copy the linklink copied!3. Strategy

Abstract

This chapter provides a commentary on the principle of strategy contained within the OECD Recommendation of the Council on Public Integrity. It describes how to develop a strategic approach to public integrity that is evidence-based and aimed at mitigating public integrity risks. It focuses on a risk-based approach to setting strategic objectives and priorities for the public integrity system; developing benchmarks and indicators; and collecting relevant data on the system’s implementation, performance and effectiveness. In addition, it addresses the challenge of balancing rules-based and values-based approaches to integrity strategies.

    

copy the linklink copied!3.1. Why strategy?

A strategy for public integrity is essential for supporting a coherent and comprehensive integrity system. However, it is not an end in itself but rather a means to an end. The process of strategy development is therefore as important as the resulting strategy. An inclusive and rigorous strategy development process can help select relevant strategic objectives that are meaningful to citizens and businesses; prioritise and sequence actions in an open manner to address the most crucial integrity risks; and provide the necessary evidence for the interventions that are most cost-effective and likely to have the greatest impact. Strategies are also a way of demonstrating commitment and can be used to establish institutional responsibilities. If however strategies do not lead to visible gains – for example, due to inadequate implementation – they can at best become irrelevant and at worst erode public confidence in national authorities.

The OECD Recommendation on Public Integrity states that adherents should “develop a strategic approach for the public sector that is based on evidence and aimed at mitigating public integrity risks, in particular through:

  1. a. Setting strategic objectives and priorities for the public integrity system based on a risk-based approach to violations of public integrity standards, and that takes into account factors that contribute to effective public integrity policies;

  2. b. Developing benchmarks and indicators and gathering credible and relevant data on the level of implementation, performance and overall effectiveness of the public integrity system” (OECD, 2017[1]).

copy the linklink copied!3.2. What is a strategy?

In essence, a strategic approach for public integrity is one that is formalised and run through existing government procedures for strategy development in consultation with relevant stakeholders; is based on evidence; takes a system-wide perspective; and focuses on the key integrity risks. To foster the conditions for increasing ethical behaviour, integrity strategies increasingly balance values-based with rules-based approaches. A comprehensive approach can result in many strategic objectives aimed at reducing integrity risks that are mainstreamed into existing government strategies. Some countries opt for a single national integrity or anti-corruption strategy, though a strategic approach does not necessitate a single strategy document. Regardless of the form, a strategic approach to public integrity contains all of the following elements:

  • problem analysis: risk identification, analysis and mitigation

  • strategy design: prioritising the 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.

3.2.1. Problem analysis: Risk identification, analysis and mitigation

The risk-based approach has implications for strategy development, implementation, monitoring and evaluation. In particular, it emphasises a problem analysis stage that identifies and analyses the integrity risks that are most harmful to public integrity. Inherent in this approach is the realisation that not all problems can be tackled at once, so prioritisation is necessary. A solid evidence base allows an informed choice as to which strategic objectives should be prioritised.

As the problem analysis process includes identifying, analysing and mitigating risks, it draws on the risk assessment process covered in Chapter 10, which deals with risk management. The two processes, however, are not the same. Risk management has a technical focus; it is used to design and adapt controls to address risks to public integrity. The problem analysis phase involves using the results of the risk assessment process to inform an integrity strategy for the national, sub-national, sectoral or organisational level. A problem analysis process could also reasonably cover risks to the whole-of-government or whole-of-society, and identify relevant mitigation strategies to address these areas.

Thus the problem analysis phase can draw inspiration from key elements of risk management – namely, the risk assessment process, including risk identification, analysis, and mitigation:

  • risk identification – identifying types of integrity risks (bribery, nepotism, absenteeism, conflict of interest violations, procurement fraud, etc.) in a given process or system, based on a risk model

  • risk analysis – estimating the likelihood and impact of each risk, among other factors

  • risk mitigation – based on the results of the risk analysis, implementing measures to treat the risk and monitor and evaluate the measures.

The problem analysis phase aims at identifying problems and their causes, as well as challenges and opportunities for reform. At a minimum, it identifies specific types of relevant integrity breaches, the actors likely to be involved, and the expected likelihood and impact if the risk materialises. Problem analysis is used to select the most effective risk mitigation measures (activities) later, when the strategy and its action plan are developed.

Many of the available methods and techniques for conducting problem analysis are time- and resource-intensive, and may require specialist skills. As a first step in the process, the team in charge needs to formulate a realistic plan for data collection to identify supporting evidence (UNODC, 2015[2]). A key choice at the outset is whether to outsource the problem analysis work, conduct it in-house, or combine the two approaches. There are advantages and disadvantages to each option, depending on the context, resources and skills available, and scope of the exercise (see Table 3.1). Regardless of the option chosen, a proper problem analysis takes time. Relevant data are rarely readily available, and it is also crucial to engage and consult various stakeholders – both state and non-state actors – in the design, implementation and output of the analytical work. This matters for validity, take-up and accountability.

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Table 3.1. Benefits and limitations of in-house versus outsourced problem analysis

Option 1: In-house public officials in ministries and agencies carry out the analysis

A working group comprised of public officials from the key institutions with complementary skills and expertise, and potentially external experts as well, led by the main institution, can be established to steer the analysis process. Proper design of the analysis, including defining the right questions and information sources in order to have an unbiased and informative picture, is the key to success in internal analysis.

Benefits: better internal insights of the problems or gaps, on-the-job enhancement of the expertise of public officials involved in the process.

Limitations: more time-consuming (public officials usually have other tasks to fulfil alongside the analysis), fewer opportunities to apply sophisticated analysis methods, greater risk of bias.

Option 2: Outsourced

An external service provider is procured to carry out the analysis. The ministry or agency has to develop the terms of reference (TOR) to properly target the scope and define the methodology; this requires expertise.

Benefits: an opportunity to use more sophisticated or complex methodological approaches to get harder evidence in cases where in-house expertise is not available; can be faster than in-house analysis.

Limitations: less in-house ownership; limited information on acute problems not visible to an external analyst; requires additional financial resources; limitations on development of the necessary in-house skills.

Option 3: Combination (public officials in ministries and agencies do the initial analysis)

An external service provider is hired to carry out deeper (or complementary) analysis in certain areas, to collect additional data, or to take an external view to check the quality and findings of the in-house analysis. The lead institution has to develop TOR to properly target the scope and define the methodology; this requires expertise. Alternatively, a combination can mean establishing a mixed working group (public officials, experts, CSOs), with experts preparing background documents and analyses and then discussing and finalising the problem analysis at the working group meetings with public officials.

Benefits: allows better insight and quality testing of the initial analysis to ensure that core issues have not been omitted; opportunity to use more solid methodological approaches to get harder evidence.

Limitations: more time-consuming; requires additional financial resources; requires additional co-ordination efforts; reduced opportunity for in-house skill development; risk of limited ownership compared to a fully in-house setup.

Source: (OECD, 2018[3]).

Strategic objectives for integrity may be located in several government documents owned by various authorities. As such, and depending on the structure of the government, it is recommended to periodically provide a mandate to an inter-institutional body, such as a joint task force with members from relevant central government bodies and oversight institutions, to prepare an analytical report on public integrity risks. This report could formulate recommendations and identify priorities for the whole public integrity system (Box 3.1).

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Box 3.1. Analysing risks to draft the anti-corruption strategy in the United Kingdom

The UK 2017-22 anti-corruption strategy was developed through extensive cross-government discussion, led by the Joint Anti-Corruption Unit (JACU) in the Cabinet Office. The strategy was built from directly analysing three specific threats posed by corruption to the country: national security, national prosperity, and public confidence in institutions. Analysis of each of the three threats was led both nationally and in relation to the international context. This process informed the objectives entrenched in the strategy as well as the national, transnational (e.g. improving the international business environment, and the integrity of development finance) and sub-national measures (e.g. borders, defence, police, prisons, sport, and integrity in the financial sector, the private sector and local government) to be implemented.

Source: Adapted from (Pyman and Eastwood, 2018[4]).

Before conducting a problem analysis, an additional consideration is which analytical framework(s) and data sources to use (for an overview of possibilities, see (Johnson and Soreide, 2013[5]; OECD, 2019[6]; OECD, 2009[7]; UNDP, 2015[8]; UNODC, 2013[9]). Commonly used frameworks for strategy development are for example SWOT (Strengths, Weaknesses, Opportunities, Threats) analysis, PESTLE (Political, Economic, Sociological, Technological, Legal and Environmental factors) and problem tree analysis (for more on SWOT and PESTLE, see (OECD, 2018[3])). Such frameworks are useful to facilitate thinking within the team and with external stakeholders. However, without robust data the process may be inclusive but not evidence-based. The following sources of information can provide useful insights to identify and analyse integrity risks:

  • employee, household or business surveys

  • other survey data, such as user surveys or polls from local research institutions

  • data from public registries (e.g. law enforcement, audit institutions, national statistics offices)

  • published research documents from national or international organisations or academia (e.g. articles, reports, working papers, political economy analysis)

  • commissioned research

  • indicators from international organisations or research institutions

  • interviews or focus groups with relevant stakeholders

  • risk assessments conducted by ministries or other government entities for their own programmes.

All of the above sources can be useful for identifying potential integrity risks, but not all can be used to analyse the magnitude or impact of different types of risks. Administrative data from public registries and reliable survey data can be used to both identify and assess the level of risk, whereas for example focus group discussions are mainly useful to identify types of risks.

In Estonia, regular surveys on ethics, corruption and trust conducted by the Ministry of Justice informed the development of the Anti-Corruption Strategy for 2013-20 (Box 3.2).

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Box 3.2. Risk identification and assessment for the integrity strategy in Estonia

In Estonia, the Ministry of Justice is responsible for general anti-corruption policy and carries out regular surveys about ethics and trust in the public service, including a regular “Survey of Corruption among Three Target Groups”, those being public officials, citizens and businesses.

Various surveys informed the country’s Anti-Corruption Strategy 2013-20. A survey of citizens conducted in 2016 revealed that 9% of Estonians have been asked for a bribe when in contact with healthcare providers, making this the most corruption-prone area of citizens’ interaction with the public sector.

The “situational analysis” that preceded the integrity strategy in Estonia also looked at corruption crime statistics and a self-assessment of existing anti-corruption activities.

Source: (Sööt, 2017[10]; Estonian Ministry of Justice, 2013[11]; Estonian Ministry of Justice, 2016[12]).

Reviews conducted by international organisations can also provide input to problem analysis and policy recommendations. Examples include the Implementation Review Mechanism of the UN Convention against Corruption (UNCAC), the Council of Europe’s Group of States against Corruption (GRECO) evaluations, OECD Working Group on Bribery (WGB) evaluations and OECD Integrity Reviews.

Understanding the current context, performance and challenges within a specific country or organisation allows strategic prioritisation of areas for action and identification of realistic objectives. A thorough diagnosis of integrity risks to inform strategic planning is however often lacking in practice in the integrity and anti-corruption field (UNODC, 2015[2]; UNDP, 2014[13]; Hussmann, Hechler and Peñailillo, 2009[14]). The consequence is that priority setting in the strategic process is biased, and ultimately the effectiveness of the integrity system in mitigating risks is undermined (OECD, 2018[15]). By identifying the major integrity risks in the problem analysis phase, policy makers begin a process of reflection on the potential consequences if such risks materialise, as well as the relevant skills and equipment required to manage those consequences (OECD, 2018[16]). A meaningful and realistic strategy is hard to develop without a robust problem analysis. Equally important though is that the design process for the strategy actually takes into account the findings of the problem analysis, and that strategic objectives are prioritised systematically on the basis on evidence (OECD, 2005[17]).

3.2.2. Strategy design: Prioritising the objectives, policy consultation and co-ordination

Having conducted a thorough problem analysis, the next step is to develop the strategy for mitigating the risks identified. The key driver for choosing the strategy type – whether it be a single strategy or mainstreaming integrity into existing policy plans and strategies – is to ensure coherence among organisations, policies and objectives. A single strategy can more easily signal commitment, and the centralisation of efforts can make co-ordination and a system-wide approach easier. However, as described below, in practice single strategies face multiple challenges when it comes to implementation, and require focus and a suitable institutional setup.

On the other hand, mainstreaming integrity into existing policy plans and strategies is also challenging. To be effective, a strategic approach for public integrity that is based on mainstreaming involves establishing primary (first-level) objectives1 for mitigating integrity risks across strategies, as well as ensuring adequate coverage to constitute a system-wide approach.

Regardless of the type of strategy document, any strategy development process benefits from taking a systematic, inclusive approach to i) identifying and prioritising objectives; and ii) consulting and co-ordinating among relevant stakeholders.

Identifying and prioritising the strategic objectives

Regardless of whether a single strategy or a mainstreamed approach is chosen, strategic objectives are the guiding stars for those responsible for executing the strategy, and are used to form indicators and targets on the basis of which the strategy will be evaluated. Objectives must be aligned with the overall vision established for public integrity, as well as specific sector policy. Strategic objectives, from the general to the specific, directly link the findings of the problem analysis and align with indicators, their baselines (i.e. those of the indicators) and targets. Major integrity risks identified in the problem analysis should be addressed through primary objectives, which then cascade down to more specific secondary objectives, actions, indicators, milestones and targets.

Generally, the following areas usually benefit from a focus on integrity risk management:

  • human resource management, including violations of public integrity standards

  • public financial management, including reducing fraud and financial mismanagement

  • internal control and general risk management frameworks

  • public procurement.

In addition to these cross-cutting areas, a system-wide strategic approach will also have primary strategic objectives aimed at mitigating integrity risks in sector strategies – for example health, education, housing, taxation, customs and infrastructure. An advanced strategic framework continues beyond the public sector and recognises the role of the private sector, civil society and individuals in respecting public integrity values in their interactions with the public sector, as stated in the principle of whole-of-society (see Chapter 5). Box 3.3 describes the cross-governmental approach in Finland to developing an anti-corruption strategy. An advanced strategic framework could have objectives to mitigate public integrity risks in the private sector, public corporations, state-owned enterprises or public-private partnerships, as well as in interactions with civil society organisations.

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Box 3.3. A cross-governmental approach to strategy design in Finland

The anti-corruption strategy in Finland was developed by a cross-government group, which included police, local government and CSOs. Six strategic objectives were defined, and then further detailed into thirteen objectives and twenty-three specific reform measures.

Identifying and prioritising strategic objectives relied upon a large spectrum risk mapping and analysis of data and statistics from the police, the Office of the Parliamentary Ombudsman, the Finnish Competition and Consumer Authority, and the Tax Administration as well as from Transparency International Finland. High-risk sectors identified were construction, public contracting and competitive tendering, urban planning, political funding and decision making, foreign trade and sports.

Source: (Pyman and Eastwood, 2018[4]).

Consulting and co-ordinating among relevant stakeholders

The strategy development process should ensure the appropriate participation of actors responsible for carrying out any part of the strategy. As discussed in Chapter 2, various agencies, departments, units and individuals across different branches of power have responsibilities when it comes to implementing elements of a strategy, and their acceptance and active support will be critical for the strategy to succeed.

When drafting strategy that involves several bodies, one option is to assign to a small committee the primary responsibility for drafting the strategy document and granting it a reasonable degree of autonomy in developing the draft; the committee would be composed of representatives from the relevant public bodies. Representatives from civil society – such as business or professional associations, think tanks and academia – may also be invited to participate, either as full members or observers (Box 3.4). Including a broad range of voices in the development process can help build a common vision and increase the legitimacy of the strategy, and hence augment political support for it in the wider society (UNODC, 2015[2]). The business community, civil society organisations, the media, academics and the public in general can provide valuable inputs, not only in the drafting stage but also in the later monitoring and evaluation of the strategy (UNDP, 2014[13]).

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Box 3.4. Example of civil society involvement in the drafting of an integrity strategy and its implementation in the Netherlands

The Platform for Corruption Prevention in the Netherlands provides an example of how various stakeholders, including civil society organisations (CSOs), can be involved in implementing an anti-corruption strategy, as well as in helping design future strategies. Beyond public institutions, representatives from business and civil society were invited. These representatives were from private integrity and investigation services; the corporate risk and security management services of multinationals; the Association of Chambers of Commerce; the Association of Business Enterprises; Transparency International Netherlands; journalists; and academia. The meetings allowed participants to exchange expertise and experiences with anti-corruption developments in the Netherlands, and to share contributions to policy design and implementation, identification of corruption risks, research and training.

Source: (Centre for the Study of Democracy, 2014[18]).

The drafting body can be chaired by an individual with sufficient stature, legitimacy and political influence to act as an effective “champion” for the drafting body, and ultimately for the strategy itself (UNODC, 2015[2]). As noted above, the UK Anti-corruption Strategy was drafted by the Joint Anti-Corruption Unit (JACU) in the Home Office, and the anti-corruption strategy in Finland was developed by a cross-government group that included police, local government and CSOs (Pyman and Eastwood, 2018[4]).

The body in charge of formulating any strategy containing objectives relating to public integrity should consider consulting the following bodies: the anti-corruption authority; the supreme audit institution; the central institution responsible for internal control; the ombudsman institution; the police, the public procurement authority; the tax or customs authorities; and the prosecution authority or court administration. For the public consultation process, all supporting documentation should be made available to the public, including for example the results of regulatory impact assessments or white papers. It should also be made clear how comments provided by the public and organisations have been considered in the final version of the strategy, including explanations for those comments not taken on board.

Implementing established procedures for intergovernmental and public consultations can increase public acceptance of policies and prevent policy capture (for more, see Chapter 13). Moreover, for strategies relating to public integrity, it is often recommended that participation go “above and beyond”, for example with open town hall-style meetings or social media outreach. Strategies can be adopted at different levels of government; doing so is useful to encourage support for the strategy and ensure co-ordination (UNODC, 2015[2]). At both the national and subnational (regional and municipal) level, each ministry, agency or other institution would benefit from preparing their own strategies for mitigating integrity risks within their area of responsibility. However, the system-wide perspective in the principle on strategy encourages a wider, more comprehensive and co-ordinated approach. In practice, therefore, it is recommended that strategies be adopted at least at the level of the government, meaning the council of ministers or equivalent collegial body in the executive.

Aligning new strategies with existing strategies supports coherence. For example, developing the integrity strategy of a local hospital can take into account its specific context (e.g. number of staff, situations in which corruption incidences occur), as well as the sectoral integrity strategy of the ministry of health or a wider strategy for public service delivery adopted at the level of the government.

3.2.3. Developing indicators with baselines, milestones and targets

A strategic approach also requires indicators and establishment of their baselines, milestones and targets. Indicators should reflect the strategic objectives, some of which may be part of the strategy document and others part of the action plan. As such, the development of indicators is an iterative process that can help improve strategic objectives at different levels as well as activities in the action plan.

Indicators – and in particular their baselines, milestones and targets – are often neglected in the strategy design phase, and developed too late in the process to be useful. This leaves those charged with implementation of the strategy without a proper roadmap for which concrete results should be achieved and how. It also makes it difficult for the government as well as non-state actors to assess the level of success, progress towards the strategic objectives, and necessary corrections, as needed.

The goal of indicators is to support comparability over time. This allows for benchmarking that can assess the effectiveness of different interventions in the strategy and in other parts of the public integrity system. In a national context, such benchmarks can be established using a before-and-after approach, if indicators are established and data collected well in advance of implementing the strategy, or a with-and-without approach where the performance of a comparison group is measured alongside the treatment group.2 Internally comparable indicators are scarce and benchmarking should be done with diligence and attention paid to the limitations of the methodologies used. The OECD Public Integrity Indicators can serve as the indicators monitoring implementation of the strategic approach, or can serve as inspiration for developing other indicators.

When developing indicators, it is especially necessary to consider the limitations of the “iconic indices” mentioned in Box 3.53 that have served as the main measures of corruption and anti-corruption. The majority of existing measures rely heavily on secondary data sources based on expert judgement, and lack a theory or normative framework defining what the indicators should be measuring (Oman and Arndt, 2006[19]).

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Box 3.5. Limitations of internationally comparable indices

Since the birth of the modern anti-corruption movement in the early 1990s, governments have requested reliable measures of corruption and anti-corruption that can be compared across jurisdictions and over time. The Corruption Perceptions Index from 1995, Bribepayers Index from 1999, and Worldwide Governance Indicators from 2002 played a crucial role in raising awareness of the issue; however, their high level of aggregation, extensive use of secondary data sources mainly based on expert judgement, and lack of an underlying theory of what works (normative framework) have been criticised by experts, and governments find them less useful as performance indicators. They also focus either on corruption as a vaguely defined concept, or on the likelihood of petty bribery from the perspective of businesses.

Surveys – of public officials, businesses, the public or specific stakeholders – can provide valuable evidence to inform integrity policies. They are a measurement instrument that can be designed to reflect the culture and challenges of a particular country or organisation. For example, according to the OECD Strategic Human Resources Management Survey, 16 member countries include integrity at the workplace in their employee surveys (OECD, 2017[20]). Regardless of whether one undertakes a dedicated survey or integrates a module into an existing survey, such surveys enable insights into patterns of corrupt behaviour, satisfaction with services, trust in public institutions, and other related areas. In the Netherlands, a comprehensive staff survey is at the core of agenda setting for future integrity policies (Box 3.6). Moreover, some cross-country surveys can provide reliable data to inform national strategies and even to form a national baseline if done with care (Box 3.7). Other data inputs, such as those found in national data registers, can also prove valuable in informing indicators for integrity strategies, if the collected data meet reasonable quality standards.

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Box 3.6. Integrity Monitor in the Dutch public administration

Since 2004, the Ministry of the Interior and Kingdom Relations in the Netherlands regularly observes the state of integrity in the Dutch public sector. To this end civil servants (among them political office holders, secretaries-general and directors) are surveyed in all levels of government using mixed methods (including large-sample online surveys and in-depth interviews).

The Integrity Monitor, which is a flexible system of integrity assessments, supports policy makers in the design, implementation and communication of integrity policies. The survey’s results are reported to Parliament. The Ministry of the Interior and Kingdom Relations uses the Monitor to raise ethical awareness, detect implementation gaps and engage the decentralised public administration in taking responsibility for integrity regulations. Insights from past surveys have helped to identify priorities for anti-corruption efforts and shift integrity policies from prohibition to creating an organisational culture of integrity.

Source: Presentation by Marja van der Werf given at the meeting of the OECD Working Party of Senior Public Integrity Officials (28 March 2017, Paris); (Lamboo and de Jong, 2016[21]).

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Box 3.7. Surveys that allow cross-country comparisons

The following are cross-country surveys which can provide reliable data to inform national strategies as well as form a national baseline:

  • The Eurobarometer produced a special edition on corruption, comparing the results against a previous poll from 2013 (European Commission, 2017[22]).

  • The International Crime Victims Survey (ICVS) (United Nations Interregional Crime and Justice Research Institute, n.d.[23]), an international programme for measuring direct experience of crime victimisation, also included a section to measure the experience of bribery among the population.

  • The World Bank Enterprise Surveys and Business Enterprise Economic Surveys (World Bank Group, n.d.[24]) provide the largest firm-level survey data on the experience of bribery.

  • Transparency International’s Global Corruption Barometer uses general population surveys, and the World Justice Project Rule of Law Index mixes expert assessment (coded as QRQ) with surveys of the general population (coded as GPP).4

3.2.4. Drafting the action plan, distributing responsibilities and costing activities

Once the strategic objectives are established and indicators and targets are set, the next step is to plan the specific activities needed so the objectives can realistically be met. This is an action plan.

All government strategies benefit from action plans, and each country has its own set of guidelines for what constitutes a good plan. Integrity strategies do not pose any particular challenge in this respect. Nevertheless, to emphasise the need for an evidence-and risk-based approach and financial sustainability, and because integrity strategies often depend on multiple implementation agents, the following characteristics of action plans are recommended for integrity strategies (see also (Council of Europe, 2013[25])):

  • outcome-level indicators, with a baseline, milestones and targets, linked to objectives and activities

  • identification of at least lead organisations for each objective

  • description of the monitoring, reporting and evaluation arrangements

  • use of administrative data sources from existing public registries, such as human resource management information systems, procurement databases, audit reports, risk registers, court case statistics and law enforcement statistics

  • use of data sources from staff, household or business surveys

  • if relevant for the strategic objective, activities at the sub-national level

  • estimates of capital and operational expenditures

  • identification of additional costs with cost estimates

  • multi-annual financial plans that are linked with the medium-term expenditure framework

  • public availability of the full action plan, together with the corresponding monitoring reports (see Section 3.2.5).

Presentation of the action plan should be kept simple, and also enable readers from outside the administration to identify at first glance answers to key questions such as, “What are the actions?”, “Who will be responsible for them?”, “When will they happen?” and “How will their impact be measured?” (Hope, 2013[26]). Even in the seemingly simple case of whether a new code of conduct has to be drafted, breaking the process into a series of steps (e.g. drafting the code, consultations, submission for approval and dissemination) could be helpful.

3.2.5. Implementing, monitoring, evaluating, and communicating the results of monitoring and evaluation, including evaluation prior to implementation

An effective integrity strategy and action plan must not only lay out a comprehensive set of substantive reforms, but also indicate the means for ensuring its implementation, monitoring and evaluation. As discussed in Chapter 2, a specific body, ministry or unit under a ministry should be assigned responsibility for this task, sometimes jointly with other entities. Regardless of the specific institutional setup, each strategy needs a central co-ordination function responsible for implementation, monitoring, evaluation and reporting of the strategy and its action plan.

Implementing the strategic framework

The entities responsible for the design of the integrity strategy and the action plan are not necessarily also responsible for all (parts) of its implementation (OECD, 2017[20]). This can hamper implementation. It will not be enough for booklets on policies to be sent round while putting them into practice is left to self-initiative and judgement (U4 Anti-Corruption Resource Centre, 2007[27]). Key to implementing an integrity strategy is therefore to join different integrity actors under a common vision and co-ordinate their action towards public integrity.

Several governments require that individual line ministries or departments prepare corruption prevention plans that are tailored to their organisation’s specific internal and external risks. Every organisation is different, and integrity risks vary depending on mandate, personnel, budget, infrastructure and IT development. For example, line ministries responsible for transferring social benefits face higher risks of fraud; likewise, departments with higher public procurement spending (such as health or defence) may face corruption risks related to that activity. Even if a strategy is implemented by multiple bodies, there needs to be a central monitoring mechanism. At a minimum, monitoring reports should:

  • be published at regular intervals, on time, and made publicly available

  • report on progress in relation to predefined indicators and targets in the action plan

  • present the rate of implementation of activities in the action plan

  • draw conclusions and provide recommendations to management

  • be discussed with relevant bodies, including non-state actors.

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. The agency responsible for co-ordinating implementation of the strategy should therefore ensure, whenever possible, that there is independent validation of progress. In some cases, it may be advisable to request that an organisation conduct a preliminary self-evaluation and then compare the results with an independent evaluation or audit (perhaps by the co-ordinating unit, another government department or an external monitor such as a civil society group or outside consultant). Among other advantages, doing so might help the implementing organisations understand how they can better assess their own performance (UNODC, 2015[2]). An example of how this is done is given in Box 3.8.

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Box 3.8. Monitoring and assessing integrity in Korea

The Anti-corruption and Civil Rights Commission (ACRC) in Korea uses two complementary assessment frameworks to monitor and assess the quality of implementation of anti-corruption efforts as well as their results: Integrity Assessment and Anti-corruption Initiative Assessment.

Integrity Assessment (IA)

Korea annually assesses integrity in all government agencies through standardised surveys. Staff from 617 organisations are asked about their experience with and perception of corruption. Furthermore, citizens who have been in contact with the respective organisations are surveyed as well as stakeholders and experts who have an interest in the work of those organisations. The answers, together with other information, are scored into a composite indicator – the Comprehensive Integrity Index.

Anti-Corruption Initiative Assessment (AIA)

The Anti-Corruption Initiative Assessment is a comparative assessment of integrity policies across government agencies in Korea. Agencies selected for assessment submit a performance report on their implementation of integrity policies. On-site visits verify the information, which is then scored by an external assessment team. This allows the ACRC to observe integrity willingness and efforts across the public sector.

Benchmarking and competition

Underperformance in the IA or the AIA does not lead to sanctions. However, the results are made public and the direct comparison of different government entities based on integrity indicators creates competition among these entities. The results also enter the Government Performance Evaluation. In addition, there are institutional and individual high-performance rewards, such as an overseas study programme for the officials presiding over outstanding integrity performance. Continuous improvement of the performance results has indicated that these incentives might be effective.

Source: Presentation by Sung-sim Min, Director, Anti-Corruption Survey & Evaluation Division, ACRC, at the meeting of the Working Party of Senior Public Integrity Officials (SPIO) at the OECD Headquarters in Paris in November 2016.

Monitoring and evaluating the strategic framework

To properly gauge the effectiveness of an integrity strategy, it is important to specify evaluation arrangements.5 These mechanisms are often institutionalised within the policy-making process for all public policies (Jacob, Speer and Furubo, 2015[28]). Evaluation mechanisms at various stages of the policy process are defined and planned prior to implementing any actions. 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 is essential to establish evaluation mechanisms before the implementation phase to ensure measurability, progress reports and accountability. Some data may overlap with what has been collected for the risk identification and assessment procedure in the ex ante stage, but the monitoring and evaluation arrangements have a different purpose: holding the implementing actors accountable for what has been achieved, and how efficiently. Similar to the problem analysis phase, the evaluation can either be done in-house or outsourced. Alternatively, it is possible to outsource only certain parts of the process. The choice depends on the purpose of the evaluation and the resources available. In short, in-house evaluations can better facilitate organisational self-reflection and learning, be less expensive, and be faster to execute; at the same time, they are also seen as less objective, and in-house staff often have neither the time nor the skills needed for a thorough evaluation. Table 3.2 details the advantages and disadvantages of each approach.

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Table 3.2. Benefits and limitations of the options for evaluation setup

Option 1: In-house evaluation

Evaluation is designed and carried out internally by the lead institution staff.

Benefits: may allow for faster evaluation, as there is no need for standard procurement procedures; availability of inside information; further enhancement of analytical skills and insight.

Limitations: could be less objective, due to reluctance to disclose challenges and problems.

Option 2: Outsourced evaluation

Evaluation is carried out by external consultants through an outsourcing procedure.

Benefits: objective evaluation by external and independent evaluators.

Limitations: requires additional resources to procure the expertise; may require more time to procure the service providers.

Option 3: Mixed/combined evaluation

Only some parts of the evaluation are outsourced (e.g. data collection and some of the more sophisticated analysis), while the rest is done in-house.

Benefits: objective evaluation due to the involvement of external and independent evaluators; faster evaluation process, as the more time-intensive evaluation steps can be outsourced.

Limitations: requires additional resources to procure certain services.

Source: (OECD, 2018[3]).

Evaluation reports for integrity strategies should be made publicly available, and it is often useful to include non-state actors either as evaluators or as part of a formal quality assurance process.6 Monitoring data should be used actively in the evaluation reports, and the ultimate goal is for the evaluation exercise to improve approaches and practices, for example by informing the design of follow-up initiatives.

Communicating the results of monitoring and evaluation

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 their action plan, countries may include information and communication activities, taking into account all new information media such as social media, as well as traditional and tested approaches such as town hall meetings and public hearings (UNODC, 2015[2]).

Communication should start as soon as the integrity strategy is ready, prior to implementation. Its content and envisaged implementation and the bodies responsible for its execution should be widely publicised. This will ensure transparency and help mobilise popular support, besides creating public expectation that those involved in the reform process will live up to their commitments. The public can be informed of the strategy and its implementation progress through the media, government websites and targeted public information events as well as by civil society organisations (OSCE, 2016[29]). Chapter 5 addresses factors related to developing and implementing an effective communications strategy.

copy the linklink copied!3.3. Challenges

A strategic approach for public integrity may face challenges depending on whether a single national strategy is formulated or strategic objectives for integrity are mainstreamed into existing strategies. Regardless of the choice of the document, a strategic approach requires high-level commitment during the strategy design process, as well as ensuring that the approach avoids overly rigid compliance objectives and places emphasis on promoting cultural change within organisations.

3.3.1. Ensuring high level commitment and assigning the appropriate resources to support the strategic framework

Without commitment at the highest political and management levels, integrity strategies are unlikely to be effective or sustained in the long term (for more, see Chapter 1). A good practice for gathering the necessary support for the strategy and the suggested reforms throughout the administration is to ensure the appropriate participation in the strategy-drafting phase of representatives of any government agency, department or unit affected by the strategy (OSCE, 2016[29]). An advantage of involving relevant actors (responsible for implementation, enforcement and monitoring) in the strategy design process is that it can improve their co-operation in those three areas, which are all critical to the effectiveness of the integrity system (UNODC, 2015[2]). Ensuring that the process includes a representative from a high-level or central government position can also support commitment to implementation (for more, see Chapter 2).

A challenge that arises especially for single national integrity strategies relates to the need for a suitable institutional setup and political champions. Strategic objectives may be meaningful but not met if management structures, processes, information technology, data registries and staffing are inadequate, or if time and budget are insufficient to put ambitions into practice. In establishing objectives, the strategy designers need to match expectations with the implementation capacity, the time needed, and available resources of the particular public administration (Council of Europe, 2013[25]). It is crucial to avoid developing an unrealistic “wish list”. Prioritisation in strategy development can be done through establishing short-, medium- and long-term objectives, and sequencing the implementation of activities.

A strategic approach that mainstreams integrity objectives into existing strategies often faces fewer problems regarding the institutional setup, staffing and funding, as those strategies are established; however, it still needs to grapple with the challenge of a whole-of-government, collaborative approach. For example, sector ministries may be reluctant to collaborate closely with oversight institutions, anti-corruption authorities or civil society organisations in fear that the weaknesses of their integrity systems may be exposed. It is even more necessary for such approaches that an inter-institutional body is given a mandate to periodically prepare an analytical report on public integrity risks that formulates recommendations and sets priorities for the whole public integrity system, as mentioned above. Otherwise integrity risks will be identified and analysed only within specific sub-systems of government.

3.3.2. Balancing rules-based and values-based approaches

A common challenge for all types of integrity strategies is to achieve the proper balance between a rule-based or compliance-based approach and a strategy based on values. Over the years, governments have adopted legal and institutional frameworks to strengthen integrity in the public sector. However, in many countries these frameworks rely heavily on compliance and enforcement mechanisms.

The goal of any integrity strategy should be to increase integrity in the public sector, not simply to curb misconduct and corruption. Compliance-based approaches focus on adherence to administrative procedures and rules setting minimum standards. While these efforts provide the necessary enabling framework, an integrity strategy additionally based on values helps create an environment that supports positive ethical behaviour. The idea is for values to serve as a common framework that can be applied in the decision-making process across different functions, departments and teams (see Table 3.3).

copy the linklink copied!
Table 3.3. Balancing rules-based and values-based integrity strategies

Rules-based strategy

Values-based strategy

Objective

Prevent misconduct

Enable responsible conduct

Ethos

Conformity with externally imposed standards

Self-governance according to chosen values and standards of conduct

Management

Lawyer/compliance officer-driven

Management-driven with the aid of integrity and ethics counsellors, and HR and legal officers

Behavioural assumptions

Autonomous beings guided by material self-interest

Social beings guided by values, standards of conduct, peers

Standards

Criminal and regulatory law

Code of ethics, code of conduct and related policies, regulations and laws

Staffing

Lawyers/HR/compliance officers

Integrity officers, HR, managers

Method

Education in existing legal framework, compliance standards and systems, reduced discretion, misconduct reporting, audit and controls, investigation processes, sanctions, etc.

Strengthen ethical competence of public officials through development of organisational values, education and training on values and standards of conduct, integrity training and ethics counselling, leadership and managerial role modelling, accountability, transparency, integrity frameworks, auditing, sanctions, mainstreaming values into the daily processes of the administration, communication and raising awareness

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Notes

← 1. Primary or first-level objectives are those formally adopted by a council of ministers or similar body, and are applicable across government or across a sector.

← 2. This could for example be done if an integrity programme in schools is planned as part of the strategy, and because of a lack of resources the programme is first implemented in selected municipalities (treatment group) and only later, once this pilot phase has been evaluated, in other municipalities (comparison group).

← 3. For more on limitations, please see the G20 Issues Paper on Corruption and Economic Growth (G20, n.d.[32]), as well as the UNDP User’s Guide to Measuring Corruption and Anti-Corruption (UNDP, 2015[8]).

← 4. The Global Corruption Barometer and regional barometers provide actionable data on the prevalence of bribery in different sectors and the attitudes of citizens towards the efforts of the administration to curb corruption. However, due to funding pressures and operational limitations the samples can be biased – for example towards urban populations – and results are often not comparable over time.

← 5. Monitoring is a continuous function that uses systematic collection of data on specific indicators to provide an indication of the achievement of objectives. Evaluation is the systematic and objective assessment of an ongoing or completed project, programme or policy, its design, implementation and results. It differs from monitoring in that it involves a judgement of the value of the activity and its results (OECD, 2013[31]). For more about monitoring government performance, see (OECD, 2009[30]).

← 6. The European Commission’s Quality of Public Administration – Toolbox 2017 edition provides examples of how to promote the active involvement of stakeholders in evaluating public policy: http://ec.europa.eu/social/main.jsp?catId=738&langId=en&pubId=8055&type=2&furtherPubs=no.

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