copy the linklink copied!2. Responsibilities

Abstract

This chapter provides a commentary on the principle of responsibilities contained within the OECD Recommendation of the Council on Public Integrity. It describes how to establish clear responsibilities at all relevant levels for designing, leading and implementing the elements of the integrity system, with appropriate capacities and resources. It includes an analysis of the types of mechanisms that can ensure horizontal and vertical co-operation within an integrity system. In addition, the chapter addresses the two commonly faced challenges of entrenched silos and competition among entities that have been assigned integrity functions.

    

copy the linklink copied!2.1. Why responsibilities?

Assigning clear responsibilities to the actors in the integrity system is necessary to ensure co-operation, avoid overlaps and prevent fragmentation. Responsibilities include developing, implementing, monitoring and evaluating integrity standards and tools, and are carried out by actors across the whole-of-government (legislative, executive and judicial) as well as across levels of government (national and sub-national). Responsibilities for public integrity are also found within each public sector organisation. All public officials at all levels of government are expected to carry out their duties in the public interest.

To prevent fragmentation and overlap in the public integrity system, the OECD Recommendation on Public Integrity recommends that adherents “clarify institutional responsibilities across the public sector to strengthen the effectiveness of the public integrity system, in particular through:

  1. a. establishing clear responsibilities at the relevant levels (organisational, sub-national or national) for designing, leading and implementing the elements of the integrity system for the public sector;

  2. b. ensuring that all public officials, units or bodies (including autonomous and/or independent ones) with a central responsibility for the development, implementation, enforcement and/or monitoring of elements of the public integrity system within their jurisdiction have the appropriate mandate and capacity to fulfil their responsibilities;

  3. c. promoting mechanisms for horizontal and vertical co-operation between such public officials, units or bodies and where possible, with and between sub-national levels of government, 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[1]).

copy the linklink copied!2.2. What are responsibilities?

Taking a systemic approach to promoting integrity and combating corruption requires understanding the wide range of entities and actors which, when combined, make up an integrity system. Moreover, it involves understanding their mandates and capacities, as well as their functions in the overall system. In line with their relevant political and legal context, each government (national and sub-national) and public organisation should have clear roles and responsibilities across the integrity system. The following are essential for a successful exercise of responsibilities and co-operation:

  • Responsibilities for designing, leading and implementing the integrity system at each level are clear.

  • Appropriate resources and capacities are in place to fulfil organisational responsibilities.

  • Mechanisms for horizontal and vertical co-operation are established and effective.

2.2.1. Responsibilities for designing, leading and implementing the integrity system at each level are clear

An integrity system, whether at the government (national and sub-national) or organisational level, includes different actors with responsibilities for defining, supporting, controlling and enforcing public integrity. These include the “core” actors, such as the institutions, units or individuals responsible for implementing integrity policies. The system also includes “complementary” actors, whose primary purpose is not to directly support the integrity system but without whom the system could not operate (including functions such as finance, human resource management and public procurement) (OECD, 2009[2]).

For both the core and complementary actors there are a number of integrity functions, as laid out in Table ‎2.1. Specific assignments of responsibility depend on the institutional and jurisdictional setup of a country. For example, some governments will place core responsibilities for integrity with a central government body or other key ministry, whereas others will make this the responsibility of an independent or autonomous body (Box ‎2.1). Complementary integrity functions will be assigned to the institutions responsible for education, industry, civil society and human resource management, as well as supreme audit institutions, regulatory agencies, and electoral bodies. Regardless of where the responsibilities are assigned, governments should ensure that the actors have the appropriate level of authority to carry out the functions.

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Table ‎2.1. Integrity functions

System

Culture

Accountability

• Assigning clear responsibilities

• Ensuring mechanisms to support horizontal and vertical co operation

• Designing and implementing the integrity strategy or strategies

• Monitoring and evaluating the integrity strategy or strategies

• Setting integrity standards

• Integrating integrity into human resource management (e.g. assessing the fairness of reward and promotion systems) and personnel management (e.g. integrity as criterion for selection, evaluation and career promotion)

• Building capacity and raising the awareness of public officials

• Providing advice and counselling

• Implementing measures to cultivate openness

• Opening channels and implementing mechanisms for complaints and whistleblower protection

• Raising awareness in society

• Conducting civic education programmes

• Implementing measures to support integrity in companies

• Implementing measures to support integrity in civil society organisations

• Assessing and managing integrity risks

• Applying internal audit

• Implementing enforcement mechanisms

• Applying independent oversight and audit

• Applying access to information and implementing open government measures

• Engaging stakeholders across the policy cycle

• Preventing and managing conflict of interest

• Implementing integrity measures for lobbying

• Implementing integrity measures in financing of political parties and election campaigns

Source: Adapted from (OECD, 2009[2]; OECD, 2017[1]).

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Box ‎2.1. Assigning responsibility for public integrity to a central institution versus an independent body or bodies

Some countries have established an independent anti-corruption institution, assigning it responsibility for overseeing a number of integrity functions. When effective, this approach can reduce gaps and potential overlaps. For example, the National Transparency Authority (NTA) in Greece brings former institutions and agencies under one organisation, with responsibilities for enhancing integrity, transparency, and accountability in public organisations; for preventing, detecting, and responding to fraud and corruption in both the public and private sectors; for achieving measurable results in the fight against corruption; and for building capacity and raising awareness regarding these actions. The establishment of the NTA aims to end overlapping competencies, co-ordination impediments, and fragmentation.

Countries can also establish independent organisations with specific integrity functions, such as overseeing the conflict-of-interest regime, the lobbying or political finance system, or other technical areas such as fraud prevention. This enables the government to develop and concentrate expertise and resources in specific technical areas, which can lead to improved implementation. Examples of specialised bodies include the Serious Fraud Office in the United Kingdom, the Office of the Commissioner of Lobbying in Canada, or the High Authority for Transparency in Public Life (HATVP) in France. For example, the HATVP is an independent administrative authority responsible for promoting the probity and exemplarity of public officials. Its independence is guaranteed by the appointment and functioning of its college and its administrative and financial autonomy. It is responsible for monitoring as well as tracking the assets of nearly 16 000 public officials to prevent conflicts of interest and to monitor post-public employment restrictions and lobbying activities.

Experience has shown that independent anti-corruption bodies are not always the solution. In particular, while independence can protect these bodies from political pressure, they can fail to enact effective change because they are not embedded in the organisational culture. Moreover, while independent organisations can help clarify responsibilities, there is a risk that other public organisations may relinquish their own responsibilities for public integrity, relying instead on the independent body to carry out all integrity functions. In light of these challenges, some countries adopt a “mainstreamed” approach where existing public bodies, such as a central government office or the institution responsible for public administration, are assigned responsibility for overseeing different integrity functions, with each public organisation then responsible for implementing a tailored version internally. In certain countries a combination exists, with independent bodies assigned specific integrity functions while other integrity functions are mainstreamed in public organisations.

Source: For Greece, adapted from inputs shared by the National Transparency Authority. For France, adapted from inputs shared by the High Authority for Transparency in Public Life.

Assigning responsibilities for integrity functions also depends on the jurisdictional setup of the country, taking into account which level of government has competency for the specific policy area. For example, in some federal countries, education is the responsibility of sub-national governments; therefore, responsibilities for developing and implementing civic education programmes for public integrity are found at the sub-national level.

When assigning integrity responsibilities at the local level, there are several issues to take into account. On the one hand, local governments face specific integrity risks: conflict-of-interest situations for example are more likely due to proximity to the community, with family and network ties a typical characteristic of the operational environment. On the other hand, local governments can face capacity limits in human, financial and technical resources, making it difficult to assign responsibility to an institution, unit or individual for all the functions in Table ‎2.1. An effective approach therefore requires local governments to weigh their capacity constraints against integrity risks and assign responsibilities accordingly (Box ‎2.2). At a minimum, dedicated processes for managing conflict of interest and basic internal control functions should be established. As additional functions may be too resource-intensive to operate in every municipality, it may be prudent to assign some integrity functions at the regional or national level. For example, an already existing whistleblowing mechanism at the regional level could also cover local governments. Making use of formal and informal networks, both at the horizontal and vertical levels, can also help identify where responsibilities should be allocated (see Section ‎2.2.3). The core consideration is to ensure that regardless of the level of government, responsibilities for the integrity functions are clearly assigned. 

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Box ‎2.2. Assigning local integrity responsibilities in the Netherlands and France

The following are examples of how local governments assign integrity functions in line with their capacity and resource levels.

The Netherlands

Most cities and communities in the Netherlands develop and implement their own local integrity strategy. In the City of Amsterdam, the Integrity Office (Bureau Integriteit - BI) is responsible for promoting integrity with the local political leaders and managers, the whole city administration, and service providers and businesses. The mandate of the BI covers ethics and legal advice, training, risk assessments, disciplinary procedures and integrity investigation. This office is also the contact point for whistleblowers to report misconduct and breaches of integrity rules. The staff is specially trained to provide integrity advice, and usually has had extensive experience working for the administration of the City of Amsterdam.

France

In France, some major cities and regions have designed and implemented an integrity policy and specific functions. Since 2014, the City of Paris has an ethics commission responsible for conflict of interest and asset disclosure, gifts and gratuities, interpretation and application of the code of conduct, and counselling and advice. In 2014, the City of Strasbourg assigned a similar role to an independent ethics officer for promoting the integrity of political leaders and managers, as well as administration of the municipality. Regions that have adopted a comparable approach include Provence-Alpes-Côte d’Azur. The 2016 revision of civil service status introduced a right to access ethics counselling in public organisations for all civil servants regardless of their status. The organisations must assign this responsibility, internally or externally. However, there are close to 35 000 municipalities, among which more than 90% count below 5 000 inhabitants and have more limited financial and human resources. Consequently, some of the integrity functions listed in Table ‎2.1 are either the responsibility of a local management centre, general director or other designated person(s) of the administration, or they are not assigned locally and rely upon other actors in the integrity system.

Source: For the Netherlands, (City of Amsterdam, 2019[3]). For France, (Mairie de Paris, 2018[4]); (City of Strasbourg, 2019[5]); (Government of France, 2016[6]).

With regard to public sector organisations, not all the functions outlined in Table ‎2.1 will fall within the remit of the organisation. For example, only a few organisations will have the mandate to ensure integrity in elections and political party financing, or carry out education about public integrity in schools. However, a number of key functions are applicable to all public sector organisations, regardless of the mandate; these are identified in Table ‎2.2, along with the position or unit normally responsible for their implementation. It should be clear which unit or individual is responsible for what. The necessary resources should be assigned, and the appropriate co-operation mechanisms established (as discussed below).

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Table ‎2.2. Actors and integrity roles at the organisational level

Position or unit

Integrity role

Highest officer

Ultimately responsible for the agenda, implementation and enforcement of integrity policies for the entire organisation

Responsible for adhering to and demonstrating the highest levels of commitment and conduct for public integrity

Management

Responsible for implementation of integrity policies and for promoting ethical behaviour within the organisational units for which they are responsible

Responsible for adhering to and demonstrating the highest levels of commitment and conduct for public integrity

Integrity officer

Integrity co-ordinator

Compliance officer

Integrity policy staff

A wide range of different types of officers who fulfil roles relating to: design, support and advice, implementation, co-operation, and enforcement of integrity policies

Internal audit and control

Responsible for establishing an internal control system and risk management framework to reduce vulnerability to fraud and corruption and for ensuring that governments are operating optimally to deliver programmes that benefit citizens

Finance

Responsible for taking care of vulnerable actions around purchasing, tenders, and expense claims in a transparent manner

Legal

Responsible for formulating administrative-legal policy, providing advice based on relevant legislation and the drafting of delegation and mandate regulations, and applying an integrity lens to ensure policies comply with integrity standards

Human resource management

Responsible for establishing procedures and providing advice concerning recruitment and selection, job descriptions, performance and assessment interviews, disciplinary research, sanctions and organisational culture, and applying an integrity lens to ensure processes comply with integrity standards

Communication / Information

Responsible for communication concerning integrity standards and procedures

Security / ICT

Responsible for setting up physical and ICT security

Confidential advisor

Responsible for advising employees on and coaching them in the internal reporting process in the event of suspected integrity violations

Source: Adapted from (Hoekstra, 2015[7]).

2.2.2. Appropriate resources and capacities are in place to fulfil organisational responsibilities

To carry out its functions, each component of the integrity system requires sufficient financial, technical and human resources that are commensurate with its mandate, as well as the appropriate capacities to fulfil its responsibilities.

Taking a systems perspective implies that reducing the resources of one part of the system below a sufficient level for effective operations not only will hamper that particular function’s ability to achieve its mandate, but also will likely have spillover effects across the entire system, affecting the overall achievement of the desired goals. A second consideration is the need to ensure that all actors have resources assigned to ensure co-operation, including partnering with others, attending committee meetings and contributing to common databases. When resources are constrained, there tends to be a bias towards concentrating them on achieving vertical operational delivery rather than horizontal collaborative working. This can reinforce silos and lead to fragmentation or gaps in the integrity system.

To effectively implement integrity policies at the organisational level, public organisations also need to ensure that their human resource management is modern and focused on bringing in the expertise that closely matches their needs. As the integrity-related skill sets become increasingly specialised, technical and digital (from legal to investigative background, IT, public management, accounting, finance, sectoral knowledge, support functions, etc.), so too must the employment frameworks that regulate the workforce. Given the scarcity of many of the skill sets required in public integrity organisations, a number of approaches can be used to make the most of them, including the following:

  • Talent pools can be established centrally and used to help individual organisations access skills that they may be unable to bring in on a permanent basis.

  • Rotation programmes can be established across various actors in the system, systematically trading employees for specific periods between, for example, local integrity offices. At the same time, a certain degree of labour stability and job security is important to build knowledge and expertise and reduce the learning curve regarding co-ordination among bodies.

  • Continuous and lifelong training and development can be prioritised (for more, see Chapter 8).

  • Monitoring the quality and quantity of human resources for integrity systems across levels of government to identify bottlenecks and areas for improvement.

2.2.3. Mechanisms for horizontal and vertical co-operation are established and effective

With regards to co-operation among different institutional actors with regard to responsibilities, the main challenge is to ensure that each, regardless of its level of independence, works towards a commonly understood and shared objective to ensure the impact of integrity policies. Moreover, co-operation among actors responsible for various integrity instruments and functions supports the identification of synergies, and therefore helps to avoid overlaps or gaps (OECD, 2009[2]). The focus is on “maximis[ing] the policy and operational advantages of multiple integrity-related bodies, while also avoiding the worst risks of ‘ad hocery’, jurisdictional gaps, imbalances between positive and coercive integrity strategies, potentially unhealthy competition, negative conflict, and confusion in the eyes of citizens and end-users” (Sampford, Smith and Brown, 2005[8]).

Both vertical co-operation among different levels of government and horizontal co-operation across line ministries, agencies and functional units are essential to mainstream integrity policies (Box ‎2.3). These co-operation mechanisms can develop in two ways (although there may be a grey area in which a tool could fall into both categories):

  • Formally, through structures and procedures created for the explicit purpose of ensuring co-operation within an integrity system. This may be the case when a joint agency is created; when a commission is established to bring together the various actors in the system; or when an integrity office is established in ministries or agencies.

  • Informally and voluntarily, through integrity networks, ad hoc working groups, or other bottom-up initiatives such as online platforms for knowledge management.

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Box ‎2.3. Formal and informal co-operation mechanisms in Canada

In Canada the central agency, the Treasury Board Secretariat, hosts two communities of practice:

  • the Interdepartmental Values and Ethics Network

  • the Senior Officers for Internal Disclosure Group (whistleblowing)

These communities of practice meet regularly, and mutually benefit from sharing good practices and lessons learned.

The communities and their regular exchanges provide the Treasury Board Secretariat with an informal means of keeping up with emerging issues and evolving challenges. Their input can also help shape integrity policies as well as the Secretariat’s awareness-raising and communications activities.

Source: Adapted from inputs shared by the Treasury Board Secretariat.

The scope and approach to co-operation will vary depending on the specific context of how governments manage public integrity and the system of governance in which integrity is embedded. A first question to answer may be “Co-operation for what?” as different functions may require different approaches. A second would be “Co-operation among whom?” – in particular when considering core versus complementary functions, which may also require varying approaches (OECD, 2009[2]). For example, co-operation among core functions may require a heavier, more formalised approach, whereas that among complementary functions may be less regular and therefore require use of informal mechanisms.

Governments can use various mechanisms to ensure co-operation:

  • formal mechanisms to ensure coherent decision making and enable support, communication and information sharing.

  • informal mechanisms to enable horizontal exchange and support.

  • mechanisms tailored to national and sub-national levels in line with the country’s governance framework.

Formal mechanisms to ensure coherent decision making and enable support, communication and information sharing

Co-operation within an integrity system will depend in part on the legal and governance arrangements in place to manage it. A particular consideration is to centralise the co-operation function. In many countries, this function is located at a visible and central place in the government to signal its importance, such as in the president’s office, or under the council of ministers. In other countries, the function may be located in an independent body such as an integrity body or supreme audit institution. Regardless of the location, this role requires some degree of influence and authority as well as clear hierarchical relationships with other individual organisations.

A separate committee can also be established, supported by the appropriate resources and expertise. A committee may include officials from core anti-corruption agencies, key line ministries, other branches of government, and civil society. For example, Korea has an anti-corruption policy co-ordination body composed of representatives from ten government agencies (ministries and supervisory bodies) to ensure communication among their institutions. Another example can be found in Mexico, where the overarching National Anti-Corruption System engages a wide range of actors across government, and includes communication tools and information-sharing mechanisms (see the OECD Integrity Review of Mexico (OECD, 2017[9]) for a detailed overview).

In addition, co-operation requires effective communication tools and the sharing of key information across bodies. Those tasked with co-operation can implement communication strategies to ensure that all actors in the system (including the private sector and civil society) are informed of the integrity policies in place. Regular use of a communications strategy can also strengthen management’s commitment and maintain ongoing co-operation. Similarly, online portals and administrative databases can be used to share information across organisations, furthering the potential for effective co-operation. Interoperable administrative databases enable public organisations to exchange up-to-date information, strengthen cross-checking and automate alerts (such as potential conflicts of interest, omissions in disclosures, risks and fraud). For example, in some countries interoperable databases may be used to cross-check tax administration data with interest and asset declarations, thereby easing detection of potential omissions in declarations or conflicts of interest.

Informal mechanisms to enable horizontal exchange and support

Across government ministries, whether at the national or sub-national level, informal co-operation mechanisms may take the form of integrity networks in which managers or employees are designated participants (see the examples from Sweden and Germany in Box ‎2.4). These networks rarely have decision-making capacities, but they can help enhance the effectiveness of integrity systems by sharing good practices, information, and lessons learned. Moreover, they can ensure that integrity remains on the agenda of public sector institutions. These informal mechanisms may however require some degree of formal support to ensure that they function appropriately (see the example from Austria in Box ‎2.4).

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Box ‎2.4. Integrity networks in Austria, Germany, and Sweden

The Austrian Network of Integrity Officers

To mainstream integrity into the public sector, Austria has established the Network of Integrity Officers, which aims to place integrity officers in various federal institutions (e.g. ministries). Tasks performed by the officers include:

  • performing advisory services for employees and senior officials

  • circulating information on integrity and awareness raising

  • providing training

  • analysing the risk of corruption

  • collaboration and experience sharing

  • serving as the focal point for compliance-related issues.

The Federal Bureau of Anti-Corruption is responsible for managing the network, generating and collecting expertise on the topic of integrity, and providing basic training and training materials to the officers.

The German network of contact persons for corruption prevention

In Germany, the lead federal ministry for corruption prevention and integrity is the Federal Ministry of the Interior, Building and Community. Since preventing corruption does not involve having a supervisory role over other ministries, co-operation is essential in order to reach a common understanding of integrity policies and comprehensive standards for their implementation.

For the German federal administration, the Joint Rules of Procedure of the Federal Ministries regulates (among other issues) co-operation within the federal government. Article 19 stipulates that “in matters affecting the remits of more than one Federal Ministry, those Ministries will work together to ensure that the Federal Government speaks and acts consistently”.

In practical terms, co-operation happens through a network of contact persons for corruption prevention that meets frequently. The network also develops guidelines, handbooks and recommendations for implementing the Federal Government Directive concerning the Prevention of Corruption in the Federal Administration.

The Network against Corruption for Swedish State Agencies

The Swedish Agency for Public Management hosts the Network against Corruption for Swedish State Agencies. Delegates participating in the network include heads of administrative departments and heads of legal departments. The network meets four times a year, and each meeting usually gathers close to 100 agencies.

The purpose of the network is to share experiences, learn about good examples and take part in the production of handbooks, reports, and other publications of the Swedish Agency for Public Management on anti-corruption measures, internal control, and efficiency.

Source: (IBN, 2020[10]); Germany: information provided by the Ministry of the Interior; Sweden: information provided by the Swedish Agency for Public Management.

Formal support to these networks affords visibility, enhances the legitimacy of the function of ethical advisor, and sustains the activity of the network. For example, the Polish Civil Service Department chairs and supports the activity of a network of ethics and integrity advisors. This support has contributed to promoting and generating awareness of the ethical advisors’ role (appointment of an ethical advisor is not mandatory in the Polish civil service), and has identified a need to provide ethical guidance and consultation mechanisms in public sector offices. As a result, the appointment of ethical advisors has increased in government administrations.

Other mechanisms such as workshops, forums and common communication strategies can also support informal collaboration among organisations:

  • Workshops can develop practical tools and instruments. Where a tool can be applied in multiple organisations, it makes sense to share the development to ensure efficiency and commonality.

  • Pools are used to gather scarce expertise that can be shared across participating organisations. For example, investigators, trainers or policy advisers for integrity matters can be shared among various smaller organisations that may lack the capacity to employ such experts on their own.

  • Forums are venues where integrity officers from various organisations can come together and share knowledge, experience, and lessons learned. These can be held in person or in a virtual environment.

  • The “Megaphone” is used when organisations partner to communicate with the public and/or at political levels to influence the design of integrity policy. Organisations together can speak with a louder and more persuasive voice when it comes time to influence opinion (Hoekstra, 2015[7]).

Mechanisms tailored to national and sub-national levels in line with countries’ governance framework

Regions and municipalities are often diverse, with different cultures, levels of socio-economic development, and levels and issues of corruption. This diversity can result in integrity policies that differ from the national level, as well as from one region to another. While there is no need for alignment, avoiding gaps and incoherence is desirable. To overcome inconsistencies, governments can assign clear responsibilities for integrity policies, as well as ensure that open lines of communication and measures for co-operation are in place. Mechanisms for building consistency will vary depending on the governance systems established by that country.

In federal states, the federal government rarely has any jurisdiction over public integrity in sub-national governments. Here, moving towards consistency across standards may rely on voluntary co-operation and information sharing. Regular meetings through a formal or informal integrity committee or commission can be used by federal countries to promote exchange of information and support coherence among integrity standards (Box ‎2.5). Such co-operation mechanisms focus on ensuring that the integrity systems at the sub-national level are coherent with the national level, while responding to the specificities of the sub-national level.

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Box ‎2.5. Co-operation mechanisms in federal countries

The following examples from Belgium and Canada provide an overview of how federal governments support informal co-operation between it and regional governments.

Belgium – Consultation Committee

In Belgium, a Consultation Committee was established in the Chancellery of the Prime Minister to discuss good governance issues requiring co-operation across different levels of government. The committee, which meets once a month, consists of the ministers from the federal government and the ministers from the governments of the communities and regions. The secretariat of the Consultation Committee is responsible for the administrative and logistical tasks of the committee, such as preparing and sending meeting agendas, organising meetings, and distributing the results of the decisions made. The secretariat also oversees the monitoring process for co-operation agreements among the different entities and publishes co-operation agreements involving the federal government.

Canada – Canadian Conflict of Interest Network

The Canadian Conflict of Interest Network (CCOIN) was established in 1992 to formalise and strengthen contact across the different areas of government regarding conflict-of-interest policy. The commissioners from each of the ten provinces and the three territories, along with two from the federal government representing the members of parliament and the senate, meet annually to disseminate policies and related materials, exchange best practices, and discuss ideas on ethics issues and the viability of policies.

Source: (FPS Chancellery of the Prime Minister, 2019[11]; Office of the Conflict of Interest and Ethics Commissioner, 2019[12]).

Some central governments develop guidelines and instruments (such as government-wide codes of conduct and conflict-of-interest regulations) that are used to support the other levels of government in interpreting these provisions and implementing them. The legal framework can also be used to explicitly designate co-operation mechanisms to address gaps that may emerge. In these cases, central governments can be mandated to provide guidance on how to establish sub-national commissions, measures to communicate between national and sub-national levels, and tools to support coherence across sub-national integrity strategies (Box ‎2.6). The goal of these measures is not to apply a “one-size-fits-all” approach, but rather to support sub-national levels of government in implementing integrity policies that are consistent and coherent for individuals, regardless of the region.

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Box ‎2.6. Regional Moralisation Commissions in Colombia

Each department in Colombia has set up a Regional Moralisation Commission (Cómision Regionales de Moralización, or CRM), which is responsible for supporting implementation of the National Anti-corruption Policy as well as for sharing information and co-ordinating local initiatives among the bodies involved in the prevention, investigation and punishment of corruption.

The CRMs are composed of the regional representatives of the Attorney General’s Office, the Colombian Treasury Inspector’s Office, the Sectional Council of the Judiciary and the Office of the Departmental, Municipal and District Treasury Inspectors. According to Law 1474 of 2011, attending these monthly meetings is mandatory and may not be delegated. Furthermore, other entities can be called on to be a part of the Regional Moralisation Commission, if considered necessary, namely: the Ombudsman’s Office, the municipal representatives, the specialised technical police forces, the governor, and the President of the Department Assembly. In order to promote citizen participation and social control over the CRMs, at least one quarterly meeting must be held with civil society organisations to address and deal with their requests, concerns, complaints and claims.

Consistency among departments is favoured by a set of guidelines elaborated by the National Moralisation Commission (Comisión Nacional de Moralización, or CNM), which are complemented by model documents the CRMs may use to carry out their Action Plans. These include the Internal Regulation, the Biannual Management Report and the Attendance List. Such guidelines also contain an overview of main challenges and good practices from the CRMs.

Source: Colombian Law 1474 of 2011; Operational guidelines for the Regional Moralisation Commissions in Colombia (in Spanish), www.anticorrupcion.gov.co/SiteAssets/Paginas/lineamientosCRM/Cartilla_CRM.pdf (accessed 3 February 2020).

copy the linklink copied!2.3. Challenges

The main challenge associated with assigning clear responsibilities for integrity is to foster the overall coherence and implementation of the integrity system. Strengthening coherence requires ensuring that responsibilities do not overlap, are not fragmented, and do not remain unimplemented. Addressing that challenge entails establishing both vertical and horizontal co-operation mechanisms and assigning resources, as discussed in Sections ‎2.2.3 and ‎2.2.2, respectively. It also requires establishing oversight mechanisms to identify potential gaps, which is further discussed in Chapter 12. While co-operation mechanisms address the challenges associated with responsibilities, they themselves also present challenges – the most prominent being entrenched silos and competition among entities.

2.3.1. Entrenched silos

Operating in silos can pose a challenge for many public organisations. A number of factors can contribute to silos, including hierarchical structures, a focus on key policy areas, and mode of delivery (e.g. thinkers, planners, doers). Silos are not always problematic; they can encourage efficiencies and optimisation of processes, and contribute to building core expertise (Riberio, Giacoman and Trantham, 2016[13]). Silos however become a challenge when they inhibit units or organisations from working across functional areas to effectively address overarching policy areas, such as public integrity.

To address the challenges related to silos, governments can take a number of steps. A strategic approach that lays out the public integrity objectives of the organisation or government, with outcomes and assigned responsibilities, helps pinpoint where potential silos may exist, while providing incentives for units or organisations to co-operate as they perform activities and formulate common objectives. Moreover, the creation of formal and informal co-operation networks can help strengthen collaboration among different organisations, and increase opportunities for co-operation. Examples of formal and informal communities, networks and co-operation mechanisms are discussed in Boxes 2.3, 2.4 and 2.5, respectively. However, governments can also consider using exchange-of-information tools. These may be formal or informal, including informal discussions and exchange of experience, memorandums of understanding and interoperable databases that allow administrations to cross-check available data in the public sector. Benefits resulting from co-operation mechanisms include increasing the efficiency of procedures by pooling resources and sharing information, as well as increasing knowledge exchange.

2.3.2. Competition among entities

Competition is a second challenge that undermines co-operation. Competition can be understood as a situation where organisations compete for limited resources, or as one based on social comparison – that is, a need to surpass peers (Wang, Wang and Liu, 2018[14]). Healthy competition does have several benefits, including innovation and improved efficiency. However, it can undermine policy outcomes as well as co-operation.

Striking the right balance of competition is therefore essential for supporting public organisations in co-operating with each other, while also pursuing innovations and efficiencies. Maintaining co-operation requires a balance between costs and benefits, where organisations reap more benefits from co-operating than costs (Stewart, 2015[15]). However, effective co-operation over the long term can lead to a complacency that undermines it. While it is impossible to guarantee co-operation in the long run, finding the right benefits can greatly support it; on the other hand, if there are too many incentives to co-operate, then defection is encouraged (Stewart, 2015[15]). For some countries, reducing competition among entities relies upon strengthening administrative co-ordination. In France, the French Anti-Corruption Agency contributes to administrative co-ordination, centralising and disseminating information to help prevent and detect acts of corruption, influence peddling, extortion, unlawful taking of interest, embezzlement and favouritism. The agency concludes co-operation agreements and memoranda of understanding with other public entities involved in the fight against corruption, formalising co-operation relations among entities and clarifying their respective scopes of action. This has helped facilitate and foster exchange of information and synergies.

References

[3] City of Amsterdam (2019), Bureau Integriteit - Gemeente Amsterdam, https://www.amsterdam.nl/bestuur-organisatie/organisatie/bestuur-organisatie/bureau-integriteit/ (accessed on 11 September 2019).

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