Abstract:
Pujas examines the comparative "cultures" of administration in Western Europe in their respective national political settings as well as the wider issue of corruption and its differing degrees of incidence across the countries of the European Union.

FOLLOWING the release of the report of the Committee of Experts into allegations of fraud, mismanagement and nepotism in the European Commission in mid-March 1999, Guardian correspondent Martin Walker wrote that: 'Europe's political future hung in the balance ... as the shattered Commission split into rival groups of self-styled saviours. No one could mask the fact that a fundamental division had emerged between those mostly northern MEPs and commissioners and officials who see a historic chance to democratise Europe's political and administrative culture, and a mainly southern bloc who simply want some sticking plaster to hold the administration together and keep the EU show on the road.' He went on to argue that the forces for change in European institutions had originated with the arrival of new member states, Sweden, Finland and Austria 'which have open and transparent political systems and have regularly clashed with the Brussels bureaucracy', a less deferential press than in the past, and the new role being assumed by the Parliament in which, once again 'the British contingent, backed up by the Scandinavian and German MEPs on both sides of the aisle have played as major role . . .'.1

In sum, this report conveyed a strong impression that a virtuous 'north' has been conducting a crusade against a corrupt 'south' within the European institutions, reflecting quite different standards of public behaviour in the member states in which Commissioners, officials and MEPs originate. On this account, we should not be surprised that only one of the four senior Commission bureaucrats allegedly responsible for misconduct or mismanagement in the committee of expert's report was from a 'northern' country-the German Commissioner for regional policy, Monika Wulf-Mathies -while the remainder were Portuguese (Joao de Deus Pinheiro), Spanish (Manuel Marin) and French (Edith Cresson). The fact that Paul van Buitenen-the accountant in the Commission's auditing department who passed the dossier detailing malpractice at the highest levels of the Commission to Green Party MEPs -was Dutch would seem to reinforce this popular view of events.

But how fair is this view? Is there really a 'clash of cultures' in Europe between quite different types of public administration, responsible for a 'fundamental division' in the European institutions between the ambassadors of 'clean' northern government and the cynical representatives of closed, corrupt and clannish southern bureaucracy? In this article we concentrate on the first part of this question and examine the comparative 'cultures' of administration in Europe in their respective national political settings. We begin by considering the wider issue of corruption and its differing degrees of incidence across the countries of the European Union, locating these contrasts as much in political systems and forms of political development as in social norms of behaviour. We then consider the role and organisation of public administration and the importance or rules and systems of control in guaranteeing low corruption environments, as well as trends across all European societies which threaten to increase incentives for corruption in public life. We conclude by returning to the crisis of the European Commission, suggesting that, while its problems are the result of a unique set of institutional features, lessons from national experience should be used to tackle them.

A 'Clean north' and a 'corrupt south'?

There is certainly plenty of evidence available to support the view of a 'clean north' and a 'corrupt south' in the European Union. The proliferation of corruption scandals across southern Europe in recent years, leading in the case of Italy to the removal of an entire generation of senior politicians from power and a renewal of the party system, has certainly drawn European public attention to the less than healthy condition of public affairs in these countries. For many years, as revealed in Table 1, the only available index of corruption we have, based on surveys of business people, has divided Europe unequivocally into clusters of highly corrupt, fairly corrupt and hardly corrupt countries, with a clear distinction between the northern Protestant countries and the southern Catholic countries, with others ranged somewhere in between.

Indeed, it is this division that is frequently accounted for in terms of political culture or national character: the presence in Spain of 'amiguismo', 'l'arrangement i la franqaise' or 'l'arranglarsi' of the Italian, are ways of describing fluid, informal and potentially corrupt relations across the public-private divide. What would be considered as nepotism or shameless patronage in Britain might be seen as fair practice or even a moral duty in other countries, including the countries of southern Europe. To this extent, even though bribery, fraud and corruption are also to be found in northern European countries, their acute or systemic incidence in southern Europe, as indicated in the Transparency International figures, would appear to validate the notion of a 'clash of cultures'. This contrast might also justify the view that politicians and officials from different parts of Europe will bring very different norms of social and political behaviour with them when they are appointed or transferred to the European institutions.

Such a view is given academic credibility by a certain school of corruption analysis which focuses primarily on social norms as the main explanatory variable. Economist Vito Tanzi prioritises the notions of 'arm's length rules' and 'social capital' in distinguishing northern European from southern European and Third World countries in their proclivities for corruption: 'The very features that make a country a less cold and indifferent place,' he argues, 'are the same that increase the difficulty of enforcing arm's length rules so essential for modern efficient markets and governments.' He uses the notion of social capital to explain why social relations create a different context for administrative behaviour in some countries rather than others. 'The existence of social capital links individuals in a network of obligations that both increases their opportunities and reduces their individual freedom. It puts strong pressures on individuals to accommodate the needs of friends and relatives and creates a presumption that they will in turn accommodate the individual's needs.' Thus the government employee or civil servant in such cultures is expected to help friends and relatives and might well break rules to do so. According to this argument, creating a rational Weberian democracy in such circumstances is likely to be impossible.2 But do these social practices alert us to a specific southern mentality or culture or to differences in socio-political development and organisation? Institutional settings breed certain types of relationship and social practice and either punish or perpetuate 'social norms'. For example, the notion of 'conflict of interest' as an antidote to corruption is much stronger in northern Protestant than in Latin and Catholic countries. In more sophisticated versions of the social norm argument, these differences between (and even within) countries are attributed to levels of 'trust', as in the work of Putnam and Fukuyama.3 But attempts by Putnam to locate the origins of 'civicness' in the Italian case in particular types of 'norms and networks' have foundered on the fact that those regions defined as 'civic' (the centre and north) have been hit as hard by corruption revelations this decade as have those traditionally considered 'amoral' (the south) in terms of their social relations.

For this reason it is important that both 'culture' and 'trust' are defined historically and institutionally. An understanding of corruption based solely on social norms is too simplistic, as revealed by examples of countries that successfully eradicate corruption and by others that are geographically close to the so-called 'clean' countries of the north but suffer nevertheless from relatively high levels of corruption. Historically, there are exemplary cases of countries making successful transitions from 'corrupt' to 'clean', as in the case of Britain in the nineteenth century when the 'moral revolution' of the Victorians involved the imposition of professional standards, with the eradication of patronage and corruption from government and administration.4 As for countries that fit ill with the north-south dichotomy, the case of contemporary Belgium is also important in this respect, for here we have a northern country with a cold climate with the highest incidence of corruption in Europe (according to TI figures) after Italy. Furthermore, it is generally recognised that corruption involving politicians, public officials and business people has also been increasing in the less corrupt or apparently 'clean' countries of northern Europe in recent years. Something else apart from embedded 'social norms' is clearly at work here. Why then have patron-client relations across the public-private divide and informal channels for exercising political influence been more accepted in southern Europe and certain parts of northern Europe than elsewhere; and why has the incidence of corruption in apparently 'clean' northern countries been increasing? We suggest that developmental factors and the 'structure of political opportunity' provide a major part of the answer and that rules and institutions provide powerful incentives or disincentives for corrupt public behaviour. As we discuss below, this observation applies as much to the European institutions as to national political systems.

Developmental factors and institutional incentives for corruption5

To the extent that a public administration embodies ethical codes, or a sense of civic responsibility, duty or even honour on the part of civil servants, this will depend not just on traditions or social norms (though these will clearly play a role) but on a wide range of influences. It has already become clear in our discussion that it is impossible to talk about ,administrative culture' as such. The bureaucracy or the administration is part of an institutional complex. Although in some countries it may have strictly policed borders between its personnel and organisational rules or procedures and those of other parts of society, in many countries the administration is heavily penetrated by other political influences and social practices. The range of influences is considerable. If we take the elements for an 'ethical infrastructure' in the public service elaborated by the OECD, we see how these range from mechanisms internal to the administration to the external framework and nature of the civil society in which the administration is located: political commitment to ethical behaviour (i.e., political leadership);

an effective legal framework;

efficient accountability mechanisms;

workable codes of conduct;

professional socialisation mechanisms (including training);

supportive public service conditions;

the existence of some ethics coordinating body;

and an active civil society (including a probing media) playing the role of watchdog over the actions of public officials.6

These elements embody systems of political leadership, control, guidance and management within the administration but are highly dependent on conditions outside it. The conduct of the individual civil servant will be conditioned by both the internal incentive structure of the bureaucracy -which will establish the supply of corrupt acts on the part of public employees -and the external incentive structure which will establish the demand for corrupt acts by private agents.7 This incentive structure will shape the extent of what economists call 'rentseeking' behaviour on the part of both private actors and public officials -i.e. the degree to which both will engage in a process of what we can call 'illicit exchange' through paying and accepting bribes or becoming involved in conspiracies to defraud the public sector for mutual enrichment. There is a vast range of illicit acts that can take place across the public-private divide, especially when that divide is bridged, or in certain cases even removed, by the interpenetration of politics and bureaucracy in systems where political parties have 'colonised' the state machine. This is most clearly the case in Italy and Belgium but also in less acute form elsewhere in continental Europe. These conditions- or 'opportunity structures'- have been established in various forms and to varying degrees in different European societies in certain historical circumstances, leaving a legacy of rules and institutions that determine the standards of contemporary public behaviour. Focusing primarily on the 'corrupt cluster' of European countries, we examine these conditions below in four major areas: relations between parties and the state; and the nature of party finance regulation (which has tended to make politicisation a more pernicious phenomenon); the ineffectiveness of political checks and balances; and the nature of administrative regulations and controls.

As for relations between parties and the state, politicisation of the bureaucracy is one of the most important institutional contributors to corrupt political behaviour. A clear contrast can be drawn between Britain-whose civil service has long had a reputation for integrity and where patron-client relations in the political sphere have been rare-- and countries such as Italy or Belgium where patronage and favouritism have been a central feature of relations between parties, bureaucracy and business. Already in the late nineteenth century Britain had tightly guarded borders between its bureaucratic and political systems. Britain institutionalised its parties and party system long before it institutionalised bureaucracies, and when it did so in the nineteenth century, the Victorian moral code -which made a close connection between professionalism and honesty ('the word of a gentleman')-was imposed on the civil service through a reform which rejected nepotism and patronage appointments, and replaced them with open examination and promotion on merit in the 1850s and 1860s.11 In the southern countries, by contrast, the patron-client relations that had always substituted for rational, administrative interaction in their pre-modern polities were transposed into new institutional structures with late economic and administrative development.

Authoritarian rule did not eliminate these practices but institutionalised them in the absence of the checks and balances of a free press and independent judiciary. In Spain, the Francoist state saw the proliferation of networks of personal influence, involving large numbers of badly paid bureaucrats and the expansion of black market practices. In Greece, at the beginning of the modernisation period, corruption functioned as a substitute for the ineffectiveness of bureaucracy and the state machinery and was used cynically by the authoritarian regime (1967-74) to secure its control on power.9 Once they democratised, certain continental countries that experienced totalitarian dictatorship saw the penetration of bureaucracies and even judiciaries by parties as an essential check against threats to democracy. We should note, though, that the consequences have not been the same across these countries. In Italy, parties have shared power through the 'lottizzazione' spoils system and dominated a weak executive, eventually destroying any notion of 'the public interest' in the process. In both Spain and France, by contrast, parties of government have been able to use a strong executive to dominate the administration by political placements. Nevertheless, in all cases the outcome has been a confusion of powers and the multiplication of structures in which corruption is more likely to occur and the ethos of public life degraded. The Belgian case-our example here of 'corruption in a cold climate'-has seen a highly fragmented party system make deep inroads into the civil service, circumventing formal procedures, controlling recruitment (in coalition talks, parties agree on the nomination and promotion quotas allocated to each party) and marginalising the role of civil servants in decisionmaking.10

Where there is a high degree of politicisation, one of the major causes of corruption is likely to be linked to the funding of political parties or individual politicians, either for political reasons (the financing of expensive election campaigns for example) or personal gain. The two are often found together, as in the Italian case where vast sums of public money were transferred into both party coffers and personal bank accounts. Even in relatively uncorrupted systems, there are a number of ways in which legitimate party financing may border (or move over into) the corrupt: professional politicians and parties may 'tax' public sector firms for their own organisational or elections expenses; public employees will meet this demand as a means of gaining promotion or retaining their job; and politicians may also arrange for international or national firms, as well as local businessmen, to obtain public permits, licences or government contracts (involving a corrupt exchange with public officials) in return for a 'kickback' or compensatory payment. The borderline with corruption often has to be crossed in order to ensure the flow of party revenue from the spoils of office. In this respect, the rules governing the financing of political parties are likely to contribute to the incentive structures for corruption, either by preventing parties from raising funds via legitimate means (often a counter-productive way of regulating party behaviour) - as (often the cases of France and Italy until reforms in the 1990s -or by giving them too much freedom to 'milk the state' in systems where parties exert a strong influence over the public sector by their control of appointments and promotions.

The growth of expenditure until the 1990s in those countries with politicised bureaucracies and public sectors -due both expansion of the welfare state and public works (sometimes linked, in the south, to regional development spending, including the important contribution of EU structural funding) -has produced three general types of public corruption. In most instances these have been linked to the search by politicians for sources of illicit political finance: Corruption linked to the awarding of public works' contracts (a sporadic form of illicit funding in France and Spain but more systematic in Italy). The creation of client groups via welfare commitments and the use of state patronage (also limited, short-term and largely local in orientation in France and Spain but, again, more systematic in Italy).

The corruption of public sector management, which shows evidence of having become an engrained, and systematic - if not systemic - feature of the Spanish and French systems in some sectors, although it is still less widespread and institutionalised than in the Italian case.

In all cases, the net result is the degradation of public life, with the development of a cynical and exploitative ethos that triumphs over notions of administrative independence and impartiality or altruistic public service.

Countries with high levels of bureaucratic politicisation also tend to be characterised by ineffective political checks and balances. Italy's Cconsociative democracy' has long seen a remarkable degree of crossparty consensus, not just in coalition governments but between government and opposition." The political contest and regular alternation in power characterising the British system-and which has contributed to that country's record of relatively clean government (at least until recently) -has been quite absent in most continental European polities. Although Italian 'consociativismo' cannot be reduced to solely clientelism or 'lottizzazione' (the competition between parties to control public appointments and promotions), the key to the postwar settlement was the use of state resources for building consensus under the hegemony of the Christian Democratic Party (DC) which completely dominated Italian politics until the late 1970s. Even then, real alternation in government did not occur. The most effective means of challenging the hegemony of the Christian Democrats was less to beat them than join them, producing a decade or more of tacit alliance with the Socialists under Bettino Craxi, who made corruption an art form in their endeavours to emulate DC empire-building. 12 Real political competition was suppressed under a deal in which the spoils of the state and the control of the state machine were divided proportionally between the parties.

Elsewhere in Europe, the pursuit of political hegemony was less successful, either in minimising political competition or in dividing up the state. But in many cases-even in majoritarian systems that are based on the principle of alternation in power-there have been attempts to minimise political competition as a check on party political control of the state machine. In the case of France (1981-86) and Spain (1982-93) with single (Socialist) parties in powers benefiting from a majoritarian vote, there was a colonisation of the management of all important institutions. This included, in Spain, those intended to check government powers (e.g. the national audit office), while ministries with large ministerial offices ('cabinets') witnessed large-scale political appointments. This occurred, of course, against a background of wellestablished collusion across the public-private divide. In Spain, as already discussed, there was a system of generalised corruption under the dictatorship system until 1978, after which many of the Francoist elite simply continued in office under the new regime. In France until 1981, it is evident that the Gaullist party and its candidates had been favoured by privileged relationships with industrial and business lobbies and therefore, a little like the DC in Italy, were the 'natural' party of corrupt governance. There was also a degree of collusion in France in the present decade, since it was the Rocard government that submitted the bill to parliament which granted an amnesty to corrupt practices that had taken place before 1990: investigations which could have involved the Right, especially those dating back to the 1970s, cannot therefore come to light.

These systems have also tended to lack strong independent judiciaries and that critical element of the OECD checklist for an 'ethical infrastructure'- an active civil society (including a probing media) playing the role of watchdog over the actions of public officials. Indeed, in the societies of the 'corrupt cluster', relations between the political system, the judiciary and media have also been characterised by 'competition avoidance' through long-standing deals that have only recently begun to break down. As for the judiciary, in terms of the principle of the separation of powers, it is an independent part of the constitution and considered politically impartial. In practice, however, in many democracies politicians have tried to produce mechanisms that allow political interference in its activities. The politicisation of the judiciary in Italy, France, Spain and Belgium, producing both direct political constraint and protective elite collusion, means that the application of the law has often been politically influenced, effectively neutralising-- at least until recently -the pursuit of political crimes and illicit public behaviour. As for the press, politicians have always tried to control information given to journalists. This control can take the form of direct censorship or an indirect, more insidious, form of disclosing certain information to hide other facts. Political ownership of the press has also brought journalists within the sphere of political consensus, making them bulwarks rather than subverters of the status quo.

Recent years have seen an invigoration of competition in these systems at all levels, between political parties and among political, judicial and media elites. This greater competition goes a long way towards explaining the sudden explosion of corruption scandals in the 1990s and should, in principle, lead to a decline in corruption, especially where ruptures in the traditional collusive bargains also produces new rules and renewed respect for the principle of public service (although, of course, this is not guaranteed). In France in 1981, one dominant power was replaced with another when the Socialist Party of Francois Mitterrand came to office, but then cohabitation between a Socialist President and right-wing Prime Minister (and the reverse after 1998, with the Chirac/Jospin tandem) has altered the nature of political competition in the country, but with uncertain results (see below). Spain had a relative majority for the first time in 1993 since the late 1970s and then, in 1996, first real alternation in government, with the arrival of the People's Party in power. Italy had its first coalition without the Christian Democrats in 1992, followed by the collapse of the old parties and the emergence of new ones, leading in 1994 to the first the coalition of the right-wing Polo under Berlusconi, which was replaced by the centre-left Ulivo coalition in 1996.

But political competition on its own may even have perverse effects with regard to corruption if democratic checks and balances are not also strengthened. Italy and Belgium provide two instances of this. In the Italian case, greater party competition from the late 1970s generated by the spectacular electoral growth of the Socialist Party simply led to a new form of competition avoidance and an expanded exploitation of the public sphere for political ends. In the Belgium case, greater party competition linked in part to the emergence of the extreme right (Vlaams Blok and Front National)-which has politicised and campaigned on the corruption issue-has helped to encourage non-denunciation and retaliation pacts among traditional parties which realise that an escalation of corruption disclosure will only benefit these radical anti-system parties at their expense.13 Only if other checks and balances are simultaneously strengthened will greater party competition contribute to greater rectitude in the public sphere. In the southern countries and France, precisely this has been occurring, and there the emergence of new checks and balances has been critical in both exposing scandal and in undermining the credibility of the traditional political parties. In all of these countries, the judiciary and journalists have assumed new and more independent roles-in the 1990s, the first by exercising greater control on politicians, the second by communicating (and interpreting) the corrupt affairs of state to the citizenry. In conjunction, these control and communication functions have undermined-to one degree or another-the corruption status quo. It remains to be seen how far-reaching the campaign to eradicate corruption will be. Signs from Italy are less than positive in this respect: to date (summer 1999) the Italian parliament has failed to pass into law any of the ten draft laws proposed by the Chamber of Deputies' Special Commission on Anti-Corru tion Laws in 1997.

Of course, one of the most important changes to accompany this invigoration of checks and balances and civil society will be in administrative regulations and controls. As Tanzi points out, the most effective controls are those that exist inside institutions - honest and effective supervisors, good auditing offices and clear rules on ethical behaviour should be able to discourage or uncover corrupt behaviour. 14 The inadequacy of such controls in the past has clearly contributed to the political corruption incentive structure in many European countries. Even where they have existed, accountability and control, codes of conduct and professional socialisation are considerably weakened by politicisation, multiple office-holding and systems of poorly regulated personnel transfer from the public to the private sector, producing conflicts of interest and opportunities for corruption on a wide scale. This has been the case of France, for example, even in the presence of strongly socialised and self-conscious bureaucratic elite imbued with the notion of public service.15 In the other countries of the 'corrupt cluster' politicisation has even extended to the institutions supposedly responsible for ensuring accountability and control. The Belgian case is an example. There, the official anti-corruption service has itself been highly politicised, and its two most senior positions have been the subject of Christian Democrat and Socialist Party patronage. Politicisation at its lower levels has ensured that information has been leaked to politicians under investigation. Inspectors of Finance depend for part of their income on good relations with their minister, to whose party they will also typically belong (troublesome ones are transferred to other ministries), while reports of the parliamentary Audit Office are generally voted on several years late and are ignored by MPs. While parliamentary committees of investigation have a greater role than in the past, not one single minister denounced by them has resigned. Meanwhile, as in most other European countries, civil servants are subject to secrecy rules and there is no 'whistle blowing' system that protects public officials who reveal administrative malpractice.

New opportunities for corruption in the 1990s

Corruption incentive structures have expanded everywhere in the 1980s and 1990s as a result of a number of simultaneous developmentsgreater problems of party finance and its regulation, a revolution in the international economy, associated with ideological change, and the transformation of the state and the public sector through privatisation and deregulation.

It is worth noting that problems of party finance and its regulation have increased in all countries in recent years. 16There are numerous, interrelated, explanations for these problems, including:

The growing bureaucratisation of party organisations, linked to the emergence of 'cartel parties'.17 State funding for parties has not only strengthened their oligarchic tendencies but also their capacity to resist new challenges, given that state funding is often tied to prior party performance or position.

The increasing costs of campaign expenditure, driven in part by the new and expanded role of the media. Television has enhanced the conditions that allow, or compel parties to make universal appeals to voters, rather than communicate through and to their core supporters.

A change in the nature of political competition. Greater use of the media helps create new rules of party competition, based on leadership-- focused contests, which weakens the traditional character of parties and increases the cost of politics.

The decline of traditional means of party finance (e.g., membership dues, voluntary donations, fund-raising events, lotteries), as well as in contributions from business and labour (as politics becomes less ideologically driven), has led parties to seek alternative, and often illegal, sources of funds.

The last twenty years have seen a significant restructuring of the economy, including changes in the nature and location of production, the appearance of new services, the internationalisation of trade and the globalisation of financial markets, which have given a new dimension to certain forms of corrupt behaviour (for example, insider trading, the manipulation of public markets). As the corruption investigations in Italy have revealed in the 1990s, the internationalisation of the black market in corruption makes it difficult for judges to untangle the sophisticated bank transactions involved in 'laundering' money through dozens of accounts placed in the world's tax havens. The creation of the European single market also provides new opportunities for such practices, as traditional barriers to the free flow of capital and persons have been removed. EU integration has produced a clash of regulatory cultures and an imposition of certain 'Protestant' norms and values on the South. But financial market deregulation and the retreat of the state-as well as the proliferation of EU funds through complex and poorly monitored channels-have provided new opportunities for the expansion of corruption and fraud. Italian corruption could not have been so extensive without facilitating banking practices, financial transactions and offshore operations. At the same time, the neo-liberal devaluation of the state, public services and public administration has had important side-effects, such as the discrediting of the traditional values- which underpinned these very institutions._

Meanwhile, of course, the institutional structure has itself been changing in a rapid and far-reaching fashion, including: the transformation of regulatory system; the weakening of representative bodies, such as parties and unions, with elites or leaders cut off from an everdiminishing base; the blurring of the dividing lines between public and private sectors by privatisation and the transfer of elite personnel from one sector to the other; the decentralisation of government and public administration (extending opportunities for corruption in Italy and Spain, for example); and the creation of a new, parallel, opportunity structure for corrupt practice in Europe's transnational polity, by poorly monitored and controlled transfers of funding through the EU's agricultural and structural funds budgets. While the southern countries (especially Italy) have always figured large in the list of fraud cases involving EU funds, northern countries have hardly been absent, with Germany figuring prominently in agricultural fraud (revealing apart from anything else the efficiency with which its reports such cases).

Contrary to assumptions often made about reducing the size of the state to reduce the incidence of corruption (the recipe for traditional societies without arm's length social relations, according to Tanzi18), neither privatisations nor the extension of private-sector management techniques to bureaucracies across western Europe has clearly separated the private from the public sphere, nor politics from markets. Instead they have blurred the dividing lines and increased the scope for discretionary powers. Thus a public bank can now take all the risks in the international market but is not constrained by controlling shareholders (for example, certain public regional banks in Germany); a private business with public markets and contracts where public services have been 'semi-privatised' or 'contracted out' will seek to influence the politicians or civil servants who manage that 'public' market. Such incestuous relationships have been multiplied by the increasing interplay between political, administrative, economic and financial elites.

The detrimental consequences of such changes have been observable in all European countries.19 In Britain, the 'marketisation' of the public sector and the introduction of new management techniques have created the preconditions for a proliferation of corruption and fraud, producing a wide range of new conflicts of interest. Over the ten years from the 1985 to 1995, nearly 80% of civil servants were moved from working in central government departments into semi-autonomous agencies, raising an important issue of how such agencies -some with chief executives brought in from the private sector-should be made properly accountable. At the same time, Parliament has no clear and uniform standards for the conduct of MPs: bribery of MPs does not fall under criminal law; trade unions donations to the Labour Party are regulated (they must be approved by membership ballot) but there are no controls on company donations to the Conservatives; and patronage in various forms has been dispensed widely. In the Netherlands, the opportunity structure for corruption expanded in the 1960s and 1970s with the growth of government services, creating a complex network of cooperation, consultation and mutual involvement between private and public bodies. Corruption has increased particularly in the customs service, the police, local administration and the sector of semipublic and subsidised bodies, while the evasion of taxes and social security contributions has increased. In Germany, with a professional civil service and a strong sense of public morality, the 1980s witnessed a series of corruption disclosures, one of which-the Flick Affair-- revealed how political parties had long depended on money from foundations set up in order to evade the tax laws and clientelistic relations between donors and politicians. A long string of public works and construction scandals implicated both Social Democrat and Christian Democrat mayors. Other disclosures followed, especially in local government where in many parts of the country auditing controls are too lax. Everywhere, as a result of these developments, the issue of public service ethics has risen higher on the political agenda, stimulating organisations such as the OECD to promote new codes of behaviour and institutional reform.

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