For a clean and sustainable reconstruction of Ukraine

European Research Centre for Anticorruption and State Building (ERCAS)
corruptionrisk.org | acrec.org.ua | ercas@hertie-school.org


We need to collect needs based on multiple sources, involve civil society from planning to audit, set targets for both the public procurement process and outcomes and tie them to the performance evaluation of a newly trained generation of public managers in charge of allocating and managing reconstruction funds.

 

Nothing creates more opportunities for corruption than war. But a war where foreign money pours in is bound to multiply exponentially such opportunities, especially in an already enabling environment. An estimation based on Forbes billionaires database by The Economist magazine found that in 2021, Russia topped the world when comparing crony versus non-crony sectors’ contribution to GDP: but Ukraine also came in fifth place, nearing 40% of Russia’s bad performance (see Figure 2). However, Ukraine had embarked in a variety of serious reforms prior to the Russian invasion (see Figure 1): but none triggered the self-sustainable virtuous circle able to clean the country, in a manner similar to the earlier success stories of Estonia and Georgia. Hence the lack of popularity of both Presidents Poroshenko and Zelensky with Ukrainian civil society before the war.

This short text presents five clear issues that the reconstruction has to grapple with and indicates the type of solutions. This is not a detailed report, but simply a statement of principles needed for a sound reconstruction.

 

Figure 1. Enablers and disablers of corruption in Ukraine 2021.
Source: www.againstcorruption.eu

 

Issue number one is how to organize an evidence-based needs assessment. Public procurement is often corrupted before it has even taken place, by discretionary purchases or distorted terms of reference. A central system based on a validation mechanism (at least two sources) and a decentralized and plural data collection, relying on transparently published needs statement at the local level may alleviate a part of the risk. Due consideration needs to be given to avoid the reconstruction turning into either a Samaritan dilemma, where the purchases are driven by the needs of the suppliers rather than the ones of the buyers, or a locally captured process, where higher kickbacks from more concentrated rents get priority over the rest. At such a scale of destruction, this is no easy task. This is why the collection of information should rely on civil society (in the broadest sense- including the private sector and communities, not only NGOs), on local government and central government, with findings triangulated in a central mechanism (as an online map with various categories). This can be completed with special reports on specialized areas commissioned to international NGOs which have experience working in disaster areas of developing countries.  Development agencies such as the World Bank or UNDP could contribute to the centralization of the needs assessment.

  

Figure 2. The Economist crony capitalism assessment 2021.

 

Issue number two is how centralized should the reconstruction process be. It is natural that the government of Ukraine wants to have ownership of the process, but we know from international experience that the ownership that guards against corruption is one exercised by the whole society, not just the recipient country’s government. The proposals of civil society to create a central purchasing body run by NGOs, both national and international are too radical to have a realistic choice of being accepted. However, a middle ground exists. The model, albeit just as a starting point, are the integrity pacts that the European Commission funds to enable civil society: Transparency International and national anticorruption NGOs- to audit the procurement process at the national level. As it stands, the model (funded by DG Regio) is a good idea poorly put into practice. The governments select what contracts civil society can audit (therefore setting aside those that matter to them), and the process is technologically primitive, based on a few observations instead of the observation of all data and follow-up of red flags. For Ukraine, which already has pro-Zorro, a far better process can be constructed, where civil society is involved from the writing of terms of reference to the allocation, negotiation, signing and execution. Such a process would also create a sustainable model of good governance where representatives of the entire community would be involved on a permanent basis in procurement decisions. Central purchasing bodies tend to reduce corruption risk, but the involvement of civil society, especially the one with relevant knowledge and representation (geographical or sectorial) would be in this case the key to building sustainable good governance in Ukraine, both at the central and local level.

Issue number three is how to shift from post-factum anticorruption – after the corruption act has already taken place- to preventive anticorruption, which deters corruption from the onset. No successful control of corruption has ever worked post-factum except where corruption was already exceptional and isolated and public integrity the norm. Convictions in Courts take years even in countries where they happen, and they can get reversed: recovering assets is highly expensive and takes years. Turning judiciaries which are themselves problems into solutions to corruption is highly unrealistic, although building a non-corrupt and effective judiciary is a worthy goal- in itself. Ukraine has already invested too much in the top architecture, with very high political risks as we have seen (US presidential candidates fighting over who gets appointed general prosecutor in Ukraine!). Ukrainians proved great solidarity and resilience after the invasion, showing that the main institutions work, and the public cooperates with the state as in a high-trust society. The existential threat helped the nation get together. So, an anticorruption focused on the past, on repression rather than prevention would not achieve control of corruption but might bring political risks that Ukraine can do without. After the war ends, the anticorruption of Ukraine should focus on reforms: to eliminate the sources of economic privileges, the monopolies and oligopolies of every sector rather than spend years putting in jail those who profited in earlier times from such political opportunities. Ukraine needs sustainability and national consensus, and profiteers of earlier times who survive the war can always be overtaxed to bring their contribution. But the fight against them should not absorb the core resources and energy.

Issue number four is how to achieve this functioning, self-driven prevention system. Ukraine has previously done many reforms: but, prior to the invasion, the Ukrainian civil society complained that while transparency is perfect, it only allows seeing how corrupt the country is because accountability is missing. Figure 1. shows that Ukraine has indeed arrived on top of the world when administrative transparency was concerned. But that is not enough. Anticorruption is like a bicycle, which manages to stand as long as it runs: but its separate pieces are worthless if they do not amount to a full-running bike. Transparency is only one wheel: accountability is another, and different parts of the government are supposed to deliver these different wheels. Pro-Zorro was a model monitoring system of procurement when e-procurement was concerned. But the responsibility and accountability of procurement are not with the public procurement agency (PPA). Nowhere do PPAs manage the last part of the cycle, accountability, which belongs to the government. The role of the monitoring agency is to show exactly what buyers (contracting authorities) from the government fail to reach the targets of competitiveness, value for money and integrity: an administrative sanctions mechanism needs to be in place to discipline the buyers, who are appointed by the government. The sanctioning is generally done by auditors when finding procedural problems and Ukraine did not have a high rate of sanctions prior to the war. In 2021, 265 officials were subject to disciplinary sanctions, of which 45 were dismissed from their positions and 274 were subject to financial liability from the 1,500 enterprises, institutions and organizations that were inspected by Ukrainian State Audit Agency. However, we know that favouritism in public procurement is not always openly illegal: single bidding, the main indicator of corruption, that the European Commission has now used to motivate the sanctioning of Hungary, is legal in most countries (meaning that the bidding process is not suspended and reorganized if only one bid is presented). What is needed is that the government itself sets targets (as the EU Public Procurement webpage indicates) and sanctions its PP buyers if they do not meet them, even in the absence of evidence of fraud in order to ensure the integrity and value for money of the process. A simple rule for integrity could be that no bidding is allowed outside pro-Zorro, that the admissible single bidding is allowed only on the EU-27 average (currently very high at around 20%, see Figure 3) and that all single bids instances are automatically audited with priority.

How many public officials were sanctioned or dismissed due to their incapacity to meet the standards of an effective and clean public procurement? An effective prevention system is not based on a case-by-case investigation, followed by prosecution, but by the existence of clear targets and their enforcement by monitoring followed by administrative sanctions. Aside from transparency (pro-Zorro), and accountability (PP targets enforced by administrative sanctions), the system needs some Government Buying Standards to define product specifications, including price, which should be mandatory for the central purchasing agency and other buyers.[1] Seeing that due to the war the Ukrainian government had to even fix some prices the development of a permanent cost standard unit would answer more needs than one.

 

Figure 3. Red flag single bidding across the European Union Member States
Source: https://single-market-scoreboard.ec.europa.eu/policy_areas/public-procurement_en
Legend : average marked in red

 

The final issue is about the human resources needed for a clean and effective management of reconstruction at all levels (from national, down to towns and villages). In environments such as Ukraine (countries with similar corruption indicators in times of normal, non-war situations) the administration is very politicized: who appoints those directly in charge of procurement purchases, for instance, decides de facto who wins and who loses a bidding process. Those who should disburse administrative sanctions are in fact those who decide who wins and who loses. Where should the human resource come from for the reconstruction money to avoid a return to the vicious circle where the principal and the agent collude, with the result of government favouritism? Aside from the macro-organization solutions suggested here, a small share of reconstruction funds should go into creating new project management procurement experts and auditors, by training a new force of civil servants and civil society as integrity compliance officers who would then become the backbone of an integrity system. This reconstruction is not business as usual: and neither should be those who work for it.

 

[1] Department for Environment, Food and Rural Affairs. (2017). Sustainable procurement: the Government Buying Standards (GBS). Available at https://www.gov.uk/government/collections/sustainable-procurement-the-government-buying-standards-gbs#history.

European public accountability trends now updated!

The European Union is the absolute achiever on standards and benchmarks. Thousands exist and are strictly guarded by various enforcement agencies: some inspired anecdotes were furiously disputed over the Brexit divorce. Less spoken about are EU standards on public accountability, in spite of the bloc now having a Rule of Law (ROL) Report on the member states and monitoring processes for accession countries. There is a very simple reason for this: they do not exist as such. While we uphold a Europe that embraces ideals of rule of law and free of corruption as ideals for member states and aspiring countries, we do not actually have a standard way of achieving those, or clear European benchmarks. Finland and Denmark are quite unregulated on public accountability but extraordinarily transparent, and they lead in all good governance charts. Hungary and Poland have been backsliding on both rule of law and democracy but their legal arrangements are quite thick. In some areas, at least.

To understand how Europeans succeed in having transparent and accountable governments ERCAS has created as part of the EU-funded project DIGIWHIST a repository of legal data. We organized them as tools, described in detail as to coverage and instruments, and quantified – assigned a score for each extra provision, resulting in a higher score for countries with more comprehensive regulation. This is Europam.eu, an exceptional legal repository created in 2017. Today we update it at the level of 2020 data. You can find out there how countries are doing on freedom of information, oversight of assets and conflicts of interest of officials, party funding, and public procurement, as well compare each country against the rest of Europe and understand what is the mechanism which enables public accountability – or not.

Despite unprecedented discussion on rule of law in the European space and neighborhood, we found few changes since 2017. All the data is available at Europam.eu, and we present here only two chapters.

 

On public procurement, the average remained roughly the same, from 63 points in 2017 to 62 points in 2020 (from a total of 100), but more jurisdictions declined than improved.

  • Previous best scorers Slovakia (2020: #1) and Hungary (2020: #5) remained in the top 5, but Czechia dropped 5 positions. Romania (2020: #2), Malta (2020: #3) and Bulgaria (2020: #4) complete the top 5;
  • Out of the 3 previous lowest scorers, only the Netherlands (2020: #32) remained in the bottom 5. Poland was the worst jurisdiction, having lost a few points. Other countries at the bottom – Georgia (2020: #34), Sweden (2020: #33), and Iceland (2020: #31) – did not see real variation from their previous points (around the 50 points-mark), which suggests that other countries doing better, rather than them doing worse, is the cause of their poorer performance;
  • Countries that declined: Belgium, Croatia, Czechia, Denmark, Finland, France, Greece, Italy, Lithuania, Luxembourg, Poland, Serbia, Sweden, and the European Union as a whole – 14/35 jurisdictions;
  • Countries that improved: Austria, Bulgaria, Germany, Ireland, Latvia, Malta, Norway, Romania, Slovakia, Spain, and the UK – 11/35 jurisdictions;
  • Countries that remained roughly the same: Armenia, Cyprus, Estonia, Georgia, Hungary, Iceland, Netherlands, Portugal, Slovenia, and Switzerland – 10/35 jurisdictions.

 

On conflict of interest, the average improved slightly, from 40 points in 2017 to 44 points in 2020, and more jurisdictions improved than declined. This is good news for GRECO, which tirelessly promotes COI further restrictions in many countries.

  • Previous best scorers remained at the top – namely Latvia (2020: #3), Croatia (2020: #4), and Slovenia (2020: #5) – with Georgia improving significantly to get to the first spot and Serbia improving slightly (2020: #2);
  • Previous lowest scorers also remained at the bottom – namely Denmark (2020: #33) and the Netherlands (2020: #32) – with Finland (2020: #34) dropping significantly to get to the second-worst position and Belgium decreasing a few points to be the worst jurisdiction;
  • Countries that declined: Armenia, Belgium, Finland, France, Germany, Lithuania, Luxembourg, Norway, Slovakia, Sweden, and Switzerland – 11/35 jurisdictions;
  • Countries that improved: Czechia, Denmark, Estonia, Georgia, Greece, Hungary, Iceland, Italy, Malta, Netherlands, Poland, Portugal, Romania, Serbia, Spain, and the European Union as a whole – 16/35 jurisdictions;
  • Countries that remained roughly the same: Austria, Bulgaria, Croatia, Cyprus, Ireland, Latvia, Slovenia, and the UK – 8/35 jurisdictions.

 

To those who are surprised by these figures we just remind that laws and practices are poorly correlated when rule of law and corruption are concerned. Clearly, there is a great difference between high honesty countries and low honesty countries, with the latter regulating far more. But does more regulation increase public integrity, and which regulation? That is what we study next, and we invite you also to use the freely available Europam for your own analyses.

EU Rule of Law Report Captive on its Tracks

The European Commission is already planning a second rule of law report, although the first brought no further evidence to the already known problems of Hungary or Poland, and only showed the weakness of conceptualization and methodology at this stage. The German presidency made the concession to Hungary and Poland that Courts will have the first say in the event of a sanction. While critics were fast to denounce Merkel to have yielded to the populists, the most elementary legal common sense shows that Courts would have anyway got involved. Is it not better, then, to have them involved sooner rather than later?

Quite a few Parliaments and Governments invited me since then to present my criticism of the report from this Carnegie paper (thank you) and the alternative ways to go about solving the rule of law problem. While I have nothing to add to the criticism and the commission seems unwilling or unable to modify anything in the bureaucratic logic of the report (and the power mechanisms which made it that Wirecard case did not even get a mention) the alternative is the one that I had already suggested. We need to separate the issues, which are luckily correlated. If we want to cut EU funds, we need to use the public procurement policy and its very good monitoring by another part of the Commission (in the EU Single Market PP Scoreboard). Member states who do not reach targets there are the same who infringe on rule of law: Hungary, Poland, Romania, Malta, Czech Republic. That is a technical issue and as such, it is entirely at the disposal of the Commission, which had already done a first excellent step in letting Hungary know that it would not get the funds until it proves it is able to spend the money correctly [1]. For freedom of speech and judicial interference we need to use the other mechanisms- political in essence, as the final and sustainable solution to the EU rule of law problems is to persuade voters not to endorse leaders who are against rule of law. Both on legal and on persuasive grounds, it is better to cut funds for poor governance and corruption than for motives Mr. Orban can say are just matters of different political opinion.

But the EC seems these days, as on the vaccine issue, a train captured by its own tracks and unable to adjust course sensibly. The second round of consultations on the ROL report, thus, is not really a consultation more than the first has been. It is merely an attempt to crowdsource, collecting information, and of course leaving at the absolute discretion of the Commission if to mention Wirecard, BAFIN, and the rest at all.

It is rather clear that the report could hardly help, had the case of some infringement end in Courts, where legal reasoning would instead prevail. The question then is why spend all this money to produce a weak and biased report, when the Commission could instead outsource reports on freedom of the press, corruption (not anticorruption, as the meagre report attempts, as there is no way to separate the two which makes any sense) and judicial independence to those who generally deal with these issues and are both independent and professional? Such reports could be cited by those who work on the legal cases, as we have already seen in the legal cases against Hungary and Poland so far, although, of course, they would not make the bulk of the argument any more than the ROL report would. At least, however, there will be no stringent omissions.

The rule of law report was a concession by Von der Leyen to those who think populism can be fought only by populism, by publishing unsubstantiated figures of social loss due to corruption that no reviewer would ever validate in a normal academic review procedure or by piling up facts which do not amount to evidence, as many are simply irrelevant. The fact that it goes on like nothing happened during last year negotiations and no justified criticism was made by governments and experts who are not on the side of Poland and Hungary is not proof of resilience, but one of incapacity of a bureaucracy to learn and adjust, and the indifference which accompanies too much money one can spend.

[1] EU tells Hungary to change procurement, cites ‘systemic’ fraud | Financial Post

Europe’s Burden: Promoting Good Governance Across Borders

The EU is many things: a civilization ideal to emulate, an anchor of geopolitical stabilization, a generous donor, and a history lesson on cooperation across nations. A fixer of national governance problems, however, it is not. In this book, Mungiu-Pippidi investigates the efficacy of the European Union’s promotion of good governance through its funding and conditionalities both within the EU proper and in the developing world. The evidence assembled shows that the idea of European power to transform the quality of governance is largely a myth. From Greece to Egypt and from Kosovo to Turkey, EU interventions in favour of good governance and anti-corruption policy have failed so far to trigger the domestic political dynamic needed to ensure sustainable change. Mungiu-Pippidi explores how we can better bridge the gap between the Europe of treaties and the reality of governance in Europe and beyond. This book will interest students and scholars of comparative politics, European politics, and development studies, particularly those examining governance and corruption.

Reviews for this publication

“A blistering and contrarian critique of EU anti-corruption efforts from one of the field’s leading authorities. Based on extensive quantitative data spanning both EU member states and a large number of the union’s external partners, the book’s findings have troubling implications for the future of EU good governance strategies – and deserve to be considered with the utmost seriousness.”

Richard Youngs – Carnegie Endowment for International Peace, Europe

Anti-corruption provisions in EU free tradeand investment agreements: Delivering on clean trade.

As the European Commission has noted, trade has already been advancing the cause of good governance. Can international trade do more and become an instrument of promoting anticorruption; and with what effects? This report will summarize the existing evidence and options for the EU by addressing these four questions:

  • What is the connection between trade and corruption? What is the mechanism linking the two, according to empirical evidence?
  • What is the most recent practice in regard to free trade agreements and anticorruption provisions that should be considered by the EU when designing its own strategy for the future?
  • What is the evidence concerning the performance of pure anticorruption provisions, not directly related to trade, in the form of international conventions and treaties against corruption, seeing that their inclusion in trade agreements is increasingly recommended?
  • What are the options for the EU, seeing that it is also the world’s largest development donor, giving aid to more than 110 of the countries it trades with?

The evidence for this brief report is on the one hand based on secondary sources, as organizations such as the OECD or the Bretton Woods institutions have been researching this subject for quite some time, while on the other hand it is based on original research funded by the EU’s own Seventh Framework project ANTICORRP (anticorrp.eu) which is dedicated to anticorruption.

Crony Capitalism in the European Union: Subjective or Objective?

Long before the Panama leaks, nearly three quarters of Europeans (73%) had already endorsed the belief that bribery and connections are the easiest way to obtain public services in their respective countries. Furthermore, pan-European surveys revealed that nearly 7 out of 10 Europeans agreed that corruption was part of the business culture in their country (66% of respondents) and that favoritism and corruption hampered business competition (68% of respondents). But are such perceptions accurate, or do they reflect the general pessimism in times of austerity, uncertainty and growing inequality? This paper uses survey data to deconstruct perceptions of corruption, but also as a premiere uses fact-based data from new research projects on corruption and procurement to understand how much is real and how much is noise in the growing public perception of crony capitalism in Europe. The paper finds that individual perceptions are not disconnected with reality. Although people whose self-ascription places them in the lower part of a status scale are more inclined to perceive generalized corruption, most of the variance at both national and individual level is explained by fact based variables, for instance the number of non-competitive tenders per country.

This paper will be published in a forthcoming edited volume with Oxford University Press. Please cite as Mungiu-Pippidi, M. and Kukutschka, R. M. B (2018). Can a Civilization know its own institutional decline? A Tale of Indicators. In H. Anheier, M. Haber, and M. Kayser (eds), Governance Indicators: Approaches, Progress, Promise. Oxford: Oxford University Press.

EU Aid and the Quality of Governance

Using a panel dataset on 103 developing countries, this paper empirically analyzes the impact of the European aid flows on quality of governance in aid recipient countries. The analysis employs aggregated Official Development Data as well as disaggregated project level data. The results show that while bilateral aid from the largest European donors does not show any impact, multilateral financial assistance from the EU Institutions leads to an improvement in governance indicators. These findings thus suggest that European development assistance can help to promote good governance if aid is allocated at the EU supranational level rather than at the national level of the member states.

EU Aid and the Quality of Governance

Using a panel dataset on 103 developing countries, this paper empirically analyzes the impact of the European aid flows on quality of governance in aid recipient countries. The analysis employs aggregated Official Development Data as well as disaggregated project level data. The results show that while bilateral aid from the largest European donors does not show any impact, multilateral financial assistance from the EU Institutions leads to an improvement in governance indicators. These findings thus suggest that European development assistance can help to promote good governance if aid is allocated at the EU supranational level rather than at the national level of the member states.

Uncovering High-Level Corruption: Cross-National Corruption Proxies Using Government Contracting Data

Measuring high-level corruption and government favouritism has been the object of extensive scholarly and policy interest with relatively little progress in the last decade. In order to address the lack of reliable indicators, this article develops two objective proxy measures of high-level corruption in public procurement: single bidding in competitive markets and a composite score of tendering ‘red flags’. Using publicly available official electronic records of over 2.8 million government contracts in 27 EU member states plus Norway in 2009-2014, it directly operationalizes a common definition of corruption: unjustified restriction of access to public contracts to favour a certain bidder. Corruption indicators are calculated at the level of contracts, but produce aggregate indices consistent with well-established country-level corruption indicators. Due to the common EU regulatory framework, indicators are consistent over time and across countries, while WTO regulations underpin global generalisability. Indicator validity is supported by correlations with well-established perception-based corruption indicators, and novel micro-indicators such as prices and supplier registration in tax havens. The utility of the novel indicators is demonstrated by using them to explain the effect of deregulation on corruption risks at the country level. In order to facilitate wide use of the data and indicators by researchers, journalists, NGOs, and governments, they are made publicly available at digiwhist.eu.

Fixing Europe Is About Performance, Not Democracy

The gradual drop in public confidence in the EU since the beginning of the 2008 economic crisis indicates an erosion of the long-held belief among citizens and elites alike that European integration is the best option to secure a better future. But is it EU democracy that is being challenged here, or is democracy itself challenging the prospects for EU integration? To answer this question, this article briefly reviews first-hand evidence of the basis of trust and the loss of it in European institutions. The evidence is dealt with at a national rather than individual level, and comprises mostly survey data and primary facts that can inform a policy argument. This article does not offer a full explanation of populism nor of attitudes to democracy or globalization, each of which clearly deserve an article in their own right. Instead, it uses data to deconstruct the myths of the EU loss of confidence and its connection with democracy. The two main factors found to decrease trust in the EU are economic growth and confidence in national governments’ performance in terms of controlling corruption.

Good governance powers innovation

Many believe innovation can lead the way out of the present economic crisis. In Europe and the United States leaders have repeatedly referred to the importance of innovation, research and education to sustaining economic growth. The concept that innovation is the key to prosperity is great- but we must understand that this applies to a certain governance context which is seldom encountered in the real world.

The Splintering of Postcommunist Europe

There are two radically different versions of the postcommunist narrative. One tells the triumphal tale of the only world region in which the reforms recommended by the “Washington consensus” worked. The other and more realistic account speaks of a historic window of opportunity that lasted for only a quarter-century, during which efforts by the West and patriotic elites of Central and Eastern Europe managed to drag the region into Europe proper, leaving Europe and Russia pitted against each other along the old “civilizational” border between them. This essay argues that while Institutional choices matter in the postcommunist world, geopolitical and civilizational boundaries still set the horizons of political possibility.

The Legacies of 1989: The Transformative Power of Europe Revisited

Why has the EU succeeded in promoting democracy in the new member states but failed in promoting good governance?  This essay seeks to answer this question first by distinguishing governance from political regimes, and second by exploring to what extent national governance—which is defined as the set of formal and informal institutions that determine who gets what in a given country—is susceptible to being improved by external pressure or intervention. It concludes that improving governance remains a challenge even for the democratic character of the European project.

The Anticorruption Report. Volume 1: Controlling Corruption in Europe

The first volume of the Anticorruption Report series provides a comprehensive analysis of causes and consequences of corruption in three European regions, presenting corruption risks for several European countries and concrete policy recommendations on how to effectively address those risks.

Print and e-book version of the report can be purchased here.

The Good, the Bad and the Ugly: Controlling Corruption in the European Union

For many years corruption was seen as a problem only of developing countries, while the European Union (EU) on the contrary was the temple of the rule of law, exporting good governance both to its own peripheries and worldwide. Many European countries indeed remain among the best governed in the world, although the downfall of the Santer Commission on charges of corruption, the enlargement of the EU by its incorporation of new member countries with unfinished transitions, and the economic crisis all strongly indicate that control of corruption is difficult to build and hard to sustain. Older member countries Greece, Italy, Portugal and Spain have all regressed rather than progressed since they joined – the first two of them to worrying levels – and that has raised doubts about the EU’s transformative effect on its members.