2. Developing a strategic approach to public integrity in the State of Mexico

A strategy or strategic policy for public integrity is essential to support a coherent and comprehensive integrity system. Strategic planning, based on insight and foresight, guides the integrity system towards a proactive “culture of integrity”, instead of a reactive “culture of cases”. The OECD Recommendation of the Council on Public Integrity highlights the value of “setting strategic objectives and priorities relying on a risk-based approach” (OECD, 2017[1]).

Regardless of the form, a stringent development process of a strategic approach to public integrity contains the following elements:

  • problem analysis: risk identification, analysis and mitigation

  • strategy design: prioritising objectives, policy consultation and co-ordination

  • developing indicators with baselines, milestones and targets

  • drafting the action plan, distributing responsibilities and costing activities

  • implementing, monitoring, evaluating, and communicating the results of monitoring and evaluation, including evaluation prior to implementation (OECD, 2020[2]).

By establishing a strategic approach, the government commits itself to concrete actions and outcomes. This can be a message to citizens that the government is taking the prevention and repression of corruption seriously. If guided by the development steps detailed above, a strategic approach can support setting realistic objectives that are meaningful in the given context, avoiding copy-paste solutions, prioritising actions based on integrity risks and clearly assigning responsibilities for implementing the identified goals and objectives. It can also lead to develop benchmarks and indicators that gather evidence on successful interventions and overall effectiveness of the integrity system (OECD, 2019[3]).

A key area of responsibility of the Co-ordination Committee of the Anti-corruption System of the State of Mexico and Municipalities (Sistema Anticorrupción del Estado de México y Municipios, SAEMM) is to design, promote and evaluate an anti-corruption policy for the State of Mexico. The Executive Commission, consisting of the Technical Secretary and the Citizen Participation Committee (except its president), developed the draft policy, which was approved in July 2020 (Política Anticorrupción del Estado de México y Municipios, PEA). The Executive Secretariat is tasked with monitoring its implementation in the institutions of the public sector.

The content of the state anti-corruption policies, at a minimum, need to ensure alignment with the national one, adopting the same four strategic areas (combatting corruption and impunity, combatting arbitrariness and abuse of power, promoting the improvement of public management and contact points between government and society, and involving society and the private sector) and forty priorities. However, states may add additional strategic areas and priorities to adjust for the specific contexts (Box 2.1). As of October 2020, the State of Mexico was the only federal state that had included an additional strategic area on public ethics and integrity with twelve priorities for public policy. An evaluation of the Executive Secretariat of the National Anti-corruption System agreed that the design of the PEA is in line with the national policy.

Guided by the national anti-corruption policy, the State of Mexico started a stringent process of developing the policy along the key steps outlined above in September 2019. Starting with problem analysis and strategic design, the Executive Secretariat built on the diagnostic already conducted as part of the national policy and consulted surveys and indicators from civil society, academic institutions and international organisations. The Co-ordination Committee and Executive Secretariat also organised a broad stakeholder consultation process. This consisted of four regional citizen fora held throughout the state, an electronic survey on perceptions of corruption, nine focus groups providing feedback on the four strategic areas of the national policy, and an expert panel as a last step to evaluate and analyse the results obtained throughout the process. This extensive consultation process was useful for, on the one hand, receiving feedback on the realities of corruption among all of society. On the other hand, including such a broad range of voices builds a common vision and increase the legitimacy of the strategy, and hence augment political support for it in the wider society (UNODC, 2015[5]). As a result, the Executive Secretariat developed the State Anti-corruption Policy, approved in July 2020, consisting of 60 priorities for public policies and ensuring overall alignment to the National Anti-corruption Policy. As stated above, the PEA includes an additional strategic area on public ethics and integrity.

Furthermore, the Executive Secretariat of the SAEMM developed a proposal translating the priorities into clear objectives and indicators, which will measure whether the objective has been reached. In this way, the success or failure of the anti-corruption initiatives can be monitored. The evidence provided feedback information from the implementation level to the policy-design stage and enabled effective steering, informed decision making and improved policy design (OECD, 2019[6]).

The OECD Follow-up Report on the Integrity Review of Mexico highlights that it is essential to link the national anti-corruption policy and related action plan to key existing national strategies in order to ensure mainstreaming integrity throughout the entire public sector (OECD, 2017[7]). While the Executive Secretariat of the State of Mexico analysed the Development Plan of the State of Mexico and other relevant legislation to ensure overall alignment, the Co-ordination Committee could ensure that other state strategies, for example, the digital agenda or the security strategy, identify relevant integrity objectives and actions within their action plan where the opportunity arises.

The PEA addresses some of the key risks and vulnerabilities to integrity in the State of Mexico, such as impunity, professionalisation of the civil servants or lack of co-ordination among institutions. However, due to the fact that the state anti-corruption policy is aligned to the national policy, the recommendation given at the national level in the OECD Follow-up Report on the Integrity Review of Mexico on key integrity risks which were not addressed applies as well to the State of Mexico (OECD, 2019[8]) Compared to the national policy, Priority 59 of the PEA creates opportunities to identify and prevent capture and undue influence mitigating, such as the financing of political parties and lobbying. While this represents considerable progress, it is crucial to outline specific activities towards mitigating the integrity risks in the financing of political parties, election campaigns and lobbying, which may lead to political capture and undue influence. Interviews in preparation of this report confirm that common corruption risks are the illegal financing of political activities, clientelist practices and recurrent changes of electoral rules. Regarding the importance, these issues hold and high risk thereof, they could be considered to make them explicit priorities to ensure follow-up and specific actions.

Additional risk areas that could be considered are organised crime and insecurity, countering police corruption and ensuring accountability through a robust internal control and risk management system. Regarding police and insecurity, the 2017 Survey on the Quality and Impact of Governance by INEGI highlights that the police is considered as the most corrupt entity in the State of Mexico, with 95% of citizens considering corruption to be frequent or very frequent among the police. Similarly, in the roundtables held to support the development of the PEA, several members expressed the opinion that corruption among the police is common. Coupled with a growing number of homicides and 91% of citizens feeling unsafe, there is clear room for action. In addition, by including security as a key concern in the anti-corruption policy, it would mirror the inclusion of corruption as a factor undermining public security, as detailed in the Development Plan of the State of Mexico. As such, the Executive Secretariat could consider including these risk factors as additional priorities in the PEA to ensure a policy that is relevant in the context and targets actual corruption risks. Prior to the inclusion, a detailed analysis of the risk areas should be conducted, consisting of identifying the procedures and areas in which corruption and lack of integrity are common and their impact. The PEA would prescribe measures to manage these risks and indicators to monitor and evaluate their effectiveness.

One of the strengths of the SAEMM is the incorporation of municipalities. However, the current implementation of municipal anti-corruption systems has been slow (see sub-section “The implementation of the Municipal Anti-corruption Systems is lagging behind” in Chapter 1) and there are few initiatives of municipalities actively strengthening integrity. As such, it is a vital and exemplary step that the PEA and its priorities extend to the municipal level and set clear expectations and responsibilities in terms of integrity for this level. In a specific reference, the PEA underlines that the leadership and participation of the members of the Co-ordinating Committee, the Executive Commission and the Municipal Anti-Corruption Systems, with the assistance of the Executive Secretariat, forms the basis for actions to combat corruption in a systematic and comprehensive approach of all public entities, the public authorities, and among others, municipal governments (State Anti-corruption System Executive Secretariat, 2020[9]). In developing the concrete actions, which will accompany the PEA, it would be crucial to assign activities and responsibilities to municipalities in line with their resources and capacities and to monitor the impact in order to be able to adjust measures.

The PEA is a key step towards a systematic and coherent approach to integrity. However, it is vital that the PEA remains relevant throughout its implementation and responds to the integrity vulnerabilities in the State of Mexico. The restructuring of the Executive Secretariat and set-up of a General Directorate responsible for managing corruption risks can ensure that corruption risks are evaluated on a regular basis and proposals made to target the actions of the PEA according to new and emerging risks.

The state anti-corruption policy sets the strategic goals and objectives, but needs to be operationalised by public entities into specific objectives and actions at the institutional level. Experience suggests that if goals are not included in organisational planning and are not backed by dedicated budget and accountability mechanisms, managers will not take action (OECD, 2019[3]).

The primary purpose of the SAEMM is to strengthen co-ordination for integrity among public entities of the State of Mexico. Breaking this down further, the Co-ordination Committee could complement the anti-corruption policy with an action plan identifying the responsible entities for each line of action in relation to the priorities of the policy and set a timeline for implementation. In line with OECD practices (Box 2.2), the Co-ordination Committee could require entities to develop organisational integrity strategies in relation to the action plan. The Executive Secretariat could support public entities in developing their own strategies and specifically validate the integrity objectives and activities of this planning at entity-level.

In fact, the Technical Secretary has proposed a model of co-ordination which places the Co-ordination Committee at the centre for implementing and evaluating the PEA. The model proposes that working groups are established, consisting of at least three members of the Co-ordination Committee and supported by the Technical Secretary. The purpose of these working groups is to co-ordinate with all relevant public entities to define targeted projects, actions, goals and indicators for the 60 priorities of the PEA. This includes the evaluation and impact assessment of the priorities in order to develop recommendations for the entities implementing the relevant actions of the PEA. It also foresees the nomination of officials responsible for the activities related to the priority in each entity. While such a co-ordination model would be beneficial, it would be essential to nominate one contact point in each entity that is responsible for overseeing the different efforts within the entity related to the relevant priorities of the PEA. In this way, duplications could be avoided and efforts aligned. The integrity actors, described in Chapter 1, could fulfil such a role.

In addition, the Executive Secretariat is currently developing a manual for the implementation of the PEA. This manual clearly assigns the entities responsible for the actions envisioned to implement the PEA priorities and will provide support material.

To facilitate monitoring, follow-up and evaluation, the Executive Secretariat has been working on a proposal for an automated monitoring system (Sistema Administrativo para Resultados Anticorrupción, SARA). It is planned to enable systematisation and oversight of implementation efforts related to the anti-corruption policy, as reflected in the projects, goals and activities and those responsible for compliance. The system is also supposed to generate the necessary reports for decision making.

In addition to these efforts, the Executive Secretariat would need to ensure validation of the uploaded information. Individual agencies are often overly optimistic when assessing how well they are doing in implementing a programme and the monitoring arrangements of many strategies have fallen short because they rely on implementing organisations monitoring their own progress. To avoid this, the Anti-Corruption Initiative Assessment of the Anti-corruption and Civil Rights Commission in Korea (Box 2.3), requires entities to submit their own performance reports. However, on-site visits verify the information and overall performance is scored by external examiners. Among other advantages, doing so might help implementing organisations understand how they can better assess their own performance (UNODC, 2015[5]). The Executive Secretariat could request entities to upload the information on the SARA and follow up on a random basis with some entities to verify the information submitted.

Furthermore, the Co-ordination Committee of the SAEMM could use the public annual report to inform progress the entities are making in implementing the Action Plan, aside from monitoring and measuring the benefits of the integrity strategy. Communicating progress and results to internal and external stakeholders, including the wider public, not only enables accountability, but also increases the credibility of integrity efforts and stimulates future anti-corruption and integrity action. In addition, public scrutiny could encourage some entities to advance in the implementation of the anti-corruption policy. The Co-ordination Committee could use the annual report on the progress of the Anti-corruption System to publish detailed information on progress at the entity level. This could include, for example, the introduction of a code of conduct at the entity level, percentage of staff aware of ethical dilemmas and guidelines regarding corruption or similar initiatives. In addition, information should be made available on the Anti-corruption System’s website.

For example, the ACRC in Korea develops a tiered ranking of how the institutions progress according to performance groups (from 1 to 5, with 1 being the best performing category). The tiered ranking of each institution and a consolidated report is released to the public. The results receive significant media attention and those institutions that score well benefit from improved organisational reputation. The ACRC also provides each entity with a specific report that includes suggestions for improvement (Lee Jun-min and Lee Ahjung, n.d.[11]).

A strategic approach to integrity also requires indicators and the establishment of baselines, milestones and targets. Indicators should reflect the strategic objectives of the anti-corruption policy or the action plan. Well-designed indicators, including baselines, milestones and targets, can function as a roadmap for the kind of results to be achieved and how. Indicators can also support to assess progress towards the strategic objectives and necessary corrections, as needed (OECD, 2020[2]).

When designing indicators one should keep in mind that, ideally, indicators are specific, measurable and realistic. A good indicator measures only one variable unambiguously at a reasonable effort in order to provide clear results (OECD, 2019[6]).

In the context of the anti-corruption policy, the Executive Secretariat of the SAEMM is currently at the stage of developing indicators, which the Executive Commission will further refine. Throughout the development process, the PEA envisages collaboration with government entities, experts, organisations from the private sector and civil society, recognised for their specialisation in this area, such as INEGI and CONEVAL, the Institute of geographical, statistical and cadastral information (Instituto de Información Geográfica, Estadística y Catastral, IGECEM), the Office of the Comptroller-General of the State of Mexico (Secretaría de la Contraloría del Estado de México, SECOGEM) and the Ministry of Finance, to identify and provide feedback on relevant indicators. Such stakeholder consultation has the potential to improve the quality of the indicators and help ensure that, at the end of the process, the evaluation findings will be considered credible by the parties. Given the involvement of the members of the Citizen Participation Committee in the Executive Commission, a social control function would be established, which should prevent that the measurement indicators are set too low and too easy hindering their effectiveness (OECD, 2019[6]). In addition, the PEA also foresees this collaboration as a step towards building synergies for internal and external evaluations.

Regarding the strategy for monitoring and evaluation, the Technical Secretary is currently drafting a detailed plan on which basis the indicators will be developed. This is done in co-ordination with public entities, the private sector and civil society organisations. It will be based on four pillars:

  • Logical framework approach to identify, prioritise and define the scope of programmes, projects and indicators used for the design, operation and evaluation of public policies.

  • Strategic planning taking into account the economic, political, social, cultural and legal factors contributing to the performance of the indicators to measure corruption.

  • Management by results to identify the indicators measuring results achieved in the execution of the implementation programmes.

  • Evaluation based on institutional sources to assess the development of the level of corruption as the PEA is implemented. The focus is particularly on measuring the impact of the PEA on public life by developing several composite indexes consisting of indicators measuring trust, perception of corruption and incidence and reporting of corruption, among others.

In the process of developing the measurement framework as envisioned, it would be crucial that the objectives and indicators for specific actions of the PEA fulfil the principles of reliability and validity. This means that the definition for delivery is defined ex ante, through a clear definition of categories in the case of yes/no-indicators, a target value in the case of a quantitative variable and a baseline for indicators measuring change. Similarly, a focus should be put on developing indicators that go beyond de jure implementation and include de facto implementation. For example, mere de jure existence of an Integrity Code does not guarantee the goal to achieve integrity within an organisation (de facto); in turn, both the elaboration and the implementation process of the Integrity Code can be made conditional on certain qualitative elements, which are likely to impact on the code’s quality.

Regarding the institutional responsibility for the monitoring process of the anti-corruption policy, the Executive Secretariat could act as the impartial monitoring unit. The Executive Secretariat could undertake an examination of available data sources from public institutions to assess their relevance, applicability, validity, and reliability. The data could be collected centrally via digital means. In this way, the Executive Secretariat would be able to set the standard for data provided by the institutions and from which it could draw its conclusion for the monitoring report. As part of this, the Executive Secretariat would need to ensure that the entities have the necessary capacities and knowledge to measure data objectively and coherent. The Executive Secretariat could use the data to create a monitoring report informing the Co-ordination Committee, in line with the provisions of the Anti-corruption System Law. Based on the monitoring report, the Co-ordination Committee could develop recommendations for the entities on how to improve their integrity systems (OECD, 2019[6]). In fact, as commented above, the Executive Secretariat envisages the establishment of interinstitutional groups, consisting of at least three members of the Co-ordination Committee and supported by the Technical Secretariat, which would follow-up on and monitor the actions regarding the priorities under their responsibility. It is also foreseen that these would generate specific recommendations. These could build the basis for the recommendations issued by the Co-ordination Committee, as suggested.

To assess the effectiveness of the anti-corruption policy it is crucial to design specific evaluation arrangements from the outset.

Having a clear idea of what data will be collected for evaluation, as well as how and when measures taken will be evaluated, informs the design and implementation of actions. It can also ensure measurability, progress reports and accountability. The result of a well-designed evaluation procedure is to hold the implementing actors accountable for what has been achieved, and how efficiently. Similarly to the monitoring efforts, it may also bring vital evidence to assess progress and identify needs for adjustment (OECD, 2020[2]).

In general, the evaluation can either be done in-house or outsourced. The choice depends on the purpose of the evaluation and the resources available. While in-house evaluations may support self-reflection and learning, be less expensive and faster to conduct, outsourced evaluations are considered to be more objective and have the advantage of involving experts in the area. Table 2.1 details the advantages and disadvantages of each approach (OECD, 2020[2]).

Within the SAEMM, the Co-ordination Committee has the mandate to set the methodology for impact evaluation. The PEA envisages a monitoring and evaluation scheme based on internal and external evaluations:

  • Evaluating the results, efficiency, quality and impact of the administration and performance of internal processes, programmes, projects, actions, goals and indicators stemming from the PEA; and

  • Evaluating the impact of the PEA implementation by applying different variables, indexes and indicators, which include a measurement agenda for the short, medium and long term (0-2 and up to 4 years). These are susceptible to be evaluated externally.

To ensure accountability and independence and build public trust in the effectiveness of the system, in addition to outsource the evaluation, the Co-ordination Committee could outsource the development of the methodology for evaluation. Throughout the process of hiring independent evaluators, particular attention should be paid to manage any potential or actual conflicts of interest. The contracting process should be conducted according to a high standard of transparency, publishing relevant information throughout and keeping the public informed.

Aside from monitoring and evaluating the benefits of the anti-corruption policy, communicating progress and results to internal and external stakeholders, including the wider public, not only enables accountability, but also increases the credibility of integrity efforts and stimulates future anti-corruption and integrity action. The State of Mexico has already taken an important step in terms of communicating openly and actively the development of the policy by publishing the different steps throughout the process and organising public opinion fora. The SAEMM, mainly the Co-ordination Committee and the Executive Secretariat, could continue these efforts to communicate the envisaged implementation, the bodies responsible for execution, and the monitoring and evaluation framework. These efforts can mobilise popular support and strengthen trust in the system. It will also enable the public to act as an external accountability source demanding action on the policy.


[4] Executive Secretariat of the National Anticorruption System (2020), Guía de diseño de Políticas Estatales Anticorrupción, https://www.sesna.gob.mx/wp-content/uploads/2020/02/Gu%C3%ADa-dise%C3%B1o-PEA.pdf (accessed on 19 April 2020).

[2] OECD (2020), OECD Public Integrity Handbook, OECD Publishing, Paris, https://dx.doi.org/10.1787/ac8ed8e8-en.

[8] OECD (2019), Follow up Report on the OECD Integrity Review of Mexico Responding to Citizens’ Expectations, OECD, Paris, http://www.oecd.org/gov/ethics/follow-up-integrity-review-mexico.pdf.

[3] OECD (2019), OECD Integrity Review of Argentina: Achieving Systemic and Sustained Change, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/g2g98ec3-en.

[6] OECD (2019), OECD Integrity Review of Mexico City: Upgrading the Local Anti-corruption System, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264306547-en.

[10] OECD (2018), OECD Integrity Review of Nuevo León, Mexico: Sustaining Integrity Reforms, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264284463-en.

[7] OECD (2017), OECD Integrity Review of Mexico: Taking a Stronger Stance Against Corruption, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264273207-en.

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

[11] Son, J. et al. (eds.) (n.d.), Introduction to Korea’s Anti-corruptIon Initiative Assessment: A Tool to Evaluate Anti-Corruption Efforts in the Public Sector in the Republic of Korea, UNDP, http://www.undp.org/content/dam/uspc/docs/USPC%20ACRC%20final.pdf (accessed on 1 July 2018).

[9] State Anti-corruption System Executive Secretariat (2020), State of Mexico Anti-corruption Policy.

[5] UNODC (2015), The United Nations Convention against Corruption. National Anti-Corruption Strategies: A Practical Guide for Development and Implementation, United Nations, Vienna, https://www.unodc.org/documents/corruption/Publications/2015/National_Anti-Corruption_Strategies_-_A_Practical_Guide_for_Development_and_Implementation_E.pdf.

[12] Vági, P. and E. Rimkute (2018), “Toolkit for the preparation, implementation, monitoring, reporting and evaluation of public administration reform and sector strategies: Guidance for SIGMA partners”, SIGMA Papers, No. 57, OECD Publishing, Paris, https://dx.doi.org/10.1787/37e212e6-en.

Metadata, Legal and Rights

This document, as well as any data and map included herein, are without prejudice to the status of or sovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Extracts from publications may be subject to additional disclaimers, which are set out in the complete version of the publication, available at the link provided.

© OECD 2021

The use of this work, whether digital or print, is governed by the Terms and Conditions to be found at http://www.oecd.org/termsandconditions.