of aConvention against Corruption, United Nations Office on Drugs and Crime.

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II. BACKGROUND
The new Convention can be seen as the most recent of a series of developments in which experts haverecognised the far-reaching impact of corruption and the need to develop effective measures against it atboth the domestic and international levels. It is now widely accepted that measures to address corruption go
beyond criminal justice systems and are essential to establishing and maintaining the most fundamental good
governance structures, including domestic and regional security, the rule of law and social and economic
structures which are effective and responsive in dealing with problems, and which use available resources as
efficiently and with as little waste as possible.
The gradual understanding of both the scope and seriousness of the problem of corruption can be seen in
the evolution of international action against it, which has progressed from general consideration anddeclarative statements,1 to the formulation of practical advice,2 and then to the development of binding legal
obligations and the emergence of numerous cases in which countries have sought the assistance of one
another in the investigation and prosecution of corruption cases and the pursuit of proceeds. It has also
progressed from regional instruments developed by groups of relatively like-minded countries such as theOrganisation of American States,3 the African Union (formerly Organisation of African Unity),4 the OECD,5and the Council of Europe6 to the global United Nations Convention.7 A series of actions on specific issues
within specific regions has become more general and global in order to deal most effectively with the
problem.

III. OVERVIEW OF THE CONVENTION
A. General Provisions (Chapter I, Art. 1-4).
The first article of the Convention states that its purposes are the promotion and strengthening of
measures to prevent and combat corruption more efficiently and effectively; the promotion, facilitation andsupport of international cooperation and technical assistance, including in asset recovery; and the promotionof integrity, accountability and public management of public affairs and public property.
The Convention then includes an article on the use of terms. In addition to such definitions as“property”, “proceeds of crime” and “confiscation”, the most significant innovation of the new Convention
are the definitions of “public official”, “foreign public official” and “official of a public internationalorganization”.
The Convention contains a broad and comprehensive definition of “public official” that includes any
person holding a legislative, executive, administrative or judicial office and any person performing a public
function, including for a public agency or public enterprise, or providing a public service. The definition
retains the necessary link with national law, as it would be in the context of national law that thedetermination of who belongs in the categories contained in the definition would be made.
During the negotiation process significant debate revolved around whether there was a need for adefinition of “corruption” and, should the answer to that question be affirmative, what the content of such a
definition would be. In the end, negotiators decided that attempting to define in legal terms, i.e., in terms
that would stand scrutiny in a wide array of legal systems around the world and would add value to the rest
1 See, for example GA/RES/51/59 and 51/191, annexes, and the discussion held at the 9th U.N. Congress on the Prevention of
Crime and Treatment of Offenders, held in Cairo from 29 April - 8 May 1995 (A/CONF.169/16/Rev.1, paragraphs 245-261.
2 See, for example, the United Nations Manual Practical Measures against Corruption, ECOSOC Res.1990/23, annex,
recommendation #8 and International Review of Criminal Policy, Special Issue, Nos. 41 and 42, New York 1993.
3 Inter-American Convention against Corruption, OAS General Assembly resolution AG/res.1398 (XXVI-0/96) of 29 March
1996, annex.
4 African Union Convention on Preventing and Combating Corruption, Maputo Mozambique, 11 July 2000, available from the AU on-line
at: http://www.africa-union.org/Official_documents/Treaties_%20Conventions_%20Protocols/Treaties_Conventions_&_Protocols.htm.
5 OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, OECD
document DAFFE/IME/BR(97)20.
6 European Criminal Law Convention on Corruption, 1998, European Treaty Series #173.
7 For a summary of other international legal instruments dealing with corruption, see United Nations Manual on AntiCorruption Policy, Chapter V, available on-line at: http://www.unodc.org/pdf/crime/gpacpublications/manual.pdf.

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of the text of the Convention was neither feasible nor desirable. Corruption could easily be allowed to standas a word describing conduct that was broadly understood in a progressively more consistent manner
throughout the world. While the term might still be understood in a broader or narrower fashion dependingon national exigencies or traditions, attempting to crystallize in a short legal text requiring high precision
the core of the collective perception of the concept entailed a number of unnecessary risks. There was therisk of limiting the Convention to the current understanding, thus depriving the instrument from the
dynamism necessary for it to remain relevant to national efforts and international cooperation in the future.
There was also the risk of capturing in the definition only some aspects of the phenomenon, thus inhibiting
broader action against corruption that countries might have already taken or might be contemplating. In
deciding not to include a definition of “corruption” in the final text the negotiators were inspired to a large
extent by the similar approach taken by the United Nations Convention against Transnational Organized
Crime, which does not define “transnational organized crime” but, instead, contains a definition of“organized criminal group”.
The Chapter contains an article on the scope of application, which states that for the purposes of
implementing the Convention, it will not be necessary, except as otherwise provided in the Convention, forthe offences set forth in it to result in damage or harm to state property. This provision has particularimportance for international cooperation and asset recovery.
Finally, the chapter contains an article on protection of sovereignty, an issue which figures prominently inthe concerns of Member States, especially in view of the jurisdictional provisions that are later found in theConvention. The article was inspired and follows the formulation of a similar article in the United Nations
Convention against Transnational Organized Crime.

B. Preventive Measures (Chapter II, Art. 5-14)
The Convention contains a compendium of preventive measures which goes far beyond those of previous
instruments in both scope and detail, reflecting the importance of prevention and the wide range of specificmeasures which have been identified by experts in recent years. More specifically, the Convention contains
provisions on policies and practices, preventive anti-corruption bodies; specific measures for the public
sector, including measures to enhance transparency in the funding of candidatures for elected public officeand the funding of political parties; comprehensive measures to ensure the existence of appropriate systems
of procurement, based on transparency, competition and objective criteria in decision-making; measuresrelated to the judiciary and prosecution services; measures to prevent corruption involving the private
sector; participation of society; and measures to prevent money laundering. The chapter on prevention has
been structured in a way that would establish the principle of what needs to be put in place, but allows forthe flexibility necessary for implementation, in recognition of the different approaches that countries cantake or their individual capacities.
The provisions on preventive measures are regarded as forming an integral part of the mechanisms that
the Convention is asking States to put in place. It is the one side of the coin, the other being thecriminalization of a variety of manifestations of corruption. It is important to note that the prevention
chapter covers all those measures that the international community collectively considers necessary for theestablishment of a comprehensive and efficient response to corruption at all levels.

C. Criminalization and Law Enforcement (Chapter III, Art. 15-44)
While the development of the Convention reflects the recognition that efforts to control corruption must
go beyond the criminal law, criminal justice measures are still clearly a major element of the package. The
Convention would oblige States Parties to establish as criminal offences bribery of national public officials;
active bribery of foreign public officials; embezzlement, misappropriation or other diversion of property by apublic official; money laundering; and obstruction of justice. Further, States Parties would establish the civil,
administrative or criminal liability of legal persons.
In recognition of the fact that there may be other criminal offences which some countries may havealready established in their domestic law, or may find their establishment useful in fighting corruption, theConvention includes a number of provisions asking States Parties to consider establishing as criminal
offences such forms of conduct as trading in influence, concealment, abuse of functions, illicit enrichment, or
bribery in the private sector.

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The final formulation of the criminalization chapter, with the inclusion of both “mandatory” and“discretional” offences, created a quandary for negotiators as to how to deal with international cooperation,
more significantly certain principles such as dual criminality, which normally govern such forms ofinternational cooperation as mutual legal assistance. The solution found, which is explained below under“international cooperation”, is another innovative feature of the Convention, adding significantly to its value
for the international community.
Other measures found in Chapter III are similar to those of the Convention against Transnational
Organized Crime. These include the establishment of jurisdiction to prosecute (Art. 42), the seizing,
freezing and confiscation of proceeds or other property (Art. 31), protection of witnesses, experts andvictims and cooperating persons (Art. 32-33) and other matters relating to investigations and prosecutions(Art. 36-41).
Elements of the provisions dealing with money-laundering and the subject of the sharing or return ofcorruption proceeds are significantly expanded from earlier treaties (see Chapter V), reflecting the greater
importance attached to the return of corruption proceeds, particularly in so-called “grand corruption” cases,in which very large amounts of money have been systematically looted by government insiders from State
treasuries or assets and are pursued by subsequent governments.

D. International Cooperation (Chapter IV, Art. 43-49)
Chapter IV contains a series of measures which deal with international cooperation in general, but itshould be noted that a number of additional and more specific cooperation provisions can also be found inchapters dealing with other subject-matters, such as asset recovery (particularly Art. 54-56) and technicalassistance (Art. 60-62). The core material in Chapter IV deals with the same basic areas of cooperation asprevious instruments, including the extradition of offenders, mutual legal assistance and less-formal forms ofcooperation in the course of investigations and other law-enforcement activities.
A key issue in developing the international cooperation requirements arose with respect to the scope or
range of offences to which they would apply. The broad range of corruption problems faced by many
countries resulted in proposals to criminalise a wide range of conduct. This in turn confronted many
countries with conduct they could not criminalise (as with the illicit enrichment offence discussed in theprevious segment) and which were made optional as a result. Many delegations were willing to accept that
others could not criminalise specific acts of corruption for constitutional or other fundamental reasons, but
still wanted to ensure that countries which did not criminalise such conduct would be obliged to cooperatewith other States which had done so. The result of this process was a compromise, in which dual criminality
requirements were narrowed as much as possible within the fundamental legal requirements of the States
which cannot criminalise some of the offences established by the Convention.
This is reflected in several different principles. Offenders may be extradited without dual criminality
where this is permitted by the law of the requested State Party.8 Mutual legal assistance may be refused in
the absence of dual criminality, but only if the assistance requested involves some form of coercive action,such as arrest, search or seizure, and States Parties are encouraged to allow a wider scope of assistancewithout dual criminality where possible.9 The underlying rule, applicable to all forms of cooperation, is that
where dual-criminality is required, it must be based on the fact that the relevant States Parties havecriminalised the conduct underlying an offence, and not whether the actual offence provisions coincide.10
Various provisions dealing with civil recovery11 are formulated so as to allow one State Party to seek civil
recovery in another irrespective of criminalization, and States Parties are encouraged to assist one anotherin civil matters in the same way as is the case for criminal matters.12

E. Asset Recovery (Chapter V, Art. 51-59)
As noted above, the development of a legal basis for cooperation in the return of assets derived from or
8 Art. 44, para. 2.
9 Art. 46, para. 9.
10 Art. 43, para. 2.
11 See, for example, Art. 34, 35 and 53.
12 Article 43, paragraph 1 makes cooperation in criminal matters mandatory and calls upon States Parties to consider
cooperation in civil and administrative matters.

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associated in some way with corruption was a major concern and a key component of the mandate of the Ad
Hoc Committee. To assist delegations, a technical workshop featuring expert presentations on asset
recovery was held in conjunction with the second session of the Ad Hoc Committee,13 and the subjectmatter was discussed extensively during the proceedings of the Committee.
Generally, countries seeking assets sought to establish presumptions which would make clear theirownership of the assets and give priority for return over other means of disposal. Countries from which
return was likely to be sought, on the other hand, had concerns about the incorporation of language whichmight have compromised basic human rights and procedural protections associated with criminal liability andthe freezing, seizure, forfeiture and return of such assets. From a practical standpoint, there were also
efforts to make the process of asset recovery as straightforward as possible, provided that basic safeguards
were not compromised, as well as some concerns about the potential for overlap or inconsistencies with
anti-money-laundering and related provisions elsewhere in the Convention and in other instruments.
The provisions of the Convention dealing with asset recovery begin with the statement that the return ofassets is a “fundamental principle” of the Convention, with annotation in the travaux preparatoires to theeffect that this does not have legal consequences for the more specific provisions dealing with recovery.14
The substantive provisions then set out a series of mechanisms, including both civil and criminal recovery
procedures, whereby assets can be traced, frozen, seized, forfeited and returned. A further issue was thequestion of whether assets should be returned to requesting State Parties or directly to individual victims ifthese could be identified or were pursuing claims. The result was a series of provisions which favour returnto the requesting State Party, depending on how closely the assets were linked to it in the first place. Thus,
funds embezzled from the State are returned to it, even if subsequently laundered,15 and proceeds of otheroffences covered by the Convention are to be returned to the requesting State Party if it establishes
ownership or damages recognised by the requested State Party as a basis for return.16 In other cases assets
may be returned to the requesting State Party or a prior legitimate owner, or used in some way forcompensating victims. 17 The chapter also provides mechanisms for direct recovery in civil or otherproceedings (Art. 53) and a comprehensive framework for international cooperation (Art. 54-55) which
incorporates the more general mutual legal assistance requirements, mutatis mutandis. Recognizing thatrecovering assets once transferred and concealed is an exceedingly costly, complex, and all-too-often
unsuccessful process, the chapter also incorporates elements intended to prevent illicit transfers andgenerate records which can be used should illicit transfers eventually have to be traced, frozen, seized andconfiscated (Art. 52). The identification of experts who can assist developing countries in this process is also
included as a form of technical assistance (Art. 60, para. 5).

F. Technical Assistance and Information Exchange (Chapter VI, Art. 60-62)
The provisions for research, analysis, training, technical assistance and economic development andtechnical assistance are similar to those contained in the United Nations Convention against Transnational
Organized Crime, modified to take account of the broader and more extensive nature of corruption and to
exclude some areas of research or analysis seen as specific to organized crime. Generally, the forms oftechnical assistance under the Convention against Corruption will include established criminal justiceelements such as investigations, punishments and the use of mutual legal assistance, but also institutionbuilding and the development of strategic anti-corruption policies. 18 Also called for is work throughinternational and regional organizations (many of who already have established anti-corruption
programmes), research efforts, and the contribution of financial resources both directly to developing
countries and countries with economies in transition and to the United Nations Office on Drugs and Crime,19
which is expected to support pre-ratification assistance and to provide secretariat services to the Ad Hoc
Committee and Conference of States Parties as the Convention proceeds through the ratification process
13 See A/AC.261/6/Add.1 and A/AC.261/7, Annex I.
14 Art. 51 and A/58/422/Add.1, para. 48
15 Art. 57, subpara. 3(a).
16 Art. 57, subpara. 3(b).
17 Art. 57, subpara. 3(c).
18 Art. 60, para. 1.
19 Art. 60, paras. 3-8.

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and enters into force.20

G. Mechanisms for Implementation (Chapter VII, Art. 63-64)
The Convention contains a robust mechanism for its implementation, in the form of a Conference of theStates Parties, with comprehensive terms of reference already specified in the Convention and with asecretariat that would be charged to assist it in the performance of its functions. These provisions are
inspired by the United Nations Convention against Transnational Organized Crime, but go considerably
beyond that instrument, both in terms of scope and detail. The Secretary General is called upon to convene
the first meeting of the Conference within one year of the entry of the Convention into force,21 and the Ad
Hoc Committee which produced the Convention is preserved and called upon to meet one final time toprepare draft rules of procedure for adoption by the Conference, “well before” its first meeting.22 The
bribery of officials of public international organizations is dealt with in the Convention only on a limited basis(Art. 16), and the General Assembly has also called upon the Conference of States Parties to further address
criminalization and related issues once it is convened.23
H. Final Provisions (Chapter VIII, Art. 65 - 71)
The final provisions are based on templates provided by the United Nations Office of Legal Affairs and aresimilar to those found in other United Nations treaties. Key provisions include those which ensure that theConvention requirements are to be interpreted as minimum standards, which States Parties are free to
exceed with measures which are “more strict or severe” than those set out in the specific provisions,24 andthe two articles governing signature and ratification and coming into force. The Convention is open for
signature from 9 December 2003 to 9 December 2005, and to accession by States which have not signed any
time after that. It will come into force on the 90th day following the deposit of the 30th instrument of
ratification or accession with the Office of Legal Affairs Treaty Section at U.N. Headquarters in New York.25
IV. THE ROAD AHEAD
The Signing Conference that the United Nations Office on Drugs and Crime organized in Mérida lastDecember was yet another manifestation of the political will that made the Convention possible and enabled
the Ad Hoc Committee to negotiate it in record time, fully respecting the deadline set for it by the General
Assembly. Ninety-five countries signed the Convention and, in an unprecedented and highly significant
move, one country also deposited the first ratification of the new instrument.
While we should all rejoice with the adoption of the new Convention, we must guard againstcomplacency. The new instrument must be only the beginning of our redoubled efforts to prevent andcontrol corruption. We must all make sure that the momentum that made its negotiation possible is notallowed to dissipate. The collective political will that permitted the innovative and groundbreaking solutionsof the new Convention must continue unabated.
Before highlighting our vision for what lies ahead, let me use this opportunity to clarify what we consider
a matter of crucial importance. Quite often, and with some consternation, we come across a fundamental
misperception about the new Convention, namely that it does not foresee monitoring of its implementation.
Nothing can be further from the truth. The Convention contains provisions for a vigorous and effective
mechanism to ensure and follow up on its implementation. The relevant provisions were carefully negotiatedand, while inspired by similar provisions in the United Nations Convention against Transnational Organized
Crime, go considerably beyond that Convention both in terms of details and potential impact. We must dispel
this misperception and, instead of engaging in theoretical discourses about our own individual image of how
20 GA/RES/58/4, paras. 8 and 9 and Convention Art. 64. UNODC is already designated as the secretariat for the Ad Hoc
Committee pursuant to GA/RES/55/61, paras, 2 and 8 and GA/RES/56/261, paras. 6 and 13. By convention, the General
Assembly calls on the Secretary General to provide the necessary resources and services, leaving to his discretion thedesignation of particular U.N. entities and staff to do so.
21 Art. 63, para. 2.
22 GA/RES/58/4, para. 5.
23 GA/RES/58/4, para. 6.
24 Art. 65, para. 2.
25 Art. 67 (signature, ratification, acceptance, approval and accession) and 68 (Entry into force). For further information see
the segment on procedural history and footnotes 10 and 11 (sources of assistance), above.

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the Convention should read, concentrate on the task at hand, which is formidable.
We must organize our efforts around some key elements that we must always keep in mind.
The first step must necessarily be to secure the necessary ratifications for the entry into force of theConvention within the shortest time possible. Implementation would be a word devoid of meaning if theConvention languishes on the shelves for long. The best way to achieve implementation is to bring into
existence the Conference of the States Parties and make sure it functions effectively. To secure thenecessary ratifications, we should exercise all the influence we possess to bring ratification to the top of thedomestic political agenda in as many countries as possible, in all regions of the world. We have been
informed that a number of Governments, which were also very active during the negotiation process, arethinking about forming an informal group of “friends of the Convention” to seek ways to keep the
momentum alive. We should support them and encourage them in pursuing that direction.
The Office on Drugs and Crime intends to pursue the following actions in achieving the objective ofeffectively promoting the new Convention and securing the necessary ratifications for its entry into force.
•
•

•
•
•

Organization of high-level seminars to increase awareness of the Convention on the part of Member
States, as well as intergovernmental and non-governmental organizations.
Assistance to requesting States in the development of legislation and regulations to facilitate theratification of the Convention. The Office intends to develop a Legislative Guide for the
Implementation of the United Nations Convention against Transnational Organized Crime andfurther explore the development of appropriate implementation tools.
Provision of expertise or technical cooperation to requesting States with a view to strengthening
domestic criminal justice systems capabilities in dealing with corruption.
Assistance in the establishment or intensification of bilateral and multilateral cooperation in theareas covered by the Convention.
Facilitating the sharing of information, experience and expertise between States.

Implementation rests firmly in the hands of States. And for good reason. First, effective action against
corruption is the responsibility of Governments. Only through their commitment and determination can we
see tangible results. Second, the Convention is the first truly global instrument of its kind. This is aprominent feature that distinguishes it from the very commendable initiatives and instruments thatpreceded it at the regional level. This global nature is also the source of special attributes that we must notignore. Mechanisms for implementation that were developed for, and are functioning in the context ofregional legal instruments cannot be readily emulated at the global level. We can learn from the experience
gained by those mechanisms, and we fully intend to continue and strengthen our close working relationships
with the international organizations that are supporting those mechanisms. But, we must also take into
serious consideration legitimate concerns of our constituency and, most importantly, the gaps in capacitythat exist in many developing and least developed countries. On that basis, and remaining faithful to theletter and spirit of the Convention, we must nurture its implementation mechanism and support the widest
possible participation in the development and functioning of that mechanism, including through welltargeted technical assistance to developing countries.
While guided by these considerations, we must not underestimate the role that civil society and theprivate sector can and must play. Governments must be prompted, encouraged, supported and held
accountable. And both civil society and the private sector can help in all of these efforts. To complement andsupport the initiative of Governments forming a support group for the Convention, we are exploring thepossibility of putting together two other informal groups, one that would serve as a forum for civil society
and one that would offer the opportunity to the private sector to become engaged and bring to bear its own
great potential and influence. In putting together these groups, we would seek the cooperation and guidanceof the Global Compact and would welcome ideas and support from all concerned.
In the United Nations, we believe that it is a matter of consistency, credibility and efficiency to lead byexample. Our interaction with Governments and all other members of our constituency stand to gain
enormously from the realization and the firm belief that we “practice what we preach”. And theOrganizational Integrity Initiative, spearheaded by the Office of Internal Oversight Services is a case inpoint.

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The same principle applies to the private sector. I believe that the issue must be approached in a twopronged fashion. The private sector must realize and accept that its position and operations in a globalized
economy bring with them great potential, but also great responsibility. Integrating and projecting
transparency, and using influence to help fight corruption is a sound business practice, it makes eminent
business sense. Investments require a stable and secure environment to produce returns. They require a“level playing field”. Corruption produces invariably a host of distortions in markets, it removes the mostbasic elements from the environment that is conducive to productive investment and thrives on the
confusion that ensues. Just like businesses invest seriously in their own infrastructure, they must look very
carefully at investing in the infrastructure of the environment in which they wish to operate. And it is asound investment, an investment in the future carrying very little risk, to support the efforts of countries tostrengthen their systems in order to fight, domestically and together with others, corruption. Its returns
may not be easily and immediately quantifiable in a way that they would be reflected in a balance sheet. But
the results and returns are bound to show in the medium to longer term. This is why the Office on Drugs
and Crime is an avid supporter of the Global Compact and stands ready to contribute to its efforts in any way
it can, especially in view of the imminent introduction of transparency and action against corruption as its
tenth principle.

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