1. Adapting the anti-corruption system to the needs of the State of Mexico

Experience suggests that a strong and crosscutting integrity system at all levels of government, and involving the private sector and society as a whole, is essential to combat corruption. However, while many governments in Latin America have prioritised anti-corruption policies and strategies, enforcing these policies and promoting a broader culture of integrity in public and private institutions remains one of the major challenges in the region, including in Mexico. Many countries tend to rely on fighting corruption by reinforcing investigative and sanctioning powers, hereby ignoring preventive measures to eliminate systemic and institutional weaknesses that facilitate corruption and other integrity breaches. By balancing prevention, investigation and sanction, countries work towards achieving a proactive “culture of integrity”, instead of merely reacting to cases (OECD, 2019[1]).

Public integrity implies that those in charge of managing the public sector not only comply with the law, but also that they align their behaviour according to well-defined values and standards of conduct, with the aim of prioritising the public over the private interest. In this way, citizens and private sector actors can feel confident that they are living and working in a context of equal conditions and opportunities, where meritocracy and effort, not connections or bribes, determine opportunities. Ensuring that values and standards of conduct in public service are effectively implemented is therefore a necessary condition for reversing the decline in trust in government (OECD, 2017[2]).

The 2017 OECD Recommendation of the Council on Public Integrity provides policy makers with a vision for a coherent and comprehensive public integrity system. It underlines the need for a context dependent, behavioural and risk-based approach to public integrity with an emphasis on cultivating a culture of integrity across government and the whole-of-society (Figure 1.1). A culture of integrity is achieved through resilient systems that emphasise values and establish an environment where corruption risks are identified and minimised, integrity is rewarded, and where accountability and the credibility of the system are ensured through timely and visible enforcement mechanisms (OECD, 2017[2]).

This chapter assesses the integrity system in the State of Mexico, examining issues related to co-ordination, implementation and high-level commitment. It takes as its model the theoretical framework provided by the OECD Recommendation of the Council on Public Integrity (OECD, 2017[2]), as well as experience and good practices from other countries. Special emphasis is placed on analysing the Local Anti-corruption System that the State of Mexico established in 2017 in line with the broader national anti-corruption reform initiated in 2015 to co-ordinate all institutions in charge of preventing, detecting and sanctioning corruption across all levels of government (Box 1.1).

In a public integrity system, various institutions and entities from all government branches and levels have mandates and functions contributing to public integrity. Setting clear and co-ordinated institutional responsibilities for designing, leading and implementing the elements of the integrity system are a fundamental prerequisite to ensure the implementation of normative requirements and measures that mutually reinforce each other and contribute to positive change. These responsibilities need to be supported by the mandate, resources and capacities necessary to fulfil them effectively.

Managing public integrity is therefore a whole-of-government responsibility involving many organisations in the public sector. In OECD countries, a decentralised approach for managing integrity prevails. In most cases, individual line ministries within the executive branch are responsible for designing and leading the core integrity policies (integrity rules and codes of conduct; policies for the management of conflict of interest; the transparency of lobbying activities; and internal control and risk management). The same can be noted in relation to the design of a country’s national integrity or anti-corruption strategy. A risk of duplication and overlap arises from several line ministries being responsible for specific integrity policies, threatening the effectiveness of integrity policies and the integrity system as a whole. It is, therefore, essential, as stressed by the OECD Recommendation on Public Integrity, to establish mechanisms for horizontal and vertical co-operation between all relevant actors within the executive “through formal or informal means to support coherence and avoid overlap and gaps, and to share and build on lessons learned from good practices”. (OECD, 2017[2]; OECD, 2018[4])

In the State of Mexico, several institutions are responsible for the areas related to public integrity and, as such, for part of the public integrity system (Box 1.2). According to Article 38 bis of the Organic Law of the Public Administration of the State of Mexico (Ley Orgánica de la Administración Pública del Estado de México), the Office of the Comptroller-General of the State of Mexico (Secretaría de la Contraloría del Estado de México, SECOGEM) is the leading body on integrity and anti-corruption. Its responsibilities include prevention, detection and sanctioning of corruption in areas such as public ethics, asset declarations, managing conflict of interest, internal control, the efficiency of the public administration, receipt of whistleblower reports, and investigation of violations of public servants’ administrative responsibilities. Within the executive, the Ministry of Finance (Secretaría de Finanzas) is responsible for human resources management, in co-ordination with the Institute of Professionalisation of Public Servants (Instituto de Profesionalización de los Servidores Públicos del Poder Ejecutivo del Estado de México).

In addition, the Supreme Audit Institution of the State of Mexico (Órgano Superior de Fiscalización del Estado de México, OSFEM), the Superior Court of the State of Mexico (Tribunal Superior de Justicia del Estado de México), and the Institute for Transparency, Access to Public Information and Data Protection (Instituto de Transparencia, Acceso a la Información Pública y Protección de Datos Personales del Estado de México, INFOEM) play a key role. Their core mandates relate to external control, justice and transparency.

To improve co-ordination and avoid gaps and duplication in the prevention and detection of corruption, the State of Mexico implemented the Anti-corruption System of the State of Mexico and Municipalities (Sistema Anticorrupción del Estado de México y Municipios, SAEMM) in 2017. In this way, the State of Mexico harmonised its legal framework with the model established at the federal level (Box 1.1). The SAEMM aims to:

  • addressing fragmentation in policies and developing a more comprehensive and coherent approach to integrity

  • overcoming notorious “implementation gaps” by improving co-ordination both vertically (across the state government) and horizontally (between levels of government), and particularly by bringing municipalities under the remit of the system

  • strengthening enforcement mechanisms for integrity breaches under both administrative and criminal jurisdictions, and including for private sector actors

  • reinforcing oversight by requiring greater transparency, expanded auditing powers and greater involvement of civil society (OECD, 2017[3]).

Building on the National Anti-corruption System, the Law on the Anti-corruption System of the State of Mexico And Municipalities (Ley del Sistema Anticorrupción del Estado de México y Municipios) specifies the composition, roles and processes making up the internal governance structure of the SAEMM (Figure 1.2 and Table 1.1).

The design of the SAEMM promotes a co-ordinated and coherent integrity system across government and society. The participation of the Specialised Anti-corruption Prosecutor, the Chief Magistrate of the Administrative Tribunal and the Judicial Council ensures co-ordination and consistency in enforcing the new integrity rules and criminal provisions. In addition, the system facilitates alignment with other areas relevant to integrity such as audit, by explicitly including a section on the State Auditing System in the Anti-corruption Law and, as such, promoting co-ordination between the two systems (OECD, 2018[4]). Lastly, by including the responsibility for municipalities to establish their own anti-corruption systems, vertical co-ordination can be improved throughout all levels of government through a dedicated focal point for co-ordinated action. This is reinforced by the State Anti-corruption Policy (Política Anticorrupción del Estado de México y Municipios, PEA), which includes all three branches, autonomous bodies and the municipalities.

However, in order to ensure that the SAEMM is implemented, it is indispensable that institutions fulfil their responsibilities. The State of Mexico is among those states that have carried out all the appointments necessary for the functioning of the anti-corruption system, as pursuant to the law ensuring the functioning of all governing bodies of the System. In addition, all institutions have actively and regularly participated in all ordinary and extraordinary meetings of the Co-ordination Committee and the Governing Body of the Executive Secretariat of the SAEMM, ensuring the adoption of the annual work plans, an annual progress report and the development and adoption of the PEA (see Chapter 2 for further analysis of the anti-corruption policy).

In addition, the State of Mexico was the first state to adhere to the National Digital Platform. The Platform’s objective is to gather, consult and cross-examine key information to prevent, investigate and sanction corruption, such as a database on asset declarations, records of public officials involved in public procurement contracts, sanctioned public officials and individuals, public complaints related to corruption and public procurement contracts. Until 2020, the State of Mexico has achieved 100% interoperability with the data systems providing information on sanctioned public officials and individuals and the system on public officials involved in procurement contracts. The Platform is not only essential to carry out integrity risk assessments and improve the use of public procurement information, but it is also a source of information for the public on all data relevant to analyse the government´s progress in strengthening integrity, both at the national and state level. By joining the platform, the State of Mexico is reinforcing its commitment to transparency.

The OECD Recommendation on Public Integrity advocates for commitment at the highest political level. One way to demonstrate this is to ensure that public integrity is integrated into the wider public management and governance framework. Based on the institutional framework for the SAEMM in 2017, the government incorporated anti-corruption into the development plan 2017-23. Preventing, detecting and investigating corruption is mainstreamed throughout the plan, as a specific objective to strengthen the fight against corruption (Objective 4.3) within the public security pillar. Furthermore, the pillar on transparency and accountability sets the implementation of the SAEMM as a specific objective (Objective 5.6). This objective is broken down into several strategies with clear lines of action. In this way, the development strategy ensures that integrity is mainstreamed throughout the entire public sector by linking the implementation of the Anti-corruption System with the development strategy. This also sets the basis for committing the necessary financial and human resources.

Furthermore, illustrating the commitment of the state leadership to SAEMM, the State of Mexico is the federal state that has committed the highest budget in absolute numbers to the Executive Secretariat of the Anti-corruption System. Interviews with stakeholders confirm that the budget allocated is sufficient for the running costs of the system and executing the necessary actions. However, in order to ensure that the budget remains consistent and is not dependent on political fluctuations, the State of Mexico could consider amending the Anti-corruption System Law to guarantee a stable budget in relation to a specific percentage of the state overall budget.

Principle 13 of the OECD Recommendation on Public Integrity calls adherents to promote accountability and the public interest throughout the policy-making process by averting policy capture by narrow interest groups. One way is instilling transparency in the financing of political parties and election campaigns. Indeed, policy capture and corruption are closely interlinked. Special interests may influence the results of elections to ensure that the elected public officials, once they are in office, represent the interests of those who supported them. For example, elected politicians may have to return favours to those who supported them and brought them into office by providing them with public contracts, e.g. infrastructure projects, subsidies, or public employment, e.g. through “bureaucratic quotas” in the public administration. The financing of political parties and election campaigns is thus a powerful instrument for narrow interests to exercise influence and “capture” the policy process.

The integrity of the electoral process is also a necessary condition to guarantee inclusive participation in democracy, prevent unbalanced influence of private interests, and support a public integrity system. Interviews with stakeholders confirm that key priority elements to prevent corruption in the State of Mexico include, among others, illegal financing of political parties, clientelist practices, recurrent changes of electoral rules, as well as the openness, transparency and democratic governance of representative organisations, like political parties and trade unions.

However, replicating the flaw in the national model and the general law, the SAEMM does not include the Electoral Institute of the State of Mexico (Instituto Electoral del Estado de México, IEEM) in the Co-ordination Committee. To strengthen policies and standards on the financing of elections and political movements, the Electoral Institute may be involved, either formally or by being invited to specific meetings, in the Anti-corruption System. While the formal inclusion of the IEEM would be preferable to ensure continuity and sending a strong signal on the priority of ensuring integrity in electoral processes, under the current design of the Anti-corruption System this might not be possible. In that situation, the invitation of the IEEM in meetings as a key stakeholder would be crucial. Likewise, the State of Mexico could lead the discussions so that electoral institutions can be considered in both, the national and the state anti-corruption systems. In the meanwhile, IEEM could develop its own integrity frameworks and tools, to be applied to political parties as well.

A strategic approach to public integrity needs to be based on evidence, adopt a system-wide perspective and focus on the key integrity risks. While the SAEMM is a significant step to improving co-ordination among the principal integrity actors in the State of Mexico, additional public sector institutions would need to be consulted on a regular basis to develop balanced and actionable integrity policies. By not involving these additional actors in the system, it fails to acknowledge that action can only be demanded from those bodies involved. It may also weaken the System by not being able to access timely information from these bodies, which supports the identification of areas and sectors that are particularly vulnerable to corruption. In this way, priorities can be set and a risk-based approach developed. This is in line with the recommendation given by the OECD at the national level to include additional actors in the National Anti-corruption System (OECD, 2017[3]). A formal inclusion in the Co-ordination Committee poses the risk of overburdening the system and making meetings of the Committee ineffective due to its size. However, the Anti-corruption Law gives the Governing Board (Article 28) and the Executive Commission (Article 32) the right to invite specialists in the topics discussed to their meetings with a right to speak, but not to vote. The Governing Board and the Executive Commission are responsible for preparing thematic studies on advancing integrity policies. So far, the Executive Commission has not invited other institutions to its meetings. However, it would be crucial to do so to ensure that anti-corruption priorities strategies are articulated in a co-ordinated way and as foreseen in the actions planned to implement the PEA.

Among others, the following institutions could be invited on a regular basis according to the thematic discussions held at the meetings of the Governing Board or the Executive Commission:

  • Ministry of Security (Secretaría de Seguridad): The Ministry of Security is responsible for planning, formulating, co-ordinating, executing, monitoring and evaluating public security policies, programmes and actions. Given the high level of insecurity in specific areas of the State of Mexico and the inclusion of corruption prevention within the Security Pillar of the Development Plan, it would be key to invite the Ministry of Security to meetings to ensure co-ordination.

  • Ministry of Finance (Secretaría de Finanzas): The Ministry of Finance has a broad portfolio of functions related to integrity, such as the management of human resources in the public sector, public procurement, overseeing the regional and sectorial development plans and managing the overall resources of the state.

  • Institute of Professionalisation of Public Servants of the Executive Branch (Instituto de Profesionalización de los Servidores Públicos del Poder Ejecutivo): A strategic approach to public integrity requires integrity training to be integrated into the wider skills development framework of any public service. Inviting the Institute of Professionalisation to meetings can help mainstreaming integrity training for public officials.

  • Ministry of Education (Secretaría de Educación): The Ministry could play a role in developing awareness-raising activities on corruption and including anti-corruption modules in the school curriculum.

By including these additional actors on an ad-hoc basis and according to a risk-based approach in the meetings of the Governing Board and the Executive Commission, co-ordination between the integrity actors would significantly improve and mainstreaming of integrity measures throughout the administration would be facilitated. In this way, the SAEMM would take a step towards a strategic approach to public integrity that encompasses the overall integrity system and allows the identification and analysis of the integrity risks that are most harmful to public integrity in order to mitigate them successfully. This participative approach would also help in generating ownership of the different institutions at a more technical level. Furthermore, the PEA implementation relies on and foresees the effective collaboration with these entities.

The OECD Recommendation on Public Integrity underlines that adherents should “promote a whole-of-society culture of public integrity, partnering with the private sector, civil society and individuals”. While the SAEMM involves civil society prominently, the private sector is not explicitly represented. However, the interaction between the private and public sector presents a high risk for corruption, ethical misconduct and fraud. In order to ensure that the SAEMM has a clear, concise and grounded understanding of the integrity challenges faced by the private sector, the Executive Commission could regularly invite members of the private sector to their meetings. The Executive Commission would need to invite a broad representation of the private sector on a rotating basis to ensure balanced access and that neither the perception nor actual preferential treatment of a specific actor arises. In line with this, the Executive Secretariat is indeed foreseeing the co-operation and active involvement of the private sector and the civil society in the PEA implementation.

Gathering information from the private sector would also help avert unintended impacts and avoid practical implementation problems associated with integrity policies. In addition, engaging the private sector in developing regulations can lead to higher compliance with and acceptance of such regulations, in particular when stakeholders feel that their views were considered and when they understand how their comments were taken into account. (OECD, 2020[5]; Lind and Arndt, 2016[6]). The PEA foresees the interaction with the private sector and specifically the use of information provided by the private sector in two key areas:

  • Building innovative models to generate databases that include indicators on public ethics and integrity in the public and private sector and society, taking into account a human rights and gender perspective; and

  • Developing the conditions to design, develop and implement an integrity system in the public service in which representatives of the private sector and civil society participate.

The Executive Secretariat of the SAEMM is the body in charge of providing technical support to the Co-ordination Committee, both in terms of technical assistance and agenda setting. The quality of its work will affect the measures taken by the Co-ordination Committee and therefore the effectiveness of the SAEMM as a whole. The Executive Secretariat is formed by the Technical Secretary, the Executive Commission consisting of the Technical Secretary and the Citizen Participation Committee except its President, and the governing body consisting of the members of the Co-ordination Committee and led by the President of the Citizen Participation Committee.

The strength of the SAEMM lies in bringing together the main integrity actors and their different perspectives, experiences and good practices. In order to take full advantage of this multitude of experiences and available data, the SAEMM could create two technical sub-commissions within the Executive Commission, one on prevention and another on enforcement. Prevention and enforcement of corruption usually involve two different sets of actors. For instance, concerning enforcement, drafts and proposals on disciplinary issues would benefit from exchanges and consultation with SECOGEM, OSFEM and the Special Anti-corruption Prosecutor. Furthermore, a sub commission could contribute to create mutual confidence, favour the exchange of information and foster the discussion, as well as the elaboration of effective measures to overcome common challenges. The sub commissions would feed into the discussion in the Co-ordination Committee, preparing technical inputs and debates. These sub commissions consisting of the members of the Citizen Participation Committee and the technical entities responsible for prevention or investigation could hold their meetings in the form of extraordinary meetings. In order to not overburden the head of the respective institutions, they could be represented by the technical level given that the work in these sub-commissions would involve technical discussions, rather than political decisions (OECD, 2018[4]).

Establishing these two sub-commissions would contribute to addressing common gaps that often emerge in the work of the anticorruption co-ordination bodies, such as:

  • focusing on legislative and normative reforms with insufficient emphasis on actual implementation;

  • favouring politically attractive high-level prosecution cases instead of deeper structural reforms targeting the root causes of corruption;

  • setting overly ambitious objectives with limited institutional capacities technocratic solutions with no acknowledgement of the problem of vested political or economic interests;

  • favouring holistic and broad approaches without acknowledging the necessity to set priorities and consider the timing of interventions (Hussmann, 2007[7]).

The sub-commissions would be aligned with the proposal of the PEA to create interinstitutional groups, consisting of three members of the Co-ordination Committee and supported by the Technical Secretary, to oversee the implementation of the Policy in specific areas. Therefore, the Co-ordination Committee could evaluate the proposal for the interinstitutional groups within the aspect of creating sub-commissions relevant for technical discussion, analysis and proposals on prevention and investigation and overseeing the implementation of the Policy in these areas. The organisational set-up could be tested informally first and, after evaluation, formally establishing the sub-commissions at the statute level pursuant to Article 28 of the Anticorruption System Law of the State of Mexico. This set-up could be replicated within the Executive Secretariat of the SAEMM, specifically the General Directorate of Anti-corruption Public Policies and Risks.

The effectiveness of the SAEMM does not only depend on the design of the system, but also on the proactive role of its members to contribute to it, provide necessary information, and implement measures and policies agreed within the Co-ordination Committee. While the former aspect is crucial to ensure that all relevant actors are part of the system, the latter ensures that SAEMM does not remain a formal mechanism having little or no impact on entities and, in turn, on citizens. Both aspects are recognised in the OECD Recommendation on Public Integrity, which stresses the need to establish responsibilities at all levels not only for designing and leading the integrity system, but also for implementing its elements and policies, including at the organisational level (OECD, 2018[4]).

To achieve this, a dedicated contact point in each institution could be established. The contact point would be tasked to liaising with the Executive Secretariat of the Anti-corruption System by reporting on the progress of implementation and communicating implementation challenges. The contact point would not itself be responsible for implementation, but rather ensure continuous support and active participation of the institution in any activity or initiative related to the SAEMM, prepare the high-level discussions in the Co-ordination Committee, provide all the necessary information and follow up on commitments undertaken and recommendations issued by the Co-ordination Committee for the respective entity. In addition, contact points (or units) would thus create a network to support the achievement of objectives set by the Co-ordination Committee. In this context, Article 13 of the Anti-corruption System Executive Secretariat Statute (Estatuto Orgánico de la Secretaría Ejecutiva del Sistema Estatal Anticorrupción) mandates each member of the governing body to nominate a permanent contact point for the Executive Secretariat. For example, SECOGEM created the Unit for Corruption Prevention, which among other tasks, is acting as a counterpart for the state and national Anti-corruption Systems and prepares any technical inputs necessary. At the federal level, the Ministry of Public Administration (Secretaria de la Función Pública, SFP) created a specific unit (Unidad de Vinculación con el Sistema Nacional Anticorrupción) to co-ordinate – within the Ministry – the necessary follow-up to policies, plans, programmes and actions related to the National Anti-corruption System. Another example in this context is the model used by the Anti-corruption Commission of Piura (Peru), whereas all institutions participating in such subnational anti-corruption body appoints a unit or office to comply with the objectives, plans, and activities set (Box 1.3).

The objective of the SAEMM is to strengthen the State of Mexico´s anti-corruption efforts and promote public integrity. To ensure that the System does not merely become another formal body without any impact, the Co-ordination Committee has the power to issue non-binding recommendations to the respective entities to prevent administrative misconduct and corruption, as well as to improve the performance of internal control bodies (Article 9 of the Anticorruption System Law). The Citizen Participation Committee has the right to propose recommendations to the Co-ordination Committee via its participation in the Executive Commission, which presents the proposed recommendation for its approval to the Co-ordination Committee (Articles 21 and 31). Institutions must respond to the recommendations issued within fifteen days, either rejecting or accepting them and present the necessary actions to implement them. If institutions accept recommendations, they must inform the Co-ordination Committee of the concrete actions foreseen to fulfil them.

The Anti-corruption System Law foresees that the Co-ordination Committee reports on progress of the recommendations in its annual report. To ensure transparency and accountability to citizens, the Co-ordination Committee could consider publishing all recommendations in a dashboard on its website. This dashboard could include the measures proposed by the institutions concerned, any necessary updates and the progress assessed in the annual report. In this way, individuals could easily track progress and contribute to hold institutions accountable. The Executive Secretariat could be made responsible for ensuring that all information is kept up-to-date and easy to find.

The Citizen Participation Committee has no right to issue recommendations, but rather can only propose recommendations to the Co-ordination Committee via its participation in the Executive Commission. However, recommendations may target the members of the Co-ordination Committee given that they are the main integrity actors. There is a potential risk that the Co-ordination Committee systematically blocks or adjusts proposals for recommendations through a majority vote or amends the proposals in a way to make them easier to achieve.

The fact that this scenario has not materialised so far does not mean it could not happen, particularly as SAEMM is a relatively young institution. In order to mitigate the risk, the Co-ordination Committee could adopt an internal regulation that the public institutions, to which a recommendation is addressed, cannot decide on the issuing of the recommendation, while still having the possibility to make precisions or clarifications. Furthermore, if recommendations were blocked, the Citizen Participation Committee would have the right to publish the recommendations developed through its own channels and by including the proposed recommendations prominently in the meeting protocols. In this way, the Citizen Participation Committee could strengthen external accountability and build public pressure.

The Anti-corruption System places great emphasis on the role of civil society overseeing the system. The institutional set-up of the anti-corruption systems reflects this by assigning the Citizen Participation Committee the Presidency of both the Co-ordination Committee and the Executive Commission. Among its tasks, the Citizens Participation Committee is called to propose co-ordination mechanisms and non-binding recommendations, build a network of civil society organisations and experts, channel the inputs of civil society and academic institutions into the system, as well as implement its own annual programme of work, which may include research, investigations, and projects for improving the Digital Platform or reporting of corruption by the public.

The institutional framework of the SAEMM is in line with the OECD Recommendation, which stresses the importance of collaborating with the whole of society to build effective public integrity systems and calls states to engage relevant stakeholders in the development, regular update and implementation of the public integrity system (OECD, 2017[9]).

According to the procedure laid down by the Anti-corruption System Law, the selection of the Citizen Participation Committee members is conducted by members of civil society and research institutions, who are in turn selected by the State Congress (Figure 1.4).

In order for civil society to be a pillar of the SAEMM, a key priority for the State of Mexico is to ensure that the appointment procedure is carried out through an open and transparent process enabling the participation of independent and reputable experts representing various components of civil society. This would not only enable the effective contribution of civil society, but it would contribute to strengthening the overall legitimacy of the system. However, interviews pointed to a risk that both the members of the Selection Commission and the Citizen Participation Committee might be captured de facto by local powers, either by political power or, at the municipal level, by organised crime. This has also been raised by members of the Citizen Participation Committee of the National Anti-corruption System (OECD, 2019[10]).

Considering the pivotal role of the State Congress in initiating the selection process for the Citizen Participation Committee, Congress should make sure that all steps to appoint the Selection Commission are subject to the highest standards of transparency and guarantee the fairness and inclusiveness of the process. This implies setting up an open process for considering and designating candidates of the Selection Commission. While the Anti-corruption Law sets requirements for the information published concerning the nomination of the members of the Citizen Participation Committee, the same information could be made public for the nomination process of the Selection Commission. According to Article 18, this information would be:

  • Methodology to register and assess candidates.

  • List of candidates.

  • Documents submitted by candidates.

  • Chronology of hearings.

  • The deadline to make a decision and the session in which it is taken.

Concerning the decision on the members of both the Selection Commission and the Citizen Participation Committee, the authorities could also consider providing additional information concerning the justification for the final decision, including explicit reference to experience and knowledge of the selected members. This could also include financial information concerning the selected candidates such as their assets, activities and a signed declaration disclosing any conflict of interest. Lastly, Article 16 of the Anticorruption System Law could be amended to clearly state that the members of the Citizen Participation Committee cannot exercise any other employment that would create a conflict of interest (OECD, 2017[9]) Furthermore, the Executive Secretariat should prioritise the development of a strategy to prevent the capture of the nomination processes.

Given the prominent role of the Citizen Participation Committee in the functioning of the Anti-corruption System, its members have multiple tasks and functions to fulfil. However, interviews confirm that the Citizen Participation Committee has been encountering difficulties in carrying out all the tasks and functions entrusted by law. The Citizen Participation Committee at the national level also experiences these difficulties. At least in part, this is due to the fact that –pursuant to the LGSNA– it is not formally granted legal personality and its members are remunerated by an honorary fee and do not receive any formal compensation from the state to safeguard their objectivity in their contribution to the Executive Secretariat. While maintaining the independence of the CPC is essential for its legitimacy as representatives of civil society, it should be able to carry out the tasks entrusted by law.

The SAEMM could therefore consider to widen the Executive Secretariat´s mandate to not only provide technical support to the Co-ordination Committee, but also specifically to the Citizen Participation Committee. Administratively, a new directorate could be created which would be responsible for research and analysis of the proposals developed by the members of the Citizen Participation Committee. This should go along with the necessary increase of the budget for this Secretariat. In addition, Article 25 of the Anti-corruption System Law would need to be amended to formalise this change in mandate.

Related to this, clear parameters for setting the honorary fee for members of the CPC should be established to mitigate the risk of exercising pressure on them by threatening to reduce their fee. The honorary fee should take into consideration the average salary for a public official with similar experience and level of responsibility. In addition, it should not be possible to modify the honorary fee during the term of the member of the Citizen Participation Committee apart from adjustments to the National Consumer Price Index.

The effective implementation of integrity standards and policies requires, among other things, a clear assignment of responsibilities in the integrity system (OECD, 2017[2]). At an organisational level, this discussion frequently tends to focus on particular “integrity actors”: persons, committees or units whose main responsibility is to advance and fulfil integrity within the organisation (OECD, 2019[11]).

As stated by the OECD (OECD, 2019[11]), there are several reasons why it is important to have a unit dedicated to integrity in an organisation:

  • A visible place for integrity management in the organisational structure increases the scope of co-ordination between integrity management instruments and, therefore, allows synergies between instruments. The explicit designation of this co-ordination function to a person, group or organisational unit will significantly increase the possibility of producing such co-ordination.

  • A clear location of integrity management in the organisational structure also allows a true accumulation of expertise, as recommendations, insights and better practices would be compiled in a single location within the organisation.

  • The anchoring of the integrity management system in the organisation also guarantees the continuity of integrity policies. In practice, it is common that, even when integrity management does bring attention and enthusiasm when launched for the first time, this tends to decrease after some time. Holding a person or entity accountable for long-term integrity management and asking them to report on their progress will significantly reduce this risk.

  • The organisational anchoring also has a symbolic element. It provides the signal that integrity is deemed important within the organisation. A typical rule in the theory of organisational design is that “the structure follows the strategy”: the structure reflects subjects of strategic importance for the organisation. If an organisation seeks to attribute importance to integrity, this shall be reflected in its organisational chart.

  • Providing integrity with its own position in the organisational chart also provides its own identity. A separate identity does not mean that integrity management instruments are to be isolated from other relevant management lines, such as human resources or financial management. Neither does this mean that those responsible for integrity management have to try to take over areas or instruments of other units that may be considered as integrity management instruments within their own competence sphere. Consequently, the co-operation and articulation among those responsible for integrity and actors of other areas is fundamental.

While the exact design might be different, an OECD survey on public integrity in Latin America shows that the majority of countries requires entities in the Executive Branch to designate integrity officers or units (see, for example, the case of Brazil in Box 1.4).

In line with the reform at the federal level, the Government of the State of Mexico reformed the mandate, functions, attributions and organisational integration of the Ethics Committees of the ministries of the executive branch and its auxiliary agencies (Acuerdo por el que se emiten los lineamientos generales para establecer las bases de la integración, organización, atribuciones y funcionamiento de los Comités de Ética de las dependencias del Poder Ejecutivo y sus organismos auxiliares del Estado de México).

In Article 4, the Agreement states that the objective of the Ethics Committees is to promote ethics and public integrity to optimise public service, in accordance with the constitutional and legal principles and values. To do so, each Ethics Committee must define, during the first three months of the year, an annual work plan with specific objectives, goals and activities, in the framework of its permanent obligations:

  • Communicating, within the institution, the values and principles of both the Code of Ethics and the Code of Conduct.

  • Carrying out training in ethics, integrity and prevention of conflict of interest issues.

  • Monitoring and evaluating implementation and compliance of the Code of Conduct.

  • Identifying, advancing and monitoring improvement actions for the prevention of breaches of the values, principles and rules of integrity.

  • Issuing non-binding opinions and recommendations derived from the knowledge of complaints, related to alleged violations of the Code of Ethics, the Integrity Rules or the Code of Conduct.

To carry out these functions, the Ethics Committee of each entity relies on the human, material and financial resources of the ministry or auxiliary agency, which implies that no additional and independent resources are allocated for its operation. In terms of human resources, every Committee has nine members, each of them with voice and vote. Two of the members participate permanently and seven are elected on a temporary basis, for a two-year period. The permanent members are: 1) the head of the ministry or auxiliary body; and 2) the Technical Secretary, who is appointed by the head of the ministry. The temporary members are public servants of the following hierarchical levels or their equivalents (for every member, there must be a substitute from the same hierarchical level):

  • a general director

  • an area director

  • a deputy director

  • a department head

  • an administrative delegate

  • a liaison

  • an operational official.

However, as identified in the OECD Integrity Review at the federal level, the Ethics Committees suffer from several weaknesses which have been replicated in the design of the Committees in the State of Mexico (OECD, 2019[10]). First, the members of the Ethics Committees are selected among the staff from the entity on a temporary basis. They often do not have any previous experience in the subject matter. Therefore, they require training on integrity to fulfil effectively their tasks. However, in many cases, once members are trained to fulfil their mandate, their terms are over or, due to high staff turnover, members are replaced prior to the end of their mandate. This affects the continuity and effectiveness of the Ethics Committees. It has also been reported that it has been difficult to mobilise higher-ranking public officials as candidates for the Committees. Furthermore, given that being a member is an additional task, the work will often be only the second priority.

Interviews also confirmed that superiors are often reluctant to facilitate their staff’s participation in the committees. Second, while having an Action Plan, the Committees often do not have the resources required to implement these actions effectively. The way the activities in the Action Plan are selected is in few cases strategic or building on a theory of change, as members lack experience in integrity policies. As such, activities are often only punctual exercises without long-term objectives (OECD, 2019[10]).

Recognising these weaknesses, the Corruption Prevention Unit of SECOGEM is considering establishing so-called ´Integrity actors´ in addition to the Ethics Committees. While this is an important step, this could create an overlap with the functions of the Ethics Committees. Therefore, it would be advisable to replace the Ethics Committees with these Integrity actors. The integrity actors or units should be permanent, count with dedicated staff, full-time or part-time depending on the size and integrity risks of each entity, financial resources to implement the activities related to their mandate and report directly to the highest authority.

The exact design of the integrity actors could be set in line with the actions foreseen in the PEA and the priorities of the strategic area on “public ethics and integrity”. Specifically, priority 51 focuses on the implementation of innovative mechanisms to assess the functioning of ethics committees (and codes of conduct and integrity). As part of this assessment, the design of the integrity actors could be discussed. In general, the following key elements should be contemplated: The functions of the unit should strengthen preventive tasks. The State of Mexico could consider a model similar to the Offices of Institutional Integrity in Peru. The Institutional Integrity Offices focus on promoting integrity throughout the entity by co-ordinating efforts regarding the implementation of an integrity system, lead internal planning and monitoring in the subject matter and provide a degree of assurance for the head of the entities regarding compliance with the standards in effect. This includes, for example, alerting the head on the need of strengthening complaint processes and investigation units, and hiring personnel to perform these functions with the required speed and avoiding a perception of impunity. In addition, the integrity unit would fulfil an advisory role for the public officials on public ethics and conflict of interest, as foreseen in the General Guidelines of the Ethics Committees of the State of Mexico (Lineamientos Generales para Establecer las Bases de la Integración, Organización, Atribuciones y Funcionamiento de los Comités de Ética de las Dependencias del Poder Ejecutivo y sus Organismos Auxiliares del Estado de México, Article 27.g). In line with good practices in OECD countries, the integrity units should not receive complaints and whistle-blower reports. Even though some ethics committees assert that receiving complaints and whistle-blower reports help identify opportunity areas, it may generate expectations of results that such committees and the integrity units are not able to deliver, as they are lacking investigative powers. As such, the integrity unit could guide and advise potential whistle-blowers regarding internal and external reporting options or available protection measures, but ideally does not receive reports itself (OECD, 2019[10]). Lastly, as part of the second line of defence, the integrity unit should be invited to the meetings of the Committee of Control and Institutional Performance (Comité de Control y Desempeño Institutional, COCODI) (OECD, 2019[10]).

The creation of the integrity units should take existing resources and proportionality into account to limit additional bureaucratic layers. Depending on the size and integrity risks of the entity, the integrity unit could be as small as one person.

In terms of co-ordination, the Corruption Prevention Unit in SECOGEM is currently in charge of maintaining communication channels between all Ethics Committees and SECOGEM itself. It is also responsible for programming, co-ordinating, monitoring and carrying out an annual evaluation of the actions executed by the Committees. The Unit should maintain this function overseeing the integrity units and co-ordinate and liaise with all integrity units across the public administration, monitor their work, provide tools and materials, and support them with ad-hoc guidance, and provide up to date trainings focusing on integrity management.

In addition, the Corruption Prevention Unit could establish a network of integrity units. This network could be used to exchange good practices, discuss common problems and develop a joint sense of the culture of integrity in the State of Mexico.

While integrity is a concern at every level of government, opportunities for certain types of corruption can be more pronounced at the municipal level. The increased frequency and closeness of interactions between local government authorities and citizens and firms, as compared to the national and state level, can create both opportunities, especially by facilitating local accountability, and risks for integrity. Local governments’ responsibilities for the delivery of a large share of public services (e.g. drinking water, waste management, utilities, granting licences and permits) increases the frequency and directness of interactions between government authorities and citizens and firms, which creates opportunities to test the integrity of local governments (OECD, 2018[12]). The PEA recognises this by explicitly including responsibilities at the municipal level throughout all five of its strategic areas to fight corruption and strengthen integrity.

The municipal level often suffers from specific challenges that may lead to opportunities for corruption:

  • Limited technical and financial capacities and resources of municipal administrations.

  • Higher discretion of local politicians due to often limited opposition, limited independence and effectiveness of local auditors, insufficient disclosure requirements for annual budget, public tenders and similar.

  • Close ties between local business and political elites or organised crime groups leading to clientelistic practices.

  • Weak presence of the State in remote rural areas.

  • Weakness of local election processes, practices of vote-buying and patronage undermining the integrity of the electoral process.

  • Weaknesses in organised local civil society (low capacities, capture of civil society groups, etc.), holding local governments to account for their actions.

  • Unclear assignment of responsibilities across levels of government, limiting co-ordination and accountability, coupled with an often low degree of professionalisation of public officials.

Poor data collection and performance monitoring of public service delivery and investments affect the needs assessment and the monitoring and evaluation of policies (OECD, 2018[12]) These challenges are often coupled with political dynamics that oppose any demand for change as it could weaken positions of power. In Mexico, there have been only sporadic efforts to tackle corruption at this level. According to the National Institute for Statistics and Geography (Instituto Nacional de Estadística y Geografía, INEGI) Census of Municipalities and Delegations of Mexico, in 2017 only 6.8% of all municipal and delegation administrations had an anti-corruption programme or plan in place. 10.5% had a training or capacity-building programme established on the subject with the most frequent topics being: Consequences for breaking the anti-corruption laws and norms (41.4%), internal control (26.7%), accountability (20.7%), risk management (19.9%) and mechanisms for fighting corruption (17.7%). At the same time, according to the 2017 National Survey on the Quality and Impact of Government (Encuesta Nacional de Calidad e Impacto Gubernamental, ENCIG), in the State of Mexico municipal administrative procedures are among the three administrative procedures most prone to corruption. The PEA specifically suggests actions to improve and reduce corruption in government processes and services as part of its strategic area on combatting impunity.

The SAEMM is the only one of the state anti-corruption systems that establishes an obligation for the municipal level to create a body in charge of anti-corruption similar to the structures at the state level. Article 61 of the Anti-corruption System Law of the State of Mexico and Municipalities establishes that the Municipal Anti-corruption Systems (Sistema Municipal Anticorrupción, SMA) co-ordinate with the SAEMM. Among their objectives are to establish principles, guidelines, procedures and integrity policies to prevent, detect and sanction administrative misconduct and corruption, as well as supporting the competent authorities in the oversight and control of public resources.

The SMA consists of the Municipal Co-ordination Committee and the Municipal Citizen Participation Committee. The head of the municipal comptroller´s office, the head of the transparency and access to information unit and a representative of the Municipal Citizen Participation Committee compose the Municipal Co-ordination Committee. The Municipal Citizen Participation Committee consists of three citizens known for their anti-corruption expertise. They are appointed by a Selection Commission for three years and receive an honorary fee. Both of the bodies have similar attributes to their counterparts at the state level. As such, the governance of the SMA mirrors the SAEMM while slightly reducing the size of the two bodies, acknowledging scarcer resources at the municipal level.

One of the key principles set out in the OECD Recommendation on Public Integrity is the commitment and leadership by the top-level management to build a culture of integrity. Political will at the municipal level responds to its own incentives with specific dynamics of power. However, reform incentives and the “business case” for integrity are often formulated at the state or national level, as it has been the case of the SMA. The municipal government authority political calculus has little to do with incentives for reform at the state or national level, and instead are directly connected with its immediate context.

Interviews during the fact-finding mission of this report revealed that the leadership and public officials in municipalities often have either limited knowledge of the SMA or a limited awareness of its benefits. As such, they perceive very limited incentives to embark on integrity reforms other than complying with the obligations set at the state level. This is confirmed by the fact that while the law obligates municipalities to establish the SMA, 59 out of 125 municipalities have set up a full functioning SMA (as registered on 31 January 2021).

The design of the SMA struggles with several weaknesses, which undermine its functioning. As confirmed throughout the fact-finding mission in preparation of this report, in many cases the internal comptroller of the municipalities is highly dependent on the mayors and there is a low degree of professionalisation undermining the control function (see Chapter 3). In addition, internal audit functions at the municipal level are often understaffed, and they suffer from a lack of sufficient resources for their audit work, including the use of their own vehicles and personal computers (see also Chapter 4). This raises doubts about whether the municipal comptroller has the resources to dedicate time to the SMA. In addition, the limited independence from the mayor may result in limited effectiveness of the SMA as the municipal representatives may outvote accountability measures proposed by the Citizen Participation Committee, unless the mayor has an incentive to strengthen integrity. During the interview, these doubts were confirmed and cases reported of mayors blocking any attempts for reforms originating from the municipal Citizen Participation Committee.

Concerning the municipal Citizen Participation Committee, the weaknesses identified at the state level are exacerbated at the local level and contribute to the low level of implementation. Interviews with the SAEMM, municipalities and civil society confirmed several challenges. First, in several municipalities, it was reported that it is difficult to integrate the Selection Commission, which oversees the process for selecting the members of the Citizen Participation Committee. The law states that the municipality calls on the research and higher education institutions, civil society organisations or individuals who are integrity specialists from the municipality to suggest five suitable candidates for the Selection Commission. In particular, the smaller municipalities do not always count on research and higher education institutions. There have also been cases where the municipalities have not received any applications from candidates. This might be because the position is unpaid and potential candidates would rather apply to the Citizen Participation Committee, which is paid. Second, it has also proven difficult for some municipalities to nominate three qualified citizens to the Municipal Citizen Participation Committee. On the one hand, this is due to the fact that in remote areas, the profiles are scarce. On the other hand, there have been cases where political parties and other vested interests have tried to place candidates within the Committee or candidates are not truly representing civil society. For example, in 2019, several municipal systems had to repeat the selection procedures for the members of the Citizen Participation Committee as they included current or former civil servants (Huerta, 2019[13]). Third, there have been complaints that the calls for candidates, either for the Selection Commission or the Citizen Participation Committee at the municipal level, have not been made sufficiently public or were published with a very tight deadline for citizens to apply.

The Executive Secretariat of the SAEMM has undertaken efforts to support municipalities in strengthening integrity and to build capacities. For example, as of October 2020, it had conducted 17 workshops to train public servants at the municipal level on anti-corruption. This included courses such as “Introduction to the State Anti-Corruption System" and "Municipal Anti-Corruption System", which were attended by 124 municipalities. A regional training was conducted on the same topic in the municipality of Atlautla for 26 municipalities in the eastern part of the State of Mexico. In addition, the Executive Secretariat provides advice to municipalities either in person, by phone or online.

The inclusion of the municipalities in the SAEMM is a recognition of the specific integrity risks municipalities face and the importance to co-ordinate anti-corruption efforts with this level. While it is an important and laudable recognition, this raises expectations among society for reforms and change. However, as argued above, the SMA suffers from inherent weaknesses undermining its functioning and impact. If the institutional framework yields little or no success in bringing about reform or strengthening accountability, the initial expectations for change may turn into resignation and individuals’ withdrawal from civic and public life. Evidence collected confirms that the maturity level and core integrity functions in municipalities would need to be built up before the SMA could be successfully implemented. This is in line with the diagnostic included as part of the PEA and according to which specific priorities were set to establish policies and integrity systems at the municipal level.

Considering this, it could be beneficial to adopt an incremental approach to strengthening the maturity of the municipalities before mandating them to implement an anti-corruption system that is likely to fail. This does not preclude those municipalities who would like to set up a municipal anti-corruption system to do so, particularly if they feel their capacities to establish it are sufficient. As a first step, the Anti-corruption System Law could be amended to mandate municipalities to adopt a strategic approach towards strengthening integrity, instead of setting up their own anti-corruption system modelled after the state system. Furthermore, the law could assign the Executive Secretariat the function of guiding and supporting municipalities on how to strengthen integrity according to a strategic approach. By including this role in the law, the State of Mexico would prominently recognise the importance of strengthening integrity at the municipal level. To develop such an approach, the law could mandate municipalities to implement a diagnostic tool assessing the internal strengths and weaknesses and external opportunities and threats of corruption and integrity (also known as SWOT- analysis), with support from the Executive Secretariat. This problem analysis could identify the priorities for integrity taking into account available capacities and resources. Based on the diagnostic and identified priorities, a municipal integrity action plan could be designed aligned with the state anti-corruption policy. One approach could be to identify areas in which efforts to strengthen integrity are most likely to deliver tangible results in order to create buy-in from stakeholders. The plan could identify concrete actions and measures to mitigate the risk factors identified. The plan should also include indicators that allow monitoring and evaluating efforts. Both in the problem analysis phase and in the design of the municipal integrity plan, the engagement of stakeholders from civil society and the private sector would be key to ensure a broad representation of views and experiences, correctly identify procedures most vulnerable to corruption, assess the impact of these corruption vulnerabilities and design targeted and feasible measures.

There is a risk that efforts will not transcend from paper to practice unless a dedicated person is responsible for overseeing the efforts and following up on the different actions aimed at strengthening integrity. In line with principle 2 of the OECD Recommendation of the Council on Public Integrity, which advocates establishing clear responsibilities, a dedicated contact point for integrity could be set up in every municipality. In line with the recommendation for the contact point at the state level, the contact point would support, oversee, organise and follow-up on different actions and provide information and ask for guidance from the Executive Secretariat. The anti-corruption law could include a provision mandating municipalities to set up such a function and provide a budget to execute the necessary measures. In addition, the contact points could create a network for strengthening integrity at the municipal level, exchanging challenges and success stories to promote mutual learning.

The role of the Executive Secretariat would be crucial to support integrity at the municipal level. First, it will need to develop an argument or business case to incentivise municipalities to strengthen integrity and generate an understanding of the benefits of doing so, instead of underlining the obligation. Second, the Executive Secretariat would need to support the municipalities in the implementation of the diagnostic tool and elaboration of the municipal integrity plan by developing detailed guidance and toolkits, facilitating discussions with stakeholders and providing model plans. It could also collect good practices and facilitate exchange between municipalities and the respective contact points. Third, the Executive Secretariat could collect information and data on the progress of municipalities and publish a ranking on the website of the anti-corruption system to inform civil society and build external pressure and accountability. Currently, the Executive Secretariat has developed a diagnosis stemming from a citizen consultation and desk research to design tailored anti-corruption programmes for municipalities.

Considering the structural weaknesses at the municipal level, the efforts to develop a strategic approach to integrity in the municipalities will need to be accompanied by efforts at the state level. The Co-ordination Committee, uniting the main institutions for integrity, is in a unique position to co-ordinate technical support and guidance for municipalities. As a first priority, the Co-ordination Committee should address the weakness of the control system at the municipal level (see Chapter 4 for detailed recommendations). In addition, and as it has done in the past, the Co-ordination Committee could issue and follow-up on recommendations to strengthen integrity at the municipal level. To facilitate the adoption of the recommendations, these should be targeted and concrete. The members of the Co-ordination Committee could offer their support in addressing these recommendations. Lastly, the SAEMM could create a mechanism to formally involve municipalities in its decisions to create ownership. They could be invited to participate in the activities of both the Co-ordination Committee and the Executive Commission, in particular in instances in which proposals for designing integrity policies and co-ordination mechanisms are discussed. Municipalities could actively participate in these discussions and make substantive contributions by describing challenges and good practices relevant in developing policy drafts or proposals. The elaboration of the PEA was a good example of how the perspectives of the municipalities are included through surveys, feedback mechanisms, and similar.


[13] Huerta, V. (2019), “Retroceden sistemas anticorrupción municipales”, El Sol de Toluca, https://www.elsoldetoluca.com.mx/local/retroceden-sistemas-anticorrupcion-municipales-en-edomex-3854190.html (accessed on 17 April 2020).

[7] Hussmann, K. (2007), Anti-corruption policy making in practice: What can be learned for implementing Article 5 of UNCAC? Synthesis report of six country case studies: Georgia, Indonesia, Nicaragua, Pakistan, Tanzania, and Zambia, Chr. Michelsen Institute (U4 Report), https://www.u4.no/publications/anti-corruption-policy-making-in-practice-what-can-be-learned-for-implementing-article-5-of-uncac/ (accessed on 26 May 2020).

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[9] OECD (2017), OECD Integrity Review of Coahuila, Mexico: Restoring Trust through an Integrity System, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264283091-en.

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[2] OECD (2017), OECD Recommendation of the Council on Public Integrity, OECD, Paris, http://www.oecd.org/gov/ethics/Recommendation-Public-Integrity.pdf.

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