Executive summary

Experience suggests that a strong and crosscutting integrity system at all levels of government, involving the private sector and society as a whole, is essential for combating corruption. Setting clear and co-ordinated institutional responsibilities for designing, leading and implementing the integrity system is crucial to ensure implementation and contribute to positive change.

To improve co-ordination and avoid gaps and duplication in the prevention and detection of corruption, the State of Mexico established its Anti-corruption System (Sistema Anticorrupción del Estado de México y Municipios, SAEMM) in 2017, harmonising its legal framework with the model adopted at the federal level. The SAEMM aims to address policy fragmentation, develop a more comprehensive and coherent approach to integrity, and overcome notorious “implementation gaps” by improving co-ordination both vertically and horizontally, and by bringing municipalities under the remit of the system.

A public integrity strategy is essential to support a coherent and comprehensive integrity system. After a broad multi-stakeholder consultation, the SAEMM Executive Commission developed the draft anti-corruption policy, which was approved in July 2020 (Política Anticorrupción del Estado de México y Municipios, PEA). As of October 2020, the State of Mexico was the only federal state that had included an additional strategic axis on public ethics and integrity with twelve priorities for public policy.

The Code of Ethics for the Executive contains 15 principles and 8 values of the public service, which are mostly consistent with those defined in other relevant legislation. These 23 values and principles are also similar to those emphasised by most OECD Member countries. However, some of the 23 principles and values seem repetitive and may lead to confusion among public officials.

The State of Mexico has a solid regulatory framework to promote a control environment that is oriented towards public integrity. The existence of mechanisms that contribute to the control environment was confirmed, but also that they are sometimes conceived as formalities that do not really contribute to ensure the achievement of institutional objectives. The functions of the Committees of Control and Institutional Performance (Comités de Control y Desempeño Institucional, COCODI) and the Internal Control Bodies (Órganos Internos de Control, OIC) are not fully understood by line public officials, since the organisational culture of ministries and auxiliary bodies leads them to consider control as an exclusive task of the Office of the Comptroller-General (Secretaría de la Contraloría, SECOGEM).

The anti-corruption reform to implement the SAEMM in 2017 included a regulation on administrative liability and proceedings, which is the Law of Administrative Responsibilities of the State of Mexico and Municipalities (Ley de Responsabilidades Administrativas del Estado de México y Municipios, LRAEM). The legal framework provides a comprehensive and solid foundation for enforcing integrity rules and standards, which is also coherent with the national framework. However, given the significant amount of new procedures and mechanisms, further efforts will be required to facilitate their implementation and, eventually, the enforcement of sanctions.

  • To ensure the implementation of the SAEMM at the entity level, a dedicated contact point in each ministry and auxiliary agency could be established.

    • The contact point would be tasked to co-ordinate with the Executive Secretariat of the SAEMM by reporting on the progress of implementation and communicating challenges.

  • Integrity units could replace the Ethics Committees to ensure effective mainstreaming of integrity policies and practices.

    • The functions of the integrity units should be purely preventive, with dedicated staff, sufficient financial resources and a direct reporting line to the highest authority of the entity.

  • Instead of mandating municipalities to establish Municipal Anti-corruption Systems, the SAEMM could focus on building the necessary level of maturity for successful implementation at local level.

    • In order to manage expectations and set realistic objectives for strengthening integrity, municipalities could be mandated to conduct diagnostic analyses of internal strengths and weaknesses and external opportunities and threats of the municipal government, on which basis the priorities for integrity would be set.

  • To ensure that the anti-corruption policy reflects the key issues of the State of Mexico, it should consider additional priorities, such as:

    • measures to mitigate the risk of political capture and clientelism;

    • disentangling the nexus of corruption, organised crime and insecurity; and

    • countering police corruption.

  • The State of Mexico could identify, in a participative manner, 5 to 7 core values that public officials consider as most relevant, with which they identify and to which they aspire.

    • The State of Mexico could initiate a process to simplify the values contained in the current Code of Ethics and thereby enhance its clarity and practical relevance while remaining aligned with the existing legal provisions.

  • The State of Mexico has a solid regulatory framework to promote a control environment oriented towards public integrity. However, more could be done to set specific objectives for an effective control system:

    • ensuring the ownership of control and accountability by officials and key personnel in the process of implementation and developing an internal control system with the aim of achieving impact in ensuring the fulfilment of institutional objectives.

  • The State government needs to have coherent control mechanisms and SECOGEM should promote an appropriate function of internal audit, through a series of measures:

    • strengthening SECOGEM’s capacity to add information about control mechanisms, so that it delivers reports that increase the strategic capacity for decision making of the government and the SAEMM; and

    • clearly separating the control, supervision and audit roles, using the Three Lines of Defence Model, in such a way that the third line of defence is embodied by OICs and SECOGEM.

  • SECOGEM could scale up existing training efforts for staff working in administrative liability offices – including at municipal level – focusing on the correct and uniform application of procedural rules and interpretation.

    • SECOGEM – together with the Administrative Justice Tribunal of the State of Mexico – could organise awareness-raising activities on administrative liability enforcement, targeting all public officials to support and legitimise the new legal framework.

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