ast week, I, Patricia Wanjama had the privilege of training a group of senior legal officers and certified secretaries from some of Kenya’s public corporations on anti-corruption frameworks and whistleblowing mechanisms. I walked in with my facilitator’s hat on. I walked out genuinely inspired.

These were busy, senior professionals — people who carry enormous institutional responsibility — and yet the room was electric. The questions were sharp, the case study discussions were fierce, and the commitment to lead the ethics agenda within their state agencies was unmistakable. In a country where public cynicism about corruption runs deep, these officers refused to accept the narrative that the battle cannot be won. That energy stayed with me.

So let me share what we covered — because this conversation belongs beyond the training room.

What Are We Actually Talking About?

An anti-corruption framework is not a poster on a wall. It is a living system — policies, internal controls, risk assessments, training programmes, enforcement mechanisms and oversight structures — all working together to prevent, detect and respond to corrupt conduct. A whistleblowing mechanism is its listening ear: a safe, confidential channel through which anyone — staff, supplier, or member of the public — can report wrongdoing without fear of retaliation.

The Cost Is Not Abstract

Kenya loses an estimated KES 608 billion annually to corruption. That is not a statistic — that is hospitals not built, teachers not paid, roads not maintained. We rank 130 out of 180 countries on Transparency International’s Corruption Perceptions Index. These numbers should make every governance professional uncomfortable enough to act.

We Already Have the Legal Architecture

Kenya is not starting from zero. We have Chapter 6 of the Constitution, The Anti-Corruption and Economic Crimes Act Cap 65 the Anti-Bribery Act Cap 79B, The Ethics & Anti Corruption Commission Act, The Conflicts of Interest Act and for us governance professionals, the Mwongozo Code of Corporate Governance and The CMA Code of 2015, The Laws exists. The question is whether we are inclined to abide by them.

The Common Pitfalls

What I see most often is the same across organisations: a policy that exists on paper but has never been tested; a whistleblowing hotline nobody knows about; an integrity committee that has never convened; and a culture where reporting is quietly discouraged. Knowing the law is not enough — operationalising it is where most organisations fall short.

The Dual Mandate

Legal Counsel and Company Secretaries are not just compliance officers. They are the ethical backbone of their institutions. Legal Counsel must advise on legislative exposure, oversee investigations, and champion the ethics agenda at senior level. Company Secretaries must ensure the Board sees whistleblowing reports, coordinates Mwongozo compliance submissions, and keeps ethics on every Board agenda — not just once a year.

If you are new at this, where should you start? A 90-Day Roadmap

In the first 30 days: conduct an ethics risk assessment, draft or review your anti-corruption and whistleblowing policies, and establish your integrity committee. Days 31 to 60: launch your reporting channels, train the committee, and communicate the policy to all staff. Days 61 to 90: deliver organisation-wide ethics training, test your whistleblowing channel with a dummy report, and present your ethics framework to the Board. That is it. Structured. Achievable. Transformational.

A Word to the Private Sector

This conversation does not end at the public sector gate. Kenya’s private sector equally needs structured anti-corruption and whistleblowing frameworks — from SMEs to listed corporates. We often look to Singapore as a benchmark — ranked 3rd least corrupt country in the world — and wonder how they got there. The answer is not magic. It is consistent institutional commitment, independent enforcement, and a culture where ethics is non-negotiable at every level of every organisation, public and private.

If your organisation — public or private — would like to build or strengthen its anti-corruption and whistleblowing framework, I invite you to reach out to Akira Consult Limited for us to shine the light in this dark space. The fight is winnable. The officers I trained last week proved that.