Autonomous

The chamber has voluntary membership systems `membership buy-in processes is open, and MNCCI divides its membership into four categories by their size of the organizations and number of employees: Diamond members, Platinum members, Gold members and classis members. Each member should pay annual taxes and categories annual membership and the members will be provided consulting services, trainings, support for investments, participate regular events, connecting international organizations, and other services from the chamber.

Proper accounting, operation and certification process

The Chamber has open accounting and operation process for the members and consists of four main bodies: Congress, Presidium, Council, Auditing Committee. The organization is self-organized, structure is very large and the supreme decision making body of the MNCCI is the chamber congress. Meets once every four years to consider activities of the organization and elects and fixes the number of members to the Council and Auditing committees, approves the Rule of chamber and make amendments and additions. Council is an administrating body that elects chairman, vice-chairman, and general secretary and to discuss the chamber's annual reports and reviews, approves reports and summaries of the Auditing committee, and settles membership fees. Chairman acts as Chairperson of the Presidium and Council as well as CEO for day-to-day operations. The Auditing committee works under the supervision of financial and economic activities. However, its accounting and operating system and governance mechanisms that are available to all members, not open to public.

Policy-oriented

MNCCI protects the common interests of businesses through participating in the government policy-making process, promoting their interests to be included in the policy and supports public and private sector partnership relationships. The Chamber also runs government-private sector consultative committee and cooperate with the government and its agencies to create a healthy business environment. The policy advocacy activities are to improve business environment by stabilizing governance and legal frameworks, realistic recommendation for tax environment, and fighting against corruption and redundant level of bureaucracy.

Clear mechanisms for promoting responsibility, accountability to its members

According to the Chamber's Regulation, the Chamber shall do activities and comply with Constitution of Mongolia, the Civil Code of Mongolia, Law of Mongolia on Non- Governmental Organizations, National Chamber of Commerce and Industry Law and other relevant laws. Also, there is Auditing committee, consisting of five persons elected on four year terms undertaking financial and economic activities, and on cash and assets accounts on two year terms.

Broad range of membership

There is broad range of members in MNCCI from all sectors and industry including agriculture and products, construction, auditing and insurance provided consulting services, trainings, support for investments for its members at different size and different sector, organizes regular events, and cooperates international organizations. The Chamber Congress consists of 75 persons from leading companies and SMEs operating in Mongolia, but SMEs accounts most of them.

Various funding resources

The financial resource of the MBD also comes from the annual tax of members, donation from individuals and companies, and consulting service profit. The chamber has voluntary membership systems and MNCCI divides its membership into four categories by their size of the organizations and number of employees: Diamond members, Platinum members, Gold members and classis members. Each member should pay annual taxes and will be provided consulting services, trainings, support for investments, participate regular events, connecting international organizations, and other services from the chamber.

Intellectual expertise and standing in the community

According to National Chamber of Commerce and Industry Law and other law, the MNCCI participates and cooperate with government and its related commission and committee is to promote the common interest of business owners, companies, entrepreneurs and individuals. Therefore, the influence of the chamber on policy making process is pretty strong that it prepared several recommendations, prepared policy briefs and projects for policy makers. Also the former CEO of the chamber, Demberel Sambuu, is now Member of Parliament and present chairman of MNCCI was a member of one of the leading political party member, leader of social movement “Soyombo” and advisor of former prime minister. Also the chamber consists of thousand companies as members, so that the lobbying capacity is high

Credibility among other business associations and NGOs

Although credibility of the Chamber is good MNCCI works for protecting and promoting common interest of business owners, companies and entrepreneurs, the public perception of chamber has come under recent criticism. The organization criticized because it's not doing its duty and they are not delivering business owners interests to the government, not promoting the public interests during harsh economic situation in 2011-2012. In addition, the organizations policy activities are not very open to public. The leading members are bigger companies therefore dependency from few bigger companies is high and small and individual business owners' interest can be unconsidered.

Mongolian Bankers Association (MBA)

History of the organization and main goals

Mongolian Bankers Association (MBA) is a non-governmental, non-profit and independent sectoral organization for the banking and nonbanking financial institutions operating in Mongolia, which was established in 2000. It aims to develop banking sector in Mongolia and build infrastructure of the sector. Under initiative of MBA, following institutions included: The Banking and Finance Academy-on purpose of conducting training and capacity development programs for the banking and finance sector; the Credit Guarantee Fund - on purpose of providing credit guarantee service; the Mongolian Mortgage Corporation - on purpose of development of mortgage market in Mongolia;

Autonomous

The Mongolian Bankers Association is a self-regulated, voluntary based organization and membership is open to any interested organizations in the finance and emerging markets. The Association membership has following functions:

· Principal members concern officially registered national and foreign entities on commercial banks operating in Mongolia;

· Supporting members concern non-banking and financial institution authorized to enforce the Charter of the association;

· Associate member concern an institution complying objectives on conducting research and training;

Mission-driven proper accounting, operation and certification process

The Mongolian Bankers association has open operating system governance mechanisms that are available to public and all members. Yet open information of accounting is limited. The association comply all laws in the field of bank and financial institution including took initial role on developing the development of Business Ethic Standard, which is supposed to unite all business entities against corruption in 2014.

Policy-oriented

The MBA's vision is to lead the banking and financial sector to provide and promote sustainable social and economic development in Mongolia. The MBA coordinates advocacy campaigns on the development, implementation and enforcement of the law, regulation, and policy on banks and financial institution delivering the common interests and rights its member, protect its members' legal rights, and facilitate he member's legal assistance and counseling.

Broad range of membership

Currently, the MBA integrates 23 member organizations, including 14 local commercial banks and, 5 financial and non-bank financial institutions, as well as 3 representative offices of foreign bank, such as Representative Office of Sumitomo Mitsui Banking Corporation of Japan, Union Pay International and several other The Banking and Finance Academy and more. Each member is provided legal protection, timely and objective information about the area, training and educating events, consulting services and a wide social network.

Various funding resources

As like MNCCI, the Mongolian Bankers Association is financed by annual tax of members, donation from individuals and companies, and consulting and other service profit. Yet, information related its funding resource is not ublicly available.

Credibility among business organizations and strong standing in the community

MBA's standing in the community is stronger than other business organizations. It regularly public statement in the media, and speech in the relevant conferences, and do policy research based on the policy options and strategies to decision makers, including participation in the government working groups to develop specific programs or monitoring and evaluation of government decisions. Since its establishment in 2000, with more than 20 member organizations, the professional association continually enhance its cooperation with other international financial and bankers' associations such as Asian Bankers Association, International Financial Institution, and more. To strengthen the development of financial sector, it has established several Banking and Finance Academy, Credit Information Bureau, Credit Guarantee Fund and Mongolian Mortgage Corporation collaborating with its members. Since 2007, the MBA started to publish weekly newsletters in providing its members timely and objective information, exchange views, helpful communication and to provide knowledge. Today, MBA deliver the news and information via online MBA email newsletter, its official website, and other social networks. Mongolian Bankers Association, available at: http://mba.mn/

CEO Club

History of the organization and main goals

CEO Club is leading advocacy group in Mongolia, was founded in 2007 under Mongolian National Chamber of Commerce and Industry (MNCCI) to build a network platform to senior executives in Mongolia for better business environment. Its mission is to contribute development of Mongolia through promoting open, transparent and stable business environment. It has following goals:

· to become private sector voice delivering business community interests to the government;

· to create environment that promote and stabilize the development of major sectors of the country;

· to promote cooperation of business community and government agencies;

· to work with the educational organizations to educate and train new forces of business enterprises to meet the standards and international practices;

· to support the training required in order to reduce reliance on external staff;

· to support initiatives of advancement of new technology to enhance competitiveness;

Autonomous and policy-oriented

The Club is an autonomous, advocacy groups that are apart from any political and commercial interest and strongly promotes open market competition and fair rule of law, addressing concerns of business community in the broad range of topics, including taxation, investment laws and regulations, business environment, and so on. It protects and advocates legal rights of business community, their interests through promoting ethical business and cooperating with government on the issue on improving business environment.

Broad range of membership and funding

The Club consists of broad range of membership from leading corporations of Mongolia like MCS, Petrovis, Mobicom and have wide local and international alliances with other business organizations such as from the Mongolian National Mining Association, Mongolian National Chamber of Commerce, Mongolian Bankers Association, Mongolian Mining association from local alliance, Japan Association of Corporate Executives, The Chief Executive Officers Club International. INC and CEO Club UAE from global alliances. However, it has observed that there is small proportion of SMEs in the membership of the association. The financial resource of CEO Club is from membership fee but no clear, information can found on its official website other publicly available materials.

Adequate intellectual, professional, technical expertise

The CEO Club has a wide range of professionalized, sector-specific expertise, advisors and mentors. Governance on Board in the Club consists of 5 members incuding Gakhuyag Chuluun, former Vice Minister of Finance of Mongolia, currently working as an Executive Chairman of Ard Financial Group, Odjargal.J, Chairman of MCS, Oyungerel., the Chairman of Petrovis Matad Ltd, Batsaikhan.B, the Head of Mongolian Opportunities Fund, and Davaajargal.L, Chairman of the Bridge group. Advisors and mentors of this organization are Demberel Sambuu, is now Member of Parliament and former chairman of MNCCI and Khashchuluun.Ch, executive Director at National Council for Private Sector Support and former director at School of Economics of National University of Mongolia.

Credibility among other business associations and NGOs

About credibility, CEO Club is recognized for the establishment of Mongolian Economic Forum which enforce public and private collaboration and draw concrete attention on the emerging social, political, economic issues. Also, it signed with Mongolian People's Party and Democratic Party, leading political party in Mongolia, in stopping cash distribution during the election. Currently, the CEO Club is developing “C30” brand, that will be a representative platform intended for integrating country's leadership and international business community.

Mongolian Coal Association

History of the organization and main aims

The Mongolian Coal Association is a non-profit, non-governmental voluntary based organization, integrating coal related institutions, schools, and profession individuals, which was established on 12^th of January, 1998. Its main objective is to protect legal interests of its members and to participate in activities to develop the legal environment for the coal sector of Mongolia and to facilitate coal sector growth. To achieve its objective, the association do following activities:

· to facilitate and mediate activities of all coal-related professionals, businesses and organizations;

· to participate in legal law procedure regarding coal industry and address the decisions on coal-related laws, regulations, and legal acts;

· to promote business community in relation with government agencies;

· to conduct training and educate new forces of business enterprises to meet the standards and international practices;

· to promote new technology initiative to enhance competitiveness;

Autonomous

The Mongolian Coal Association is a voluntary-based organization not involved to any political and commercial interest, rather can be voice of community related to the coal sector. According to charter of the Mongolian Coal Association, any organization and individuals running or planning to run activities on coal sector can be member of the association, membership of the association is classified 3 categories: core member, honorary member, and supportive member. Core member refers to business entity organization, and individual having rights to elected in a management board of the association and get discounted service, honorary member refers to individual members, and supportive members who cannot elected but vote. Honorary member refers to individual elected by the management of board of the association.

Proper accounting, operation and certification process

The Mongolian Coal Association has open accounting and operating system and governance mechanisms that are available to both public and all members but its official website is currently in operation. The Assembly is a highest authority of the association and convenes once a year. This Assembly is empowered to discuss, evaluate, and working report of management board and the chairman of the organization; elect and dismiss the chairman of the management board and other respected activities. The Management board of the association has 9-11 members elected every two years by assembly of all members of the association. The Supervisory Council of the Association is a charged for monitoring and controlling enforcement of decisions of the association as well as is charged for monitoring of operational and financial action of the organization. The Supervisory Council consists 3 members elected by the assembly.

Policy-oriented

Competitive coal market and development of the sector is main priorities for the Mongolian Coal Association. It actively to participate in legal drafting of the law coal industry and address the decisions following coal-related laws, regulations, and legal acts.

Various funding resources

The association fund consists of following sources: member fee; donation from individuals, organizations, business entities; income from its operation; and income from affiliated organizations.

Clear mechanisms for promoting responsibility, accountability to its members

Under the Charter of the Mongolian Coal Association, it is stated that the association forbidden to issue financial guarantee for the individuals, business entities, and organizations; member of the association is forbidden to use assets of the association for commercial or debt purposes; donation is forbidden for any political purpose, and the association is obliged to prepare yearly report to the Mongolian Taxation Authority. Mongolian Coal Association. Available at : http://www.coalmining.mn/images/Durem_English.pdf

Credibility among other business associations and NGOs and standing in the community

The Mongolian Coal Association is an old but strong business organizations that already established its position and strongly endorse activities for development of coal sector through public statement in the media, and speech in the relevant conferences, participation in the government working group and prepare policy research. Moreover, the associations have an active network in national and international level, integrating more than 50 organizations, most of them are SMEs.

3.2 Kazakhstan study

3.2.1 Current situation of corruption and anti-corruption measures

Kazakhstan, officially known as Republic of Kazakhstan, is a country in Central Asia, covered by land and ninth-largest country in the world (2,724,900 km2). Its population amounted to 17.397.200 million, as of December 1, 2015, including 55.3 percent of urban population and rests are urban population. Kazakhstan is one of those countries with nomadic culture and its population density rates are placed 227^th in the world. Kazakhstan has abundant crude oil reserves, which roughly accounts for 50% of the government's total revenue, and produces 36% of the world's uranium. Kazakhstan is upper-middle income country and its GDP per capita are accounted for 12 424 US dollars.(World Bank, 2013) Kazakhstan declared its independence in 1991 and now is a unitary state with a presidential form of government, which has three independent branches: executive, legislative and judicial. The president is a head of state and nominate head of the government. The executive power carried out by government. The legislative power is hold by two chambers of parliament. The judicial power is carried out by Supreme Court of Kazakhstan. According to the Freedom House 2014 Indicators, political freedom in Kazakhstan is not optimistic, and Freedom of the press 2015 presents same result.

Corruption has been always serious problem in Kazakhstan and majority of the corruption crime are engaged with a bribery, in which many of representatives in the corruption cycle involve those who close to higher ranking public officials or head of informal financial and powerful industries. According to official data, a shadow economy in Kazakhstan is amounted to 20 percent of GDP, and sometimes 50 percent in specific sectors. (Dossym Satpayev, 2014) According to International Monetary Fund (IMF), the unofficial economy can be equal to 30 percent of GDP. (Juha Kahkonen, 2012) Financial police revealed the unofficial turnover is equivalent to more than $30 billion in 2012, and nearly 20 percent of companies operating in Kazakhstan gave bribe to public official to comprise for their interests, according to member of Mazhilis, lower chamber of Parliament.

According to CPI of Transparency International 2015, Kazakhstan occupied 123 the out 168 countries, which is considered the highest corrupted, and its rank often change, sometimes improves sometimes not. According to the to this survey, Kazakhstan has ranked in 107th out of 158 countries in 2005, then want down to 150th out of 179 countries in 2007, and then increased to 120th out 180 countries in 2009. (Transparency International, 2015)

Rating of Kazakhstan by Transparency International's Corruption Perception Index:

2010	2011	2012	2013	2014	2015
Ranking	Score*	Ranking	Score*	Ranking	Score*	Ranking	Score*	Ranking	Score*	Ranking	Score *
105	2.9	120	2.7	133	28	140	26	126	29	123	28

*0 = highly corrupt, *10 = very clean

**0 = highly corrupt, *100 = very clean

However, it has to be recognized that the country is making much efforts in the fight against corruption recent years and made some improvements. For instance, its rank on doing business indexes are improving and EBRD survey revealed that corruption as a problem for doing business in Kazakhstan is improving from ranked 59 in 2011 to 50 in 2014. (World Bank, 2010)

Anti-corruption efforts and measures

Kazakhstan first adopted law “On the Fight against Corruption” on 7^th of February, 1998. It involves a variety of actions intended to prevention, detection, investigation and suppression of corruption, categorization of corruption-related offences, and restoration of its costs. In this law, corruption was defined as follows “the act of people using their official powers and opportunities to obtain material benefits for themselves via personally or intermediaries”. To strengthen implementation of this law, the President of Kazakhstan signed decree on a State Programme for the Fight against Corruption for 2001 - 2005 and its Action Plan of the implementation of the Programme approved by Government in April, 2001. It aims to development of socioeconomic conditions to reducing the level of corruption and shadow economy, building the legal framework for the combat corruption, improving law-enforcement and judicial authorities, developing state anticorruption policy, and strengthening international cooperation in addressing corruption. The Action Plan contains actions regarding anti-corruption preventive, implementation and monitoring measures. After then, a Presidential Commission on Corruption and Enforcement of the Civil Service Ethics was founded by President as an advisory and consultative body of the President in 2002. The commission is charged for monitoring of the implementation of anti-corruption programme and proposing enforcing discipline of sanctions against public officials. The Government established disciplinary councils in every region in Kazakhstan in order to increase the implementation of anti-corruption strategy. The disciplinary council is a consultative and advisory body under the Agency for Public Service Affairs of the Republic of Kazakhstan. The Council do following activities:

· to issue recommendations of imposition of disciplinary actions against public officials for their violation of the of ethics or engagement of corruption and relevant offences;

· to develop recommendations and proposals on improving compliance of anti-corruption legislation and ethical standards in public service;

The Agency of the Republic of Kazakhstan is a specialized anti-corruption law enforcement body for fighting against economic and corruptive crimes. The Agency was established in 2003 based on the former Financial Police. The Agency has characteristic to comprehensive multipurpose anti-corruption body and has coordinative, analytical and preventive measures in economic, financial and corruption-related crimes. (OECD, 2007)

The Agency is subjected to:

· to participate in the government's anti-corruption policy and ensures its implementation;

· to do investigation on corruption-related crimes;

· to organize anti-corruption public awareness-raising campaigns and educating and training people in public and private sectors;

· to develop international cooperation in the anti-corruption law enforcement;

Kazakhstan's Criminal Code criminalizes bribery and money-laundering, extortion, other illegal actives and adopted United Nations Convention against Corruption in 2008. Kazakhstan's Law on Combating Corruption provides legal protection of whistleblowers (civil servants, private sector employees etc.) reporting/witnessing corrupt practices or promoting anti-corruption efforts. Kazakhstan's Public Procurement Law (PPL) provides to being a fair, transparent, objective in a public procurement process. According to the law, all procurements are required to have competitive bidding system and publicly available to the announcements of government tenders for companies and citizens. In January, 2014 the Government introduced some amendments to the Public Procurement Law to combat corruption in the public procurement process and to draw attention of foreign investment. Also, Kazakhstan made some amendments “Law on Fight against Corruption” in 2015. The Government started “Sectoral Anti-Corruption Program 2011-2015”, aimed at strengthening the effectiveness of anti-corruption efforts by the Government. The program mainly focused on improving international and national anticorruption legislation and providing guidelines to the state for enhancing their ability to reduce or eliminate corruption risks. The fighting against corruption is also included priority list in Kazakhstan 2050 Strategy, which intends to adopt number of economic, social and political reforms joining the world's most developed 30 countries by 2050. Also among other anti-corruption initiatives, the Government will keep working on increasing the wages of public officials to match people working in private sector to decrease incentives for public officials to engage to bribe.

3.2.2 BOs and their potential for effective collective action against corruption

The development of civil society in Kazakhstan has two stages: the period before 1985; and period between 1985 to 1991, is named perestroika . During the period in Soviet Union, the Communist Party ruled all public life in in Kazakhstan and there was a limited number of civil society organizations under the close tie of party; in 1930 pioneer organizations, trade unions and other public association was established. These organizations have been considered as a foundation for the development of CSOs. However, the communist regime was limiting the development of CSOs and in Kazakhstan, the term of civil society became officially introduced in the 1995 Constitution of Kazakhstan and almost 400 non-governmental organizations were established after the collapse of the Soviet Union, most of them are on human rights issues including gender equity, youth, environment protection etc. gender, the environment and youth. During the period between 1994-2001, was a period for the growth of diversity of NGOs activity and quality. Since then, NGOs on environment and health protection has flourished. According to estimation of government sources, there are 25,000 CSOs in Kazakhstan, employing almost half of the population 16.5 million, and 13,000 of them is recognized as NGOs. The Ministry of Justice data show different image but the overall picture has been showed the growth, especially in rural areas. During the period 2003-2010, a steady growth has shown 69 percent growth in the number of registered associations, from 5,000 in 2003 to 8,000 in 2010. There are a large number of professional and business associations and NGOs operating active on the issue of human rights, gender equality, health protection etc. However, majority of them are state associations or association under the Presidential initiative. (CIVICUS , 2011)

This paper will study several leading business associations and chambers of commerce based on CIPE's internal and external considerations to identify their potential for effective collective action against corruption. The Internal consideration of CIPE includes establishment of an organization, autonomous from any political interests, mission-driven promoting business ethic standard, having proper accounting and operation system, policy-oriented, clear mechanisms for accountability and responsibility, range of membership, funding, and adequate intellectual, professional, technical expertise. External considerations include standing in the community and credibility among other business associations. In this paper, following leading business associations and chamber of commerce will be assessed, which include National chamber of entrepreneurs of the Republic Kazakhstan “Atameken”, Forum of Entrepreneurs of Kazakhstan, Association of Kazakhstan Entrepreneurs KAZKA, and. In this paper, some of the considerations can be excluded due to lack of evidence.

National chamber of entrepreneurs of the Republic Kazakhstan “Atameken”

History of the organization and its aims

The National Chamber of Entrepreneurs of the Republic Kazakhstan "Atameken" is a non-profit organization, which was founded on 9^th of Sptember,2013. It aims to enhance the negotiation power of business with the government and government agencies. The primary task of the National Chamber of Entrepreneurs "Atameken” is to protect legal rights and interests of the business community, promoting integration and participation of all entrepreneurs in the policy formulation process of relevant laws and regulations. Its main functions as follows:

· to represent and to protect rights and legitimate interests of business community;

· to conduct public monitoring on business environment in the regions;

· to participate government programs for the development of entrepreneurship;

· to encourage the domestic industry and its share in the economy;

· to conduct training, educational programs, certification, qualification, and technical and vocational education;

· to promote cooperation with foreign economic business associations;

· to attract investment and diversity of the economy;

Autonomous

The National Chamber of Entrepreneurs of the Republic of Kazakhstan is an organization established by the joint initiatives of the government of Kazakhstan and NEPK "Union" Atameken ". Therefore, the Chamber is not considered as an autonomous organization. However, membership is not open to everyone and doesn't apply to following condition:

* foreign organizations' branch and representative;

* business entity related to audit and evaluation activities;

* state-owned enterprises;

* non-profit organizations;

Transparent accounting, operation and certification process

The Chamber has open accounting and operating system and governance mechanisms that are available to public and all members. NCE has following main bodies: Congress, the Presidium, the Board, the Audit Commission, the Regional Chambers and the Council of Entrepreneurs. Here, the government has right to refuse decisions of the Congress.

Policy-oriented

The main purpose of the Chamber is to form favorable conditions for the development of business through building effective cooperation between business and the government and to represent legitimate rights and interest of the business community to decision makers.

Broad range of membership

The National Chamber of Entrepreneurs of the Republic of Kazakhstan the Chamber represents SMEs and large business' interests and involve all areas of business domestic and foreign trade. Also there are various program designed to facilitate to serve and protect for the development of SMEs such as services for start-small business, medium sized enterprises, large sized enterprises, and for all etc. so there is large proportion of SMEs in the Chamber.

Association of light industry of Kazakhstan"

History of the organization and main aims

"Association of Light Industry Enterprises of Kazakhstan" was established by industrial enterprises of light industry of Kazakhstan on October 26, 1999. It aims to improve the regulatory and legal acts, the development of effective mechanisms to protect interests of the enterprises and develop joint programs with governments in the field of light industry development and protect the light industry enterprises' interests.

Membership and autonomous

Currently it has 85 member companies, including enterprises of sewing, textile, shoes, and so on. The Association is accredited by the Ministry of Industry and New Technologies of Kazakhstan, and active work with government bodies. In improving legislative and regulative reform that meets business interests.

The Association of Mining and Metallurgical Enterprises (AGMP) 

The Association of Mining and Metallurgical Enterprises (AGMP) The Association of mining and metallurgical enterprises is one of the largest sector-specific association of Kazakhstan, which has more than 90-member mining companies in the ferrous and nonferrous metals, uranium and coal. It was founded in 2005 and accredited by National Chamber of Entrepreneurs of the Republic of Kazakhstan. Now the association aim to protect legal interests of member companies and ensure transparent and effective dialogue between government and business community. It main principle is promote private entrepreneurship development in the extractive industry based on the socially responsible and accountable business principle.

Association of Kazakhstan Entrepreneurs KAZKA

One of the most active business association of Kazakhstan is KAZKA - Association of Kazakhstan Entrepreneurs that supports entrepreneurship to promote the economic development of Kazakhstan, established in 2006. The association has more than 400 SMEs in targeted 5 regions of the country. The main strategy of the organization is to support the development of current businesses and new business project developments of the member companies. Moreover, KAZKA represent the interest of entrepreneurs and enterprises in relation with government through several ways such as

· Supports the members' interest to impact the policies,

· Promotes the protection of members' right and interests on any circumstances,

· Works with government bodies, ministries and experts about analysing legislation, regulations and state, regional or industrial programs of development

· Organizes conferences, forums and discussions on entrepreneurship issues

In addition, the organization makes entrepreneurial training, consulting services for businesses and provides market research and information to attract foreign investments.

European Business Association of Kazakhstan (EUROBAK)

There are several international and influential business organizations in Kazakhstan and EUROBAK is one of them, which represents European business community in the country. The organization was formed in 1999 by the joint initiative of European Union companies and the Delegation of the European Union. EUROBAK has about 150 members including, international well-known companies and Kazakh businesses. It is an influential organization for supporting and helping the companies in Kazakhstan, mostly EU companies, by representing their interest and views through strong collective voice. EUROBAK organizes and creates forum seminar and social events to support the networking opportunities for businesses, provide their own database of the market and contacts of world-wide organizations for their members, and organizes exhibitions in international and local levels.



Conclusion

Generally speaking, corruption is widespread in all level of society in Mongolia and Kazakhstan and combating corruption is one of the top priorities for both countries for sure. According to the Corruption Perception Index (CPI) of Transparency International 2015, Mongolia and Kazakhstan are placed respectively 72^nd and 123^rd out of 168 countries Therefore, this paper purposes the collective action approach to combat corruption where all stakeholders including business and the government together discuss, join forces against corruption and develop enforcement and monitoring mechanisms to make sure that every stakeholder is adopting and implementing properly common measures in the fight against corruption. Business organizations take leading role in the effective collection action against corruption representing business community.

From the study to assess potential of business organizations, including business associations and chambers of commerce in Mongolia and Kazakhstan, to impact on anti-corruption, the main findings as follows:

· Participation of business organization in policy making process is low in both countries cases due to their transition to market economy, which means government and business organizations are focusing on other market issues.

· From our cases of Kazakhstan and Mongolia, it can be seen that the potential of business organizations in these countries are different in several ways. For Mongolian business associations the potential can be greater than Kazakhstan' because of political environment in Mongolia is freer than Kazakhstan and openness of government is better. For Kazakhstan, governmental activities are dependent from President.

· Most of Business Associations in Kazakhstan are funded by state, which makes them dependent from governmental activities and president. This leads to weaker impact on policy making. On the other hand, Business Associations in Mongolia, looks independent from outside but there are connection between these organization and politicians and governmental authorities. For instance, former president of Mongolian Chamber of Commerce is a parliament member. Current head of CEO club was a vice ministry of finance previously. (APPENDIX)

· There are several cases that shows that business organizations in Mongolia have been participated in each policy making stages. (illustrated in the APPENDIX). Contrary, in Kazakhstan's case it is not suitable to illustrate due to higher dependency from government and their weak autonomy of business organizations.

·



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Appendix

Policy making process	Participation of BOs	Cases
Agenda Setting/ Identification of issues or problems	- Address problems and propose alternative solutions based on the experience and representing business community and their members - Initiate activities to develop business environment and sustainability in the sectoral/ areas development.	- In 2014 the Bank Association, the Chamber of Commerce and Industry and the Employers' Association established a union against corruption, which is supposed to unite all business entities against corruption. - Mongolian Sustainable Finance Initiative was initiated by the Dutch Development Bank, and Trade and Development Bank of Mongolia, International Finance Corporation, Mongolian Bankers Association and the Banking and Finance Academy. In this initiative Mongolian 14 banks have joined under the principles of the sustainable banking that transparency and accountability and prohibition of providing bank loans to black-listed companies.
Policy Formulation	- Participate in working group set up by the government. - Propose alternative solutions to the problems that result corruption.	Currently, a new draft anti-corruption program is being developed by working group set up by the President's Office. In this programme, following stakeholders included: Independent Authority Against Corruption of Mongolia (IAAC), CSOs and business organizations, the Chamber of Commerce and Industry and the Employers' Association. In anti-corruption programme, business community points out corruption occurs because of the limited access to public service.
Policy Adoption/ Legitimization	- Propose policy recommendations/ proposals representing business community based on their sectoral knowledge and experience	The Chamber of Commerce and Industry and Employers' Association were invited to give comment on the amendments to the Criminal Code.
Policy Implementation	- Work with Independent Authority Against Corruption of Mongolia (IAAC) on the public awareness raising events and discuss the implementation process, problems - Establish independent department/ subsidiary which is responsible for combating corruption.	-The Chamber of Commerce and the Employers' Association have close cooperation with IAAC, in the area of increasing public awareness and prevention from corruption. IAAC's Public Awareness and Prevention Department organized various public awareness-raising events and invite the business community representatives. - Mongolian Chamber of Commerce and Industry has an independent Integrity Policy Department responsible for combating corruption in private sector and strengthening corporate social responsibility. Its activities concentrates gold and mining associations that are considered powerful lobby groups.
Policy assessment/ evaluation	- Express opinions and share experiences in the implementation of the policy - Assess result of the policy	-CEO Club have done comprehensive studies on the law about “Non-governmental organizations” in order to strength the body of NGOs and their role in the policy making, finally delivered advises to the government.

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