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================= Civilian-Military Alliance for Reforms in Society ================= ================= ================= ================= ================= The Cavaliers, the PMA Alumni Association ================= ================= Young Officers Union of the New Generation (YOUNG) ================= Restoring Democracy in the Philippines ================= Rene Jarque . USMA West Point Class 1986 ================= Rene Jarque . USMA West Point Class 1986 ================= Message To The Filipino People Armed Forces of the Philippines ================= The Last RevolutionTowards A New Philippine Order================= Sen. & Lt. Col. Gregorio Honasan ================= Corruption in the Philippine Navy Procurement System ================= A Study of Corruption in the Philippine Navy ================= |
Corruption in the Philippine Navy Procurement System
INTRODUCTION On February 2001, the Philippine Navy (and the AFP) was rocked by a leadership crisis when the Philippine Marines (PMAR) demanded the relief of the Flag-Officer-In-Command, Rear Admiral Guillermo Wong (Pazzibugan, 2001). The crisis was triggered by the berating of the Marines by RAdm Wong for alleged irregularities in the procurement of P3.8 million worth of Kevlar Helmets (Pablo, 2001). In the events that followed, the Marines prevailed and RAdm Wong was stripped of his command and was “promoted” to an ambassadorial post. The crisis, while it was eventually resolved peacefully, exposed a previously unseen face of the Navy - the face of CORRUPTION. BACKGROUND: THE PHILIPPINE NAVY The Philippine Navy (PN) is one of three branches of service of the Armed Forces of the Philippines (AFP). Its mission is ”to conduct prompt and sustained naval operations in support of the AFP’s mission”. Among its functions are; to provide naval defense to ensure the sovereignty of the Philippines and to protect the people from external threats; to conduct naval operations in support of air and ground operations; to conduct maritime law enforcement within the territorial waters and Exclusive Economic Zone; to promote safety of life at sea and environment protection; and to assist in national development efforts (NOQC Naval Orientation Reference Handguide, 1997). The following are the other relevant information about the Philippine Navy: A. Personnel - 1,687 Officers 10,561 EP
Marines - 387 Officers 7,142 EP
B. Budget - P6.88B (see Annex C) (Source: GAA 2000) C. Organizational Chart
* The units highlighted in red ink will be the subjects to be used to generalize the findings in this research as explained in the Methodology chapter below. AUTHORITY The authority of the Philippine Navy and all government agencies to procure is “in accordance with the guidelines prescribed under the Implementing Rules and Regulations (IRR) of Executive Order No. 302 (entitled ‘Providing Policies, Guidelines, Rules and Regulations for the Procurement of Goods/Supplies by the National Government’) dated February 19, 1996” (this was amended later by E.O. 262) “and with due regard to the provisions of the Government Accounting and Auditing Manual”. (Manual on Procurement, 1999). For the AFP, this was operationalized by the Department of National Defense Department Order Nr 47 dated 30 April 1996 entitled “Delegation of Authority on Local Procurements” and further regulated by J-4 Logistics Directive Nr PC-97-03 dated 01 August 1997. PROCUREMENT PROCESS
RESEARCH PROBLEMS This research seeks to resolve the following problems: 1. Does corruption exist within the procurement system of the Philippine Navy? If so, what are the different forms of corruption being practiced? And, where within the PN bureaucracy do these corrupt practices occur? 2. Is there a relationship between offices exposed to boundary exchange and corruption propensity? CONCEPTUAL AND THEORETICAL FRAMEWORK This research covers two parts. The first part is a descriptive analysis of the existence and extent of corruption, the forms of corruption being practiced, as well as the other variables stated. The second part will follow the theoretical framework shown below:
From this framework, this research hypothesizes that the boundary exchange processes between PN procurement officials and accredited dealers, which work within the milieu of the procurement system will result to bureaucratic corruption. CONCEPTUAL DEFINITIONS 1. BUREAUCRATIC CORRUPTION - is “defined as a dysfunctional and pathological act that negates the accomplishment of its constitutional mandate of promoting public interest” (Sosmena, 1999: 6). 2. CORRUPTION – According to Klitgaard, “it is the misuse of a public office for personal gain” (Sosmena, 1999). Corruption may be categorized into two: individualized or systemic (Carino, 1985: 15). Individualized corruption is where a person performs a secret moneymaking act in relation to his duties as public official or government employee. While systemic corruption is committed in an agency where “corruption has become so regularized and institutionalized that organizational supports back wrong-doing and actually penalizes those who live up to the old norms” (Caiden, 1977: 306). It is “demonstrated when bureaucrats and clients can describe the same illegal process, including such details as bribery rates per service and the way these are shared among the members of the syndicate throughout the agency. Those with ‘initiative’ and ‘daring’ share the largesse with their colleagues with less opportunities, thus engulfing everyone in an administrative culture that tolerates, even idolizes, the fruits of corruption.” (Carino, 1985: 15) 3. BOUNDARY EXCHANGE – “a value-free interaction” or exchange of boundaries between the client and the public official (as defined by Dr Prosperina Tapales during an interview conducted on 21 March 2002). 4. PROCUREMENT OFFICIAL- for the purpose of this research, all PN officers, enlisted personnel, and civilian employees involved in the PN procurement system will be labeled as procurement officials. It will also include the officials and personnel of the local Commission on Audit office. 5. FORMS OF CORRUPTION: A. Bribe or Lagay- also known as SOP, commission, porsyento, “for the boys”, etc. This is “grease money” given to the procurement official by the dealer to facilitate the processing of documents or as a return favor for a project given. B. Extortion or Tong- money demanded by the procurement official to a dealer to facilitate the processing of documents. C. Negotiated Canvass or Nego- an arrangement made by the dealer and the procurement official to manipulate a canvass method of procurement to ensure that the purchase order would be “won” by the said dealer. This is done by giving all the canvass papers of a certain project to the favored dealer. Thus, effectively depriving other interested dealers. D. Rigged Bidding or bidding-biddingan- an arrangement made by the dealer and the procurement official/s to manipulate a public bidding method of procurement to ensure that the purchase order would be “won” by the said dealer. This is done by the collusion between all the attending bidders, which include the favored dealer, and the Bids and Awards Committee. E. Ghost Delivery or Conversion – the process in which government funds allocated through budget releases are “converted” into cash. This is done by preparing procurement documents taken from either a negotiated canvass or a rigged bidding, then, instead of delivering the items stated in the purchase order, the dealer would deliver the cash equivalent of the goods in the purchase order, less certain percentages for the dealer’s profit. F. Over-Pricing – to cover for the additional expenses incurred by the lagay, the dealers and procurement official mutually agree on setting the price, which are way above the authorized limits. G. Under Delivery – again to cover for the additional expenses incurred by the lagay, the dealers and procurement official mutually agree that the quantity of the delivery would be lower than the one specified in the purchase order. H. Substitution – to circumvent certain prohibitions of the law, specifically the General Appropriations Act, where certain gov’t agencies have no capital outlay and, therefore, cannot buy equipment, the dealer and the procurement official mutually agree to deliver items other than those stated in the purchase order. OPERATIONAL DEFINITIONS 1. Perception of corruption on the PN procurement system – this will be measured by asking the respondents the question, “Sa pananaw ninyo, mayroon bang corruption sa procurement system ng PN sa kasalukuyan?” 2. Perception of corruption on the procurement system of major units of the PN – this will be measured by the statement “Base sa inyong pananaw, sukatin ninyo ang level ng corruption ng mga sumusunod na unit ng PN.” To quantify the different levels, a fixed ratio scale was formulated wherein a standardized value was assigned to a corresponding level of corruption. A value of 0 was assigned for the level, walang corruption; 1 for the level, madalang ang corruption; 2 for the level, di-gaano laganap ang corruption; 3 for the level, laganap ang corruption; 4 for the level, talamak ang corruption. 3. Perception of corruption of the different offices involved in the procurement system- is measured by the question “Sa pananaw ninyo, alin sa mga sumusunod na opisina na kasapi sa procurement system ay mayroong nagaganap na corruption?” 4. Perception on the eradication of corruption in the PN procurement system- is measured by the question “Kayo ba ay pabor na alisin ang corruption sa procurement system ng PN? REVIEW OF RELATED LITERATURE While there are volumes of literature on corruption, there are very rare writings that directly dealt with corruption on the procurement system of a military organization or any government agency for that matter. One such writing is the article for the Philippine Center for Investigative Journalism by Malou C. Mangahas entitled “Kickbacks and Negotiated Deals mar AFP Procurement System”. While the said article made some startling revelations, it did so under conditions of “journalistic freedom”, where the data gathered came as unstructured information fed by people from both inside and outside of the organization (AFP) and, therefore, lacks the criteria of validity and reliability to support its findings as in a technical research. SIGNIFICANCE OF THE STUDY The Martial Law years have created a fearful reputation for the AFP organizations. Because of this, no group has ever dared to conduct any formal research on corruption on the procurement system of a military organization. Thus, the significance of this research couldn’t possibly be overstated. This research will provide a vivid picture of what used to be a restricted domain of the AFP. It can also be seen as a microcosmic representation of the procurement systems of various government agencies. METHODOLOGY RESEARCH DESIGN The survey design was used since it is the most applicable for the quantitative-descriptive and quantitative-explanatory approaches of this research. UNITS OF ANALYSIS The following are the units of analysis: 1. The Philippine Navy. It is represented by its five major units based in the Manila-Cavite area namely; Headquarters Philippine Navy, Headquarters Support Group (HPN,HSG); Headquarters Philippine Fleet (HPHILFLT); Headquarters Philippine Marines (HPMAR); Naval Logistic Center (NLC) and the Naval Sea Systems Command (NASSCOM). These units were chosen because of their huge individual budgets and, therefore, are the main procuring agencies of the PN. A. HPN,HSG – The support unit of the main headquarters of the PN. B. HPHILFLT – One of two operating arms of the PN. This unit has the administrative control over all floating and air assets. C. HPMAR – The other operating arm of the PN. It has administrative control over all Philippine Marine (PMAR) brigades and other PMAR units. D. NLC – The main procuring agency of the PN. It is responsible for supplying the bulk of the logistical requirements of the whole PN. E. NASSCOM – The main service support group of the PN. It is also responsible for the repair of ships and other major equipment. 2. All offices involved in the procurement process (as shown in the diagram above). 3. Accredited dealers of the PN. RESPONDENTS The respondents chosen are the accredited dealers of the PN because they are considered to be insiders in the procurement system and they would be easier subjects to extract confidential information from, than the officials involved in the procurement system. TECHNIQUES OF DATA COLLECTION A primary technique of data collection (questionnaire) was used for this research. As for the sampling strategy, a simple random sampling from a sample frame of all accredited dealers of the PN was initially planned. However, it was found that there was no updated list available and the said non-current list contained inactive or inexistent dealers, which made probability sampling inapplicable. Hence, purposive sampling methods were resorted to. STATISTICAL TOOLS Chi-square Statistic was used to establish the relationship between two nominal variables namely; boundary exchange and corruption. The application of said statistical tool was facilitated by the use of Statistical Package for Social Sciences (SPSS) software. LIMITATIONS OF THE STUDY Due to the sensitivity of the research subject, which could expose or incriminate a military organization like the Philippine Navy, the respondents may not have fully detached themselves from the physical or professional risks involved, despite the assurances of the researcher. Thus, the objectivity of some of their answers may have been affected by the fear of reprisal. FINDINGS DESCRIPTIVE STATISTICS PROFILE OF THE RESPONDENTS Of the 30 accredited dealers chosen as respondents, only 1 (3.3%) is a male while 29 (96.7%) are females (Table 1). This could be explained by the conjecture that since the PN is a male-dominated workplace, having females as dealers may help in facilitating business transactions. TABLE 1: FREQUENCY DISTRIBUTION BY GENDER Gender Frequency Percent Female 29 96.7 Male 1 3.3 Total 30 100.0 PERCEPTION OF CORRUPTION ON THE PHILIPPINE NAVY PROCUREMENT SYSTEM The frequency distribution on the perception of corruption on the PN procurement system yielded an absolute (100%) affirmative answer that corruption does exist. (See TABLE2) PERCEPTION OF THE LEVEL OF CORRUPTION ON THE PROCUREMENT SYSTEM OF THE MAJOR UNITS OF THE PN HPHILFLT scored the lowest at 1.43 and falls under the level of madalang ang corruption. This is due mainly to the integrity and moral resolve of its incumbent commander, RAdm Ruben G Domingo. Most of the respondents even qualified their answers in a way that if it weren’t for the lagay at COA, HPHILFLT would have been corruption-free. HPN,HSG came in a distant second with a score of 2.30, followed by the HPMAR at 2.39. Both of these units fall under the level of di-gaano laganap ang corruption. The most corrupt PN units as far as the dealers were concerned were NASSCOM (2.87) and NLC (2.95), whose scores fall under the level of laganap ang corruption. According to them, the high levels of corruption of these units were caused by their commanders’ blatant negative bureaucratic behavior. (See TABLE 3) FORMS OF CORRUPTION The most common form of corruption being practiced is the lagay, which recorded a 100% frequency. This was followed by the “negotiated canvass” at 86.7% and “rigged bidding” at 76.7%. The least practiced is the “under delivery” at 36.7%. (See TABLES 4 and 5) REASONS WHY CORRUPTION IS BEING RESORTED TO The main reason why corruption is being resorted to by the dealer is, in order “to expedite the processing of documents” (96.7%). A significant number of respondents (63.33%) also said that another reason is “to be able to get a project or transaction”. While only 36.7% of the respondents answered that utang na loob was the reason. (See TABLE 6) WHO INITIATES CORRUPTION? On the question of “who initiates corruption?”, a significant number (83.3%) claimed that the corrupt practices were mutually agreed upon by both parties with neither one initiating directly. Instead, these under-the-table transactions have become a routine activity that it had evolved to an SOP or standard operating procedure. (See TABLE 7) PERCEPTION OF CORRUPTION PER OFFICE Surprisingly, the offices, which emerged as the top three from the frequency distribution, are civilian offices; the Commission on Audit (100%); the Accounting Office (66.7%); and the Supply Accountable Office (66.7%). While the finding for the COA is indisputable, a big factor in the findings for other two offices could be that the dealers are more willing to volunteer information against civilian employees than against military officers. Among the military offices, the procurement office figured the highest in terms of corruption perception at 60%. It is followed by the logistics office and the Commander’s office both at 56.7%. The Bids & Awards Committee (16.7%), Deputy Commander’s office (20%) and Chief of Staff office (20%) are the three lowest in terms of corruption perception. (See TABLE 8) IS THERE A FIXED RATE OF “LAGAY’ PER OFFICE According to all 30 respondents, there is a fixed rate of lagay per office. However, this finding is deceiving because, while it is applicable to the COA where there is consistency in the fixed rate indicated by the respondents at 1-2% of the total amount of the purchase order, the entries for the other offices had a wide range of variance. This could be explained by the tendency of the dealers to get confused in assigning fixed values for every office. They further qualified that these are dependent on the total amount of the transaction. At any rate, the finding for the COA is very significant and indisputable at the same time. (See TABLES 9 and 10) IS IT PROFITABLE TO DEAL WITH THE PN? 28 out of 30 respondents (93.3%) felt that despite the existence of corruption, transacting business is still profitable. This could give us an idea of the high profit margins being padded by the dealers on the goods and services delivered to the end-users just to cover for the expenses incurred by the corrupt practices. (See TABLE 12) PERCEPTION ON THE ERADICATION OF CORRUPTION IN THE PN PROCUREMENT SYSTEM Amazingly, a slight majority of the respondents (53.3%) were not in favor of the eradication of corruption, while 46.7% felt otherwise. One possible explanation for this is that the dealers who did not favor the eradication of corruption are apprehensive that a level playing field may not assure them of getting transactions and, thus, not favor them as much as the status quo. Specifically, a level playing field will negate whatever “business” connections they have with those with discretionary powers. (See TABLE 13) INFERENTIAL STATISTICS RELATIONSHIP BETWEEN CORRUPTION PROPENSITY AND BOUDARY EXCHANGE Chi-square statistic was used to establish if there is a relationship between boundary exchange and corruption propensity for every office involved in the procurement system. Of the 12 offices subjected to the research, only the Deputy Commander’s office and Bids & Awards Committee obtained a significance level higher than the 0.05 threshold set to conclusively establish a relationship. Hence, for these two offices, there was not enough evidence to conclude that there is a relationship. But for each of the other offices, the relationship between boundary exchange and corruption propensity was found to be conclusive. COMMANDER’S OFFICE Chi-Square Tests
Value df Asymp. Sig. (2-sided) Pearson Chi-Square 19.615 1 .000 ANALYSIS: The data indicate to us that, at the office of the Commander, corruption propensity and boundary exchange are directly related. Of the 17 respondents who perceived that there is corruption at the office of the Commander, all of them had boundary exchange processes with the said office. Statistically, this is validated by the chi-square test value of 19.615 and significance level of 0.000. DEPUTY COMMANDER’S OFFICE Chi-Square Tests Value df Asymp. Sig. (2-sided) Pearson Chi-Square 3.750 1 .053 ANALYSIS: The chi-square test value of 3.75 and significance level of 0.053 will indicate to us that, at the office of the Deputy Commander, there is not enough data to conclude that corruption propensity and boundary exchange are directly related. Of the 6 respondents who had perceived that there is corruption at the said office, 4 (66.66%) had boundary exchange processes, while 2 respondents (33.33%) did not. CHIEF OF STAFF OFFICE Chi-Square Tests Value df Asymp. Sig. (2-sided) Pearson Chi-Square 5.868 1 .015 ANALYSIS: The data indicate to us that, at the office of the Chief of Staff, corruption propensity and boundary exchange are directly related. Of the 6 respondents who perceived that there is corruption at the office of the Chief of Staff, 5 (83.3%) of them had boundary exchange processes with the said office while only 1 (16.66%) did not. Statistically, this is validated by the chi-square test value of 5.868 and significance level of 0.015. LOGISTICS OFFICE Chi-Square Tests Value df Asymp. Sig. (2-sided) Pearson Chi-Square 11.940 1 .001 ANALYSIS: The data indicate to us that, at the Logistic Office, corruption propensity and boundary exchange are directly related. Of the 17 respondents who perceived that there is corruption at the Logistic Office, all of them had boundary exchange processes with the said office. Statistically, this is validated by the chi-square test value of 11.940 and significance level of 0.001. COMPTROLLER’S OFFICE Chi-Square Tests Value df Asymp. Sig. (2-sided) Pearson Chi-Square 8.684 1 .003 ANALYSIS: The data indicate to us that, at the Comptroller Office, corruption propensity and boundary exchange are directly related. Of the 10 respondents who perceived that there is corruption at the Comptroller Office, all of them had boundary exchange processes with the said office. Statistically, this is validated by the chi-square test value of 8.684 and significance level of 0.003. PROCUREMENT OFFICE Chi-Square Tests Value df Asymp. Sig. (2-sided) Pearson Chi-Square 5.000 1 .025 ANALYSIS: The data indicate to us that, at the Procurement Office, corruption propensity and boundary exchange are directly related. Of the 18 respondents who perceived that there is corruption at the Procurement Office, all of them had boundary exchange processes with the said office. Statistically, this is validated by the chi-square test value of 5.000 and significance level of 0.025. SUPPLY ACCOUNTABLE OFFICE Chi-Square Tests Value df Asymp. Sig. (2-sided) Pearson Chi-Square 6.667 1 .010 ANALYSIS: The data indicate to us that, at the Supply Accountable Office, corruption propensity and boundary exchange are directly related. Of the 20 respondents who perceived that there is corruption at the Supply Accountable Office, all of them had boundary exchange processes with the said office. Statistically, this is validated by the chi-square test value of 6.667 and significance level of 0.010. COMMISION ON AUDIT Chi-Square Tests Value Pearson Chi-Square N of Valid Cases 30 ANALYSIS: The SPSS could not compute statistically the chi-square value and significance level of the given data because the variable of corruption perception at the Commission on Audit was misread as a constant since all the respondents perceived the COA to be corrupt. Nonetheless, by looking at the Cross Tabulation count, of the 30 respondents who perceived COA to be corrupt, 28 (93.33%) had boundary exchange processes at the said office. Hence, corruption propensity and boundary exchange are directly related. FINANCE OFFICE Chi-Square Tests Value df Asymp. Sig. (2-sided) Pearson Chi-Square 6.563 1 .010 ANALYSIS: The data indicate to us that, at the Finance Office, corruption propensity and boundary exchange are directly related. Of the 14 respondents who perceived that there is corruption at the Finance Office of the Commander, all of them had boundary exchange processes with the said office. Statistically, this is validated by the chi-square test value of 6.563 and significance level of 0.010. TECHNICAL INSPECTION COMMITTEE Chi-Square Tests Value df Asymp. Sig. (2-sided) Pearson Chi-Square 6.982 1 .008 ANALYSIS: The data indicate to us that, at the Technical Inspection Committee, corruption propensity and boundary exchange are directly related. Of the 13 respondents who perceived that there is corruption at the Technical Inspection Committee, all of them had boundary exchange processes with the said office. Statistically, this is validated by the chi-square test value of 6.982 and significance level of 0.008. BIDS & AWARDSS COMMITTEE Chi-Square Tests Value df Asymp. Sig. (2-sided) Pearson Chi-Square 3.409 1 .065 ANALYSIS: The chi-square test value of 3.409 and significance level of 0.065 will indicate to us that, at the Bids and Awards Committee, there is not enough data to conclude that corruption propensity and boundary exchange are directly related. Of the 5 respondents who perceived that there is corruption at the office of the Commander, 3 (60%) of them had boundary exchange processes with the said office while 2 respondents (40%) did not. ACCOUNTING OFFICE Chi-Square Tests Value df Asymp. Sig. (2-sided) Pearson Chi-Square 4.286 1 .038 ANALYSIS: The data indicate to us that, at the Accounting Office, corruption propensity and boundary exchange are directly related. Of the 20 respondents who perceived that there is corruption at the Accounting Office, all of them had boundary exchange processes with the said office. Statistically, this is validated by the chi-square test value of 4.286 and significance level of 0.038. CONCLUSIONS Based on the data gathered, the following are the conclusions: 1. There is corruption in the Philippine Navy procurement system. However, the levels of corruption of the different units of the PN varied and are dependent on the corruptive or non-corruptive behavior of their respective Commanders. 2. There are several forms of corruption being practiced. These are; lagay, negotiated canvass, rigged bidding, “ghost delivery”, overpricing, tong, substitution and under delivery. 3. The main reason why corruption is being resorted to is to expedite the processing of documents. Also, the corruptive behavior is not initiated by the dealer nor the procurement official instead, the practice had become a routine that both parties readily and mutually agree on the terms. 4. All offices involved in the procurement system had corruption incidences. However, some offices were perceived to be more corrupt than the others. Ironically, the COA, which is supposed to be the watchdog of the government against corruption, got a 100% response in corruption perception. 5. There is a prevailing fixed rate of lagay. However, this is dependent on the amount of transaction except for the COA, where the consistent response yielded the amount of lagay at 1-2% of the amount of the transaction. 6. The data gathered validated the hypothesis inferred from the theoretical framework that boundary exchange processes between the procurement officials and accredited dealers, which work within the milieu of the procurement process, will result to bureaucratic corruption. However, this is not applicable to offices, which have no discretionary powers, as in the case of the Deputy Commander’s office and to offices, which are already part of the largesse as in the case of the BAC. RECOMMENDATIONS There are only two practical recommendations that can be formulated as a result of this study. First, is for the PN to strictly adhere to the merit system of promotion and selection of officers to be designated as commanders of its different units. The primary criteria for qualification should be an officer who possesses technical competence and vision to effectively formulate reforms and, more importantly, he should have the moral integrity and political will to implement these reforms. The other recommendation is to limit the boundary exchange processes to the front line levels only so as to totally insulate the other offices. This way, these offices can perform their review and inspection functions with a more independent and dispassionate perspective. AREAS FOR FURTHER RESEARC This research has opened a floodgate for future investigative researches. Foremost of which is an operations research on the auditing processes of the COA. It is very frustrating to know that the very agency tasked to weed out corruption was unanimously found to be the most corrupt office. Another future study is a policy research to formulate policies to address this endemic problem of bureaucratic corruption.
TABLES TABLE2: PERCEPTION OF CORRUPTION ON THE PN PROCUREMENT SYSTEM
TABLE 3: MEAN/STANDARD DEVIATIONS OF THE LEVELS OF CORRUPTION PER PN UNI
TABLE 4: FREQUENCY OF DEALERS’ EXPOSURE TO/EXPERIENCE ON CORRUPTIO
TABLE 5: FREQUENCIES OF DEALERS’ EXPOSURE/EXPERIENCE ON THE VARIOUS FORMS OF CORRUPTION "LAGAY" "TONG"
NEGOTIATED CANVASS OR "NEGO" RIGGED BIDDING
GHOST DELIVERY or CONVERSION OVER PRICING
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