Four Components of Combating Corruption in Customs: The Polish Experience

IT Systems, Management and Human Resources, Society, and Law Enforcement – The Key Components of Success

Twenty years ago, Poland faced a pressing question: how to stop the spread of corruption in customs? What plan and methods should be applied to deliver noticeable results in a relatively short time? There are no perfect models, but there is experience that can be considered successful. Given the shared border between Ukraine and Poland, their common past in the “socialist bloc,” and Ukraine’s goal of joining the EU Customs Union in the near future, Poland’s experience can be highly valuable for Ukraine.

In 2003, on the eve of EU accession, Poland ranked 64th out of 133 countries in Transparency International’s Corruption Perceptions Index (CPI), with a score of just 3.6 out of 10 (where 10 means no corruption).

The percentage of citizens convinced of widespread corruption in Poland was also growing year by year. According to research by the state-owned Public Opinion Research Center (OBOP), 43% of respondents considered corruption very widespread in 1999, 54% in 2002, and 68% in 2003. Only 3% regarded corruption as a rare phenomenon. Social tolerance of corruption was relatively high.

This is why great attention was paid to transparency, anti-corruption policies, and measures.

The success of anti-corruption efforts in Polish customs can be explained by four key factors:

1. IT Systems – Reducing the Human Factor

Reducing the human factor through the introduction of modern IT tools significantly minimized opportunities for corruption. IT solutions reduce or even eliminate direct contact between customs officers and traders, which is one of the main corruption risk points. Digital systems also allow proper tracking, logging, and auditing of processes.

Poland introduced IT tools for change management, declaration processing, and audit control. Among the systems implemented: electronic queues for processing, registration of every processing step, automated risk analysis, systems for selecting customs officers for posts, and indication systems for inspections.

Additionally, Poland adopted the Polish Electronic Customs Plan 2008–2013, which covered external, infrastructure, and internal components. The list of systems was aligned with the EU’s Multi-Annual Strategic Plan for Customs (MASP-C).

Importantly, it was recognized that IT systems themselves could also be a corruption risk if controlled by a small group. To minimize risks, functional requirements were defined by customs in consultation with DG TAXUD (European Commission’s Directorate-General for Taxation and Customs Union), tenders were held separately for each component, and external developers were engaged. Customs developed only smaller, non-critical components in-house. A Steering Committee was established to coordinate IT development.

2. Management and Human Resources

Since the human factor cannot be completely eliminated, working with and managing personnel was just as important.

Roles and Responsibilities:
Polish customs identified seven key “players” within the organization who had to be engaged in fighting corruption:

• Head of Customs Administration – overall responsibility and project implementation (project leader).

• Central Coordination Group – coordinated efforts, prepared reports, liaised with business associations, NGOs, and research institutions.

• Control Team (special unit) – ensured compliance with the law, cooperated with external agencies, analyzed cases, identified root causes of corruption, and maintained a risk register.

• HR Department Staff – handled recruitment, training, and competitive selection of personnel.

• Departmental Managers (control, audit, organization) – responsible for implementing anti-corruption procedures.

• IT Staff – implemented anti-corruption elements in IT systems and tools.

• Regional Managers and Middle Management – ensured execution of anti-corruption policies.

Key measures: anti-corruption training for new and existing employees, transparent hiring campaigns, incentive and motivation systems, practical staff rotation, random selection of officers for control tasks, inspections and audits based on risk analysis, and clear instructions on handling bribes or external pressure.

Organizational improvements included process optimization, duty segregation, multiple layers of oversight (“four-eyes principle”), expanded border control points, and enhanced re-inspection capabilities. Reporting procedures for corruption attempts were formalized, and control decisions were increasingly based on risk analysis. Random assignment of duties further minimized misconduct risks.

Monitoring and Enforcement: zones at checkpoints were monitored, and cooperation with authorized bodies was strengthened, including the Central Anti-Corruption Bureau (CBA), Internal Security Agency (ABW), Police, and Border Guard (SG).

Motivation: salaries were raised, and additional bonuses were provided to border unit staff and crime-fighting divisions, making these positions more competitive and rewarding.

Education: campaigns emphasized zero tolerance for corruption and reframed corruption as a “cancer” harming society, economy, and security. Anti-corruption training, courses, and seminars ensured all staff were informed and committed to upholding integrity standards.

3. Society and Public Engagement

Because the primary stakeholder in fighting customs corruption is society – both businesses and citizens – Poland launched a Public Anti-Corruption Campaign.

This campaign ran both offline and online (including social media) and was based on cooperation with business partners and civil society organizations. Its goals were to identify corruption-prone areas, develop solutions to limit corruption, and raise awareness about anti-corruption procedures. Meetings, seminars, and joint initiatives were organized regularly.

By supporting this campaign, customs leadership demonstrated that the “zero tolerance” policy started from the very top.

4. Law Enforcement Cooperation

Polish customs did not have its own internal investigative powers and could only participate as a partner in investigations led by other law enforcement agencies.

Under its anti-corruption strategy, customs established close cooperation with the Central Anti-Corruption Bureau (CBA). This cooperation included identifying corruption-prone areas, processes, and positions, evaluating the resilience of processes and IT tools, and working jointly with CBA, ABW, Police, and SG on investigations and recommendations for improvements.

In 2011, customs introduced the legally approved right to use polygraph testing, initially for special surveillance units and later for new hires and specific justified cases.

Results and Impact

Within a relatively short period, Poland significantly improved the situation regarding corruption at customs, which also impacted the country’s overall indicators.

In Transparency International’s CPI, Poland improved from 63rd place in 2010 to 41st in 2012, and by 2015 ranked 29th. Within just five years, its score increased from 3.6/10 to 63/100 (TI switched to a 100-point scale), where 100 means no corruption.

Conclusion

Poland’s experience shows that sustained results require a systemic approach that includes IT systems, effective management and human resources, public engagement, and close cooperation with law enforcement.

The EU4PFM Programme is ready to support Ukraine in adopting and implementing these key elements and initiatives, helping strengthen the anti-corruption foundation of Ukraine’s customs service and bringing the country closer to its goal of EU membership by 2030.

Jurgita Domeikiene
Head of the EU Public Finance Management Programme (EU4PFM)

Jacek Kapica
EU4PFM Expert,
Former Head of the Polish Customs Service (2008–2015)