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The Organisation for Economic Cooperation and Development (OECD) Working Group on Bribery has recently reviewed Finland's anti-corruption laws and found them wanting. In an unusually sharp rebuke, Finland was criticised for "general lack of awareness and understanding of the foreign bribery offence in both the public and private sectors".
The OECD monitors and evaluates enforcement of its "Convention on Combating Bribery of Foreign Public Officials in International Business Transactions" in its 38-country membership on a regular basis. This review mechanism is unique among anti-corruption conventions, and marks out the OECD charter as unusually effective.
What makes the working group's review - and subsequent criticism - of Finland particularly interesting is that the Scandinavian nation is generally considered to be one of the least corrupt countries in the world.
This is in large part due to its high ranking in Transparency International's famous Corruption Perceptions Index (CPI), which is regarded both by the media and corporate compliance groups as an important corruption benchmarking tool.
Finland was judged to be the sixth least corrupt country in the 2009 CPI. However, Transparency International takes great pains to point out that a top ranking doesn't rule out the possibility of graft.
"New Zealand - whose perceived public sector corruption is the lowest of the 180 countries surveyed - is not necessarily the 'world's least corrupt country' – and New Zealanders are not in turn immune to corruption. Though its institutional and governance framework have translated into what is perceived to be a success, with limited corruption, New Zealand - like any other state - remains susceptible to corruption," the anti-graft watchdog says on its website.
There are also issues surrounding measurement. Any survey that relies on perceptions of corruption is subjective by definition - something that Transparency International also acknowledges.
The OECD working group's review of Finland does support the findings of the CPI, noting that Finns believe their country to be largely corruption-free and pointing to "an excellent record of a low level of corruption in government".
However, it seems Finnish companies may act differently when carrying out business abroad. "Finnish companies know that, when they deal with developing countries, tenders have to include a budget for bribes," the review cites a Finnish public official as saying.
It concludes that the low level of corruption in Finland itself could be part of the problem: "Finland appears to rely on its long-held reputation as a transparent and non-corrupt society, rather than proactively raising awareness (in both the public and private sector) of the offence of foreign bribery and the responsibility to report it."
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