Francis Li, for the ICAC, in a letter to these columns on November 4, wrote that the ICAC was puzzled by Transparency International's (TI) bribes survey methodology. This letter was in response to a Post report of October 27 headlined, 'SAR businesses top foreign bribes list'. The story quoted the latest TI survey finding on corruption perceptions. TI's new Bribe Payers Index (BPI) survey ranks China and Hong Kong together at the bottom of 19 leading exporters in respect of propensity to pay bribes to win business. We can understand that the ICAC is puzzled by the result when compared with the finding of another TI survey, the Corruption Perceptions Index (CPI), which consistently rates Hong Kong as one of the world's least corrupt places. The fact of the matter is that the ICAC (whose work we much admire and have publicly praised on many occasions) simply does not have the mandate to inquire into the corrupt practices of Hong Kong exporters when those acts take place outside the SAR. Indeed, some press reports in Europe record a spokesperson for the ICAC as saying that for this reason, it could not make any comment on the subject. Yes, there is an apparent contradiction. But when one compares the situation with, for example, Singapore, one finds that there is no invariable correlation between how businesses act at home, and how they act abroad. We can speculate, however, that the rating of China (including Hong Kong) would have been significantly worse had it not been softened by business practices now well established within the SAR. Transparency International would have tried to create separate indices for the Chinese mainland and for the SAR, but found in pilot tests that in the emerging markets there seems to be a general inability to make the necessary distinction. When it comes to exporting, the special quality of the SAR becomes obscured. When it comes to rating internal corruption, however, the necessary data is relatively simple to obtain. Therein lies the distinction between the two polls. JEREMY POPE Executive Director Transparency International London, UK