Chapter 9. Proposals for Actions

1. Mandate and establish a responsible authority as foreseen in the Public Ethics Law.

Legislative branch

Short term

2. Mandate and establish a responsible authority as foreseen in the Public Ethics Law.

Judiciary

Short term

3. Mandate and establish a responsible authority as foreseen in the Public Ethics Law.

Attorney General’s office

Short term

4. Mandate and establish a responsible authority as foreseen in the Public Ethics Law.

Defender General’s Office

Short term

5. Mandate and establish a responsible authority as foreseen in the Public Ethics Law.

Judicial Council

Short term

6. Establish a policy dialogue between the different branches through regular meetings between the authorities of application of the Public Ethics Law.

Authorities of application (rotation)

Medium term

7. Conduct a comprehensive analysis of the quality and the level of enforcement of existing public ethics laws in the provinces.

Anti-corruption Office

Short term

8. Discuss and elaborate a concrete proposal for revising the Public Ethics Law to require the implementation of a Federal Council for Integrity, steered by the Anti-corruption Office.

Permanent Forum of State Prosecutors for Administrative Investigations and Anti-corruption Offices

Short/Medium term

9. Develop guidelines for Provincial Integrity Systems in line with the national Public Ethics Law and beyond.

Permanent Forum of State Prosecutors for Administrative Investigations and Anti-corruption Offices / Federal Council for Integrity

Short/Medium term

10. Promote an evidence-based informed discussion on challenges related to corruption through comparative data across Provinces and municipalities, collected through surveys.

National Institute of Statistics and Censuses

Short term

11. Merge the roundtables of integrity and administrative reform to institutionalise a Commission for Integrity and Transparency in the PEN as a formal co-ordination mechanism, hosted by the JGM and steered by the Anti-corruption Office.

Executive Office of the Cabinet of Ministers

Medium term

12. Assess the strength, weaknesses, opportunities and threats faced by the existing Ethics and Transparency Units (UET) in the executive and in State-Owned Enterprises.

Anti-corruption Office

Short term

13. Develop a proposal for a policy that clearly assigns the function of promoting integrity and transparency in the organisational structure of public entities, separating this function clearly from the task of detecting individual cases of wrongdoing, as well as from investigation and enforcement (i.e. dedicated integrity contact points).

Anti-corruption Office

Short term

14. Provide guidance and support to implement a dedicated integrity contact point in each public entity as a pilot in selected public entities to draw lessons and fine-tune the policy.

Anti-corruption Office

Short term

15. Implement dedicated integrity contact points following the guidance of and with the support from the Anti-corruption Office in selected pilot entities of the national executive branch.

Selected pilot public entities in the national executive branch

Short term

16. Establish a network of the integrity contact points.

Anti-corruption Office

Short term

17. Decide and co-ordinate the development of a National Integrity Strategy for the executive branch.

Executive Office of the Cabinet of Ministers

Short term

18. Steer a strategic participatory planning exercise, ideally in the context of the National Commission for Integrity and Transparency, to develop the National Integrity Strategy with strategic goals and priorities for the public integrity system.

Anti-corruption Office

Short/Medium term

19. Operationalise the National Integrity Strategy in public entities and/or sectors, with specific objectives and actions at organisational and/or sectorial level.

Sector line ministries

Medium term

20. Support and guide line ministries in operationalizing the National Integrity Strategy at entity level.

Anti-corruption Office (content) and Secretary of Modernisation (methodology)

Medium term

21. Ensure and communicate not only internally, but also and especially to external stakeholders the strict separation of the two sub-secretariats.

Anti-corruption Office

Short term

22. Make more visible and invest more into its preventive and advisory role by further strengthening its Sub-secretariat for Integrity and Transparency.

Anti-corruption Office

Short term

23. Strengthen its analytical and planning capacities in order to fulfil its functions related to steering the development of a National Integrity Strategy and to providing guidance to public entities through capacity building and through attracting the right human resources.

Anti-corruption Office

Short term

24. Develop a strong communication strategy aimed at clarifying and emphasising its preventive role and that pays particular attention to highlighting solutions, good practices and successes instead of a problem-oriented communication strategy emphasising corruption cases and the costs of corruption. In this context, initiate a discussion on advantages and disadvantages of rebranding the Anti-corruption Office into “Integrity Office”.

Anti-corruption Office

Short term

25. Strengthen the justice system, in particular the Prosecutor Office for Administrative Investigations (PIA), the Attorney General’s Office, and the Judicial Council.

Prosecutor Office for Administrative Investigations (PIA), Attorney General’s Office, Judicial Council

Medium/long term

26. Increase the Anti-corruption Office’s administrative autonomy and financial independence. For example, following the model of the Financial Information Unit (UIF), to ensure that the OA has the autonomy to decide over its own staff, to align the job description to its needs, and ensure professionalism and multidisciplinary by a merit-based contracting of the staff.

Anti-corruption Office

Short term

27. Implement measures mitigating internal integrity risks of the OA, in particular through adequate human resource management and facilitating access to training opportunities and guidance on ethical dilemmas and conflict-of-interest situations to its staff.

Anti-corruption Office

Short term

28. Implement formal procedures for checks-and-balances when selecting and removing the head of the Anti-corruption Office. For instance, the process of selecting and removing the head of the OA could be inspired by the Law on Access to Public Information (Articles 20 to 23 of Law 27.275) or the Financial Information Unit (Articles 9 and 10 of Law 25.246).

Anti-corruption Office

Short term

29. Identify a set of indicators measuring both the implementation of the concrete actions derived from the strategic goals and the desired outcome of the National Integrity Strategy (chapter 1).

Anti-corruption Office

Medium term

30. Establish a central monitoring system at the level of the Secretary for Institutional Strengthening under the Executive Office of the Cabinet of Ministers.

Executive Office of the Cabinet of Ministers

Medium term

31. Integrate integrity indicators measuring the implementation and results of the National Integrity Strategy into the Results Based Management System (Gestión por Resultados, or GpR) headed by the JGM in cooperation with the Secretary of Modernisation and the Ministry of Finance. In this system, all ministries upload the required information on an online platform.

Executive Office of the Cabinet of Ministers

Medium term

32. Regularly discuss progress and challenges in the Commission for Integrity and Transparency as recommended (chapter 1).

Commission for Integrity and Transparency

Long term

33. Issue annual or semi-annual public reports or establish a dynamic website to communicate progress on the status of implementation of the National Integrity Strategy, both at central and organisational levels.

Commission for Integrity and Transparency

Long term

34. Establish an annual evaluation plan that clearly stipulates which aspects, projects or public entities are going to be evaluated, defines and openly communicates criteria and parameter for the evaluation, and assigns budget for carrying out these evaluations.

Commission for Integrity and Transparency

Short term

35. Contract out evaluations in the annual evaluation plan to a national university, an evaluation institute, a governmental body, an evaluation council, or the private sector.

JGM, the Secretary of Modernisation, the OA and line ministries

Short/Medium term

36. Establish a council of representatives from academic institutions and civil society to review the evaluations.

Commission for Integrity and Transparency

Medium term

37. Identify opportunities for conducting rigorous impact evaluations of pilot measures, testing the variation in a randomised control trial, to provide valuable information before considering up scaling the implementation.

Anti-corruption Office

Secretary for Institutional Strengthening

External partner

Short term

38. Design and implement a centrally administered and regular public employee survey in the whole National Public Administration with questions aimed at measuring aspects relevant for integrity policies.

National Institute for Public Administration

Short/Medium term

39. Develop and conduct ad-hoc staff surveys in specific sectors or public entities to inform specific integrity policy making.

Anti-corruption Office and other entities

Short term

40. Develop and add questions or modules to existing household surveys or conduct separate representative citizen surveys.

National Institute of Statistics and Censuses

Short/Medium term

41. Develop and conduct ad hoc citizen surveys to investigate relevant aspects of public opinion, knowledge and experience to inform integrity policy making.

Anti-corruption Office and other entities

Short term

42. Harmonise the Public Ethics Law, the National Public Employment Framework, the Code of Ethics and other regulations on integrity during the current reform process of the Public Ethics Law.

Legislative in consultation with Anti-corruption Office and other stakeholders

Short term

43. Develop a clear and realistic description of the circumstances and situations leading to a conflict of interest, delineating conflict of interest from disqualifying factors.

Anti-corruption Office

Short term

44. Include a non-exhaustive list of solutions that could be taken to resolve a conflict-of-interest situation in the reformed Public Ethics Law.

Legislative

Short term

45. Pass a regulatory provision introducing the duty to declare a conflict of interest, clearly stating the actor and timeframe in which the conflict has to be declared and in which timeframe a resolution of the conflict has to be pronounced.

Anti-corruption Office

Short term

46. Release a form that has to be used to declare, manage and archive a conflict-of-interest situation.

Anti-corruption Office

Short term

47. Publish explanatory material for the private sector defining and explaining key concepts relating to public ethics to facilitate the implementation of decree 202/2017.

Anti-corruption Office

Short term

48. Develop a manual on conflict-of-interest situations specific to public procurement and how procurement officials can identify them.

Anti-corruption Office

Medium term

49. Revise the current cooling-off period for pre- and post-public employment according to the level of seniority or/and occupation.

Anti-corruption Office

Medium term

50. Require former public servants to regularly report on their employment situation to the OA after leaving public service.

Anti-corruption Office

Medium term

51. Publish decision on post-public employment cases online.

Anti-corruption Office

Medium term

52. Introduce disciplinary sanctions for pre-and post-public employment breaches both for the public servant and the private sector.

Legislative

Medium term

53. Steer a process to simplify the current code of ethics in a participatory approach identifying 5-9 principles.

Anti-corruption Office

Short term

54. Develop further guiding and orientation material for ethical dilemmas and conflict-of-interest situations.

Anti-corruption Office

Medium term

55. Develop guidance/directives for developing entity-specific codes of ethics in a participatory manner.

Anti-corruption Office

Medium term

56. Development and implementation of entity-specific codes following the guidance/directives provided by the OA.

All public entities

Medium term

57. Provide clear methodological guidance for entities to develop codes of ethics.

Anti-corruption Office

Medium term

58. Establish specific codes of ethics and guidance for at-risk areas such as senior civil servants, auditors, tax officials, and political advisors.

Anti-corruption Office

Medium term

59. Including contact details of the OA and the integrity contact points in the conflict-of-interest simulator.

Anti-corruption Office

Short term

60. Limit the use of short-term contracts and introduce the same qualification and performance criteria for short-term and permanent positions.

Office of National Employment

Medium term

61. Ensure the government-wide implementation of the Directory of Competencies and design a common job profile template.

Office of National Employment

Medium term

62. Establish key qualifications and performance criteria for all positions and personnel management processes to assess candidates and public officials against.

Office of National Employment

Medium term

63. Extend Decree 93/2018 prohibiting recruitment of relatives to the level of secretary.

Anti-corruption Office

Medium term

64. Make it mandatory to disclose any family relations during the recruitment process.

Office of National Employment

Medium term

65. Include integrity as a performance indicator for senior management.

Office of National Employment

Medium term

66. Make induction training for public servants on public ethics mandatory once an extensive pool of trainers is built.

Sub-Secretariat of Labour Relations and Strengthening of the Civil Service

Long term

67. Build a network among the trainers with regular meetings to discuss problems the trainers face, exchange good practices and training case studies.

Anti-corruption Office

Long term

68. Accompanying the training course, set up an online discussion forum, guided by a moderator, to discuss ethical dilemmas and conflict-of-interest situations.

National Institute of the Public Administration /Anti-corruption Office

Medium term

69. Conduct selected sessions of the training course on public ethics for senior management in-person and add a training component in which managers have to identify individual risks and challenges to integrity and develop a personal risk mitigation plan.

National Institute of the Public Administration /Anti-corruption Office

Medium term

70. Build a mentoring programme for junior public servants to encourage the development of ethical capacities.

Sub- Secretariat for Public Employment Planification

Long term

71. Design and test different behavioural reminders for awareness raising.

Anti-corruption Office

Medium term

72. Engage senior public officials to provide guidance, advice and counsel.

Sub-Secretariat for Public Employment Planification

Medium term

73. Develop a specific training course for senior public officials to familiarise management with general measures to build trust among employees to express any grievances or concerns.

Anti-corruption Office /INAP

Medium term

74. Nominate staff champions for openness who would consult with staff on measures to improve employee well-being, work processes and openness. This could be piloted in the Secretary of Modernisation before rolling the initiative out to other entities.

Sub-Secretariat for Public Employment Planification

Medium term

75. Adopt comprehensive regulation on the protection of public servants who denounce acts of corruption.

Legislative

Medium term

76. Clarify the overlap between witness and whistleblower protection and ensure that disclosure that do not lead to a full investigation or to prosecution are still eligible for protection.

Legislative

Medium term

77. Develop internal and external communication strategies on the protections available for whistleblowers.

Anti-corruption Office

Medium term

78. Elaborate guiding material on the type of functions that are equivalent to the position of director required to file an asset declaration.

Anti-corruption Office

Short term

79. Include data on the obligation to file an asset declaration in the Integrated Information Database On Public Employment and Wages to create a harmonised and centralised list of filers throughout the executive branch.

Public Employment Secretariat

Short term

80. Transmit the list of filers to the OA on a regular basis.

Public Employment Secretariat

Ongoing

81. Cross-check the filer list with other information, such as the overall number of people employed in an entity to ensure its correctness.

Anti-corruption Office

Ongoing

82. Decouple the asset declarations from the tax declarations to strengthen the system’s purpose of preventing conflict of interests.

Legislative (after proposal by the Anti-corruption Office)

Short term

83. Modify the asset declarations to include information on:

• employment history

• registration number of assets, where applicable

• information on other shareholders of assets

• acquisition value of assets

• date of when liabilities were incurred

• deadline for repayment of liabilities.

Legislative (after proposal by the Anti-corruption Office)

Short term

84. Specify a threshold for immovable and movable assets. For assets below the threshold the accumulated value of assets would be indicated.

Anti-corruption Office

Short term

85. Introduce beneficial ownership as a complementary declaration category for public officials fulfilling the politically exposed person definition by Article 1 of Resolution 52/2012.

Anti-corruption Office

Short term

86. Raise awareness and sensitise the staff to recognise suspicious information in relation to beneficial ownership.

Financial intelligence unit and anti-money laundering experts

Medium term

87. Elaborate written guidance providing examples of how a public official might beneficially own assets or certain rights.

Anti-corruption Office

Medium term

88. Creates a legal basis for the use of a digital signature as the authentication of the declaration.

Legislative (after proposal by the Anti-corruption Office)

Medium term

89. Send reminder messages to public officials prior to the filing deadline based on behavioural insights.

Anti-corruption Office

Medium term

90. Modify the electronic filing form to embed information which answers common questions and avoids common errors when submitting information.

Anti-corruption Office

Short term

91. Ensure that public officials can contact the integrity contact point in case of doubts over the asset declarations.

Integrity Contact Points

Medium term

92. Distribute flyers with the details and objectives of the declaration system and communicate the objectives on the internal platform.

Anti-corruption Office and entities

Short term

93. Underline the declaration system’s purpose of prevention in regards to conflict-of-interest by highlighting support tools and processes to resolve conflict-of-interest situations and clearly communicate that submitting the declaration does not free the public official from resolving the conflict of interest.

Anti-corruption Office

Short term

94. Grant the Anti-Corruption Office access to reserved information and create an additional confidential annex with confidential information, such as bank account details and precise addresses, which can only be consulted by the judicial authority or the Public Prosecutor’s Office in a judicial case or by the Anti-Corruption Office by means of a substantiated resolution in the framework of a control procedure.

Legislative (after proposal by the Anti-corruption Office)

Short term

95. Select a sample based on a random lottery each year for verification that ensures that each year a different sample is chosen. In addition, take media reports and whistleblower reports into account in the selection for verification.

Anti-corruption Office

Short term

96. Integrate a higher quantity of relevant databases to allow for an automatic cross-check of information.

Anti-corruption Office

Medium term

97. Make more detailed information accessible to the public.

Legislative/Judiciary/ Anti-corruption Office

Short term

98. Introduce a tiered system for public availability of asset declarations.

Anti-corruption Office

Short term

99. Design a more user-friendly online interface and include a search function which at a minimum autocompletes the name of public officials.

Anti-corruption Office

Short term

100. Make more frequent and effective use of the possibility to administratively sanction heads of Human Resources offices who do not comply with their duty to withhold salaries from non-complying public officials.

Anti-corruption Office

Short term

101. Introduce civil sanctions in addition to criminal sanctions for wilfully not submitting information or declaring false information.

Legislative

Medium term

102. Provide mandatory training on control objectives and requirements.

SIGEN

Medium term

103. Introduce awareness programs on the need for internal control and on the roles of each area and staff member.

SIGEN

Medium term

104. Provide induction training for all staff, including senior management and managers on the internal control system.

SIGEN

Medium term

105. Clearly outline standards for specific roles.

SIGEN

Medium term

106. Embed controls into the daily operations of the public service.

SIGEN

Long term

107. Give greater responsibility for internal control and risk management to operational management.

SIGEN

Short term

108. Assist government entities with capacity building.

SIGEN

Medium term

109. Build on already existing training and awareness activities for public servants, to help ensure they understand and consistently apply the internationally recognised three lines of defence model across the public sector.

SIGEN

Medium term

110. Improve the risk management framework to be more strategic, consistent, and operational.

SIGEN

Medium term

111. Incorporate a risk management tool that is clearly separated from the audit function.

SIGEN

Long term

112. Give operational managers the ability to undertake risk assessments without the fear of reprisal.

SIGEN

Long term

113. Maintain a separate risk assessment process undertaken by auditors in their audit planning.

SIGEN

Medium term

114. Provide clear guidance for operational staff.

SIGEN

Short term

115. Include risk management requirements in mandatory training and induction sessions.

SIGEN

Medium term

116. Assign clear responsibility for specific risks, including fraud and corruption risks needs to the appropriate senior managers.

All entities in the national public sector

Short term

117. Managers take ownership of the risks that could affect their objectives.

All entities in the national public sector

Short term

118. Managers use risk information to inform decision-making.

All entities in the national public sector

Medium term

119. Managers actively monitor and manage their assigned risks.

All entities in the national public sector

Medium term

120. Managers are being hold accountable to the executive through regular reporting on risk management.

All entities in the national public sector

Medium term

121. Aim control activities at reducing the risks that can affect the achievement of the objectives of the organisation.

SIGEN

Medium term

122. Ensure that internal control activities are being implemented throughout each entity, at all levels and in all functions.

SIGEN

Long term

123. Ensure that internal controls include a range of detective and preventive control activities.

SIGEN

Medium term

124. Build on the existing annual audit risk map and guidelines for internal audit planning by establishing dedicated strategic integrity objectives and by identifying trends and systemic issues.

SIGEN

Medium term

125. Give management the ability to respond to integrity risks, in a cohesive and holistic way—through reporting on the status of integrity risks, trends and issues that are systemic across the public service.

SIGEN

Long term

126. Set up committees that are independent from the day-to-day activities of management and that regularly review the entity’s systems of audit, risk management and internal control.

All entities in the national public sector

Medium term

127. Give these committees the ability to assess and track each entity’s implementation of audit recommendations.

All entities in the national public sector

Long term

128. Strengthen the functional independence of the AGN by increasing the AGN’s power to select its own audit topics.

AGN / Legislative

Long term

129. Strengthen the functional independence of the AGN by clearly outlining the AGN’s independence and mandate in a specific organic law.

AGN / Legislative

Long term

130. Strengthen the follow-up and monitoring of audit recommendations through adding a selection of follow-up audits to their annual audit work program.

AGN

Short term

131. Strengthen the follow-up and monitoring of audit recommendations through organising annual self-assessments of entities by writing to the management of entities to ask for their assessment of the status of audit recommendation implementation.

AGN

Medium term

132. The AGN could increase its influence by setting an example of transparency, by providing the public with information on the AGN’s discretionary spending. This would serve as an example of transparency for the rest of the public sector. This could be done by providing access to information on the AGN’s website—similar to how information is provided by the Australian SAI.

AGN

Medium term

133. Formally extend the application of the disciplinary regime to all categories of public officials provided for by the LMREPN.

Legislative (after Treasury Attorney General Office proposal)

Medium term

134. Amend the Administrative Investigations Regulation in order to allow disciplinary offices not having a public official belonging to the permanent regime to exceptionally rely on temporary staff having the appropriate experience to carry out disciplinary proceedings.

Legislative (after Treasury Attorney General Office proposal)

Medium term

135. Discuss any additional proposals to overcome the challenges of the Administrative Investigations Regulation, such the need to ensure the functional independence of disciplinary proceedings as well as to improve the identification of elements indicating possible fiscal damage caused by the conduct under consideration.

Treasury Attorney General Office, disciplinary offices

Medium term

136. Improve harmonization and consistency between the existing fragmented integrity framework and the disciplinary system by:

• ensuring formal and substantial coherence between the Public Function Ethics Law under revision with the LMREPN and the Ethics Code by making explicit reference to these closely-related instruments and avoiding any inconsistency

• providing a more explicit link between the Public Function Ethics Law under revision with accountability mechanisms and responsibilities for breaches of the ethical rules.

Legislative (after Anti-corruption Office proposal)

Medium term

137. Introduce a duty to declare a conflict of interest situation in the Public Ethics Law under revision, whose breach could lead to disciplinary proceedings and sanctions (on top of other criminal sanctions the subsequent conduct may lead to), similarly to the what is already envisaged for not presenting asset declaration on time.

Legislative (after Anti-corruption Office proposal)

Medium term

138. Expand the typologies of sanctions and include additional ones having economic relevance such as fines or salary reduction.

Legislative (after Treasury Attorney General Office proposal)

Medium term

139. Consider introducing administrative sanctions for private entities involved in corruption cases.

Treasury Attorney General Office, Legislative Power

Medium term

140. Create a formal network of disciplinary offices to further support coordination and communication between and among them.

Treasury Attorney General Office

Short term

141. Elaborate a case management and follow-up system to foster communication and coordination with public entities on disciplinary issues.

Treasury Attorney General Office, Prosecutor Office for Administrative Investigations

Medium term

142. Establish a formal working group through a multi-party agreement with all the institutions have a role in disciplinary proceedings to enhance coordination, communication and mutual learning.

Treasury Attorney General Office,

Prosecutor Office for Administrative Investigations,

Anti-corruption Office,

Office of the Comptroller General

Short term

143. Improve the data-collection activity by collecting an increasing number of information, but also drawing trends according to criteria such as year, entity or sanctioned conduct.

Treasury Attorney General Office

Medium term

144. Regularly update and publish disciplinary-related data and statistics in the institutional website in different formats.

Treasury Attorney General Office

Medium term

145. Communicate aggregate information on the disciplinary system to citizens in a more engaging and interactive way in order to stimulate accountability and foster trust among citizens.

Treasury Attorney General Office

Medium term

146. Develop a system measuring the performance of the federal administrative disciplinary regime by means of KPIs on effectiveness, efficiency, quality and fairness.

Treasury Attorney General Office, Integrity Working Group (Mesa de Integridad)

Medium term

147. Ensure continuous training of disciplinary staff to improve the effectiveness and consistency of the disciplinary regime.

Treasury Attorney General Office’s National Directorate of State Lawyers (Dirección Nacional de la Escuela del Cuerpo de Abogados del Estado)

Medium term

148. Provide tools and channels guiding and supporting disciplinary offices in carrying out cases such as through guides, manuals, or a dedicated email addresses.

Treasury Attorney General Office

Medium term

149. Strengthen the existing framework on lobbying by extending its subjective scope beyond the executive branch to include the legislative branch.

Legislative (after Ministry of Interior proposal)

Medium term

150. Ensure the transparency of any kind of lobbying activity that may take place in practice and not restrict the definition to activities carried out through certain channels.

Legislative (after Ministry of Interior proposal)

Medium term

151. Align the definition of lobbying to any oral or written communication with a public official to influence legislation, policy or administrative decisions whereas the term public officials include civil and public servants, employees and holders of public office in the executive and legislative branches, whether elected or appointed.

Legislative (after Ministry of Interior proposal)

Medium term

152. Extend the competence of the co-ordination mechanism which is currently being developed for the uniform implementation of the transparency framework – the Roundtable for Institutional Coordination on Access to Public Information coordinated by the Ministry of Interior – to lobbying issues.

Legislative and Ministry of Interior

Medium term

153. Give the co-ordination mechanism for lobbying the following tasks:

• ensure the uniform implementation of the lobbying obligations

• provide technical assistance to those institutions lagging behind

• create and manage a single on-line portal, which would facilitate the consultation of information across branches of government, help communication of all the existing information, and eventually incentivise public scrutiny of citizens and interested stakeholders

• collect enforcement statistics from application authorities and publish them on the single platform.

Legislative and Ministry of Interior

Medium term

154. Establish dialogue with stakeholders and citizens by communicating and involving them throughout the on-going reform process of the lobbying regulation, but also in the following implementation phase. This could include:

• education and awareness raising campaigns addressing the negative perception of lobbying through information material and social media

• creation of a permanent advisory group to the co-ordination mechanism composed of public and private actors but also civil society representatives.

Ministry of Interior

Short and medium term

155. Increase the accountability and responsibility of the private sector and lobbyists by including a few explicit obligations for lobbyists in regulations clarifying their essential role in providing information which public entities will be then obliged to register and eventually publish on-line.

Legislative (after Ministry of Interior proposal)

Medium term

156. Promote specific dialogue with private stakeholders and underline their responsibility and role in making lobbying a transparent and professional activity. In this context, guidance for lobbyists on the regulations in relation to issues such as conflict-of-interest, preferential access, political activities and gifts could be provided.

Ministry of Interior

Medium term

157. Clarify the potential sanctions provided for by the legal framework and introducing different typologies such as fines or “name and shame” mechanism affecting the reputation of those breaching the rules.

Legislative and Ministry of Interior

Medium term

158. Review the requisites for political party recognition, stating individual requisites that cannot be replaced by the formation of electoral alliances, as a way to revalue public financing and guarantee a representative political arena.

Legislative (after Ministry of Interior proposal)

Medium/long term

159. Explore establishing a ‘votes or representativeness criteria’ when assigning campaign financing.

Legislative (after Ministry of Interior proposal)

Medium/long term

160. Establish formal procedures and define strict criteria to assign extraordinary contributions and how these should be spent and declared, in order to allow a stricter control on parties’ expenses.

Legislative (after Ministry of Interior proposal)

Long term

161. Ban government propaganda during all campaign periods and strictly regulate official advertising, detailing accountability mechanisms.

Legislative (after Ministry of Interior proposal)

Medium/long term

162. Consider prohibiting contributions in cash altogether and establishing a system based only on the use of bank accounts.

Legislative (after Ministry of Interior proposal)

Medium/long term

163. Allow contributions by legal persons (including unions) for campaign financing. This could assure a balance between different interests and promote a level playing field.

Legislative (after Ministry of Interior proposal)

Long term

164. Make sanctions applicable to candidates in addition to parties and campaign authorities, developing a co-responsibility system of sanctions. That would lead to candidates being held to account by citizens and the electoral justice system.

Legislative (after Ministry of Interior proposal)

Medium/Long term

165. Establish stricter regulations for electoral alliances, while prohibiting their dissolution before all campaign financing reports have been approved.

Legislative (after Ministry of Interior proposal)

Medium/Long term

166. State stronger penalties for parties that do not send their previous financial reports of campaigns in the established deadline (i.e. freezing their accounts).

Legislative (after Ministry of Interior proposal)

Medium/Long term

167. Clearly stipulate vote buying as an illicit practice prohibited by law.

Legislative (after Ministry of Interior proposal)

Short term

168. Consider implementing the Australian ballot system, uniform ballots printed and distributed by the government. This system would discourage clientelist practices.

Legislative branch (after Ministry of Interior proposal)

Long term

169. Specify sanctions for those who provide benefits to citizens with the aim to influence their votes and regulate the provision of material goods during campaigns.

Legislative (after Ministry of Interior proposal)

Medium/Long term

170. Detail regulations regarding the prohibition of official advertising and acts during campaigns.

Legislative (after Ministry of Interior proposal)

Medium/Long term

171. Sanction public officials that use public resources to promote or undermine the campaign of a given candidate, or force other public employees to participate in campaign activities.

Executive branch

Medium term

172. Strengthen the coordination and the sharing of information between Electoral Chamber and other relevant public agencies through Memoranda of Understanding (MOUs), for example with the IGJ and exchange more information and data with the Anticorruption office.

Executive and judiciary branches (CNE, OA, AFIP)

Short term

173. Increase the electoral audit staff to avoid capacity constraints and improve the operative activity of the financing control system.

Cámara Nacional Electoral (National electoral chamber, judiciary branch)

Short term

174. Create a register for campaign contributors and parties’ accounts accessible online, where all contributions and expenses are uploaded in real time.

Cámara Nacional Electoral (National electoral chamber, judiciary branch)

Medium/long term

175. Consider to make agreements with provinces and to encourage reforms at the provincial level.

National and provincial executives

Long term

176. When provincial elections are simultaneous with the national ones, promote that they comply with national electoral rules and justice. Provinces that have adhered to the regime of simultaneous elections would have to adopt the national political finance regulations.

National and provincial legislative branches

Long term

177. Allow provinces that have not adhered to simultaneous elections to adhere to national campaign financing rules when having subnational elections.

Provincial legislative branches

Medium/long term

178. Strengthen Access to information Law in the dimensions related to appeals and sanctions:

• specifying the consequences of appealing a decision of the Agency

• conferring it the power to require remedial actions of public authorities who systematically fail to disclose information

• granting legal immunity to the staff for acts undertaken in good faith in the exercise or performance of any power, duty or function under the Access to Public Information Law.

Legislative

Medium term

179. Promote effective participation through the establishment of general and formal regulations for the realization and development of hearings.

Legislative

Medium term

180. Ensure an effective implementation and enforcement of the Access to Information Law, establishing Access to Public Information Agencies and the Federal Council for Transparency, designing all authorities and providing them with the resources required to fulfil the respective mandate and responsibilities.

Legislative, Judiciary branches

Short term

181. Improve the coordination mechanism among Access to Information Agencies to ensure the uniform implementation of the transparency and access to information framework, for example by formalizing and having more joint meetings.

Ministry of Interior

Short term

182. Improve the effectiveness of tools for stakeholder engagement and participation, as well as their awareness among citizens by: formally allowing the reception of comments by e-mail; replying or addressing public comments; and making draft regulations public on official websites for both social control and constructive feedback to interested stakeholders.

Executive branch

Medium term

183. Create a whole-of-society communications unit under the Sub-secretariat of Integrity and Transparency and assign resources and responsibility to prepare and implement awareness-raising programmes.

Anti-Corruption Office

Long term

184. Develop a whole-of-society communications strategy for awareness raising that identifies the target audiences, key messages, communication channels and expected outputs. Identify within the communications strategy behavioural interventions that could support salience for moral norms and identities.

Anti-Corruption Office

Long term

185. Identify relevant ministries in the communications strategy on awareness raising activities and assign responsibilities for carrying out integrity and anti-corruption awareness raising campaigns for each through Memorandum of Understanding. Relevant ministries could include (but are not limited to) the Ministry of Labour, Employment and Security, the Ministry of Health, and the Ministry of Social Development.

Anti-Corruption Office

Long term

186. Develop an awareness campaign that communicates success stories from effective behaviour changes throughout the government, highlighting “everyday ethical public officials” who have helped change the way their team works for integrity in the Argentine government.

Anti-Corruption Office

Long term

187. Incorporate guidance on building a culture of integrity in firms into the wider business integrity guidance.

Anti-Corruption Office

Short term

188. Incorporate guidance on obtaining independent verification on the quality of business integrity programmes into the wider business integrity guidance.

Anti-Corruption Office

Long term

189. Sign an agreement between the Ministry of Education and the Anti-Corruption Office that clearly lays out the roles and responsibilities to cooperate on developing and mainstreaming education about public integrity into the Citizenship and Ethic s curriculum (Formación Etica y Ciudadana). The agreement should assign responsibility for implementation to Federal Council for Education.

Anti-Corruption Office

Ministry of Education

Federal Council for Education

Long term

190. Develop an action plan for creation and implementation of public integrity education materials.

Ministry of Education

Long term

191. Create a learning outcomes framework on public integrity, teaching and learning materials, and pilot these in select schools:

• the learning outcomes framework should identify the core knowledge, skills and attitudes desired for Argentine students about public integrity and anti-corruption

• the teaching and learning materials should be based on the learning outcomes framework, appropriately tailored to specific age groups and should include activities for students to apply their integrity knowledge in an applicable way.

Ministry of Education

Long term

192. Develop a monitoring and evaluation framework to assess the impact of integrity and anti-corruption education on students’ knowledge and skills.

Ministry of Education

Long term

193. Develop guidelines on including content related to integrity and anti-corruption in the ethics and citizenship component of the respective Jurisdictional Curriculum Designs. The guidelines could suggest developing modules on concepts of corruption and integrity, as well as strategies for cultivating an open classroom environment and managing difficult conversations.

National Institute of Teacher Education (INFD)

Long term

194. Encourage universities to sign up to the Poznan declaration and utilise the teaching resources made freely available by the UNODC Anti-Corruption Academic Initiative (ACAD).

Ministry of Education

Anti-Corruption Office

Short term

195. Partner with universities through Memoranda of Understanding to mainstream integrity and anti-corruption throughout their degree programmes.

Ministry of Education

Anti-Corruption Office

Long term