Executive summary

Ensuring a comprehensive and coherent public integrity system

At national level, institutional co-ordination of the Colombian public integrity system takes place through the National Moralisation Commission (CNM), which brings together integrity actors and steers national integrity policy. However, the CNM could also include the National Electoral Council (CNE) and the Administrative Department of the Public Service (DAFP) as full members. The former is crucial to safeguarding the integrity of elections, and the latter is the main actor for developing and implementing integrity policies in the executive branch. In addition, the co-ordinating and steering potential of the CNM could be enhanced through more technical and regular discussions among the actors and stronger links with the National Citizen Commission for the Fight against Corruption.

At the regional level, each department in Colombia has set up a Regional Moralisation Commission (CRMs). Although this represents a positive step forward, a strategic approach is needed to strengthen the integrity-related capacities of the local public administration in co-ordination with the CRMs and other local initiatives such as the integrity pacts and integrity links. The institutional arrangements of the CRMs could be improved to ensure a comprehensive and co-ordinated approach at territorial level by making sure that all three branches are represented, as is the case in the CNM. The CRMs could also establish technical units to ensure continuity and effectiveness. Moreover, it is important that both central and subnational levels have the capacities and financial resources to operate effectively, as well as mechanisms for dialogue and co-operation among CRMs.

The Transparency Secretariat (ST) supports the CNM and co-ordinates anti-corruption policies across the whole-of-government and society. To help the ST fulfil this role, Colombia could institutionalise the practice of inviting it to the Council of Ministers. A stronger formalisation of the Secretary of Transparency would bolster its legitimacy vis-à-vis other high-ranking public officials. Introducing checks and balances in the appointment and removal of the Secretary of Transparency would ensure that the position will not be subject to interference or used for personal benefits. Finally, granting the ST a higher degree of administrative and financial independence would help it focus on core priorities and develop strategic and operational planning capacity, while overcoming challenges related to contracting, human resources management and communication.

Cultivating a culture of integrity

The DAFP is best positioned to provide policy guidance and implementation support for mainstreaming integrity throughout the public administration. Integrity contact points could be established within each public entity to encourage an open organisational culture of integrity. The integrity management framework and General Integrity Code currently developed by the DAFP lay the foundation for promoting integrity in the administration. The framework should be based on the identification and prevention of corruption risks, and include guidance on ethical dilemmas and conflict of interest. The current reform also provides the opportunity to revise existing organisational codes, aligning them with the principles of the General Integrity Code while reflecting each organisation’s specific needs. The DAFP and the National Civil Service Commission could mainstream integrity in human resource management, for instance by including integrity criteria in the recruitment process and annual performance evaluations. In addition, a set of specific training courses on integrity could be developed by the Higher School of Public Administration, whose governance rules should be reviewed, however, to ensure accountability, and adequate independence from the executive.

Colombia’s asset declaration system suffers several weaknesses, affecting each step of the disclosure system, from the type of information submitted to an ineffective audit process. To leverage the system’s potential to build public trust and strengthen the public integrity system, Colombia could narrow the scope of public officials required to submit a declaration, based on risk, and request further information related to possible conflict of interests. Verification has to be ensured by mandating one agency, for example the Inspector General, the power to cross-check information, or by making parts of the declarations publically available to enable citizen oversight.

Taking a risk-based approach to strengthen and mainstream internal control

A solid internal control system is not only crucial for safeguarding integrity, but also for strengthening accountability, cost-effectiveness and, ultimately, the effective delivery of public services. Colombia has developed an identification and assessment model for institutional risks (Modelo Estándar de Control Interno, or MECI) and a separate, explicit anti-corruption risk management process. While the two systems are aligned, they often result in duplication of effort given different reporting channels. To create synergies between the two processes, Colombia could gradually integrate corruption risk management into the standard MECI process. The development of the Unified Management Model, incorporating internal control components and functions as an integral part of the public governance and management cycle, is a significant step towards streamlining internal control. Currently, three governmental actors are assessing the effectiveness of internal control. A further alignment of the methodologies would help to avoid overlapping and competing evaluations while improving the validity of findings.

Colombia has ensured the meritocratic selection and appointment of skilled experts as heads of internal control offices (OCIs) at the national level. However, attracting and retaining competent personnel in the OCIs and establishing strong and independent OCIs at the territorial level are still presenting challenges. Colombia could consider transferring the budget line for OCI staff remuneration from the individual institutions to the DAFP and designing a coherent training and certification programme to support the implementation of reforms. Furthermore, independent audit and risk boards or committees could be introduced to ensure the independence of the internal audit function.