The IACA Anti-Corruption Tailor-made Training for

Good Governance and Anti-Corruption Academy of

Côte d'Ivoire representatives

FIGHTING CORRUPTION RISKS

IN PUBLIC SECTOR

Drago Kos
Yamoussoukro, 28 April 2025
 UNCAC AND CORRUPTION RISK
ASSESSMENT

Article 5/3: Each State Party shall endeavour to periodically evaluate

relevant legal instruments and administrative measures with a view to
determining their adequacy to prevent and fight corruption.

THIS IS NOT EXACTLY A PROVISION ON THE NECESSITY OF THE CRA BUT

THE BASIC IDEA IS THE SAME: TO FIND OUT WHERE ARE THE
LOOPHOLES/RISKS IN FIGHTING CORRUPTION.

[Link] Slide 2
 OECD AND CORRUPTION
RISK ASSESSMENT

2021 Recommendation for Further Combating Bribery of Foreign

Public Officials in International Business Transactions

Annex II: Good Practice Guidance on Internal Controls, Ethics and

Compliance
A. Good practice guidance for companies
„Effective internal controls, ethics, and compliance programmes or
measures for preventing and detecting foreign bribery should be developed
on the basis of a risk assessment addressing the individual circumstances
of a company,……
Such circumstances and risks should be regularly monitored, re-assessed,
and taken into account as necessary, to determine the allocation of
compliance resources and ensure the continued effectiveness of the
company’s internal controls, ethics, and compliance programme or
measures

[Link] Slide 3
 IF WE WANT TO FIGHT CORRUPTION
RISKS, WE HAVE TO KNOW THEM

In order to identify corruption risks, threatening their sectors

(public, private), countries usually apply „corruption risk
assessments“ (CRAs) as corruption risk identification and
management tools.

CRAs can be defined as „careful examination of corruption

risks that could cause harm to people, business interruption,
loss of business reputation or any other damage to people
and organisations“.

[Link] Slide 4
 USUAL CORRUPTION RISKS
ASSESSMENT‘S STEPS

1. Identifying the hazards

2. Deciding who might be harmed and how
3. Evaluating the risks and deciding on
countermeasures
4. Recording of findings and implementing them
5. Reviewing the assessment and updating it (if
necesary)

[Link] Slide 5
 IDENTIFYING THE HAZARDS

Assess risks from internal and external sources

Get the employees’ opinion

Collect experience from others (theory, practise)

Respect your own experience (long – and short-

term risks)

[Link] Slide 6
 DECIDING WHO OR WHAT MIGHT BE
HARMED – AND HOW

There is no harm without a victim

Who: employees (from top to bottom)

What: economic loss, business interruption, loss of

business reputation, loss of trust, loss of
integrity,..…

[Link] Slide 7
 EVALUATING THE RISKS AND
DECIDING ON COUNTERMEASURES

Evaluation = Prioritisation : in accordance with the

likelihood of the occurence of risks and the gravity
of possible consequences

Enhance existing and introduce new control

activities

Reduce risks to acceptable levels !

[Link] Slide 8
 RECORDING THE FINDINGS AND
IMPLEMENTING THEM

Write down the results of risk assessment and

share them with the staff.

Appoint persons responsible for monitoring of the

implementation.

Link results of the risk assessment with the

objectives of your institution.

Start implementation.

[Link] Slide 9
 REVIEWING THE ASSESSMENT AND
UPDATING IT

Everything is changing: legal framework,

institutional set-up, working conditions, risks,
their consequences, controls, …

Adjust assessment of risks and control activities

[Link] Slide 10
 WHY TO IDENTIFY AND FIGHT
CORRUPTION RISKS IN AN INSTITUTION?

- To increase official performance and society well-being

- Corruption is costly and less efficient

- Officials work harder, perform better, more inovative as

they are in a trust environment

- There are better mutual relationship between officials, with

management, pride and loyalty of officials increase

- „Ethical investment“ as expectations of interest groups are

met

[Link] Slide 11
 INSTITUTIONAL INTEGRITY

PERSONAL DEPARTMENT
INTEGRITY INTEGRITY

2: Risk assessment – interviews, focus groups

1:
Ident.
of areas

3:
Improve
ment
measures
Corporate integrity

COMPANY
INDUSTRY INTEGRITY
INTEGRITY

[Link] Slide 12
 SOME FORMS OF CRAs

a) „Voulnerability to corruption assessment“ (VCA, USA)

b) „System integrity development“ (SID, USA)

c) „Integrity assessment“ and „Anti-Corruption Integrity

Assessment“ (Korea)

d) „Corruption risk assessment“ (Korea)

e) „Corruption risk assessment“ (Sri Lanka)

f) „Integrity plan“ (CEE)

Five tools deal with institutions, „corruption risk assessment“

from Korea deals with legislation („corruption proofing“).
[Link] Slide 13
 VOULNERABILITY TO CORRUPTION
ASSESSMENT (VCA)

It is a corruption risk analysis and management

method for organisations, developed in the USA,
enabling subjective (also political) influence on the
results of the assessment.

An example from the US: 2017_vulnerabilities-to-

corruption-handbook_iri_web.pdf

[Link] Slide 14
 VCA‘S STEPS

1. Explore: The first step is to determine the existence of political will and
tentatively determine the focus of the assessment. For this a steering
committee of key decision makers within the government and civil society is
convened to conduct a political economy analysis to understand the context
and opportunities for corruption.

2. Assess: An assessment through consultations and interviews with

government officials and other stakeholders, such as civil society and
community leaders, is conducted, followed by an assessment report including
findings and recommendations, which is presented to the steering committee
for feedback.

3. Enact: Following the presentation of the assessment report and through a

collaborative process, an action plan is developed to address the identified
weaknesses and prevent possible corruption.

4. Showcase: At the end of the VCA‘s implementation, the successes in

identifying, addressing and reducing voulnerabilities to corruption are shared
and elected local officials, civil society and community leaders are engaged to
create sustained political will and potentially expand the VCA to additional
government areas or new municipalities.
[Link] Slide 15
 VCA‘s WEAKNESSES

1. POLITICAL ECONOMY ANALYSIS? („A basic political economy analysis

(PEA) to gain a clear understanding of the current political and
economic context is conducted. The PEA looks at motives, relationships,
and distribution of power between different groups and individuals.
Based on the steering committee’s guidance and the PEA results,
recommendations will be made of where the VCA could best be
implemented.“)
2. HIGHLY SUBJECTIVE !
3. EXCLUSIVELY TOP-DOWN APPROACH (NO ENGAGEMENT OF
OFFICIALS)
4. THIS IS A SEMI-POLITICAL AND NOT A TECHNICAL MECHANISM !

[Link] Slide 16
 SYSTEM INTEGRITY DEVELOPMENT (SID)

It is a corruption risk analysis and management

method for organisations, developed by a
company (Unishka) in the USA, enabling important
subjective (also political) influence on the results
of the assessment.

An example: UNISHKA | Systems Integrity

Development

[Link] Slide 17
 SID‘s STEPS

1. Scoping (political economy analysises in the

following areas: legal gaps analysis, voulnerable
population assessment, process mapping,
organisational framework assessment, human
factor analysis)
2. Data collection analysis, leading to an
„actionable research report“
3. Recommendations (= a reforms roadmap)
4. Implementation („integrity outcomes“)

[Link] Slide 18
 SID‘s WEAKNESSES

1. POLITICAL ECONOMY ANALYSIS ? („A basic political economy

analysis (PEA) to gain a clear understanding of the current
political and economic context is conducted. The PEA looks at
motives, relationships, and distribution of power between
different groups and individuals.“)
2. OBJECTIVELY - SUBJECTIVE !
3. THIS IS A MIXTURE OF A POLITICAL AND A TECHNICAL
MECHANISM !

[Link] Slide 19
 INTEGRITY ASSESSMENT

It is a corruption risk analysis and management method for

public institutions in Korea, composed of two surveys: „Integrity
Assessment of Public Institutions“ and „Anti-Corruption Initiative
Assessment“
(bb26ffe35422b770200a34cfb8d7774e9560e5bb67c0fb6aef698
[Link] ([Link]).

More about both surveys in: „The Korea experience shared with
other countries to contribute to global anti-corruption efforts
(슬라이드 1 ([Link]).

[Link] Slide 20
 ANTI-CORRUPTION INITIATIVE
ASSESSMENT OF PUBLIC INSTITUTIONS

AC Initiative Assessment of Public Institutions (the Winner of 2013 UN

Public Service Awards) is nothing but a public survey of what citizens
think and experience in selected public institutions (in 2018, around 260
000 citizens were commenting on 705 public institutions).

Weaknesses:

•in important part, it is a perception survey,

•respondents to the questions of researchers are unconditionally

subjective,

•there is no internalisation of the process and its findings,

•it describes the integrity image of the institution and not its real
integrity.

[Link] Slide 21
 ANTI-CORRUPTION INITIATIVE
ASSESSMENT (AIA)‘s STEPS, I.

1. At the beginning of each year, the ACRS (South Korean ACA) develops and releases
the annual anti-corruption guidelines and draft indicators for that year’s AIA.

2. In March every year, ACRC organizes a policy workshop for government offices and
public enterprises, including those who are subject to AIA, to explain the AIA
implementation guidelines and draft indicators in detail, and receive questions and
suggestions from the participating institutions.

3. ACRC then finalises the assessment criteria and indicators, and releases them along
with the AIA implementation plan in April, including the assessment schedule,
reporting templates and a sample AIA report, for reference.

4. The public institutions follow the guidelines for the rest of the year and submit their
implementation reports (covering the period from November 1 of the previous year
and until October 31 of the current year) by early November. For verification of the
reported facts, target institutions have to submit official documents as evidence for
their performance reports. In addition, ACRC selects about 15% of the target
organizations for further verification through an on-site inspection.

[Link] Slide 22
 ANTI-CORRUPTION INITIATIVE
ASSESSMENT (AIA)‘s STEPS, II.

5. Once all performance reports are submitted, ACRC works with the
external evaluation panel and evaluates the reports, along with site visits
and verification activities. ACRC consolidates the assessment scores and
releases draft scores to the target institutions in early December, after which
it receives feedback until mid-December and makes necessary adjustments
thereafter.

6. With their final scores, institutions are then ranked in performance groups
or tiers (from 1 to 5, with 1 being the best performing category), rather
than individually from the first to last. The tiered ranking of each institution
is released to the public through ACRC press releases, and the final
consolidated report of AIA as a whole is published in January of the following
year.

[Link] Slide 23
 AIA‘s WEAKNESSES

1. The AIA‘s emphasis is on the assessment (score) and not

on the improvement of the situation.
2. Sustainability is not ensured (since every year there is a
different set of criteria).
3. No follow-up procedure to monitor the improvement of
the situation.
4. Unreliability - caused by the fact that it is all about the
score (which leads institutions into „polishing“ their
results).

[Link] Slide 24
 CORRUPTION RISK ASSESMENT
(KOREA)

It is a corruption risk analysis and management method for legislation,

developed in South Korea.

More about it at: Introduction to Korea's Corruption Risk Assessment: A

Tool to Analyze and Reduce Corruption Risks in Bills, Laws and
Regulations | United Nations Development Programme ([Link]).
In other countries, this is not considered a real CRA since it does not
assess the institutional but legislative integrity (corruption risks) and a
completely different set of methods applies. In other countries, this
method is called „corruption proofing of the legislation“ (see also:
Corruption Proofing of Legislation (CPL) – Regional Anti-Corruption
Initiative ([Link])).

[Link] Slide 25
 CORRUPTION RISK ASSESMENT
(SRI LANKA)

It is a corruption risk assessment in Sri Lankan public institutions,

introduced by a Presidential Circular from 18 February, 2025, requiring
all governmental institutions to introduce so-called „Internal Affairs
Units“ (IAUs).
One of the responsibilities of the IAUs is also to „conduct corruption risks
assessments to identify areas in the institution voulnerable to corruption
and unethical conduct and take targeted preventive measures“.
The next IAU‘s responsibility is to „develop and implement Institutional
Integrity Action Plan outlining specific anti-corruption objectives and
strategies tailored to the institution‘s needs.“

In practice, CRAs in Sri Lankan institutions have not been introduced yet
(dicussions are going on right now).

[Link] Slide 26
 INTEGRITY PLAN

It is a corruption risk analysis and management method for

organisations, based on a method developed by the Dutch
intelligence services (for other purposes) and upgraded for
the use in the anti-corruption area. Today it is used in
Slovenia, Serbia, North Macedonia, Kosovo, Bosnia and
Herzegovina, Moldova, Romania,..

An example from Serbia: Manual for the Integrity Plan

Development and Implementation .pdf ([Link])

[Link] Slide 27
 WHAT IS INTEGRITY PLAN?

- a corruption risk analysis & management method for creation of

legal, ethical, and professional quality of work
- a program of preventive maintenance
- a method for identifying organisation’s vulnerabilities to fraud and
corruption
Possible definition of the Integrity Plan: “measures of legal and
practical nature, which eliminate and prevent the possibilities for the
occurrence and development of corruption in an organisation.”

[Link] Slide 28
 INTEGRITY PLAN CONSISTS OF:

- analysis of corruption exposure of the organisation

- information on the project group for the integrity plan
- description of the work processes and methods of decision
making including the description of the exposed tasks
- preventive measures for reducing the possibility and risk of
corruption
- other parts (dependent on the organisation adopting it)

[Link] Slide 29
 BENEFITS OF THE INTEGRITY PLAN:

Integrity Plan:
- strengthens preventive mechanisms in the institution
- stimulates awareness of the voulnerable activities
- creates possibility for a greater integrity of the institution
- increases efficacy, level of quality, respect, trust
- increases institution‘s resistance toward corruption
- increases awareness of officials
- and many more…

[Link] Slide 30
 INTEGRITY PLAN - STEPS

Step No. 1: Determination of tasks-preparatory phase

Step no. 2: Assessment of voulnerable activities

Step No. 3: Assessment of the existing preventive measures

Step no. 4: Introduction of new measures and control

mechanisms

Final report

[Link] Slide 31
 STEP No. 1

- management accepts the project

- it nominates the project group and project’s leader
- project group prepares the integrity plan program
-management approves and adopts the integrity plan
program

[Link] Slide 32
 STEP No. 2

- assessment of the institutions‘ work processes

- in depth review of internal rules/regulations and standards
- assessment of the most voulnerable activities

[Link] Slide 33
 STEP No. 3

- assesment of the existing preventive systems

- critical analysis of the existing situation (questionnaires and
interviews)
- prioritisation of the assesed voulnerable activities/risks

[Link] Slide 34
 RISK LEVEL ASSESSMENT
(PRIORITISATION)

After defining risks, the next step is the assessment of the likelihood
and impact of risks.

[Link] Slide 35
 STEP No. 4

- improvement recommendations
- improvement priorities
- management adopts the Integrity Plan and oversees its
implementation

[Link] Slide 36
 ELIMINATION OF RISKS

Identified and assessed risks need to be dealt with, therefore, the

Integrity Plan includes:
-proposed improvement measures and activities (economical,
efficient, and easily feasible in the institution)
- priority measures in accordance with the risk level
- risk ownership for implementing measures
- deadlines for their implementation
- monitoring (compliance officer, risk owners)

[Link] Slide 37
 PRACTICAL EXAMPLE OF AN
IT SUPPORTED INTEGRITY PLAN

[Link] Slide 38
 REMEMBER:

While developing an Integrity Plan:

- Do not cause additional risks

- Prepare for incidents

- Deal with incidents

- Respect wider framework and objectives (institutions’ policies)

[Link] Slide 39
HOW DO INTEGRITY PLANS INFLUENCE
AC POLICY DOCUMENTS (STRATEGIES, PLANS,..)?

If we are adopting policy documents (policies, strategies, plans)

on the prevention and suppression of corruption, we have to
know what corruption risks we need to prevent or suppress.

With other words: no meaningful anti-corruption policy/plan can

be adopted without a CRA in the
geographical/sectoral/political/organisational institution, for
which the policy/plan is to be developed.

[Link] Slide 40
 TWO WAYS OF DRAFTING ANTI-
CORRUPTION POLICY DOCUMENTS

1. First, conducting a CRA and following it develop an AC

policy, corresponding to the identified corruption risks (very
useful for a national or any other „geographical“ AC policy).

2. Second, making a decision on the substantive areas to be

dealt with by the AC policy and only then conducting a CRA in
the selected areas.

Combination of both approaches is also possible.

[Link] Slide 41
 IN PRACTICE:

CRAs should identify corruption risks, which serve as a basis for

planning countermeasures in the AC policies.

In organisations and sectors, CRA is normally not a problem but at

the national level it is difficult to conduct a meaningful CRA. There
are three ways how to identify corruption risks at the national
level:
- collection and analysis of the existing data (e.g., from the
existing integrity plans)
- new CRA (which – due to its general nature – will mostly contain
collection and analysis of the perception data),
- combination of both methods.

[Link] Slide 42
 SOME PRACTICAL PROBLEMS

1. Time (conducting a CRA takes time, which means that we have to plan
our activities carefully, taking into account both, time needed for the
CRA and time needed for making the AC policy/action plan)
2. Resources (conducting a CRA requires resources – the same as making
the AC policy/action plan)
3. „Translation“ of the CRA results into an actionable AC policy/plan
4. The level of cooperation (between CRA/integrity plans experts and AC
policies experts)
5. Difference between an integrity plan and an AC policy/action plan
(integrity plan is a „mini AC policy“)
6. Time-span of both – the CRA and the AC policy/action plan - does not
have to coincide
7. Monitoring the implementation of both – the CRA and the AC
policy/action plan
8. Responsibility for the implementation

[Link] Slide 43
 LIST OF IMPORTANT
ANTI-CORRUPTION INDICATORS

It is taken from currently the best monitoring framework for countries:

the OECD Istanbul AC Action Plan 5th Round of Monitoring Assessment
Framework, adopted in 2022, and covering countries of Eastern Europe
and Central Asia.

African countries are not part of the monitoring framework but indicators
given here might serve for a very credible self-assessment and as a part
of the CRA before entering the new phase of developing the national anti-
corruption strategy and related bi-annual action plans.

The Framework is divided into 9 performance areas with indicators,

benchmarks and scoring methods.

[Link] Slide 44
 PERFORMANCE AREA 1:
ANTI-CORRUPTION POLICY

Indicators:
-The anti-corruption policy is evidence based and up-to date:
3 benchmarks (BM)
-The anti-corruption policy development is inclusive and
transparent: 2 benchmarks (BM)
-The anti-corruption policy is effectively implemented: 2
benchmarks (BM)
-Coordination, monitoring, and evaluation of the
anticorruption policy is ensured: 4 BM

[Link] Slide 45
 PERFORMANCE AREA 2:
CONFLICT OF INTERESTS AND ASSETS DECLARATIONS

Indicators:
-An effective legal framework for managing conflict of interest
is in place: 5 BM
-Regulations on conflict of interest are properly enforced: 3 BM
-Asset and interest declarations apply to high corruption risk
public officials, have a broad scope and are transparent for
the public and digitized: 7 BM
-There is unbiased and effective verification of declarations with
enforcement of dissuasive sanctions: 6 BM

[Link] Slide 46
 PERFORMANCE AREA 3:
PROTECTION OF WHISTLEBLOWERS

Indicators:
-The whistleblower’s protection is guaranteed in law: 6 BM
-Effective mechanisms are in place to ensure that whistleblower
protection is applied in practice: 3 BM
-The dedicated agency for whistleblower protection has clear
powers defined in law and is operational in practice: 4 BM
-The whistleblower protection system is operational, and
protection is routinely provided: 4 BM

[Link] Slide 47
 PERFORMANCE AREA 4:
BUSINESS INTEGRITY

Indicators:
-Boards of listed/publicly traded companies are responsible for
oversight of risk management, including corruption risks: 2 BM
-Disclosure and publication of beneficial ownership information
of all companies registered in the country, as well as
verification of this information and sanctioning of violations of
the relevant rules, is ensured: 4 BM
-There is a mechanism to address concerns of companies
related to violation of their rights: 2 BM
-State ensures the integrity of governance structure and
operations of state owned enterprises (SOEs): 5 BM

[Link] Slide 48
 PERFORMANCE AREA 5:
INTEGRITY IN PUBLIC PROCUREMENT

Indicators:
-The public procurement system is comprehensive: 3 BM
-The public procurement system is competitive: 3 BM
-Dissuasive and proportionate sanctions are set by legislation
and enforced for procurement related violations: 4 BM
-Public procurement is transparent: 4 BM

[Link] Slide 49
 PERFORMANCE AREA 6:
INDEPENDENCE OF JUDICIARY

Indicators:
-Merit-based appointment of judges and their tenure is
guaranteed in law and practice: 5 BM
-Appointment of court presidents and judicial remuneration and
budget do not affect judicial independence: 3 BM
-Status, composition, mandate, and operation of the Judicial
Council guarantee judicial independence and integrity: 4 BM
-Judges are held accountable through impartial decision making
procedures: 4 BM

[Link] Slide 50
 PERFORMANCE AREA 7: INDEPENDENCE
OF PUBLIC PROSECUTION SERVICE

Indicators:
-Prosecutor General is appointed and dismissed transparently
and on the objective grounds: 3 BM
-Appointment, promotion, and accountability of prosecutors are
based on fair and clear mechanisms: 4 BM
-The budget of the public prosecution service, remuneration
and performance evaluation of prosecutors guarantee their
autonomy and independence: 3 BM
-The status, composition, functions, and operation of the
Prosecutorial Council guarantee the independence of the public
prosecution service: 6 BM

[Link] Slide 51
 PERFORMANCE AREA 8: SPECIALISED
ANTI-CORRUPTION INSTITUTIONS

Indicators:
-The anti-corruption specialisation of investigators and
prosecutors is ensured: 3 BM
-The functions of identification, tracing, management and
return of illicit assets are performed by specialised officials: 2
BM
-The appointment of heads of the specialised anticorruption
investigative and prosecutorial bodies is transparent and merit-
based, with their tenure in office protected by law: 4 BM
-The specialised anticorruption investigative and prosecutorial
bodies have adequate powers and work transparently: 2 BM

[Link] Slide 52
 PERFORMANCE AREA 9: ENFORCEMENT
OF CORRUPTION OFFENCES

Indicators:
-Liability for corruption offences is enforced: 9 BM
-The liability of legal persons for corruption offences is provided
in the law and enforced: 6 BM
-Confiscation measures are enforced in corruption cases: 5 BM
-High-level corruption is actively detected and prosecuted:3 BM

[Link] Slide 53
 THEORIES OF CHANGE

Old models or frameworks for anti-corruption policies focus explicitly

on the results chain from inputs to outcomes (and impacts). They
fail to take into consideration external factors that may either
influence outcomes or are beyond the control of project parameters.

Theories of Change add elements of explanation and consideration

of external influences to the results chain, they link outcomes and
activities to explain how and why the desired change is expected to
happen. Theories of change also make explicit the political and
economic processes that serve as both preconditions to project
activities as well as limitation factors in the process of change.

[Link] Slide 54
 THEORY OF CHANGE AND ANTI-
CORUPTION, I.

Decreasing corruption is about changing behaviours, attitudes, and the

structures of accountability, transparency, and integrity. Old models of change
that rely on a stable set of outputs are rarely adequate to capture the multiple
actors, relationships, and behaviours that characterize anti-corruption efforts.

Jonathan Fox argues that “when accountability efforts actually work, it is often
because initiatives in one arena trigger pro-accountability actions in another“.
Therefore, anti-corruption efforts are not bound by location, time, or actor.

Theory of change is a way to fight corruption by taking into account all, internal
and external elements. Unfortunately, many anti-corruption interventions do
not have a built-in theory to guide the results chain, making it difficult to
meaningfully track the progress and measure the desired results. Theory of
change makes known the underlying assumptions about why and how an AC
policy will be successful, and maps out the intermediate steps that must be
taken to reach a long-term result. An explicit theory of change outlines a
robust framework for monitoring, and more importantly, leaves an evidence
trail for evaluation purposes.

[Link] Slide 55
 THEORY OF CHANGE AND ANTI-
CORUPTION, II.

It should be done in the following manner:

1. Preparatory analyses (analysis of the political and economic
processes that prevail in the project context (country/region/local
community), including the incentives, relationships, distribution and
contestation of power among stakeholders).
2. Mapping of results chain (identification of long-term goals and
mapping out the steps needed to reach those goals).
3. „Reality check“ (consideration of the internal logic of the results
chain, and the external factors that may influence outcomes).
4. Building the theory of change (identification of preconditions that
are necessary for plausible causal pathways to occur, as well as the
challenges that may prevent goals from being achieved).
5. Validation or revision of designed AC policy/plan (based on the
outcomes identified, and given the prevailing political and economic
constraints, indicators and targets are developed to monitor
performance and assist with evaluations.)

[Link] Slide 56
 AN EXAMPLE OF A
THEORY OF CHANGE
IV Impacts changes in
Timely and efficient transnational cooperation against corruption
conditions in 10-15 years,
that are tangible, specific, A global community of anti-corruption practitioners informally cooperates effectively and efficiently to detect corruption, progress investigations and advance
plausible, why, for whom transnational corruption cases.

III Outcome changes in

GlobE and partners are progressing investigations and advancing transnational corruption cases through informal cooperation at an impactful scale, working in a synergistic manner
capacities and/or
performance of duty Full operational coordination with partners Practitioners of GlobE authorities consistently use informal cooperation effectively
bearers to which GlobE, and
others, directly contributed Growing trust between practitioners, authorities & regional components, in GlobE & between GlobE & partners drive cooperation

Growing GlobE partner Increased Bi & m Increased SCP case More use of site More
II Outputs changes in Right global Effective More practitioners
collaborations case collaborations collaborations and practitioner knowledge
capacities, skills or abilities, GlobE regional trained on more
systems or availability of More GlobE observers and components Increased bi-& Increased right SCP and regional resources training modules
membership
new products and services observership multilaterals users subsites and tools
delivered by GlobE
GlobE plenaries and events grow in in-person participation, have high connections and engagement and deliver useful outcomes

Advocate Build Serve Practitioners

I Activities for partnerships
Foster collaboration
Performed by GlobE Support
Synergise Build trust Increase informal
Build trust
Increase
Primary beneficiaries are p Case
SCPSCP Support Increase cooperation
c regional
the member r usage practitio- on cases
G a
o usage
compon ner site
practitioners r c
o
l p Coordinate ents usage
Secondary beneficiaries o
t
i
e
Enable connections Enhance capacity
are the authorities and o c
r

other relevant
l a
a Host case and
b l
t
Cooperate
Host interactive Provide SCP Provide knowledge thematic
organizations, bodies and e i plenary & events & grow right resources & tools discussions
networks E c
o
users
n
a Hold training Facilitate peer-
s Grow no. of right Trust in events to-peer learning
e
Collaborate members & states secretariat

Problem statement Anti-corruption law enforcement practitioners do not have connections with peers across the world, are not all comfortable with informal cooperation, and don’t have a
identifies the key secure way to directly communicate globally
problem conditions Corruption and its negative consequences are a global reality. Cases quickly become transnational. Transnational anti-corruption law enforcement cooperation is difficult. Domestic
and their cause-and- legislation differs and mutual legal assistance processes take a long time. Cases often involve politically connected persons and case material is confidential or classified. Requiring
effect relationships competence, trust and secure communication, informal cooperation is under-utilised.

[Link] Slide 57
 INDICATORS AND
AC THEORY OF CHANGE

Indicators identified through different CRAs enable us to assess

the effectiveness of the AC efforts/effectiveness of the AC theory
of change – but only if these indicators are SMART:

- Specific: Is the indicator specific enough to measure progress

towards the results?
- Measurable: Is the indicator a reliable and clear measure of
results?
- Attainable: Are the results in which the indicator seeks to chart
progress realistic?
- Relevant: Is the indicator relevant to the intended outputs and
outcomes?
- Time-bound: Is data available at reasonable cost and effort?

[Link] Slide 58
 PRACTICAL HINTS TO FIGHT
CORRUPTION IN THE PUBLIC SECTOR, I.
1. Notwithstanding the organised approach to prevent and fight
corruption risks through CRAs, there will always be cases of officials‘
corrupt or other misbehaviour.

2. Each public institution has to have a manager or unit (group,

department,..), able to identify misbehaviour of the officials. In some
countries, they use „inspectors general“, „general counsels“ (USA), in
other countries they use „internal affairs units“ (mostly in the law
enforcement sector), and in some countries they use „compliance
mechanisms“. There are also countries, where identification of
misbehaviour is a task of general managers.
3. Identified misbehaviour can be sanctioned in the labour proceedings (as
disciplinary breach, investigated or sanctioned by the institution itself),
in the administrative proceedings (as administrative breach or
misdemeanor, investigated and sanctioned either by the institution
itself or by external authority) or in the criminal proceedings (as
criminal offence, investigated by the law enforcement agencies and
sanctioned by judiciary).
[Link] Slide 59
 PRACTICAL HINTS TO FIGHT
CORRUPTION IN THE PUBLIC SECTOR, II.

4. Whatever the organisation of the institution looks like, its managers

have to ensure that no misbehaviour is left unpunished. This policy and
rules defining the desired behaviour (codes of conduct, codes of ethics,
internal rules,...) of officials have to be known to every official in the
institution.

5. When concrete cases of misbehaviour are dealt with, the management of

the institution has to ensure transparency of proceedings and their
outcomes (respecting the legal right to privacy) in order to use these
proceeding as a general preventive measure.
6. Not only sanctions assist in maintaining the integrity of the institution,
what is equally important is that institutions reward (not necessary
financially!) officials showing an exemplary respect of rules of behaviour!

[Link] Slide 60
 PRACTICAL HINTS TO FIGHT
CORRUPTION IN THE PUBLIC SECTOR, III.

7. Managers of the institutions have to serve as models for the

behaviour of „their“ officials – in their official capacity but also in their
private life.

8. In the UNCAC, there is a whole set of measures, preventing

corruption in the public sector, of which the folowing ones are the most
important ones: political will, preventive policies, preventive agencies,
recruitment and promotion of public officials, prevention of conflicts of
interests, codes of conduct. reporting on assets and interests, proper
public procurement, transparent management of public finances, public
reporting,whistleblowing, legislative traceability, participation of society
and anti-corruption training.
9. Prevention is just as important as repression but citizens don‘t care
about it (prevention) if they don‘t see corrupt individuals brought to
justice!

[Link] Slide 61
 THE MOST IMPORTANT LESSON:

THERE SHOULD BE NO
UNTOUCHABLES!!!

[Link] Slide 62
 SOURCES:

➢ OECD 2021 Recommendation for Further Combating Bribery of Foreign Public Officials in
International Business Transactions, 2021 OECD Anti-Bribery Recommendation – OECD
➢ OECD Istanbul AC Action Plan 5th Round of Monitoring Assessment Framework (Istanbul-
[Link]
([Link]))
➢ Transparency International, Corruption Risk Assessment – Topic Guide, Corruption Risk
Assessment Topic Guide
➢ UNCAC, UNITED NATIONS CONVENTION AGAINST CORRUPTION
➢ UNDP, Users Guide – Measuring Corruption and Anti-Corruption, User's Guide - Measuring
Corruption and Anticorruption | United Nations Development Programme ([Link])
➢ UNODC GlobE, Theory of Change, GlobE Network ([Link])

[Link] Slide 63
Thank you for
your attention!

[Link]