EU Catalogus

Catalogue of
promising practices
in the field of integrity,
anti-corruption and
administrative measures
against organized crime
in the EU
november 2008
Commissioned by the Ministry of the Interior and

Kingdom Relations of the Netherlands
Executed by the Utrecht School of Governance
Utrecht University
Content
Chapter 1: Introduction .............................................................................7
Chapter 2: Acquis of Anti-corruption and Integrity measures ............10

2.1 Introduction
10
2.2 Content of the Acquis
10
2.3 EUPAN Ethics Framework document 2004
14
2.4 Reflection
14
Chapter 3: Three ways to read this catalogue .......................................15

3.1 Introduction
15
3.2.1 Contributions by member states
15
3.2.2 Contributions by the European Commission
18
3.3 Categories
23
General principles of good administration codified
23
Integrity codes for public officials
24
Transparency / confidentiality and accountability on central and decentralised level
24
Preventive measures: compliance instruments and awareness raising of staff
24
Anti-corruption measures and administrative vigilance
25
Public procurement
25
Legal incompatibilities and other forms of conflicts of interest
25
Financing of political parties and/of electoral campaigns
26
Special innovative cases
26
3.4 Specific themes
26
Compliance and integrity
27
Prevention and Anti-corruption
27
Public Administration and Police
27
Organizations and networks
28
3.5 Reflection
28
Chapter 4: Promising practices ...............................................................29

4.1 Introduction
29
4.2 Austria
30
Anti-Corruption Awareness Raising within Austrian Law Enforcement Entities
and Beyond
30
4.3 Belgium
33
Coordinator of Integrity Care
33
4.4 Denmark
37
Drafting a Code of Conduct for Public Employees
37
Content
4.5 Estonia
40
Reward System for Whistleblowing by Police Officers
40
4.6 European Commission
42
1. Training on Ethics and Integrity in the Commission
42
2. Ethics Day Seminar
44
3. Guidelines for Applying Article 22 of the Staff Regulations on the Financial

Liability of Officials
46
4. Internal Control Standards for Effective Management
48
4.7 Finland
50
Values to be Part of the Daily Job
50
4.8 France
53
Annual Reports on Fraudulent and Corrupt Practices
53
4.9 Germany
55
Recommendations for implementing the Federal Government Directive Concerning

the Prevention of Corruption in the Federal Administration
55
4.10 Hungary
57
Anti-Corruption Coordination Board
57
4.11 Ireland
60
Requirements for the Disclosure of Interests
60
4.12 Italy
63
Code of Conduct for Government Employees
63
4.13 Latvia
66
The Corruption Prevention and Combating Bureau
66
4.14 The Netherlands
70
1. Public Administration Probity in Decision-Making Act (BIBOB): Promotion of

Integrity Assessment by Public Administration
70
2. The National Office for Promoting Ethics and Integrity in the Public Sector
72
3. The Integrity Cube: a Multimedia Dilemma and Training Instrument
75
4.15 Poland
78
1. Ethical Principles of Police Officers
78
2. Moral Integrity in the Work of a Police Officer as a Public Official
79
4.16 Slovenia
82
Implementing Integrity Plans
82
4.17 Spain
85
1. Act regulating the conflicts of interest of the Members of Government and the
Senior Officials of the General State Administration
85
2. Code of Good Governance of the Members of Government and the Senior Officials
of the General State Administration
87
4.18 Sweden
89
1. National Network Against Corruption
89
Content
2. Openness as a Means for Democracy and for Preventing Corruption
91
4.19 United Kingdom
95
1. Inquiries into Policy Issues Relating to Standards of Conduct by Elected and

Appointed Public Office-holders
95
2. Whistleblowing (speaking up) - the raising of a genuine workplace concern about

serious malpractice
97
Chapter 5: The Integrity Infrastructure Model.....................................102

5.1 Introduction
102
5.2 Role of top management
103
5.3 Core values and standards
104
5.4 Structures and processes
105
5.5 Culture and personnel policy
105
5.6 Incidents
106
5.7 Evaluation and reports
107
5.8 Reflection
107
The Integrity Infrastructure Model: promising practices per area of attention
110
Chapter 6: Looking back and ahead .....................................................112

Annex 1: Overview of EU acquis of Anti-corruption and Integrity
measures
114
Annex 2: Format of promising practices
116
Annex 3: Overview of promising practices by sections
124
Annex 4: Literature
126
This catalogue is the result of a commitment made by the Netherlands during

its presidency of the European Union in 2004. In that year, the Irish and Dutch
EU presidencies put the issue of integrity firmly on the European agenda.
Ethics Framework
In the first half of 2004 a study of common values and elements of
ethics policy among the EU member states was commissioned in the
framework of EUPAN (European Public Administration Network). The
results of that study were collected in a report entitled Ethics in the
Public Services of the EU Member States. Under the Dutch presidency,
that initiative was followed up with a second report entitled Working
towards common elements in the field of ethics and integrity and a
document entitled Main Features of an Ethics Framework for the Public
Sector, which contained a Resolution on Ethics in the Public Service.
This resolution was adopted on 22 November 2004 by the Directors
General Responsible for Public Administration in the EU at their 43rd
meeting in Maastricht. The resolution included a commitment by all
the Directors General to enforce the Ethics Framework throughout the
public service. The Directors General agreed that the framework could
help EU member states to generate awareness of ethics and integrity in
the public service and facilitate further discussion of ethics and
integrity in the member states. The Directors General further agreed
that the framework would enable EU member states to stimulate
innovation, improvement and implementation with regard to ethics
policies in public administration.
This 2004 framework document set out the common values and
standards which member states believe to be important for the public
service to function effectively and could serve as a toolkit for the
development of concrete policies. In addition to these core values, the
framework offered a number of guidelines for its implementation, such
as suggestions for a whistleblowing procedure. However, further
initiatives were badly needed.
Sharing practices
Accordingly, on 6 February 2006 the member states and the European
Commission met and decided to share experiences and information on
integrity, anti-corruption efforts and administrative measures against
organized crime. A Dutch-chaired open working group was established
and went on to propose the publication of an EU catalogue of good anticorruption and integrity practices. The member states and the
European Commission were invited to share their own good practices in
this area.
7
The actual project started soon afterwards. In May 2006, member states
and the European Commission were invited to submit good practices
they felt were promising. A format was devised to provide a structure
for providing the information about the practices in order to make the
practices easily accessible for other interested parties (see annex 1).
Several contributions were presented and discussed during a first
informal meeting of the working group in Scheveningen in July 2006.
They included practices from Austria, Denmark and the Netherlands.
This meeting was attended by a relatively small number of member
states, Austria, Belgium, Denmark, Malta, the Netherlands, Slovakia,
and Sweden, but also by the European Commission and Eurojust.
During a second informal meeting of the working group in Amsterdam
in November 2006, practices from Bulgaria, Belgium, Ireland, Slovenia
and the United Kingdom were presented and discussed. This meeting
was attended by a large group of member states and international
organizations. The countries that attended were Austria, Belgium,
Bulgaria, Denmark, Finland, France, Germany, Ireland, Luxembourg,
Malta, the Netherlands, Slovenia, Spain and the United Kingdom. The
European Commission also attended (DG Admin). The participating
international organizations included the United Nations (UN Office for
Project Services), Eurojust and Europol, as well as the European
Institute for Public Administration and the Dutch Police Academy. The
catalogue was finalized (as version 1.0) in the summer of 2008.
Results
You are about to read the first results of that work. This EU catalogue
contains 27 promising and inspirational practices relating to integrity,
anti-corruption activities and administrative measures against
organized crime. The catalogue presents a wide range of tools that can
be employed to safeguard integrity and combat corruption. They are
examples of specific measures that have raised quality standards
within the public administration and public sectors of the member
states concerned. The promising practices are presented in a common,
consistent format in order to maximize their accessibility and to
provide a clear insight into the approaches that have been chosen, their
success and possible pitfalls. The contents also provide the readers with
a glimpse of what goes on behind the scenes in the public sector in EU
member states and the European Commission and may offer useful tips
for their organization.
One of the goals of this catalogue is to learn from each other and at
least as important inspire each other to push the boundaries of
innovation and improvement in our own organizations.
Whats next?
In addition to this printed version, there is a provisional digital version
of this EU catalogue at www.integriteitoverheid.nl, where additional
examples of promising practices in promoting integrity, fighting
corruption and administrative measures to combat organized crime can
be added later. Accordingly, the format used on the website will be the
same as in this book. All the member states and EU organizations are
cordially invited to keep sending in their latest initiatives so that the
catalogue can continue to grow and stay up to date.
I hope that, with the help of this catalogue, we can continue to share
experiences, engage in a dialogue about integrity issues and discuss
how, together, we can make even greater strides forward in the future.
Mrs G. ter Horst

Minister of the Interior and Kingdom Relations of the Netherlands
2.1 Introduction
The practices presented in this catalogue do not function in a vacuum
but are shaped, and sometimes initiated, by relevant national acts and
international conventions, agreements, and protocols. Before
presenting the promising practices, it is therefore necessary to describe
the European and wider international context of these practices.
This chapter outlines the current legislative-jurisdictional context of
anti-corruption and integrity measures of member states of the EU. This
acquis is constantly evolving and generally includes:
the contents, principles and political objectives of the treaties on
which the European Union is founded;
legislation and decisions adopted pursuant to the treaties and the
case law of the Court of Justice;
other acts, legally binding or otherwise, adopted within the Union
framework, such as inter-institutional agreements, resolutions,
statements, recommendations, guidelines;
joint actions, common positions, declarations, conclusions and other
acts within the framework of the common foreign and security policy;
framework decisions, joint positions, conventions signed, resolutions,
statements and other acts agreed within the framework of justice
and home affairs;
international agreements concluded by the Communities, the
Communities jointly with the member states and the Union and
those concluded by the member states among themselves with
regard to Union activities.
The acquis has been reconfigured in the course of the accession
negotiations with Turkey and Croatia. The anti-corruption measures
have been inserted in a new chapter 23, Judiciary and Fundamental
Rights. According to that, member states must fight corruption
effectively as it represents a threat to the stability of democratic
institutions and the rule of law. A solid legal framework and reliable
institutions are required to underpin a coherent policy of prevention
and deterrence of corruption. The following section describes the main
elements of this acquis.
2.2 Content of the acquis
10
There are 35 chapters in the acquis for new member states. Chapter 23
contains an indicative list of conventions and instruments to which the
new member states must accede in accordance the Act of Accession
and an indicative list of international agreements, conventions and

protocols to which member states must indirectly accede. The main
international partners are the Council of Europe, the United Nations
(UN), and the Organization for Economic Cooperation and Development
(OECD). An overview of this part of the acquis can be found in annex 1.
EU Legislation in force
Combating corruption in the public sector is not an area of Community
competence, it remains the sole responsibility of the Member States,
except in cases concerning the protection of the EU financial interests.
In this respect, the 1996 Protocol to the EU Convention on the
protection of the Communities financial interests requires Member
States to make both the deliberate giving and deliberate acceptance of a
bribe or advantage, leading to a breach of duty which damaged or was
likely to damage the Communities financial interests, an offence under
their criminal law.
The 1997 EU Convention on the fight against corruption involving
officials of the European Union or officials of Member States of the
European Union criminalised corruption involving public officials, it
requires Member States to be able to investigate and prosecute cases,
even when they involve an official of another Member State or of the
European Union.
As regards to combating corruption in the private sector, Framework
Decision 2003/568/JHA requires Member States to provide for offences
of corruption in the private sector whether involving a profit or nonprofit organization and to extend the offences beyond those which
distort competition in relation to the purchase of goods or commercial
services, unless they make a formal declaration to retain this limit.
11
Non-binding rules: the 10 Principles

The 10 Principles for Improving the Fight against Corruption in
Acceding, Candidate and Other Third Countries are central. These
principles are laid down in the Commissions Communication on a
comprehensive EU Policy against Corruption (Com(2003)317). The 10
principles are:
a clear stance against corruption by leaders and decision makers;
full alignment with the EU acquis and ratification and
implementation of all main international anti-corruption
instruments;
implementation of anti-corruption laws by competent and visible
anti-corruption bodies;
access to public office for every citizen;
integrity, accountability and transparency in public administration
should be raised through the employment of quality management
tools and auditing and monitoring standards;
the establishment and monitoring of codes of conduct in the public

sector;
the adoption of clear rules on whistleblowing in both the public and
private sector;
increasing public intolerance of corruption through awarenessraising campaigns in the media and training;
clear and transparent rules on political party financing;
the development of incentives for the private sector to refrain from
corruption.
These principles are laid down in the Commissions Communication on
a Comprehensive EU Policy against Corruption (Com(2003)317).
International Conventions
Indirectly, the acquis for member states of the EU is formed by
international agreements, conventions and protocols. Key elements of
this part of the acquis are the Council of Europes Criminal Law
Convention on Corruption, the evaluation conducted by GRECO and the
United Nations Convention against Corruption (UNCAC).
The Council of Europes Criminal Law Convention on Corruption is an
instrument designed to harmonize the criminalization of a large
number of corrupt practices. It also provides for complementary
criminal law measures and for improved international co-operation in
the prosecution of offences involving corruption.
The Convention covers the following forms of behaviour which are
normally regarded as specific types of corruption:
active and passive bribery of domestic and foreign public officials;
active and passive bribery of national and foreign parliamentarians
and of members of international parliamentary assemblies;
active and passive bribery in the private sector;
active and passive bribery of international civil servants;
active and passive bribery of domestic, foreign and international
judges and officials of international courts;
active and passive trading in influence;
money laundering of proceeds from corruption offences;
accounting offences (invoices, accounting documents, etc.) connected
with corruption offences.
According to this Convention, states are required to provide for
effective and dissuasive sanctions and measures, including deprivation
of liberty that can lead to extradition. Legal entities must also be liable
for offences committed to benefit them and be subject to effective
criminal or non-criminal sanctions, including monetary sanctions.
12
The Convention also incorporates provisions concerning aiding and

abetting, immunity, criteria for determining the jurisdiction of States,
liability of legal persons, the establishment of specialist anti-corruption

bodies, protection of persons collaborating with investigating or
prosecuting authorities, gathering of evidence and confiscation of
proceeds. It also provides for enhanced international co-operation
(mutual assistance, extradition and the provision of information) in the
investigation and prosecution of corruption offences.
The Group of States against Corruption (GRECO) was established in 1999 by
the Council of Europe to monitor compliance by the member states
with the organizations anti-corruption standards. The objective of
GRECO is to improve the capacity of its members to fight corruption by
monitoring their compliance with Council of Europe anti-corruption
standards through a dynamic process of mutual evaluation and peer
pressure.
By means of Mutual Evaluation Rounds, GRECO helps to identify
deficiencies in national anti-corruption policies, prompting the
necessary legislative, institutional and practical reforms. It also
provides a platform for the sharing of best practices in the prevention
and detection of corruption.
The United Nations Convention against Corruption, in particular some
specific articles of chapter 2 on preventive measures, calls upon states:
to develop and implement or maintain preventive anti-corruption
policies and practices (article 5);
to insure the existence of preventive anti-corruption body or bodies
(article 6);
to enhance transparency and prevent conflicts of interest in the
public sector (article 7);
to promote, inter alia, integrity, honesty and responsibility among its
public officials by applying codes or standards of conduct for public
officials (article 8);
to establish appropriate systems of public procurement and promote
transparency and accountability in management of public finances
(article 9);
to enhance transparency in public administration by, inter alia, public
reports on the risks of corruption (article 10);
to take measures to strengthen integrity and to prevent opportunities
for corruption among members of the judiciary and prosecution
services (article 11).
An example of a code of conduct is the International Code of Conduct
for Public Officials contained in the annex to the General Assembly
Resolution 51/59 of 12 December 1996. This code covers the following
topics: general principles, conflict of interest and disqualification,
disclosure of assets, acceptance of gifts or other favours, confidential
information, and political activity.
13
2.3 EUPAN Ethics Framework document 2004

The EUPAN Framework on Ethics, agreed upon by the Director-Generals
of public services of all EU-member states in November 2004 provides
useful guiding principles which constitute the essence of the
appropriate discharge of public-staff duties. The expansion of the
discretionary powers of administrative bodies, the changes in
administrative relations and the emphasis placed on interactive policymaking nowadays have all created more scope for civil servants
individual responsibilities. The Ethics Framework introduces various
measures to facilitate the detection, investigation, prosecution and
adjudication of corruption cases, such as common standards for
collection of evidence or protection for whistleblowers, victims and
witnesses of corruption but also recommends that Member States
might engage, for example, through the EUPAN network in a
comprehensive dialogue within the EU on common administrative
integrity standards in public administrations and policies across the EU.
An ideal integrity policy would focus on the prevention of damage to
integrity in a manner that offers scope for the individual
responsibilities and requires civil servants to arrive at carefully
considered decisions on specific integrity issues within society and
administration. For this reason integrity policy should also place great
emphasis on cultural issues.
The Document Main Features of an Ethics Framework for the Public
Sector contains common elements and points out the determining
factors for ethical behaviour and may help EU Member States to
generate awareness of ethics and integrity in the public service, may
facilitate further discussions on ethics and integrity in the EU Member
States and may serve as a framework document and/or general
guideline for the implementation or development of ethics and
integrity in the public sector. It was meant to provide an important tool
in fostering an appropriate culture within public administrations.
2.4 Reflection
As the acquis shows, the EU has demonstrated a strong and lengthy
commitment to fighting corruption and fostering integrity. As a whole,
it provides a framework within which measures can be and are taken. It
is within this framework that this catalogue proves its relevance. It is
the first document in which working practices in this field have been
collected, presented and made accessible to member states.
Having described the acquis, it is now time to present the promising
practices themselves.
14
3.1 Introduction
As mentioned in the introduction, this catalogue contains 27 promising
practices. These practices were submitted by member states in
response to an open call for contributions. In other words, the practices
presented here were chosen by the member states themselves.
Consequently, these practices do not provide a systematic and
representative picture of instruments in place but give an impression of
practices which have already proved themselves or can be described as
promising in view of the initial results.
There are three ways of studying the practices contained in this
catalogue. The first is by contributor, the second is by category and the
third is by specific theme. These three methods are fleshed out in the
next three sections of this chapter.
3.2 Contributors
3.2.1 Contributions by member states
This section provides an overview of the eighteen contributors and
their contributions. Four member states sent in two practices each, the
Netherlands submitted three practices and the European Commissions
DG Admin contributed four practices for the catalogue and provided an
overview of its corruption prevention policy by means of fostering
ethics and integrity. This section provides brief descriptions of the
promising practices submitted by the contributing member states in
alphabetical order. The practices are described in full in chapter 4.
Austria sent in the project entitled Anti-Corruption Awareness Raising
within Austrian Law Enforcement Entities and Beyond as a promising
practice. This practice describes a campaign and educational activities
organized by the Federal Bureau for Internal Affairs (BIA) as part of a
series of preventive measures taken by the Ministry of the Interior in
the fight against corruption.
The promising practice from Belgium is the recent creation of the
position of Coordinator of Integrity Care. This function is part of the
structure of integrity management in the Flemish government. The
coordinators principal tasks are knowledge management, providing
input, follow-up and feedback with respect to integrity policy,
supporting the Commission for Integrity Care, networking, providing
advice and carrying out projects.
15
The promising practice from Denmark describes the recent process of

drafting a Code of Conduct for Public Officials and the lessons learned
in the course of that process. The code of conduct is expected to be
published before the summer of 2007.
Estonia submitted a promising practice involving the introduction of a
reward system for whistleblowing by police officers. In this system, a
police officer has to inform his or her superior when a person continues
to offer bribes after being warned. If the case is proved in court, the
police officer is entitled to a reward.
The Values to be Part of the Daily Job is a project that was submitted as
a promising practice from Finland. The goal of this project was to
incorporate value-driven activity and management into everyday work.
A promising practice from France is the preparation of annual reports
by the Service Central de Prvention de la Corruption (SCPC). These
reports contain studies of fraudulent and corrupt practices in individual
risk areas.
The Federal Ministry of the Interior of Germany sent in the Federal
Government Directive Concerning the Prevention of Corruption in the
Federal Administration. The annexes to this directive contain the AntiCorruption Code of Conduct and Guidelines for supervisors and heads
of public authorities/agencies. The directive is accompanied by nonbinding recommendations for implementing the directive. Together,
they can be considered a toolbox for preventing corruption in the
federal administration.
From Hungary we received the promising practice of the Advisory
Board for Corruption-Free Public Life. This board is made up of
representatives from government and civil society. The tasks of the
board are to conduct research relating to corruption, to provide advice
on anti-corruption measures and to liaise with international
organizations. The board is the coordinating body of the National AntiCorruption Action Plan.
The promising practice from Ireland concerns the role of the Standards
in Public Office Commission in relation to the disclosure of interests.
This Commission is provided for by the Ethics in Public Office Act 1995
and the Standards in Public Office Act 2001.
Italy submitted the Code of Conduct for Government Employees of 28
November 2000. This code lays down principles and criteria for the
everyday conduct of public employees. The code was evaluated in 2002
by the Inspectorate Office of the Department for Public Administration.
16
The role of the Corruption Prevention and Combating Bureau is a
promising practice from Latvia. The bureaus activities cover three main
areas: prevention of corruption, combating corruption and educating
the public on corruption issues. One aspect of the bureaus preventive
work is to monitor the financing of political parties and violations of
the relevant rules.
The contribution from the Netherlands consists of three promising
practices: the activities of BIBOB, the National Office for Promoting
Ethics and Integrity in the Public Sector and the Integrity Cube.
The promising practice of BIBOB describes the activities of the Bureau
BIBOB, which are based on the Public Administration Probity in
Decision-Making Act (BIBOB). The task of this bureau is to screen the
criminal antecedents of applicants for licences, subsidies and/or
tenders.
The National Office for Promoting Ethics and Integrity in the Public
Sector facilitates public sector organizations to implement integrity
policy within their organization. The National Office developed several
integrity instruments, guides and manuals to enable them to do this.
The Integrity Cube is an instrument designed to stimulate discussion of
integrity within government organizations and to increase awareness
of integrity among management and staff.
Both promising practices from Poland have to do with principles of
police ethics. One practice involves a document setting out ethical
principles and behavioural models that serve as a guide for police
officers in the performance of their duties and in their private lives. The
other practice describes the incorporation of these principles as an
element of police education at every level of police training.
The promising practice from Slovenia describes the implementation of
integrity plans in public bodies and local community bodies in the
Republic of Slovenia. The implementation of these plans is based on the
Prevention of Corruption Act (ZPKor).
17
From Spain we received two interesting contributions. The first is the

Agreement Approving the Code of Good Governance of Members of
Government and Senior Officials of the General State Administration,
and the second is Act 5/2006 regulating conflicts of interest of the
Members of Government and the Senior Officials of the General State
Administration. One aspect of the Agreement is that annual report has
to be produced concerning possible non-compliance with principles of
ethics and good conduct. The purpose of the report is to analyze the
procedures and actions that apply in the event of non-compliance and
to propose measures that are deemed appropriate to guarantee the
objectivity of decisions by the administration and public institutions.
Due to the recent implementation of this agreement no annual reports
or additional information are available yet. The act regulating conflicts

of interest contains a section on a sanctioning system.
Sweden has sent in two promising practices. The first concerns the role
of transparency in the Swedish public service as a means of promoting
democracy and preventing corruption. The second concerns the
activities of a national anti-corruption network set up by the National
Anti-Corruption Unit.
From the United Kingdom there are two promising practices, one on
inquiries into policy issues relating to standards of conduct by elected
and appointed public office holders, and one on whistleblowing.
The practice involving inquiries describes the activities of the
Committee on Standards in Public Life (CSPL). This committee
undertakes, on average every year, a public inquiry into a policy area
related to standards of conduct in public life where there have been or
are ongoing public concerns.
The promising practice of whistleblowing describes the background,
mechanics and effects of the Public Interest Disclosure Act of 1988 in
relation to the role of Public Concern at Work (PCaW), an independent
self-funding non-governmental organization dedicated to public
interest whistleblowing.
3.2.2 Contributions by the European Commission
This section provides an overview of the Commissions corruption
prevention policy by means of fostering ethics and integrity.
Introduction
Commission officials are public servants. Officials (and other members
of staff employed under the conditions of employment of other
servants) are paid, ultimately by the European taxpayer, to assist the
Commission in carrying out its responsibilities to the best of their
ability, to be productive and to obtain results in connection with the
Commissions annual work programme. As officials are in public
administration, staff rules require them to behave with the utmost
probity. In their work, they must act exclusively in the public interest
and in particular in the service of the European Union, to the exclusion
of all other interests, whether national, personal, private or of a
voluntary or philosophical origin or character.
18
The Commissions credibility in performing its tasks, both externally

and internally, is based, in part, on the conduct of its staff and in
particular its senior staff, who have been asked to give a lead in these
matters. It is expected that those who work for the Commission, do so
with objectivity, independently and for the good of the greatest number.
Their conduct has to be subject to clearly enunciated ethical rules
which must be adhered to.
This is a considerable challenge in a multicultural institution with

different attitudes, cultures and a variety of public expectations of 27
Member States.
The staff of the European Commission have to work and act according
to the Staff Regulations which are in place for all Community
Institutions. Moreover, officials have to act according to the
Commissions Internal Control Standards which directly affect the
management of human resources within Directorates-General and
cover issues such as compliance with the Commissions Code of Good
Administrative Behaviour, the maintenance of professional standards
as well as the need to report any actions which do not fully comply
with the relevant norm. In order to refresh the awareness on ethics and
to put the staffs obligations in a general wording applicable to all
situations, the Commission adopted on 5 March 2008 a Communication
on Enhancing the environment for professional ethics. It proposes to
discuss and ultimately adopt by 2009 four broad principles of
professional ethics which define staffs obligations:
1. Upholding public interest and accountability
2. Competence, responsibility and objectivity
3. Safeguarding public assets and information
4. General conduct
With the revised Staff Regulations that entered into force in 2004,
individual responsibilities were reinforced, especially in the field of
financial liability and procurement. As laid down in Article 22, members
of staff are required to make good, in whole or in part, any damage
suffered by the Communities as a result of serious misconduct in
connection with the performance of their duties. Obviously, this does
not concern a simple error or a slight mistake causing financial damage.
However, financial liability could be incurred where a member of staff
disregards a legal obligation, has caused financial damage and is guilty of
deliberate misconduct or gross negligence. [See Guidelines for applying
Article 22 of the Staff Regulations as an example of good practice].
Another issue of relevance is the Commissions rotation policy whereby
managers and others occupying posts designated as "sensitive" are
moved on after five years as a rule and a maximum of seven years. The
object of the policy is to bring fresh and innovative approaches into top
level management as well as to avoid individuals accumulating power
and resources. [See Internal Control Standards as an example of good
practice].
19
Information on almost all these matters can be found on the European

Civil Service website
http://ec.europa.eu/civil_service/admin/ethic/index_en.htm and on the
website of the European Transparency Initiative at
http://ec.europa.eu/civil_service/admin/transp/index_en.htm
For the purpose of deterrence, comparable sanctions should apply to

civil servants of the EC institutions and to national ones. To that end a
Convention on the fight against corruption involving officials of the
European Communities or officials of Member States of the European
Union was drawn up by the Council Act of 26 May 1997 (See OJ C 195/01
26.5.1997). According to this Convention, passive corruption is defined
as the deliberate action of a Community official, who, directly or
through an intermediary,
requests or receives advantages of any kind whatsoever, for
him/herself or for a third party, or accepts a promise of such an
advantage,
to act or refrain from acting in accordance with his/her duty or in the
exercise of his/her functions in breach of his/her official duties
(Article 2).
Similarly, active corruption is also defined as an act involving breach of
duties (Article 3). According to the Convention, each Member State shall
take the necessary measures to ensure that conduct of the types
mentioned above is made a criminal offence.*
Deontological set
There is a broad range of rules, codes of conduct and guidelines in place
which staff are required to follow. They include (enumeration not
conclusive):
The Staff Regulations of Officials of the EC (in particular Articles
11-23, regulating the conduct of officials and former officials, e.g. the
requirement to restrain from harassment and the rules on whistleblowing
http://ec.europa.eu/dgs/personnel_administration/statut/tocen100.pdf
General implementing decisions adopted by each Institution on the
basis of the Staff Regulations, e.g. the Commission Decision on
outside activities, guidance on favours, gifts and hospitality: these
will be revised to provide clearer guidance as part of the follow-up to
the Commission Communication on Professional Ethics mentioned
above).
The Code of Good Administrative Behaviour (regulates dealings with
the public) http://ec.europa.eu/civil_society/code/index_en.htm
Internal Control Standards
http://ec.europa.eu/budget/documents/implement_control_en.htm
The Financial Regulation and implementing rules and procedures
http://ec.europa.eu/europeaid/work/procedures/legislation/financial_
regulation/index_en.htm
Regulation 45/2001 on the protection of personal data
http://ec.europa.eu/
dataprotectionofficer/regulation/index.cfm?TargetURL=D_REG
20
* This wording reflects the wording already used for offences of passive and active corruption in relation to
the Communities' financial interests, in Articles 2 and 3 of the Protocol to the Convention on the protection
of the European Communities' financial interests (Council Act of 27 September 1996 96/C 313/01).
Guidelines on Standards of Conduct (laid down by individual

Directorates General)
The case law of the Court of Justice (since 1 January 2006, a dedicated
Civil Service Tribunal is in operation)
All these documents are easily available on the Commissions intranet.
As one of the actions outlined in the above mentioned communication
on professional ethics, a new single, all encompassing Ethics Website will
be established. It will, among other things, include a section for
frequently asked questions, and a check list which gives a systematic
overview of all aspects of actual or potential conflict of interests.
Not only must staff follow ethical rules, but also the Commissioners,
political office holders, who are required by the EC Treaty to discharge
their duties in the general interest of the Community, and neither seek
nor take instructions from any government or from any other body.
The Barroso Commission adopted a Code of Conduct for
Commissioners at its first meeting on 24 November 2004. By virtue of
this Code of Conduct, all Commissioners have to declare their
interests, including information on former and current outside
activities, financial interests and assets, and spouses activities
(http://ec.europa.eu/commission_barroso/interests/index_en.htm).
Awareness raising
The rules in place have to be transparent and made accessible to staff
and the public. Considerable emphasis is placed on the dissemination
of information, communication and training.
Training plays a vital role, first of all for new members of staff, but also
for staff in its entirety. This applies with regard to ethical questions and
all areas of financial management, and, in addition, to officials with
appropriate responsibilities with a view, inter alia, to preventing fraud
[See Awareness raising training on keeping highest standards of ethics
and integrity in the Commission as an example of good practice]. There
is also compulsory training for those involved in budget management.
In addition, members of staff can find comprehensive information on
budget management and implementation, accounting and financial
reporting, internal control issues, procurement and other related issues
on the Intranet website of the Directorate-General for Financial
Programming and Budget; staff can also contact the Central Financial
Services Help Desk.
More recently, a series of seminars [See Ethics Day as an example of
good practice] has been organised to improve the staffs understanding
and knowledge of the rules regarding the conduct that is expected from
them.
21
The Commissions services / Ethics infrastructure

Since 1999, new structures and services have been set up which have a
bearing on ethical questions:
The European Anti-Fraud Office (OLAF, replacing UCLAF) aims to
protect the financial interest of the EU, and may investigate conduct
liable to give rise to disciplinary proceedings.
The Investigation and Disciplinary Office (IDOC) is a directorate in
the Directorate-General for Personnel and Administration which
undertakes administrative inquiries independently, if OLAF decides
not to conduct an inquiry itself in areas falling within the
competence of both bodies, and assists the Appointing Authority in
disciplinary proceedings.
The Panel for Financial Irregularities (PIF), which is attached to the
Directorate for Personnel and Administration, is able to provide the
Appointing Authority with the necessary expertise on suspected
financial irregularities.
The mission of the Internal Audit Service (IAS) is to audit the internal
control systems that exist within the European Commission in order
to assess their effectiveness and, more generally, the performance of
Commission departments in implementing policies, programmes and
actions with a view to bringing about continuous improvement.
The recent Communication on Professional Ethics has decided to set
up a network of ethics correspondents from each of the
Commissions departments, to meet regularly and discuss questions
and new developments. The aim of the network is to have a pool of
expertise for decision makers and individual members of staff to
consult, as well as to ensure a coherent but decentralised application
of the provisions.
As for established services, the Secretariat General, which is responsible
for the overall coherence of the work of the Commission and which
undertook the conception and planning of the Commission-wide Ethics
Day 2006, is the Commissions interface with the public and the other
institutions as well as with the Ombudsman. The Secretariat General is,
thus, in charge of transparency issues, and in particular of questions
relating to access to documents. Additionally, the Directorate-General
for Financial Programming and Budget remains a major actor in terms
of supplying information on rules and procedures in financial matters
which serve to protect the financial interests of the EU.
22
Under the Commissions internal rules, decisions on ethical issues

affecting individual staff are often devolved to the Directorate General
in which the staff member works this is on the basis that this DG is
best placed to appreciate how a particular issue relates to the officials
work. But the Directorate General for Personnel and Administration
retains over all responsibility for application and interpretation of the
Staff Rules and the Code of Good Administrative Behaviour, as well as
for instituting disciplinary proceedings in the case of serious breaches.
According to the Communication on Professional Ethics, in order to

simplify the overall processing of all declarations or requests for
authorisation under the Staff Regulations a single one stop shop
electronic approval system will be set up.
Four promising practices
The European Commission has contributed four promising practices to
the catalogue, three of them relating to raising staff awareness. The first
practice involves compulsory training on ethics and integrity for new
staff members; the second concerns a one-day training course to raise
awareness of ethical issues among Commission staff; the third involves
the formulation of a policy on the financial liability of officials and
other public servants; and the fourth practice describes the
requirements for working according to the Internal Control Standards
in the European Commission.
3.3 Categories
The contributors were asked to classify the promising practices
according to a number of categories. These categories cover the usual
elements and topics of anti-corruption and integrity measures. The first
is values and codes (general principles of good administration codified,
integrity codes for public officials, and transparency/confidentiality and
accountability). The second is rules and instruments (preventive
measures, compliance instruments, awareness-raising among staff,
anti-corruption measures and administrative vigilance). The third
category covers specific topics (public procurement, legal
incompatibilities and other forms of conflicts of interest, financing of
political parties and/or electoral campaigns and special cases). This
section gives a brief description of the practices in each category. It is
important to note that practices can fall into more than one category
and most practices are in fact multifaceted. See annex 3 for an
overview.
Category 1 Values and Codes

23
This category encompasses promising practices relating to principles of

good administration in member states. The guidelines drawn up by the
European Commission on the financial liability of officials are one
example. Another example is the Code of Good Governance of the
Members of Government and Senior Officials of the General State
Administration in Spain. This code contains sections on basic principles,
ethical principles, principles of good conduct and compliance with the
code. Interestingly, this code is evaluated on an annual basis.
Integrity codes for public officials

Practices in this category address the question of how desirable
behaviour of civil servants is made explicit, how norms and values are
codified and what efforts are made to make them work. The acquis
offers models for such codes, for example the model code for public
officials of the Council of Europe and the United Nations International
Code of Conduct for Public Officials. An example of how desirable
behaviour is made explicit is the Code of Conduct for Government
Employees from Italy. This code was evaluated in 2002. The promising
practice from Poland is a code of conduct for police officers and the use
of this code in the education of police officers. The Anti-Corruption Code
of Conduct from Germany contains guidelines and recommendations
for making it work. The practice from Denmark describes the process of
drafting the Code of Conduct for Public Officials.
Transparency / confidentiality and accountability on central and

decentralised level
Practices in this category address the issue of how member states
reconcile organizational interests (i.e. the image of government) and
the interests of transparency (in the sense of public scrutiny of
government), and how unethical behaviour is dealt with from this
perspective.
An example is the practice from Sweden which describes the role of
openness as a means of promoting democracy and preventing
corruption. Another practice relating to transparency is the Values of
the Daily Job project in Finland. The goal of this project was to reinforce
a common set of values and to promote the translation of the values
into practice. The United Kingdom offers the practice of the Public
Disclosure Act. This act sets out a clear and simple framework for
raising and addressing genuine concerns about malpractice.
Category 2 Rules and Instruments

Preventive measures: compliance instruments and raising awareness
among staff
24
What types of instruments are used to identify weaknesses and prevent

repetition of norm deviation in the future (i.e. internal or external
assessment, organizational risk analysis)? This category encompasses
practices that give an answer to these questions. The annual reports of
the Service Central de Prvention de la Corruption (SCPC) in France are
one example and they cover a multitude of topics, such as new
regulations for public procurement. Since the aim of the SCPC is to
contribute to the prevention of corruption it can be categorized as a

promising practice in this field. The practice of implementing integrity
plans in government organizations in Slovenia and the inquiries of the
Committee on Standards in Public Life (CSPL) in the United Kingdom
are other examples of preventive measures.
A practice designed to raise staff awareness is the Anti-Corruption
Awareness Raising within Law Enforcement Entities and Beyond project
in Austria. This project contains three related elements: courses,
campaigns and publications. The European Commission offers three
practices in this field: an Ethics Day seminar, a training course on ethics
and integrity for new staff members and the Internal Control
Standards. The Integrity Cube from the Netherlands is another practice
in this field.
Anti-corruption measures and administrative vigilance
This category includes practices that involve specific actions and
measures taken by administrative bodies in the fight against corruption
and organized crime. The guidelines on the financial liability of officials
in the European Commission are an example of a promising practice in
the field of anti-corruption measures. Another example is the
Corruption Prevention and Combating Bureau in Latvia. One of its
activities in the prevention of corruption is public education. The
Advisory Board for a Corruption-Free Public Life is a practice from
Hungary. The board has prepared a draft National Anti-Corruption
Action Plan. The national network against corruption in Sweden was
established to adopt anti-corruption measures, as was the platform for
fighting corruption in the Netherlands. The reward system for whistleblowing by policemen is an anti-corruption practice from Estonia.
Category 3 Specific Governance Topics

Public procurement
This category covers one of the three more specific themes and deals
with practices that involve measures taken to prevent conspiracies by
interested parties during tender procedures. The BIBOB Act in the
Netherlands can be categorized as a promising practice in this field. By
screening the criminal antecedents of applicants for licences, subsidies
and/or tenders, this act prevents the government from unintentionally
facilitating new criminal activities and harming its integrity.
Legal incompatibilities and other forms of conflicts of interest
25
Practices in this category relate to the question of what public or

private outside activities are considered illegal for a civil servant to
combine with his or her regular work as a civil servant and what
measures are helpful in balancing public and private interests. An
example in this field is the Standards in Public Office Commission in
Ireland. This commission plays a central role in the enforcement of
requirements laid down by the Ethics Acts. These acts regulate the
disclosure of interests of civil servants and holders of public office.
Spains Act Regulating Conflicts of Interest of the Members of
Government and Senior Officials of the General State Administration is
another example. This act describes a system of incompatibilities, a
system of activities, senior official obligations, management bodies,
surveillance and control and a sanctioning system.
How are political parties financed (or left to private sector
sponsorship)? What choices are made and why? Practices in this
category address these questions. One such practice is the activities of
the Corruption Prevention and Combating Bureau in Latvia, part of
whose work is to monitor the financing of political parties and
violations of relevant regulations.
Special innovative cases
Although the two promising practices in this category can easily be
allocated to other categories, their specific nature and organization sets
them apart. The first is the newly created function of Coordinator of
Integrity Care in the structure of integrity management of the Flemish
government in Belgium. The second promising practice is Public
Concern at Work (PCaW) in the United Kingdom. This nongovernmental organization is dedicated to public interest
whistleblowing. Its aim is to enhance individual responsibility and
organizational accountability by giving staff who are concerned about
malpractice a safe alternative to silence. The third promising practice is
the National Integrity Office for Promoting Ethics and Integrity in the
Public Sector of the Netherlands. This office supports all government
organizations to give substance to their integrity policy.
3.4 Classification according to certain themes

Some specific themes can be identified from the contributions. Because
of the variety of the contributions the practices in each theme can be
regarded as loosely knit groups. This means that not all practices in this
catalogue can be categorized under one of these themes. Most of the
themes are core topics in the literature on anti-corruption and integrity.
26
Compliance and integrity

The first theme, which receives prominent attention in the literature,
concerns the complementary strategies of compliance and integrity. A
compliance strategy is aimed at regulating the application of laws, rules
and regulations concerning ethical behaviour. An integrity strategy is
aimed at developing shared norms and values. The goal of compliance
is to prevent illegal behaviour; the goal of integrity is to foster
responsible behaviour.
The activities in the promising practices from Finland, the Netherlands,
and Slovenia are typically concerned with integrity. The practice from
Finland concerns the development of working values in daily life, the
practice of the Integrity Cube from the Netherlands is used to stimulate
discussion of ethics and integrity within public organizations, and the
practice from Slovenia describes the implementation of integrity plans
in public organizations.
The contribution from Hungary can be regarded as a practice that
focuses on compliance. One of the activities of the Advisory Board for
Corruption Free Public Life in Hungary is to provide advice on anticorruption measures.
Prevention and anti-corruption
Another theme relates to the focus of the practices. Although the
distinction between prevention and anti-corruption is similar to the
distinction between integrity and compliance, there are differences.
Prevention is not the same as fostering integrity and fighting corruption
is not the same as enforcing compliance. Prevention can be defined as
all a priori activities that are undertaken with the aim of preventing
breaches of integrity and corruption. Anti-corruption measures can be
defined as all activities that are undertaken to identify actual breaches
of integrity and corruption and to compel compliance with rules and
regulations.
The promising practice of the annual reports of the Service Central de
Prvention de la Corruption in France and the Committee on Standards
in Public Life in the United Kingdom can be regarded as examples of
prevention. Several other practices involve organizations that combine
prevention and anti-corruption activities. Among these are the
Corruption Prevention and Combating Bureau in Latvia and the Federal
Bureau for Internal Affairs (BIA) in Austria.
Public Administration and police
27
Given the subject matter of this catalogue, integrity and anti-corruption

measures, and the background of the participants in the informal
working party in EUPAN and EUCPN, it is no coincidence that a

distinction can be made between practices in the field of public
administration and practices employed by the police. Five of the 27
promising practices describe practices from police work rather than
public administration. These are from Estonia, the Netherlands, Poland
(2) and Sweden.
The practice from Estonia involves the introduction of a reward system
for whistleblowing by police officers. Both police practices from Poland
are concerned with the implementation of ethics, one in the education
of police officers and one in the police force itself. The police practices
from Sweden and the Netherlands describe the activities of a
multidisciplinary network of actors in the fight against corruption.
These networks consist of representatives of the public administration
and the police.
Organizations and networks

Besides promising practices that describe the activities of organizations
or institutions, there are practices that describe the functioning of
networks of actors from different disciplines. A central feature of these
networks is the exchange of information and the development of
knowledge. These networks seem to have an informal character. This
often means that participation is not obligatory but is based on trust.
Examples of such practices were provided by Sweden, the Netherlands
and Hungary.
3.5 Reflection
Seventeen of the 27 Member States have contributed one or more
practices to this catalogue. These practices cover every aspect of anticorruption and integrity measures. The category with most practices is
preventive measures (5), followed by anti-corruption and administrative
vigilance (4), integrity codes for public officials (3), and transparency,
confidentiality and accountability (3). From the description of the
specific themes, it is possible to make several other meaningful
distinctions between the practices in the contributions.
Readers can use the three methods of classification used in this
catalogue to find the practices they are looking for. But they also show
how practices are related. In chapter 4, the 27 practices are described in
full. In chapter 5 they are considered from an integrated perspective.
28
4.1 Introduction
In this chapter you can find full descriptions of the 27 promising
practices included in this catalogue. For each practice there is a brief
description, information about why the practice was initiated
(background and aim), how the practice came into being (content and
process), the qualitative and quantitative results achieved so far,
positive and negative lessons that were learned, an indication of the
part of government concerned and the names of contact persons. For
most practices, sources of and/or links to supplementary information
are also given. Since this catalogue can only give an impression of the
practices, the contact information should be seen as an invitation to
share knowledge and experience and in this way learn from each other.
29
4.2 Austria
Anti-Corruption Awareness Raising within Austrian Law

Enforcement Entities and Beyond
Brief
description
The Federal Bureau for Internal Affairs (BIA), the department

responsible for the investigation of corrupt acts, particularly within the
Ministry of the Interior but also throughout the public sector, has been
given the task of developing and implementing strategies for the
prevention of corruption within Austrian law enforcement agencies.
The Anti-Corruption Awareness Raising within Austrian Law
Enforcement Entities and Beyond project consists of three related
activities: courses, campaigns and publications. As the title of the
project suggests, the purpose of this practice is to raise anti-corruption
awareness.
Background
and aim
Following the international efforts, especially of the OECD, the EU, the
Council of Europe and the UN, to raise awareness about corruption and
to tackle it in a holistic way, the Austrian Ministry of the Interior
decided to strengthen its capacities in the fight against corruption.
Accordingly, in addition to its task of investigating specific cases, the
newly established Federal Bureau for Internal Affairs assumed
responsibility for the prevention of corruption.
Familiar from its operational experience of ignorance concerning the
problem and resistance to internal investigations, the BIA is especially
committed to its preventive activities. The aim of the BIAs prevention
branch is to foster awareness of the wrongful character of corrupt
actions and to provide guidance in complicated ethical situations, but
also to raise awareness of the counter-measures taken by the ministry.
Content
and process
Before the BIA started its campaigns and educational activities, there
was little in the way of preventive measures against corruption in the
Ministry of the Interior. Abuse of public authority was just one of many
issues touched on in the normal lessons about the Austrian penal
code. The BIA has therefore drawn up a curriculum, together with the
Security Academy (Police Academies), for a basic course, which has
been obligatory for every cadet joining the police since 24 August 2005,
and a three-week course for a more specialist audience, especially for
senior officers and officers designated to serve with the BIA.
The campaign on the acceptance of advantages was also inspired by
a concrete operational case which showed the lack of awareness with
regard to accepting small favours. There are now two three-week
training courses and numerous one-day training courses every year.
30
4
Content
and process
Two leaflets have been published to raise awareness about the fight
against corruption and to give advice on how to best avoid conflicts of
interest. One leaflet gives information about the BIA and its anticorruption activities, the other deals with one of the most sensitive
areas in the everyday life of public servants, the acceptance of
favours. Two sets of posters have also been developed: one series of
three posters deals with the actual consequences of corruption, while
another set of three posters addresses this issue in a more provocative
and emotional way.
Relevant publications that can be mentioned are a paper for the
International Anti-Corruption Conference held in Vienna in 2004 and a
book edited and published by the BIA called The Corruption Monster
Ethics, Politics and Corruption. Besides being distributed through
bookstores, the book was sent to over 150 key players in politics,
science, business, the judiciary and the media, at national as well as at
international level.
Two officials of the BIAs Prevention and External Relations unit are
engaged full-time organizing and holding the courses.
Results
Between 2005 and 2006:

850 police officers participated in the basic course on Combating and
Preventing Corruption, which is offered as part of the training
courses at the police academies;
40 senior police officers participated in the three-week training
course Combating and Preventing Corruption and are now important
disseminators of anti-corruption information in Austrias nine
Bundeslnder.
According to questionnaires handed out to the course participants:
90% of the participants found the course content and the knowledge
they acquired useful for their work;
70% of the participants stated that the acquired knowledge would be
useful to them personally and that they would put it into practice;
75% of the officers attending the course said that they were
motivated and determined to apply the knowledge in practice.
Lessons
learned
31
Ignorance of the problem of corruption in general, and of its

mechanisms, appears to be one of the main obstacles to the
prevention of corruption. The lack of awareness of corruption is
particularly marked among young officers. Some of their older
colleagues have in turn become accustomed to dealing with this topic
in the wrong way and pass those bad practices on to the young
officers. The courses help to break down the prejudices towards
4
Lessons
learned
internal departments these prejudices are an international

phenomenon and to raise the awareness of the problem of
corruption among civil servants. This contributes significantly to
reducing their inhibitions about reporting corruption or inappropriate
behaviour.
Generally speaking, the increased sensitivity to corruption has proved
to have positive effects on everyday life in the office.
Part of
government
BIA is part of the Federal Ministry of the Interior.

The Federal Ministry of the Interior is the second largest of the
Austrian ministries in terms of personnel. Of the ministrys 31,387
employees, 1,485 work in the Federal Central Agency, while 29,902
perform their duties in subordinate entities, the majority of them
1
28,851 as police officers .
This ministry is responsible for a broad range of tasks ranging from
internal security, especially the maintenance of public order, safety
and security, to policy on foreigners and asylum and international
police cooperation. The police force is divided into a Federal Central
Agency the Ministry of the Interior - and nine subordinate provincial
police commands, which consist of 83 district police commands, 27
city police commands and more than 1,000 local police stations.
At present, the BIAs staff consists of about 40 highly committed male
and female officers from all Austrian regions (i.e. Bundeslnder).
Contact
Name of organization: BIA Federal Bureau for Internal Affairs

Name of contact:
Address of organization: Herrengasse 7, A-1014 Vienna, Austria
Telephone: +43-(0)-1-53126-5708
Fax: +43-(0)-1-53126-5790
Email: BMI-IV-6-BIA@bmi.gv.at
Website: www.bia-bmi.at / www.epac.at
Supplementary information
Information leaflet: BIA (in German and English)
Information leaflet: Acceptance of Advantages (in German)
Posters
Various articles and papers
These documents can be downloaded from www.bia-bmi.at
32
1
Federal Public Service, Facts and Figures, 2005: http://www.bka.gv.at/Docs/2006/1/19/Folder_EN.pdf
4.3 Belgium
Coordinator of Integrity Care

Brief
description
The Flemish government has introduced the new position of

Coordinator of Integrity Care. The purpose of this function is to
coordinate the integration of policy on integrity management in the
organization. The coordinators principal tasks are knowledge
management, monitoring integrity policy, supporting the Commission
of Integrity Care, networking with relevant partners, helping
colleagues with any questions they have and initiating and executing
projects.
Background
and aim
Under the name of Better Administrative Policy (BAP), public

administration in Flanders has been subjected to a root-and-branch
reform. This has resulted in a new structure with thirteen policy areas.
The BAP is designed to make the Flemish public administration more
efficient and has also succeeded in making public administration
more transparent. The more streamlined administrative structure and
more effective services make it easier for customers to find their way
around the Flemish public administrations various entities. This
created a stronger focus on integrity care.
The political basis for these initiatives is the policy document of the
Minister of Administrative Affairs and the decision of the Flemish
government on integrity management in 2005. This document:
stresses the importance of integrity for better governance;
institutes a truly integrated integrity policy for the Flemish
government and public administration;
specifically refers to integrity audit as a means of implementing an
integrity policy;
introduces the new position of coordinator of the Flemish integrity
policy.
Content
and process
33
Based on a study conducted by the Catholic University of Leuven

(Jeroen Maesschalck), various measures have been introduced and
some existing measures have been coordinated with a view to creating
a general system of integrity management. Examples of these
measures include a whistleblowing procedure and protection for
whistleblowers, a new code of ethics, training in ethical behaviour, risk
analysis, risk management, training in the rules and the legislation
and the coaching of staff.
4
Content
and process
The Coordinator of Integrity Care is part of this system of general

integrity management within the Flemish government. The structure
of the management of integrity consists of a Coordinator of Integrity
Care, a Commission for Integrity Care and other services providing
assistance in this field.
The main tasks of the Coordinator of Integrity Care are:
knowledge management;
providing input, follow-up and feedback with respect to policy on
integrity;
supporting the Commission for Integrity Care;
networking;
advice;
projects.
Examples of the types of project include:
training about dilemmas and providing feedback from this training
for review of the code of ethics;
detecting fraud by means of business intelligence;
identifying vulnerable functions and elaborating an integrity plan for
those functions. Vulnerable activities are defined as function-related
activities that may, owing to their nature and substance, create a
potential risk for the organizations integrity.
The coordinators partners in the area of integrity care are:
the internal audit department of the Flemish government, with
respect to administrative vigilance and analyses of strengths and
weaknesses in the field of ethics and integrity;
the Flemish Ombudsman, with respect to whistleblowing;
public Personnel Agency with respect to raising awareness among
staff.
Results
34
The approach shows an increased demand of the management for

integrity related training and tools:
In the period October 2006 - September 2007, the Flemish
government organized 105 integrity workshops with training on
ethical dilemmas (about 1.4000 people are trained).
Around 30 more sessions followed in the period October - December
2007.
Several entities within the Flemish government have also asked for
risk analysis and some are drawing up their own ethical code.
The existing ethical code (from 1998 and adapted in 2006) is being
assessed and reviewed in 2008 with several focus groups to involve
the stakeholders.
4
Results
An ethical code for the cabinet officers of the Ministers is elaborated

at the end of 2007.
Several manuals are published to help the management deal with
integrity tools.
This approach is only recently implemented so there are no general
effects measured yet on the behaviour of the civil servants although
an increased amount of questions about dilemmas are measured. A
survey for measuring the effects is developed, tested and used at the
end of 2007 and the beginning of 2008, so data will be available soon.
Lessons
learned
Experiences with the coordination of the different efforts in the field of

integrity have been positive. The goal of these efforts is to make other
organizations aware of the effort required to make all the systems and
tools visible for the organization and to coordinate the different
working methods. There is therefore contact with other public services
in Belgium and information is exchanged about the actual measures
that are available. Other public organizations might learn from this
approach.
Part of
government
The Coordinator of Integrity Care is part of the Department of Public

Governance of the Flemish government. The Coordinators working
area encompasses the entire Flemish government.
Contact
Name of organization: Flemish Government, Public Governance

Name of contact: Helena De Clercq, Coordinator of Integrity Care
Address of organization: Boudewijnlaan 30, bus 37, 1000 Brussels,
Belgium
Telephone: +32 2 553 72 03
Fax: +32 2 553 72 05
Email: helena.declercq@bz.vlaanderen.be
Website: www.vlaanderen.be/integriteit (DUTCH) / www.flanders.be
35
Description of the integrated approach: structure and measures

Description of training courses
Integrity code
Charter for customers and a manual on how to put the charter into
practice
Manual for conducting customer surveys
Description of function families and the methods that are used
4
(including the values of the organization)
Appraisal system, including the values
IT support, e.g. reporting about procurement with the possibility of
risk analysis
Method of conducting a risk analysis of the psychological risk of a job
Networking method for internal quality managers
Most of the printed information is in Dutch, but organizations can visit
or send enquiries. We can translate some of the documents.
36
4.4 Denmark
Drafting a Code of Conduct for Public Employees

Brief
description
In June 2007 a Code of Conduct for Public Employees was published.

The Code is the first one of its kind in Denmark. This promising
practice from Denmark describes this process of drafting the Code of
Conduct and stresses the importance of securing acceptance and the
broadest possible support for the code. Experience in Denmark shows
that it is therefore important to seek cooperation and to involve
relevant parties in the various steps of the process.
Background
and aim
The aim of the code of conduct is to communicate to both managers

and employees, in a clear and accessible way, a number of the
fundamental rules and conditions applicable in the public sector. The
code is also a means of avoiding situations which could, for instance
in the media, raise doubt about the behaviour of public employees.
The code of conduct takes the form of general guidelines which leave
scope for the laying down of rules appropriate to the needs of specific
sectors. Apart from describing the rights and obligations of public
employees and laying down general guidelines on how to handle
various situations, the code includes a number of practical and
relevant examples to illustrate the text.
Accordingly, the text of the code of conduct is based on regulations
and good administrative practices as well as on ethical considerations.
The code of conduct is being produced in response to the wishes of
central government, local and regional employers organizations and
employees organizations. The code of conduct was finalised and
published in June 2007.
Content
and process
37
The Code of Conduct for Public Employees describes a number of

fundamental rules and conditions applicable in the public sector
covering the following themes: core values and principles of the public
sector; instructions from superiors; freedom of expression;
confidentiality; capacity; gifts and benefits offered; involvement in
outside activities; general principles of behaviour; reactions to
sanctions.
The Code of Conduct for Public Employees was prepared by the
Ministry of Finance (The States employers authority) in association
with other ministries, the public employers organizations (local
4
Content
and process
government authorities in Denmark and Danish regions) and the

public employees organizations.
The working group agreed on the overall themes to be described in the
code of conduct at the beginning of the project. During the process,
special consideration was given to areas of great complexity and
issues which had not previously been regulated in detail, e.g. how to
handle offers of gifts and benefits and how to handle illegal
instructions from superiors.
Preparation on the Code of Conduct included a consultation of
interested parties. In late 2006 the draft code was sent to a wide range
of ministries, employers organizations and employees organizations
with an invitation to make comments and suggestions about the draft
text. In addition, the Ombudsman gave input to the text before
finalisation. The working group is currently (early 2007) considering
the responses. The Code of Conduct was approved and published in
June 2007.
Results
See information above (Content and process) and below (Lessons

learned).
Lessons
learned
The code of conduct is not a collective agreement. However, it is

important that the code enjoys the widest possible acceptance and
support from employers and employees organizations. It was
therefore important to seek cooperation and to involve the relevant
parties in the different steps of the process.
It has been important to word the code in such a way that both
managers and employees find the text clear and accessible and can
use the code as a valuable tool in their daily work. This was achieved
by issuing clear guidelines, finding relevant examples from everyday
working life and by striking the right balance in describing the rights
and obligations of employees.
Part of
government
38
The process of drafting the Code of Conduct for Public Employees was
coordinated by the State Employers Authority, the Ministry of Finance.
The Code applies to public sector employees at all levels central,
regional as well as local in Denmark.
4
Contact
39
Name of organization: State Employers Authority (Personalestyrelsen),

Ministry of Finance
Name of contact: Ms. Ida Krarup
Address of organization: Frederiksholms Kanal 6, DK-1220 Copenhagen
K, Denmark
Telephone: +45 3392 2616
Fax: +45 3391 0069
Email: ida@perst.dk
Website: www.perst.dk
4.5 Estonia
Reward System for Whistleblowing Police Officers
Brief
description
A reward system was recently introduced for police officers in the

North Police Prefecture. Under this system a police officer has to
inform his or her superior if a person continues to offer bribes after
being warned. If the case is proved and a court has rendered a
decision, the police officer is entitled to receive a reward. The purpose
of this reward system is to foster an anti-bribery culture among police
and to preserve the reputation of the police.
Background
and aim
The tasks of the police control department (10 officials) are laid down
in the Regulations of the Police Board. The police control division in
the Northern Police Prefecture has 15 officials, the division in the
Western Police Prefecture has four officials, in the Eastern Police
Prefecture it has four officials and in the Southern Police Prefecture it
has five officials.
Content
and process
The police control department helps to detect and prevent bribery

cases involving police officers in all police prefectures.
If a police officer (e.g. traffic police officers, investigators, etc.) is
offered a bribe, he/she first has to warn the person. If the person still
continues to offer bribes the police officer is obliged to inform the
police control center. If the case has been proved and the court has
made a decision, the police officer concerned is entitled to receive a
reward. The reward for a police officer is approximately EUR 192 (3000
EEK).
In addition, to tackle corruption within the police if a superior, e.g. a
head of a unit, suspects there is corruption in his/her unit he/she also
has to inform the prefect (the most senior local police officers) of their
suspicions. If it later turns out that police officers were involved in
corruption and nobody informed the prefect about it (if the superior
denies knowing anything about it), the superior in question will be
demoted to a lower position. The superior will only retain his/her
position if he/she informed the prefect about the suspected situation.
Results
40
In 2006 the police control department detected 20 bribery cases

involving traffic police. Since the introduction of the reward system
there have been four court decisions and thus four rewards have been
paid.
4
Lessons
learned
The police system as a whole can benefit from practices in individual

police prefectures, e.g. when the North Police Prefecture enforces the
reward system the others might follow.
Part of
government
The police operate as a governmental agency under the auspices of

the Ministry of the Interior. The anti-corruption policy is coordinated
by the Ministry of Justice (Department of Criminal Policy).
Contact
Name of organization (for enquiries about anti-corruption policy of the

police): Police Board
Name of contact: Pille Hamer, Police Board
Address of organization: Prnu mnt 139, Tallinn, Estonia
Telephone: +372 6123228
Fax:
E-mail: pille.hamer@pol.ee
Website: www.pol.ee
Name of organization (for enquiries about anti-corruption policy in
general): Ministry of Justice
Name of contact: Mari-Liis St
Address of organization: Tnismgi 5a, Tallinn, Estonia
Telephone: +372 6208223
Fax: +372 6208 109
E-mail: mari-liis.soot@just.ee
Website: www.just.ee
41
4.6 European Commission
1. Training on Ethics and Integrity in the Commission
Brief
description
Compulsory training on ethics and integrity for all newcomers and

specific sessions for general staff and management are organized in
order to ensure that staff members are aware of the rules relating to
staff conduct, including those related to avoiding conflicts of interest
and prevention and reporting of fraud and irregularities. Moreover, the
Commissions training curriculum contributes to a culture of integrity
within the institution and its relations with the public.
Background
and aim
Training with the objective to raise awareness was initiated in line

with the European Commissions Internal Control Standards (see
4.6.4). These standards require that staff is aware of the necessity of
maintaining the highest standards of ethics and integrity.
Content
and process
Aspects of the content:

- staff regulations;
- general principles of good conduct;
- conduct in working and private life;
- relations with the public;
- conflicts of interest;
- prevention and reporting of fraud and irregularities.
Case studies, based on Commission's reality, are used to facilitate the
understanding of the subject and to clarify expected staff conduct. In
addition to compliance with staff rules, values and principles of the EU
civil service are treated by means of (group) exercises and discussions
on the basis of concrete examples. Staff is also guided in how to act in
situations of integrity risks.
Process: One-day course for all newcomers.
Strong demand exists as well for workshops for other staff, including
senior management, tailored to specific needs of the Commission's
services.
Three internal trainers deliver training and workshops on the subject
at present. The programme and its content are supported by main
services involved in ensuring good ethical conduct in the Commission.
Currently e-learning modules on the subject are being developed.
In addition to training on ethics and integrity, the general training
curriculum of the Commission ensures that course content is
consistent with Commission's values, policy and culture (e.g. diversity,
anti-harassment)
42
4
Results
Training for newcomers has helped to raise awareness of the subject

and informed new staff of the main conduct rules. By emphasizing the
importance of maintaining the highest standards of ethics and
integrity for the Commission it has contributed to promoting a culture
of integrity already at the start of the career in the institution. It also
sparked off interest and demand for further training and related
activities on the subject in the organization.
Lessons
learned
Training thus contributes to a better understanding of the core values

and principles of our organization at the very beginning of one's
career. Training for other staff, and in particular management, has
raised awareness that ensuring highest ethical standards can not be
taken for granted but will require continuous and active effort of all
staff.
Part of
government
The training is organized by the Directorate-General for Personnel and

Administration of the European Commission.
Contact
Name of organization: European Commission

Name of contact: Conrado Tromp
Address of organization: 1049 Brussels - Belgium
Telephone: +32 2 2960286 Fax:
Email: conrado.tromp@ec.europa.eu
Website:
Document: Training objectives of training on ethics and integrity
43
2. Ethics Day Seminar

Brief
description
The Ethics Day, held on 6 July 2006, was a one-day training initiative.
Its purpose was to raise awareness of ethical issues among
Commission staff.
Results
Towards the end of 2005 the Secretary-General asked for a training

course to be organized to raise awareness of ethical issues among
Commission staff. The event took place on 6 July 2006 and covered,
after a general presentation, four separate subjects.
1 Ethical Framework of the Commission: a refresher on the
Commissions rules on ethics as well as the relevant Staff Regulations
and how to implement them.
2 Independence and integrity of officials: to give suggestions on how
to avoid being dragged into situations of dependency towards
outside agents. To raise awareness of the risks faced by officials in
the execution of daily duties both in internal and in external
contexts (conflicts of interest, favouritism, lobbying, compromising
gifts).
3 Ethical Dilemmas: A test of reflexes to help in identifying ethical
dilemmas, moral temptations or tricky administrative situations. The
background presentation showed how to make decisions on these
issues and then address problem-solving situations.
4 Professional ethics applied to public procurement: to rely on selfjudgement to ensure transparency, equal treatment and the best use
of taxpayers money when faced with complex situations.
Content
and process
A working group was set up in October 2005 composed of

representatives from the Personnel and Administration Directorate
General, the Budget Directorate General, the European Anti-Fraud
Office, the Internal Audit Service and the Secretariat General. The
working group met every two weeks to discuss the programme and the
contents of the seminar and its organization.
The Interpretation DG and the Office for Infrastructures and Logistics
in Brussels provided logistical support.
To help create the right frame of mind for the seminar, four weeks
before the event all staff members were invited to participate in a
survey on ethical behaviour and rules by completing an anonymous
44
4
Content
and process
questionnaire. 2,707 officials replied and this represents a good

response from the staff.
The event was introduced by VP Kallas to give it high profile and by the
UN undersecretary general for administration, Mr Burnham, for an
outside perspective and comparison. Various high level speakers from
within the institution participated in the event.
A leaflet was distributed to all personnel of the European Commission
during the week of the event.
As for the follow-up, in view of the particular nature of each
Directorate General and the different types of ethical issues staff may
be confronted with, participants were asked to share the output of the
training with colleagues in their own Directorate General.
Results
As is usual practice, an evaluation form was distributed to participants

at the end of the seminar.
Analysis of the forms showed that the event was a success. The
majority of the participants confirmed that participation in the
seminar had improved their knowledge. They also felt that the
seminar would be useful for other colleagues. In connection with the
event, an internal web page was created where relevant information
about the seminar and ethical issues can be found.
There is sure to be a follow-up given the great interest shown by the
participants; the example has already been followed by other
Directorates General which have, for example, created individual
websites tailored to the needs of their staff.
Lessons
learned
The seminar has helped to raise awareness of ethical issues among

Commission staff.
Mr Christopher B. Burnham, (UN Under-Secretary-General for
Management) was invited to address the participants in the opening
session. He considered that the organization of such a seminar was
useful and could also serve as a model for the UN administration.
Part of
government
45
The Ethics Day was held at the European Commission in Brussels. It

was also broadcast via web streaming to Luxembourg, Ispra (Italy),
Grange (Ireland) and all the EC delegations.
4
Contact

Name of contact: Mme Claeys Bouuaert
Address of organization: 1049 Brussels - Belgium
Telephone: +32 2 2962659
Fax:
Email: donatienne.claeys-bouuaert@ec.europa.eu
Website: http://www.cc.cec/home/dgserv/sg/ethicsday/index_en.htm
(internal to EC)
Leaflet: Ethics - common values and rules to achieve common
objectives
3. Guidelines for Applying Article 22 of the Staff Regulations on the

Financial Liability of Officials
Brief
description
The purpose of these guidelines on the application of Article 22 of the

Staff Regulations is to set out a Commission policy on the financial
liability of its officials and other servants.
Background
and aim
The guidelines were adopted by the Commission on 9 June 2004 as one

of the last elements of the reforms carried out under Commissioner
Kinnock.
The guidelines are intended to underline the Commissions
determination to combat corruption, fraud, misappropriation of funds,
etc. and to apply Article 22 in those cases where they occur. At the
same time, the guidelines provide assurances that an official or other
servant may not be held financially liable for an error or for negligence
which is not sufficiently serious to amount to gross negligence.
Content
and process
46
The Commission first approved a consultation paper. At the end of a

consultation procedure, a majority of the Staff Unions expressed their
agreement with the guidelines.
Following their adoption, an elaborate information campaign was
launched involving numerous information sessions in nearly all
Commission services. These sessions lasted between one hour and
ninety minutes, with a brief presentation followed by questions and
answers. The number of participants varied from 10 to 50 persons and
4
Content
and process
the principal target group was all staff members who deal with
financial management.
Results
Officials and other servants of the Commission were informed

individually of the adoption of these guidelines, which are available on
the Intranet. Newly recruited officials and servants are made aware of
this aspect of their responsibility towards the institution upon entry
into service. Furthermore, all officials and servants taking up duties
involving active financial administration or management duties
personally receive a copy of this document. The guidelines are also
included in the training courses on financial management.
The guidelines for applying Article 22 of the Staff Regulations will be
evaluated and, where appropriate, revised after four years.
Lessons
learned
The guidelines and the accompanying information sessions have

helped to raise awareness among Commission staff, not only about
financial liability, but also about their obligations under the Staff
Regulations in general and about the disciplinary regime of the
Commission.
The principle of financial liability of officials exists in all EU
institutions, as well as in at least 19 EU Member States.
Part of
government
Responsibility for the application of Article 22 in the Commission rests

with the Investigative and Disciplinary Office of the Commission
(IDOC). The IDOC falls directly under the Director-General of the DG for
Personnel and Administration (DG ADMIN).
Contact

Name of contact: David Wansink
Address of organization: B-1049 Brussels
Telephone: 322-2969371
Fax: 322-2998709
Email: david.wansink@ec.europa.eu
Website:
47
Guidelines for applying Article 22 of the Staff Regulations (on financial

liability of officials)
4. Internal Control Standards for Effective Management
Brief
description
Individual services must annually check and report in their Annual

Activity Report on their compliance with the requirements
accompanying each of the 16 internal control standards for Effective
Management. The second of these Standards concerns Ethical and
Organisational Values, encompassing staff awareness of the rules on
ethics and integrity.
Background
and aim
An Internal Control Framework was put in place on a permanent basis

notably to assist senior members of staff in assuming their direct
responsibility for the establishment of sound internal control systems
covering their activities over a wide variety of subject areas. The
political basis for this initiative was the administrative reform of the
Commission which started in year 2000. This required the revision and
strengthening of internal control functions within each service
(Directorate-General) and the establishment of a separate Internal
Audit Service. Following a review, the Internal Control Framework was
revised in 2007, strengthening the assessment and reporting of control
effectiveness, applicable from 2008. DGs are required to ensure that
the minimum Requirements for each standard are complied with
and that control measures are effective in areas where management
consider emphasis on effectiveness as necessary, depending on their
activities, priorities, risks and other considerations.
Content
and process
A set of requirements for implementing each Internal Control

Standard for Effective Management has been established, which must
be followed by each Director General and each Directorate General.
Thus, for example, the requirement regarding Standard No. 2
concerning Ethical and Organisational Values is that "procedures are in
place to ensure that all staff is aware of those values, in particular
ethical conduct, avoidance of conflict of interest, fraud prevention and
reporting of irregularities. These procedures include updates and
yearly reminders". As regards costs, since implementation is
decentralized to the level of the Directorate General and integrated
within processes and procedures, estimates are difficult to make but
the costs are not high as control activities should be integrated into
the work cycle.
Results
Given that the costs of maintaining internal control standards are not
high, there are real gains to be made, both in terms of raising
48
4
Results
awareness amongst staff at all levels and in terms of the impact this
awareness has on internal control. The requirement to report annually
on the implementation of Standards embeds the concept of sound
internal control within management structures. Senior managers in
particular are very familiar with Standard 8, Processes and Procedures,
where it is in particular required to record control overrides and
deviations from established policy. Cases have to be fully documented
and also justified and approved at an appropriate level. Standard 9
focuses on management supervision and is also crucial for detecting
and correcting areas of potential weakness and identifying and
introducing appropriate controls and procedures according to the risks
involved.
Lessons
learned
The whole institution is subject to the Internal Control Standards for

Effective Management and related Requirements. Reporting on
internal control is therefore done on a consistent basis by different
services within a fairly large organization. The revision of 2007 of the
Internal Control Framework recognised that all standards may not be
equally important to all services at all times. It introduces the concept
of flexibility where a service can select standards most relevant for
further emphasis on control effectiveness while compliance with all
the requirements remains mandatory.
Part of
government
Throughout the European Commission
Contact

Name of contact: Mr Adrian Window
Address of organization: Brussels
Telephone: 0032 2 952271
Fax:
Email: adrian.window@ec.europa.eu
Website:
http://ec.europa.eu/budget/documents/implement_control_en.htm
See documentation on the Europa website.
49
4.7 Finland
Values to be Part of the Daily Job

Brief
description
Values to be Part of the Daily Job is a project that consisted of

identifying working values and helping employees in five pilot
agencies to act on them. The experiences in these pilots were
evaluated by a working group. The purpose of the project was to
incorporate value-oriented activity and management into everyday
work.
Background
and aim
Openness has traditionally been one of the basic principles of the

Finnish state administration and the Nordic administrative culture.
The publicity principle, dating from the 1700s, requires that decisionmaking is open and documents are made available to the public.
The basic common values for the Finnish state administration were
redefined in a Decision in Principle On State Personnel Policy taken by
the Finnish government on 30 August 2001. The decision states that
the activity of the state administration is value-oriented and of a high
ethical calibre. The objective is to continue to maintain these high
ethical standards in the future and this calls for values and ethics to
be highlighted in practical work. Although the country does not
generally have problems in this area due to a number of factors, there
is a risk that standards could decline.
The task of the State Employers Office is to reinforce a common value
basis and promote efforts to put the units values into practice. To help
with this task, a working group calling itself Values to be Part of the
Daily Job was set up in September 2002.
Content
and process
50
The principal task of the working group on Values to be Part of the

Daily Job was to select practical methods for applying values in the
units taking part in the project, i.e. good practices, which other
government units could use in their own work.
The project was divided into two parts. One part was carried out
independently in the five pilot projects chosen by the working group
and the other by the members of the working group on Values to be
Part of the Daily Job. The units selected for the pilots prepared their
own plans, formed project groups from among their own personnel
and produced an interim report midway through the project and a
final report at the end of 2003. They chose different ways of working,
but a common feature was that they engaged both the personnel and
4
Content
and process
management in formulating the definition of the organizations own

values and helped the personnel first to memorize them and then to
act according to them. A crucial point in this context was that the
entire staff participated in the process. The practical solutions
included the production of a work book for each member of the
organization or a wall map.
The Ministry of Finance did not support pilot projects financially.
Instead it organized two seminars during the project. The first was for
the pilot projects and offered instructions on how to help staff prepare
for the practical implementation of values. The second seminar,
entitled Values and Management, was attended by the top
management of the state administration as well as the project
participants. The goal of this seminar was to reflect on practical
situations that arise in state administration with regard to value
choices. Another goal was to show how values can inform effective
management tools.
Results
The working group drew on the experiences of the five pilot agencies
to produce conclusions and proposals for measures. These measures
are divided into three categories: 1) values as a tool of management, 2)
values as an officials moral code, and 3) monitoring implementation
of values.
To transform values into a management tool, careful attention has to
be paid to the implementation of the value process, the incorporation
of values into a management-by-results system and discussion of
results, developments and the opportunities afforded by the
remuneration system. Working atmosphere surveys, the example set
by directors and evaluation of management, training, recruitment and
attitudes towards actions that are contrary to values are also
important. There should be a continuous debate about values to
monitor implementation of the values in the units daily work and the
outcomes should be incorporated in the annual report.
It is the intention of the State Employers Office to assess the
effectiveness of the project separately after some time has passed.
Lessons
learned
51
Incorporating value-driven activity and management into day-to-day

work calls for conscious investment in promoting the matter in
numerous aspects of personnel policy, and particularly in
management. Every organization must go through its own process.
There are no ready-made off-the-shelf solutions, however attractive
that idea might be in theory.
4
Part of
government
The project was organized by State Employers Office, a department

within the Ministry of Finance which is responsible for providing
general guidance for state organizations in the area of personnel
policy, drafting the necessary legislation and representing the state
sector in the collective bargaining process at central level.
Contact
Name of organization: State Employers Office

Name of contact: Mr. Asko Lindqvist
Address of organization: P.O. Box 28, FIN-00023 Government, Finland
Telephone: +358 9 160 34989
Fax: +358 9 160 34839
Email: asko.lindqvist@vm.fi
Website: www.vm.fi
Values to be Part of the Daily Job. Working Papers 6b/2004. Ministry of
Finance, Finland, 2005.
Values in the Daily Job Civil Services Ethics. A handbook for the
state administration. Ministry of Finance, Finland.
Values to be Part of the Daily Job The experience of pilot
organizations and conclusions of the working group. Ministry of
Finance, Finland, 2005.
52
4.8 France
Annual Reports on Fraudulent and Corrupt Practices

Brief
description
The Annual Reports of the Service Central de Prvention de la

Corruption (SCPC) offer studies of fraudulent and corrupt practices in
individual risk areas. Not only does the SCPC draw the attention of
actors in the anti-corruption field to vulnerable areas, it also provides
them with the tools to identify the mechanisms behind corruption by
describing irregular practices specific to each area.
Background
and aim
The SCPC was established in 1993 to help protect and promote official
values and ethical standards in the public service and in the private
sector. The SCPC is an inter-ministerial service reporting to the
Minister of Justice and the Prime Minister which:
centralizes the information required to detect and prevent offences
involving active or passive corruption and the corruption of privatecompany managers or staff, undue advantage, extortion, favouritism
and influence peddling;
lends assistance, at their request, to the judicial authorities
investigating such offences;
issues opinions on measures liable to prevent such offences at the
request of a defined list of competent authorities;
implements training programmes for students and civil servants;
develops international activities (e.g. in Africa with the UN; the SCPC
is also a member of the Council of Europes Groupe dEtats contre la
corruption (GRECO)). The SCPC is playing an active part in the
preparation of the first conference of States Party to the UN
convention against corruption: there is a growing demand in this
area because of the multiplication of international and bilateral
agreements against corruption, fraud and drug trafficking;
develops partnership agreements with French private firms (e.g.
ACCOR, Crdit Mutuel, Dassault Aviation).
The SCPC produces annual reports and training modules for control
services, government services and companies.
Content
and process
53
The reports are prepared by the advisors from open sources of

information, interviews and academic works, but also from the shared
experiences of law enforcement institutions, particularly those with
specialist investigation teams, which contribute their experiences in
the field and allow the SCPC to analyze the latest forms of financial
delinquency.
4
Content
and process
For instance, the annual report for 2005 focused on the new regulation
for public procurement with a description of what it improves (the
extension of the principles of public procurement to new types of
public markets) and suggestions for further improvements (the
generalization of those principles to all sorts of public purchases, the
isolation of the public purchaser). The report also highlighted areas of
risk in the procedures involved in public procurement.
Results
In the 13 years of the SCPCs existence it has analyzed more than 40

topics in its reports, issued more than 1,000 opinions and
recommendations to specific authorities and trained more than 1,500
people in administrative and judiciary schools.
Lessons
learned
Good lessons:
the inter-ministerial composition of the SCPC brings a
multidisciplinary dimension to its work;
the SCPC is dedicated to prevention and only prevention: it is
important not to mix this with investigations;
the independence of the structure: it has freedom to choose the
topics covered in the annual reports and the right to be critical.
Part of
government
The Service Central de Prvention de la Corruption (SCPC) is part of

the Ministry of Justice.
Contact
Name of organization: Service Central de Prvention de la Corruption

Name of contact: Pierre Christian Soccoja
Address of organization: 129 Rue de LUniversite, 75007 Paris, France
Telephone: +33 1 43 19 81 60
Fax: + 33 1 43 19 81 72
Email: pierre.soccoja@justice.gouv.fr
Website: www.justice.gouv.fr/publicat/scpc.htm
Evaluating the Effectiveness of Measures to Combat Corruption in
France, in: Public Sector Integrity, OECD, 2005. www.oecd.org, topic:
corruption
The annual reports can be downloaded from the website
www.justice.gouv.fr/publicat/scpc.htm
54
4.9 Germany
Recommendations for Implementing the Federal Government Directive

Concerning the Prevention of Corruption in the Federal Administration
Brief
description
The Recommendations for implementing the Federal Government

Directive concerning the Prevention of Corruption in the Federal
Administration describe in practical terms how to act on the topics
covered by the directive. The purpose of these recommendations is to
help in implementing the directive in a wide range of practical
situations.
Background
and aim
As is often the case, when drafting the directive it was impossible to

include all conceivable practical constellations within the legislation
itself. It therefore seemed advisable to provide further information in
the form of recommendations which would allow users to adapt more
flexibly to the various aspects of implementation.
Content
and process
Like the directive, the recommendations were drafted under the

supervision of the Federal Ministry of the Interior and approved by all
the federal ministries. From the beginning, it was agreed that a
manual of some kind was needed to help implement the directive in a
wide range of practical situations and that it should be easy to revise
and update quickly in response to developments in the real world with
consensus among the ministries on the latest version.
The recommendations provide guidelines on the following topics:
identifying and analyzing areas of activity especially vulnerable to
corruption, personnel, a contact person for corruption prevention, the
organizational unit for corruption prevention and guidelines for
awarding contracts.
The directive itself has an annex that contains guidelines for
supervisors and heads of public authorities/agencies. These guidelines
describe pro-active measures that can be taken to prevent corruption.
These measures concern staff awareness and education, responsibility
for others and supervision and leadership style.
Results
55
The directive and the recommendations can be downloaded free of

charge from the Internet.
The Federal Ministry of the Interior has received numerous requests
from interested citizens and a variety of institutions.
The directive and recommendations are tools in the ongoing process
of preventing corruption. These tools combined with training
4
Results
activities have made staff aware of situations where there may be a

risk and have shown them how to deal with such situations.
Lessons
learned
The directive and the recommendations must not be considered in

isolation from one another. Both are tools designed to support an
ongoing process of preventing corruption. This process has an impact
both on the efforts of the organizational units actively involved in
preventing corruption and on the content of basic and advanced
training. Such training encompasses numerous activities offered by
federal training facilities, in-house activities offered by the ministries
and authorities and the many advisory sessions for specific
administrative units and/or individual staff members. These activities
have made staff aware of situations where there may be a risk and
have shown them how to deal with such situations properly and
appropriately. In this respect, prevention is also a precaution taken by
public employers, who have an interest in preparing their staff to deal
with difficult situations by providing them with the necessary
information and recommendations for action. Preventing corruption is
an ongoing task. Although there are no quick fixes, tools have been
developed to increase public service staff awareness of the issue.
Part of
government
The recommendations are issued by the Federal Ministry of the

Interior and are applicable for the Federal Government.
Contact
Name of organization: Federal Ministry of the Interior

Name of contact person:
Address:
Telephone: +49 (0)30 18 6810
Fax: +49 (0)30 18 681 2926
E-Mail: poststelle@bmi.bund.de
Website: www.bmi.bund.de
56
Federal Government Directive concerning the Prevention of

Corruption in the Federal Administration, including the AntiCorruption Code of Conduct and the Guidelines for supervisors and
heads of public authorities/agencies
Recommendations for implementing the Federal Government
Directive concerning the Prevention of Corruption in the Federal
Administration
4.10 Hungary
Anti-Corruption Coordination Board
Brief
description
The Anti-corruption Coordination Board, a supporting body, providing

opinions and recommendations for the decision-preparating work of
the Government, plays a professional coordinating role with respect to
the fight against corruption.
Background
and aim
The overall objective of the Board is to prepare the strategic document

illustrating the long-term objectives and the areas of intervention of
the fight against corruption, as well as the short-term action
programme related to these with respect to the period between 2008
and 2010 by the end of 2007. The Government is going to affirm the
documents in a resolution. During their development, the related
recommendations issued by the United Nations Organisation (UNO),
the Group of States Against Corruption (GRECO) of the Council of
Europe and the Organisation for Economic Co-operation and
Development (OECD) are to be taken into consideration and are to be
enforced.
Content
and process
The Government by its resolution 1037/2007. (VI. 18.) established the

Anti-Corruption Coordination Board.
Government Resolution number 1011/2004. (II.26.), on the
establishment of an Advisory Board for Corruption-Free Public Life, as
well as Government Resolution number 1023/2001. (III.14.), on the
Government strategy against corruption, expired.
The Board operates publicly performing its tasks according to the
rules of procedure it accepts with the Minister of Justice and LawEnforcement being responsible for its operation. The president of the
Board is the Minister of Justice and Law-Enforcement, who, in case he
cannot be present, is substituted by the person (president) authorised
by him. The secretarial tasks related to the operation of the Board are
performed by the Ministry of Justice and Law-Enforcement. In other
aspects the activity of the Board does not affect the tasks and
competencies of ministers defined in legal regulations and
government resolutions.
Members of the Board
57
a) the delegates of the Government bodies:

the individuals entitled to representation by
4
Content
and process
the Minister of Health;

the Minister of Economy and Transport;
the Minister of Justice and Law-Enforcement;
the Minister of Municipalities and Regional Development;
the Minister of Finance;
the Minister in charge of the Prime Ministers Office.
b) The Government asks the President of the State Audit Office, the
Hungarian Competition Office and the Council of Public Procurement,
and the Head of the Office of the National Council of Justice, as well as
the data-protection Parliamentary Commissioner and the Chief
Prosecutor to take part in the work of the Board as permanent guests
through their representatives.
c) The President involves the representatives of other professional,
social and interest-representational organizations in the work of the
Board, as well as internationally recognised experts with experience in
the fight against corruption on an ad hoc or permanent basis, and on
the basis of the recommendations worded by the Board as guests.
External partners are to be involved in the work of the Board in such a
manner that the number of these individuals or organizations reach
the portion of the delegates of Government bodies within the Board.
The tasks of the Board are the following:
promoting the exploration of corruption as a social and economic
phenomenon, analysing the general risks of corruption, making
recommendations for the application of more effective anticorruption means and methods with special respect to the
improvement of social sensitivity towards the fight against
corruption, as well as the support of the educational and training
activities necessary for this;
cooperating in the professional ground-laying and development of
the anti-corruption strategic documents, in the organization,
coordination, checking, evaluation and monitoring of their execution,
as well as the continuous updating of the above-mentioned
documents;
the theoretical co-ordination of the anti-corruption activities of the
bodies participating in the Board;
providing opinions about the presentations related to the fight
against corruption;
evaluating the results of the anti-corruption activities in harmony
with the execution of the short-term action programmes as well as
reporting to the Government.
58
4
Results
The first meeting of the Board was held in August, and according to its
schedule, after holding two professional forums, the strategic
document is to be prepared by the end of this year.
Lessons
learned
The Board is convinced that every country has to find itself its own
best practices how to fight corruption effectively, but they could and
should use the recommendations of international organizations or
forums, and the experience of other states.
Part of
government
The Anti-Corruption Coordination Board is an independent

government body.
Contact
Name of organization: Ministry of Justice and Law Enforcement /

Advisory Board for Corruption-free Public Life
Name of contact: Ms. Kozima Kopcsik
Address of organization: 1055 Budapest, Kossuth tr 4., Hungary
Telephone: +36 1 441 3688
Fax: +36 1 441 3912
Email: KopcsikK@irm.gov.hu
Website: www.irm.gov.hu
Government Resolution number 1037/2007 (VI.18).
Fight against corruption in Hungary.
59
4.11 Ireland
Requirements for the Disclosure of Interests

Brief
description
As provided for by the legislation on ethics in public life, holders of

specific positions of employment in prescribed public bodies are
required to furnish statements of registrable interests. The purpose of
this legislation is to disclose interests (including interests of a spouse,
child or child of a spouse) that could materially influence the holder in
or in relation to the performance of his/her official duties.
Background
and aim
The broad focus of the Ethics Acts is to provide for disclosure of

interests, including any material factors which could influence a
government minister or minister of state, a member of the Houses of
the Oireachtas or a public servant in performing their official duties.
The principal objective of the legislation is to demonstrate that those
who are participating in public life do not seek to derive personal
advantage from the outcome of their actions. To meet this objective, a
statutory framework has been put in place to regulate the disclosure of
interests and to ensure that other measures are taken to satisfy the
broad range of obligations arising under the legislation. The legislation
is founded on the presumption of integrity but recognizes that specific
measures should exist to underpin compliance.
Under the Ethics Acts, as well as disclosing interests, all members of
both Houses of the Oireachtas, the Attorney General and appointees to
senior office in public bodies must furnish evidence that they are tax
compliant to the Standards Commission. The legislation also provides
that codes of conduct must be drawn up for ordinary members of the
Houses, for office holders (e.g. ministers of the government and
ministers of state) and for public servants. These codes are published
by the Standards Commission.
The legal basis is the Ethics in Public Office Act 1995 and the Standards
in Public Office Act 2001.
Content
and process
60
The Standards in Public Office Commission (the Standards

Commission) is an independent body established in December 2001 by
the Standards in Public Office Act 2001.
The principal ongoing functions of the Standards Commission are to
provide advice and issue guidelines on compliance with the Ethics
Acts, to administer the disclosure of interests and tax clearance
regimes and to investigate and report on possible contraventions of
the legislation. These functions of the Standards Commission apply to
4
Content
and process
office holders and to public servants and, in relation to tax compliance

measures, to all members of the Houses of the Oireachtas. Apart from
matters relating to tax clearance, the Committees on Members
Interests of both Houses have functions similar to those of the
Standards Commission in relation to members of the Houses who are
not office holders.
Results
The annual reports of the Standards in Public Office Commission

provide the best examples of the results that have been achieved. The
last available report from 2005 mentions, for example, that as a
consequence of the introduction of regulations by the Minister for
Finance, with effect from 1 January 2006 the number of bodies in the
civil and public service falling within the scope of the Ethics Acts had
increased from almost 400 to around 470.
Lessons
learned
The best way to judge is to read the annual reports of the Standards
Commission, available at http://www.sipo.gov.ie. The annual report for
2005, for example, mentions the second evaluation round of GRECO on
Ireland and Transparency Internationals Global Corruption Report, in
th
th
which Ireland slipped from 11 to 19 place, as important sources for
assessing the ability of its laws and institutions to prevent corruption
and to improve its anti-corruption measures in order to maintain and
enhance public confidence in public administration.
Part of
government
The Department of Finance has a central role in implementing

government policy, in particular the Programme for Government, and
in advising and supporting the Minister for Finance and the
government on the economic and financial management of the State
and the overall management and development of the public sector. In
formulating this advice the department is guided by its mission, which
is to promote a growing economy which will deliver a high level of
sustainable employment, social progress and living standards.
Contact
Name of organization: Ministry of Finance

Name of contact: Paul E Murphy
Address of organization: Government Buildings, Upper Merrion St.,
Dublin 2. Ireland
Telephone: +353 1 631 8019
Fax:
Email: paul.e.murphy@finance.gov.ie
Website: www.finance.gov.ie
61
4
Guidelines on Compliance with the Provisions of the Ethics in Public
Office Acts, 1995 and 2001 - Office Holders (Third Edition)
Guidelines on Compliance with the Provisions of the Ethics in Public
Office Acts 1995 And 2001 - Public Servants (Fourth Edition)
62
4.12 Italy

Brief
description
The Code of Conduct for Government Employees specifies principles

and criteria for the daily conduct of public employees. It is mainly
designed to reinforce the principles of impartiality, efficiency,
responsibility and confidentiality of administrative information
already enshrined in the Constitution and subsequent laws. The code
applies to all government employees, excluding military personnel, the
state police and the prison police, magistrates and members of the
state legal advisory office.
Background
and aim
The code of conduct was laid down by Legislative Decree No. 29 of 3

February 1993 and was adopted by the Decree of the Minister for Public
Administration of 28 November 2000.
The code revised and updated the previous code of conduct for
employees of government departments. It was also written to reflect
new organizational measures that were adopted to safeguard the
quality of services delivered to citizens by the public administration.
Collective bargaining agreements provide for coordination between the
principles and the contents of the code and the provisions concerning
disciplinary responsibility, without prejudice to provisions in effect
concerning other forms of liability for public employees. The rules
contained in the code do not in fact have a juridical character per se;
rather they have a deontological value. The principles laid down in
the code of conduct are only effective if and when they are included in
the collective bargaining agreements, since breaches of them are then
converted into disciplinary infractions whose violation leads to the
application of disciplinary sanctions.
The code of conduct was incorporated in the last collective bargaining
agreements for the period 2002-2005.
Content
and process
63
The code establishes the following principles:

Impartiality: in performing their duties public employees shall
ensure equal treatment of the citizens who come into contact with
the administration.
Efficiency: public employees shall devote the proper amount of time
and energy to discharging their duties and undertake to carry these
tasks out in the simplest and most efficient manner possible in the
interests of citizens.
4
Content
and process
Responsibility: with respect to performing their duties.

Care: in the use and custody of goods and with respect to the
confidential nature of information.
Collaboration between citizens and administration
Simplification: public employees shall apply every possible means to
simplify administrative activity and facilitate citizens performance
of the activities permitted to them.
Subsidiarity: public employees shall observe the division of
competences between the central and local governments and
facilitate the performance of functions and duties by the authority
which has the most proximate jurisdiction and is functionally closest
to the citizens concerned.
The code also regulates the conduct in service, particularly of the
public employees who have relations with the public (observation of
the chronological order of cases, keeping appointments with citizens
and prompt response to complaints); requesting and offering gifts (the
employee shall not request not accept, for himself or others, even on
the occasion of festivities, gifts or benefits, save items for use and of
modest value, from persons who could derive an advantage from
decisions or activities of the office); the use of office materials or
equipment (the employee shall not use for private purposes materials
or equipment provided for official use); membership of organizations
or associations whose interests are affected in the performance of the
offices activities.
These measures are important for guaranteeing the transparency and
proper functioning of public administrations, for completing the
process of making public employees responsible and completing the
process of maintaining moral standards among public officials.
Results
64
On the basis of specific instructions issued by the Department for

Public Administration, in 2002 that departments Inspectorate Office
established a monitoring system designed to verify observance of the
code of conduct by ministries and the adoption of specific codes in
different sectors.
The final report produced by the Inspectorate Office, drawn up on the
basis of the responses from fourteen ministries, included the followed
conclusions:
all administrations had adopted internal codes taking into account
dispositions contained in the Code of Conduct of 28 November 2000;
all administrations had adopted codes for specific categories of
employees;
all administrations assured observance by employees of the
4
Results
dispositions contained in the Code of Conduct;

all administrations had adopted initiatives to disseminate, publicize
and analyze the Code of Conduct, including training and
re-qualification courses;
all administrations provided a copy of the Code to employees, who
had to accept it at the time they were hired.
The final report also contained detailed data and information about
proceedings for transgressions of disciplinary, penal and accounting
rules. For the period 2000-2001, disciplinary proceedings were conducted
against 1,725 employees, compared with a total of 192,816 in service
on 31 December 2006. This represents 0.89%. In the same period, 1,161
employees received disciplinary sanctions, a percentage of 0.60.
Lessons
learned
A specific code of conduct for inspection staff at the Ministry of Labour

and Social Polices was adopted in April 2006, partly with a view to
integrating the Code of Conduct of 28 November 2000. This document
is particularly interesting because for the first time it identified
specific elements of conduct applicable for all staff charged with
inspection functions in the labour and social security sectors.
Dispositions contained in the code for inspection staff operate as
internal dispositions and they are relevant for the aspect of discipline.
Part of
government
The responsible organization is the Department for Public

Administration in the Prime Ministers Office. This department is
charged with human resources policy for state administrations, public
agencies and public bodies.
Contact
Name of organization: Prime Ministers Office Department for Public

Administration Office for the personnel of public administrations
Name of contact: Francesco Verbaro Laura Ciattaglia
Address of organization: Corso Vittorio Emanuele II, 116 00186 Roma,
Italy
Telephone: +39 06 68997572
Fax: +39 06 68997498
Email:
Website:
65
4.13 Latvia
The Corruption Prevention and Combating Bureau

Brief
description
The Corruption Prevention and Combating Bureau combines the

prevention and combating of corruption with education of society on
corruption issues. As such, it is a key player in the National
Programme for Corruption Prevention and Combating. The purpose of
the bureau is to support the states programme to improve public trust
in the government.
Background
and aim
The bureau was established at a time when it was felt that the efforts
being made by various state institutions were not effective enough and
were uncoordinated and public awareness of the risk of corruption
was increasing. A working group was set up with members from
various state institutions and NGOs, which proposed creating an
independent specialist anti-corruption agency.
The state programme is intended to ensure that public duties are
carried out more effectively and ethically with respect for the rule of
law and the public interest. It aims to increase public trust in the
government.
Content
and process
The Corruption Prevention and Combating Bureau was established in

2002 and has had a significant impact in the field of preventing and
fighting corruption in Latvia over the past few years. The bureau takes
a comprehensive approach to fighting corruption that is based on
simultaneous action in three main areas: 1) prevention of corruption,
2) combating of corruption (criminal investigation and sanctioning),
and 3) education of society on corruption issues.
Prevention and Combating of Corruption
The bureau receives declarations of political parties financial
activities (declarations of expenditure on pre-election campaigns,
election expenditure declarations and annual financial declarations).
The bureau compiles and analyzes the information provided in those
declarations and monitors that the receipt of donations is in
accordance with the regulations.
66
The bureau also examines complaints and replies to enquires received

from the public concerning allegations of conflicts of interest. During
2005 the bureau examined 843 declarations by public officials and
administrative sanctions were imposed on 109 public officials for
violation of the Law on Prevention of Conflict of Interest in Activities of
4
Content
and process
Public Officials. In a number of cases, special restrictions on public

officials with respect to combining public positions were not observed.
Education
The bureau provides regular training for public officials and political
parties regarding conflict of interest, ethics and financing of political
parties. Seminars are provided on request for public and municipal
institutions. There are three modules: Prevention of Conflict of
Interest and Professional Ethics of Public Officials; Assessing
Corruption Risks and Development of Anti-Corruption Action Plans;
Corruption and its forms. Studies, evaluations, statistics.
In 2006 the bureau also released a comprehensive new training
resource on Public Sector Ethics in the form of CDs. Officials of the
bureau participated in 56 training seminars in 2005.
The bureaus activities fit in with the National Programme for
Corruption Preventing and Combating 2004-2008. This programme is
an interdisciplinary, inter-institutional policy instrument that serves
as a basis for preventing and fighting corruption in Latvia. The
measures foreseen in the programme are implemented in a
coordinated way by all the relevant state institutions. The bureau
coordinates the implementation of the measures and reports on them
to the Cabinet of Ministers. Roughly 70% of the 120 measures had been
implemented as of October 2006. Work is continuing to implement the
rest of the measures.
The bureau has provided extensive expertise on formulating a legal
anti-corruption framework, developing and implementing anticorruption policy and establishing an institutional framework to
Moldova, Kazakhstan, Ukraine, Tajikistan and other countries. The
bureau hosted delegations from the former Yugoslav Republic of
Macedonia in March 2006 and the Kyrgyz Republic in December 2006 to
discuss measures to prevent corruption in public procurement and
inform them of the organization and the work of the bureau.
Results
67
Results in the field of preventing corruption

The bureau receives regular complaints and enquiries from the public
on allegations of conflicts of interest. For example, during 2005 the
bureau examined 843 declarations by public officials. Administrative
sanctions were imposed on 109 public officials for violation of the Law
on Prevention of Conflict of Interest in Activities of Public Officials. In
most of the cases, public officials had breached legal rules prohibiting
them from performing administrative acts, exercising supervision,
control, inquiry or punitive functions or entering into contracts in
4
Results
matters where relatives have a personal or financial interest. In a

number of cases, public officials had failed to observe special
restrictions on accepting outside employment. As a result, 36 public
officials were asked to reimburse the damage caused to the State by
violations of the legal restrictions in 2005.
Results in the field of combating corruption
On 1 October 2005 the Criminal Procedure Law entered into force with
the aim of improving the efficiency of judicial institutions in Latvia by
simplifying criminal procedures. In 2005 the bureau initiated 27
prosecutions against 50 persons, compared with 22 cases (29 persons)
in 2004 and 12 cases (20 persons) in 2003. Eight cases were decided in
2005 compared with three in 2004.
Results in the field of education
The bureau has provided extensive training in the development and
implementation of anti-corruption policy for representatives of
Moldova. Officials of the bureau have also provided expertise on
establishing a legal anti-corruption framework in Kazakhstan and
Tajikistan. And in March 2006 the bureau hosted a delegation from the
former Yugoslav Republic of Macedonia to discuss measures to prevent
corruption in public procurement.
Lessons
learned
The bureau was modelled on Hong Kongs ICAC. Several other

countries have adopted this approach of establishing a multifunctional
anti-corruption agency, but so far only Lithuania, and since May 2006
Poland, in Europe. Other countries have learned from the practice of
the bureau including Moldova and the Kyrgyz Republic.
The bureau has given presentations on the National Programme for
Moldova and Ukraine. The good lesson learned is that implementing
measures in a coordinated way, with regular follow-up by a single
central institution, makes it easier to achieve results within a specific
time frame and to identify the problems. Through regular reports to
the Cabinet of Ministers, which are also available to the public on the
bureaus website, the programme is being implemented in a
transparent and accountable manner.
Part of
government
68
The Corruption Prevention and Combating Bureau is part of the State

Administration.
4
Contact
Name of organization: Corruption Prevention and Combating Bureau

Name of contact: International Co-operation Division
Address of organization: Alberta Street 13, Riga, Latvia, LV-1010
Telephone: +371 6 7356135
Fax: +371 6 7331150
Email: knab@knab.gov.lv
Website: www.knab.gov.lv
Documents are available on the website www.knab.gov.lv/eng
69
4.14 The Netherlands
1. Public Administration Probity in Decision-Making Act (BIBOB):

Promotion of Integrity Assessment by Public Administration
Brief
description
The objective of BIBOB is to promote the screening of the criminal

antecedents of applicants for licences, subsidies and/or tenders, thus
preventing the government from unintentionally facilitating new
criminal activities and harming its integrity. To perform this screening
the administration must be able to obtain the necessary information.
For that purpose a national bureau has been established to provide
administrative bodies with advice and information on the risks they
face with certain applicants.
Background
and aim
Organized crime can manifest itself at a local level. Sometimes local

governments facilitate crime wittingly or unwittingly, by granting
licences for the exploitation of a bar in which drug trafficking later
takes place or illegal money is laundered into legal money, or by
granting a procurement licence to a building company that makes
illegal pricing arrangements. Research showed that several branches
have proved to be vulnerable to organized crime, including the
transport industry, the hotel and catering industry, the building
industry, the sex industry and the housing business.
Penal law alone is not sufficient to tackle this kind of problem.
Individual criminals can be convicted, but other criminals can take
their place.
Administrative measures can help (local) authorities by targeting
situations/opportunities rather than specific individuals, for example
by closing down buildings in which illegal prostitution takes place or
coffee shops or hotels that are used for money laundering. Several
cities have faced problems of this kind, such as Amsterdam and its Red
Light District.
If (local) governments do not have enough information to adequately
screen an applicant, they can turn to Bureau BIBOB, which has access
to open and confidential sources and can therefore give advice about
the degree of risk that the licence/subsidy/tender will be misused.
Content
and process
70
The Public Administration Probity in Decision-Making Act (BIBOB) has

been in force in the Netherlands since 2003. This act aims to equip the
administrative response to crime with a complementary instrument
(grounds for refusal) and to guarantee the probity of the public
administration through the exchange of information (screening). The
BIBOB Act came into being after administrative bodies drew attention
4
Content
and process
to the fact that criminals had penetrated economic life and made use
of administrative facilities. The Dutch authorities appear to spend a lot
of time and resources on tracing and prosecuting organized crime, but
at the same time they facilitate it. Before the act took effect,
administrative organs that suspected a licence or subsidy was going to
be used for punishable offences had few if any means for refusing or
cancelling the application.
Results
Bureau BIBOB received 96 requests for a BIBOB advice in 2005, almost

all of which were related to licences. In 53% of its recommendations to
the government body, the bureau stated that there would be a serious
risk of the licence being abused for criminal activities (fraud, money
laundering, etc.). As a result, licences were not granted or were
withdrawn. The majority of the requests for advice to BIBOB came
from municipalities, followed by provinces and ministries.
Approximately two-thirds of the recommendations related to
operating licences for pubs and other establishments in the hotel and
catering industry. Most recommendations took 4-8 weeks to complete.
The BIBOB Act is currently under evaluation. The evaluation was sent
to parliament at the end of 2006.
Lessons
learned
Awareness that authorities can play a role in preventing/combating

organized crime at local level by carefully reviewing
subsidies/licences that might be used for criminal purposes.
Administrative measures can be used to complement penal law
sanctions.
BIBOB can be a useful tool for promoting the integrity of government
officials and preventing organized crime.
BIBOB is a last resort for municipalities, provinces, etc. There is a lot
that they can do themselves before turning to Bureau BIBOB for
advice, such as screening with the help of their own sources.
Part of
government
Ministry of the Interior and Kingdom Relations
Contact
Name of organization: Ministry of the Interior and Kingdom Relations

Name of contact: Mr. Maarten Vollenbroek
Address of organization: Schedeldoekshaven 200, The Hague
Telephone: +31 70 426 7174
Fax:
71
4
Contact
Email: maarten.vollenbroek@minbzk.nl
Website: www.minbzk.nl
www.justitie.nl/onderwerpen/criminaliteit/bibob/
12557/04 crimorg 79 (official EU document)
Publication Organised Crime Prevention in the Netherlands
2. The National Office for Promoting Ethics and Integrity in the Public
Sector (Dutch acronym: BIOS)
Brief
description
The National Office was installed in March 2006 to help government

organizations improve their integrity policies. The office has five tasks:
- to promote integrity policy;
- to develop instruments for putting this policy into practice;
- to support the implementation and use of instrument to promote
integrity;
- to collect, disseminate and share integrity-related knowledge;
- to generate new knowledge.
Background
and aim
Background:
The National Integrity Office was established in the context of the
ministers responsibility for coordinating policy on integrity
throughout the public sector. While each individual public sector
organization is responsible for its own integrity policy, as coordinating
minister the Minister of the Interior and Kingdom Relations is
responsible for the public sector integrity system at large. This system
comprises three aspects: steering (laws and regulations), monitoring
and evaluation and initiating, promoting and facilitating.
72
Aim of the Office:

The aim of the National Integrity Office is to work towards a situation
where governmental bodies pursue a broad integrity policy within
their organization in which the various integrity measures form an
integral and balanced whole. The Office supports all government
organizations in their efforts to put in place an integrity policy by
developing instruments, encouraging the exchange of knowledge and
good practices and offering assistance to government organizations
with regard to the implementation of integrity policies. The main
4
Background
and aim
target group is managers, ethics officers, HR officials etc. The Offices

philosophy is to enhance the learning process within government
organizations to enable them to manage integrity themselves since
government organizations should not outsource the care for integrity.
Content
and process
The need for a national centre of expertise on integrity issues has

become increasingly apparent since the Millennium, and particularly
in light of the lessons learned from the report of the Parlementary
Inquiry Committee which investigated the fraud in the building
industry. In view of the Minister of the Interiors coordinating role with
respect to integrity policy in the public sector, the institutionalization
of the National Integrity Office was a logical step. To acquire the
necessary information about the needs of public bodies in the area of
integrity policy, its future tasks and the size and the costs of the Office,
we interviewed the heads of various other centres of expertise as well
as other experts (e.g. scholars). When the Office was formally
established, the struggle began to find qualified personnel to do the
job. We also discovered that a policy environment (the ministry) is not
always the best environment for developing instruments and
addressing issues of implementation. That is why we feel the Office is
best positioned outside the ministry.
Results
We have developed several compliance and value-based integrity

instruments, some in cooperation with other key players. They include
the Integrity Infrastructure Model (which covers every aspect of
integrity in a systematic and coherent way), the Integrity Cube (a
multimedia training tool), SAINT (a self-assessment instrument for
integrity) and several guides and manuals to help public bodies
implement integrity policy within their organizations. We organized
several conferences for and in association with the umbrella bodies of
public authorities, including the Association of Dutch Provinces and
the Association of Dutch Water Management Boards, and individual
public organizations to disseminate knowledge and provide
information about new instruments for public bodies in the different
sectors. We have organized expert meetings and consultative meetings
for various organizations and key players. We have also organized
several workshops and presentations for the benefit of labour
organizations and interested groups. Our website
(www.integriteitoverheid.nl) receives a lot of hits and governmental
organizations make quite a lot of use of our instruments, such as
SAINT and the Integrity Cube.
73
4
Lessons
learned
The Office shows that the easy availability of practical integrity

instruments (via the website) and the exchange of knowledge and
information are practical and important methods of implementing
integrity policy, developing new measures and raising staff awareness
of integrity. The systematic and coherent approach, as laid down in the
Integrity Infrastructure Model, offers public bodies a clear insight into
the complexity of integrity and stimulates them to draw up and
implement an integrated integrity policy for their organization. The
most difficult aspect is positioning the Office correctly and finding
qualified personnel. The best lesson we learned is that integrity
instruments should be small, easy to use, not too ambitious and not
too expensive. Long and complicated integrity programs should be
avoided.
Part of
government
The National Office for Promoting Integrity in the Public Sector is an

initiative of the Ministry of the Interior and Kingdom Relations.
Contact
Name of organization: Bureau Integriteitsbevordering voor de

Openbare Sector (BIOS)
Name of contact: mr. Alain Hoekstra
Address of organization: Lange Voorhout 13
Telephone: +31 70 376 5885
Fax: +31 70 345 7528
Email: alain.hoekstra@minbzk.nl
Website: www.integriteitoverheid.nl
Information concerning the national office on website (in Dutch):
http://www.integriteitoverheid.nl/bios
Factsheet: The Dutch National Office for Promoting Ethics and
Integrity in the Public Sector (English)
Information concerning the national office on website (in Dutch):
http://www.integriteitoverheid.nl/bios
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4
3. The Integrity Cube: a Multimedia Dilemma and Training
Instrument
Brief
description
The Integrity Cube is an appealing and easy to use instrument that

was developed to stimulate discussion of integrity within government
organizations and to increase awareness of the issue of integrity
among management and staff. The Cube is a multimedia instrument
which can be used during group sessions on ethical dilemmas
throughout the public service. A special module offers assistance in
how to address people who act in an unethical manner.
Background
and aim
Major changes were made in the Dutch Civil Servants Act in 2006. One
of the amendments created an obligation for all public sector
organizations to discuss integrity during performance appraisals, staff
meetings and training sessions. The National Office for Promoting
Integrity in the Public Sector supports government organizations with
compliance and values-based integrity instruments. The Cube is a
typical values-based instrument designed to help in analyzing
dilemmas and improving integrity awareness and moral reasoning.
Content
and process
After the Millennium, and especially after the fraud in the

construction industry, the Dutch government started to broaden its
integrity policy to encompass a more values-based approach. The Cube
is based on similar instruments designed for the Ministry of Justice
and the City of Rotterdam. It took about two years to develop the Cube
and the accompanying manual. A focus group consisting of people
working in different tiers of government and two integrity specialists
was established to collect the relevant dilemmas and assess the initial
output of the project. The Integrity Cube is unique because it is
suitable for the entire public sector and combines various approaches
for discussing and tackling ethical dilemmas. The special module
aimed at offering assistance in addressing people who act in an
unethical manner is a new and unique method.
Government organizations can use the Cube during workshops,
training sessions, introduction meetings for new staff and other
meetings devoted to the subject of professional integrity. It is best used
with the help of an expert trainer/counsellor. However, an extensive
manual has been written to enable government organizations to use
the Cube with internal trainers.
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4
Content
and process
How does the Integrity Cube work?

The Cube is a software program on CD Rom, with footage about
dilemmas in everyday work that everybody will recognize. The CD Rom
is easy to install and to use.
The Cube consists of three parts:
1 introduction by the former Minister of the Interior and Kingdom
Relations;
2 cases menu with eight integrity dilemmas as starting point for
discussion;
3 BLAME model: guidelines for identifying and addressing unethical
behaviour.
The eight dilemmas are based on real-life situations at work. The
footage is stimulating and encourages the participants to react. The
discussion that emerges from those reactions is a starting point for a
debate on integrity dilemmas and situations in the participants daily
work. A few of the topics covered in the films are:
exemplary role of management;
relationship between private behaviour and work in the office;
misuse of company assets;
personal loyalty versus professional responsibility;
dealing with confidential information.
The BLAME model
The Dutch abbreviation BLAME is derived from the process for dealing
with situations where one is confronted with unethical behaviour by
others (Bemerken, Labelen, Aanspreken, Melden, Egaliseren). Literally
translated, this means Notice, Label, Address, Report, Settle.
Results
76
Since the project has just started (April 2007) it is too early for clear
results. The following interim results can be mentioned:
20 try-outs (pilot sessions with the Cube);
approximately 450 participants took part in these try-outs;
participants perceived the try-outs as successful and said they had
gained useful knowledge about integrity in a very pleasant, easily
accessible and positive way;
750 applications have already been received from various
government organizations;
from April 2007 onwards the CD Rom is available for free (only for
government organizations) because the development costs were
kept low.
4
Lessons
learned
A few hurdles encountered in the process of making the Cube can be

mentioned. The original planning was not good. The idea was that it
would be possible to finish the instrument within a year or eighteen
months. It took longer. Trying to combine the various existing methods
(such as moral reasoning and the Socratic approach) for handling
ethical dilemmas also proved a puzzle.
The focus group, with people working in different tiers of government,
proved very useful. Not only did they provide useful situations and
dilemmas, they also became ambassadors for the project and helped
create broad support throughout the Dutch government.
There have already been a huge number of requests for the Cube,
which is a clear sign that there is a need for this type of instrument in
the public sector.
Part of
government
The Integrity Cube was developed by the National Office for Promoting
Integrity in the Public Sector. The National Office for Promoting
Integrity in the Public Sector is an initiative of the Ministry of the
Interior and Kingdom Relations.
Contact
Name of organization: Ministry of Interior and Kingdom Relations

Name of contact: Mr. Alain Hoekstra
Address of organization: Schedeldoekshaven 200, The Hague
Telephone: +31 70 426 7191
Fax: +31 70 426 7401
Email: alain.hoekstra@minbzk.nl
Website: www.integriteitoverheid.nl
Available in Dutch are:
Fact Sheet on the Integrity Cube
Online demonstration of the Cube:
www.integriteitoverheid.nl/contents/flas/ik/demo-ik.html
77
4.15 Poland
1. Ethical Principles of Police Officers

Brief
description
Ethical principles of police officers is a document that describes

ethical standards and behavioural models. The purpose of the
document is to offer a practical guide for police officers in the
performance of their duties and in their private life.
Background
and aim
Ethical problems encountered by police officers and civilian staff in

the performance of their duties prompted the police forces
commander in chief to issue Ethical Principles of Police Officers. The
document provides police officers with an understanding of the
ethical behaviour expected of law enforcement officials in modern
society. It was also driven by a need to strengthen and supplement the
right and duties of police officers in a democracy.
This document should then be perceived as a result of a practical
approach to ethics from the point of view of the police. Research was
carried out to gather knowledge about officers behaviour in ethically
difficult situations. On the basis of this research, ethical standards and
behavioural models were described as a guide for police officers in the
performance of their duties and in their private life.
Content
and process
Ethical Principles of Police Officers was published by order of the

commander in chief of the police. According to the Act on Police, as a
rule every police officer is obliged to carry out an order or instruction
given by a superior. The legislation was drafted by the Personnel &
Training Bureau, Legislation Bureau in consultation with the police
officers trade union. The legal basis for the document is Article 7,
section 1 of the Act on Police which stated that the Police Commander
in Chief shall specify principles of police officer professional ethics,
having consulted the police officers trade union.
Results
The Ethical Principles of Police Officers should be perceived as a

model for good practice in relation to behaviour.
The implementation of the provisions of the document is a long-term
project so it is not yet possible to indicate any results or benefits.
Part of
government
The Internal Affairs Bureau is part of the Polish police. The name of the
bureau in Polish is Biuro Spraw Wewnetrznych and it is further referred
to as the BSW.
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4
Part of
government
The task of the BSW is to detect and prosecute crimes committed by

police officers and other police employees. The bureau consists of:
the management:
a bureau director,
b deputy bureau director,
3 Directorates (with 22 divisions), including the Operational
Undertakings Analysis, Forecast and Support Division, the
Operational Technique Division, the General Division and the Special
Operations Division.
Lessons
learned
It is too early to specify lessons.
Contact
Name of organization: General Police Headquarters, Internal Affairs

Bureau
Name of contact: Mr. Marek Dzialoszynski - Bureau Director
Address of organization: Pulawska str. 148/150, 02-514 Warsaw, Poland
Telephone: +48 22 646 58 22
Fax: +48 22 60 172 65
E-mail: bswkgp@policja.gov.pl
Website: www.kgp.gov.pl
Ethical principles of Police Officers has not yet been translated into
English. As soon as the translation is available it shall be provided.
A document entitled The Polish polices experiences in focusing on
strategic research and building up the police strategy
2. Moral Integrity in the Work of a Police Officer as a Public Official

Brief
description
The Principles of Police Ethics are incorporated at every level of police

training. The purpose of this is to provide police officers with a basic
understanding of their responsibilities as a public official.
Background
and aim
Ethical norms were introduced as a result of political transformations

and in connection with a new role to be performed by police officers in
a democratic state. These norms have also become an instrument for
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4
Background
and aim
influencing and increasing public trust in the police and public

approval of police actions. The legal regulations laying down
disciplinary responsibility for violations of ethical guidelines was
introduced both for educational purposes and to encourage their
pragmatic. The law regulating police work in Poland also includes a
rule that a police officer cannot be a member of any political party.
This rule is designed to avoid possible influences or attempts to exert
political pressure. There is also a requirement for police officers to
obtain their superiors permission to do additional paid work so that
conflicts of interests can be prevented.
Content
and process
Initiation of actions by the police aimed at gaining support for the

legislative changes among the police, the public and law makers.
Incorporation of police ethics as a compulsory subject in police
teaching syllabuses at every level of police education as well as
propagation of the model among related services and the civilian
staff of the police.
Conduct of research into public opinion about the police as an
institution of public trust and encouragement of non-police research
organizations to conduct their own studies.
Popularization of ethical norms (through mass media, police briefings,
posters).
Analysis of complaints against police officers with special attention
to conduct in violation of principles of police ethics.
Official oversight.
Results
Notable increase in public trust (findings of public opinion polls).

Noticeable enhancement of police officers prestige in Poland
(growing number of candidates willing to join the police, including
persons with a higher education).
Improved effectiveness of police work (increase in crime detection
rates).
The requirement to obtain official permission to do additional paid
work reduces opportunities for the occurrence of situations involving
corrupt practices.
Lessons
learned
Good experiences
The practical example can be applied in various sectors of public
administration.
Enhancement of job performance standards.
Enhanced prestige of police officers job.
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4
Lessons
learned
Bad experiences
Difficulties in classifying particular forms of police conduct as
violations of police ethics, making it more difficult to determine
whether instituting disciplinary proceedings would be legitimate.
Encroachment on police officers civil liberties (a ban on membership
of any political party).
Part of
government
The Higher Police School in Szczytno.
Contact
Name of organization: Institute of Criminal Science, (part of the)

Higher Police School in Szczytno
Name of contact: Subinsp. Rafa Kwasinski
Address of organization: 12-100 Szczytno, ul. M. Pisudskiego 111,
Poland
Telephone: +48 668 403 478
Fax: +48 0896 215 192
E-mail :
Website: www.wspol.edu.pl / www.pulprk.wp.pl
The following documentation is available: regulations in legal
instruments; Principles of Police Ethics; findings of sociological
research; course syllabuses in ethics.
81
4.16 Slovenia
Implementing Integrity Plans

Brief
description
Integrity plans are an instrument for raising awareness about

weaknesses in an institutions operations or about the vulnerability
and exposure of an institutions operations with the aim of preventing
and warning about possibilities of corruption. The purpose of these
plans is to restore or improve an institutions integrity. It represents a
strategic tool for prevention of corruption and is one of the
fundamentals of the Slovenian national strategy in the fight against
corruption.
Background
and aim
The essence of the integrity plan is to restore or improve an

institutions integrity. The integrity plan is designed to prevent
derogation from integrity caused by the breaking of rules and
preventing misconduct in the form of nepotism, clientilism,
illegitimate use of the organizations resources. Consequently, the
integrity plan is an instrument designed to increase awareness about
weaknesses in the institutions operations or about the vulnerability
and exposure of the institutions operations with the aim of preventing
and warning about possibilities of corruption. The integrity plan
studies the systems ability to resist violations that can lead to
corruption and ways of preventing the accumulation of authorisations
without special supervision or only by routine controls. In addition, it
examines under-standardization, over-standardization and the
execution of concrete internal measures in practice. As already
mentioned, the integrity plan contains legal measures requiring, for
example, that internal measures must be taken in risky areas, for
example the setting up of physical or electronic protection for rooms,
equipment and employees. The Prevention of the Corruption Act in the
Republic of Slovenia (2004) defines the integrity plan as measures of
legal and practical nature, which eliminate and prevent the occurrence
and development of corruption in a body.
The object of the integrity plan is to:
analyse the institutions vulnerability;
assess the risky areas where corruption is possible;
increase the institutions resistance to corruption;
increase the awareness level of employees;
continually implement improvements in prevention;
establish a control mechanism;
educate employees.
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4
Content
and process
The integrity plan represents a systematic effort to estimate the

capacity and vulnerability of the defense mechanisms that are built
into the structure, procedures and rules of the organization and its
anti-corruption regulations. Assessors investigate and analyse areas of
risk. The assessors then develop measures to protect any areas at risk
they discover against corruption. Based on areas that are discovered to
be vulnerable or weak, the assessors submit a report about the integrity
level in the institution and recommend possible improvements, which
can be accepted at the discretion of the institutional leadership.
The integrity plan is implemented in four phases:
the preparatory phase (first phase);
the identification of vulnerable activities (second phase);
the assessment of existing resistance mechanisms (third phase);
increasing the resistance (fourth and final phase);
According to the guidelines drafted by the Commission for the
Prevention of Corruption, the integrity plans must be completed
within two years; the actual period depends on the size of the
institution.
Results
The current situation in Slovenia is that the state bodies referred to in

Article 43 of the Prevention of Corruption Act have formulated
integrity pans and adopted them within the deadline stipulated in the
guidelines and have informed the Commission for the Prevention of
Corruption about their implementation. The Commission has already
organized various workshops and seminars. Due to the great demand
for additional training, it will organize a third round of seminars in the
near future before closely examining the operation of integrity
assessment by all the bodies.
Lessons
learned
The use of the integrity plan in institutions should be seen as a

constant learning process. One could start with a limited list of areas
with the greatest exposure to risk and later gradually expand and
improve the plan. In this way, in a few years the plan could encompass
similar assessments for other parts of the organization. Moreover, the
plan could also provide for assessment of the original security
measures and for their updating on the basis of actual experience.
Part of
government
The Commission for the Prevention of Corruption is an independent

state body.
83
4
Contact
Name of organization: Commission for the Prevention of Corruption

Name of contact: mag. Sandra A Blagojevi
Address of organization: Trzaska 19a, SI-1000 Ljubljana, Slovenia
Telephone: +386 1 478 8483
Fax: +386 1 478 8472
Email: sandra.blagojevic@kpk-rs.si
Website: www.kpk-rs.si
Document: The Integrity Plan in the Republic of Slovenia
Prevention of Corruption Act (ZPKor)
Resolution on the Prevention of Corruption in the Republic of
Slovenia (RePKRS)
84
4.17 Spain
1. Act regulating the conflicts of interest of the Members of Government

and the Senior Officials of the General State Administration
Brief
description
The objective of this act is to establish the obligations pertaining to the

members of government and to the senior officials of the general State
Administration in order to prevent situations that could give rise to
conflicts of interest.
Background
and aim
This act is not a mere reproduction of the rules for conflict resolution
as they have been interpreted up to today. Instead it establishes a new
regulatory legal framework for senior officials conduct and introduces
new requirements and guidelines, replacing the previous
incompatibilities framework, which guarantee the avoidance of
situations that put the objectivity, impartiality and independence of
senior officials at risk, without prejudice to the administrative
hierarchy. This framework introduces the changes necessary to
remedy the defects and legal gaps that have been detected over time.
In addition, it reinforces the image that the senior officials should
present to citizens as public servants. The act was ratified on 10 April
2006.
Content
and process
The act contains five chapters:

1) a system of incompatibilities,
2) a system of activities,
3) obligations of senior officials,
4) bodies of management, surveillance and control, and
5) a system of sanctions.
It establishes rules for the avoidance of conflicts of interest by
members of government and senior officials of the General State
Administration, who must dedicate themselves exclusively to their
public position and avoid all activities that could disrupt or influence
their civic duties.
Likewise, the act strengthens the control over any equity interests held
by senior officials, their spouse or cohabiting partner and certain
members of their family. This is achieved by extending the rule
prohibiting them from holding more than a 10-percent interest in
companies that have any type of agreement with the public sector, in
subcontractors of such companies or companies that receive subsidies.
The act has also introduced additional controls of restrictions on postemployment activities.
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4
Content
and process
One element of the act is the creation of the Conflicts of Interest

Office. This office will be responsible for enforcing compliance with the
obligations set out in the act by current and former senior officials. It
shall be fully operational in the near future.
Results
This act represents a very important effort to modernize the Spanish

framework for managing conflicts of interest within the public
administration. Because it was ratified only recently (April 2006) there
are no clearly identifiable results yet.
Lessons
learned
The act follows the guidelines of the Organization for Economic

Cooperation and Development (OECD) and other international
organizations and therefore comprises an efficient policy for the
prevention and management of conflicts of interest in accordance
with similar measures adopted by other countries with a democratic
tradition and foundations. In this way, Spain has learned from lessons
of others. Hopefully, in the near future other countries can learn from
Spains experience.
Part of
government
Ministry of Public Administration
Contact
Name of organization: Ministry of Public Administration (Spain)

Name of contact: Flor M Lpez Laguna, Deputy Directorate for
Incompatibility System Management
Address of organization: c/ Mara de Molina, n50, Madrid (28071),
Spain
Telephone: +34 91 273 26 41
Fax: +34 91 273 27 17
Email: florm.lopez@map.es
Website:
Act regulating conflicts of interest of the Members of Government
and the Senior Officials of the General State Administration
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4
2. Code of Good Governance of the Members of Government and the
Senior Officials of the General State Administration
Brief
description
The purpose of the Code of Good Governance is to offer citizens a

solemn promise that all senior officials shall not only satisfy the
obligations laid down by law but that their conduct must also be
inspired and guided by principles of ethics and good conduct which,
although they are no doubt implicit, have not yet been expressly laid
down in the regulations.
Background
and aim
Ever since the entry into force of Spains Constitution, the Spanish
legal system has been enriched by various regulations establishing the
framework within which senior officials, government workers and
other staff members of the public administration must act in carrying
out their responsibilities under the law. The law guarantees
transparency, efficiency and total dedication to public functions and
provides that any activity or interest which might compromise the
independence and impartiality of said workers or be detrimental to
the performance of public duties must be avoided.
Nonetheless, it is necessary for public authorities to offer citizens a
solemn promise that every senior official shall not only satisfy the
obligations laid down by law, but that their conduct shall also be
inspired and guided by principles of ethics and good conduct which,
although they are no doubt implicit, have not yet been laid down in
regulations.
The objective therefore is to offer citizens a code of good governance
that defines and lays down the fundamental values that should govern
the actions of members of the government and its senior officials in
response to the demands and requirements of citizens as participants
in the political community in which they live. In other words, the
objective of this code is to offer a solid promise that the aspirations of
individuals shall be respected, protected and fostered in a framework
of solidarity, liberty and justice.
The agreement approving the Code of Good Governance was approved
by the cabinet on 18 February 2005.
Content
and process
87
The code consists of four sections: Basic principles, Ethical principles,

Principles of good conduct and Compliance with the Code of Good
Governance. One element of the section on compliance is an
annual report to be submitted by the Ministry of Public Administration
4
Content
and process
on possible non-compliance with principles of ethics and good

conduct.
Results
This code is an important instrument for ensuring that the exercise of

public functions is guided by ethical principles. The first annual report
is currently being prepared and will soon be published.
Lessons
learned
The code follows the guidelines of the Organization for Economic

Cooperation and Development (OECD) and other international
organizations and therefore comprises an efficient policy for the
prevention and management of conflicts of interest in accordance
with similar measures adopted by other countries with a democratic
tradition and foundations. In this way, Spain has learned from the
lessons of others. Hopefully, in the near future other countries can
learn from Spains experience.
Part of
government
Ministry of Public Administration
Contact
Name of organization: Ministry of Public Administration (Spain)

Name of contact: Flor M Lpez Laguna, Deputy Directorate for
Incompatibility System Management
Address of organization: c/ Mara de Molina, n50, Madrid (28071),
Spain
Telephone: +34 91 273 26 41
Fax: +34 91 273 27 17
Email: florm.lopez@map.es
Website:
Agreement approving the Code of Good Governance of the Members
of Government and the Senior Officials of the General State
Administration
88
4.18 Sweden
1. National Network Against Corruption

Brief
description
Background
and aim
The National Anti-Corruption Unit has set up a national network

against corruption, which includes authorities, agencies and stateowned companies. The purpose of the network is to develop measures
against corruption (such as policies and education) and other actions
to hinder or prevent corruption, to develop risk assessments and to
raise public awareness in order to detect corruption (such as control
mechanisms), and to enhance investigations and judicial procedures.
The responsibility for fighting corruption rests solely with law

enforcement authorities. Sweden has had a National Anti-Corruption
Unit since 2003. Thus unit is part of the Swedish Prosecution Authority.
It was established to intensify the fight against corruption. The unit
consists of five public prosecutors with nationwide competence and
jurisdiction. The public prosecutors in the unit have lengthy
experience in investigating financial crime and organized crime and
extensive experience of international co-operation. Prosecutors in the
unit are supported by forensic accountants. A special unit of the
Swedish Prosecution Authority is also engaged in the development of
measures against corruption.
The unit co-operates with the Swedish police forces and customs
nationwide. Supervisory authorities such as the National Tax
Authority, the State Audit Institution and the National Competition
Authority are also vital partners. The unit co-operates very closely
with these authorities.
The background and aims of the national network against corruption
are as follows:
The National Anti-Corruption Unit launched the initiative in May
2006.
More specific policies, better knowledge and effective risk
management are intended to reduce the risk of corruption in the
public sector.
A quicker response by the authorities and better cooperation
between authorities will yield more efficient criminal investigations.
A better understanding of how criminals attack civil systems makes
it easier for the authorities to protect themselves.
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4
Content
and process
Support from government and authorities.

Close co-operation between law enforcement agencies (The National
Anti-Corruption Unit) and Verva, the Swedish Administrative
Development Agency.
Results
The network is still developing. General questions concerning policy

making, education and experiences will be discussed roughly once or
twice a year. However, meetings at a more operational level to discuss
various types of information needed to handle a critical situation or a
specific case will be held whenever required. Network meetings have
produced results in the shape of:
new and better policies for the authorities;
a training programme;
more adequate information for the law enforcement authorities
where crimes are suspected;
a higher number of reports of suspicions of crime;
an improved level of prevention.
Lessons
learned
See above (Results).
Part of
government
The National Anti-Corruption unit is part of the Swedish Prosecution

Authority.
Contact
Name of organization: Swedish Prosecution Authority

Name of contact: Mr. Bjrn Blomqvist, Deputy Director
Address of organization: Box 702 96, S-107 22 Stockholm, Sweden
Telephone: +46 (0) 8 762 1000
Telefax: +46 (0) 8 762 16 80
Email: bjorn.blomqvist@aklagare.se
Website:
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2. Openness as a Means for Democracy and for Preventing
Corruption
Brief
description
Openness is the normal condition in the Swedish public service and

there are several legal provisions designed to promote it. Openness is
regarded as a means of promoting democracy and preventing
corruption.
Background
and aim
This section describes some of the basic foundations for openness in

Swedish public administration. For further information, please read
the paper entitled Public Access to Information and Secrecy within
Swedish Authorities.
The Principle of public access to information
Public access to information is one of the basic principles of Swedish
society. Swedish public administration is characterized by
transparency vis--vis citizens, companies, municipalities,
organizations and the media. Central government agencies work and
their contacts with citizens, businesses and the media must be
characterized by great accessibility and the use of language that is as
simple and intelligible as possible. Nonetheless, it is essential to point
out that the citizens demands, as well as the preconditions for
developing and meeting transparency requirements, change over time.
Public administration must therefore derive benefits from the available
opportunities to use modern technology in its efforts to facilitate
openness and access to information.
In accordance with the principle of public access to information court
sessions are held in public, as are the meetings of decision-making
assemblies.
Freedom of expression for civil servants
Every citizen, including public officials, is assured of freedom of
expression towards public authorities. A public official may write
articles and express opinions in the mass media on any subject,
including issues relating to the officials place of work, as long as he or
she makes it clear that the views expressed are not those of the
employing authority.
91
Freedom of civil servants to communicate information

(whistleblowing)
The principle of public access to official documents also means that
government officials and other central and local government
employees are free to disclose information, that is to say they are
4
Background
and aim
entitled to gather information and tell the media what they know
about a matter for publication. Although they are allowed to give out
some secret (lower classified) information orally, officials are not
permitted to hand out documents that are classified as secret.
The principle of public access to official documents
In order to guarantee an open society with access to information about
the work of parliament, the government and government agencies, the
principle of public access to official documents has been incorporated
into one of the fundamental laws, the Freedom of the Press Act. This
openness gives everyone the right to study public documents, a right
which may be exercised whenever they wish. To encourage the free
exchange of opinion and availability of comprehensive information,
every Swedish citizen shall be entitled to have free access to official
documents. (Chapter 2, Article 1, Freedom of the Press Act)
In principle, all documents that are received or letters that are sent as
well as decisions and reports instantly become public documents and
must be made available for anyone to read. Under the basic rule, a
letter from a head of state to Swedens prime minister is a public
document and hence also accessible to the general public.
Errands sent to an authority are registered. The registration file is also
open to the public.
The Secrecy Act
The Secrecy Act regulates the exceptions to the legal requirement for
openness. These precise exceptions may relate to defence matters,
personal integrity, sensitive business and research information. Access
to public documents may be restricted to protect the following
interests:
the security of the realm or its relations with another state or
international organization;
the central fiscal, monetary or currency policy of the realm;
the inspection, control or other supervisory activities of a public
authority;
the interest of preventing or prosecuting crime;
the economic interests of the public institutions;
the protection of the personal or economic circumstances of private
subjects;
the preservation of animal or plant species.
92
If information classified as secret is to be disclosed or referred to in a

court session, the court may generally hold the session behind closed
doors. Furthermore, persons under the age of fifteen or persons who
suffer from a mental disorder may be questioned behind closed doors.
4
Background
and aim
The social partners

Under labour law the unions have fairly wide-ranging rights to secure
information about business matters that would affect employment.
Accordingly, the level of co-operation and trust between the social
partners in the civil service is high. Within this co-operation it is
common for the employees to be directly involved in workplace
meetings about more or less strategic issues. An agreement on Cooperation for development has been concluded in order to facilitate
this kind of democracy.
Content
and process
An open public administration is generally regarded as fundamental

for democracy, justice and effectiveness. In Sweden there have long
been strong legal provisions to promote openness in the public
administration. In addition, the social partners in the public sector
have concluded that dialogue and openness in the workplace further
promotes job satisfaction, creativity, development and a positive image
of government employment. Such internal openness is also regarded
as a prerequisite for external openness and democracy.
Of course, every employee has to balance business loyalties with the
need to inform the press, etc. Nevertheless, this responsibility rests
with the individual employee and a manager or colleague has no right
to investigate when, how and by whom information has been given to
the press. Hence the protection of whistleblowers is strong in the
Swedish administration. On the other hand, this is a major incentive
to keep employees informed and include them in decision-making
processes as well as an inducement against misuse of public power.
Results
A low level of corruption and accordingly a low tolerance of corruption:

openness and strong protection of whistleblowers ultimately help to
minimize corruption and deliberate misuse of public resources. The
relatively strong influence of employees and a co-operative climate
between the social partners helps to ensure the legal provisions are
reflected in practice.
Lessons
learned
The possibility to inform the media about business matters places a

great responsibility on the individual government employee. The
comprehensive rights of civil servants also create the need to discuss
issues of loyalty vs. the exercise of these rights. The social partners
therefore have from time to time initiated development programmes
about ethics, identification of values and openness.
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4
Lessons
learned
Another virtue sometimes claimed for the Swedish system is that it

encourages less documentation and more informal handling of
errands than would be the case if the system were more closed, but
this is more a hypothesis than accepted fact.
Part of
government
Swedish Public Administration
Contact
Name of organization: Swedish Prosecution Authority

Name of contact: Mr. Bjrn Blomqvist, Deputy Director
Address of organization: Box 702 96, S-107 22 Stockholm, Sweden
Telephone: +46 (0) 8 762 1000
Telefax: +46 (0) 8 762 16 80
Email: bjorn.blomqvist@aklagare.se
Website:
Brochure: Public Access and Secrecy within Swedish Authorities
94
4.19 United Kingdom
1. Inquiries into Policy Issues Relating to Standards of Conduct by

Elected and Appointed Public Office-holders
Brief
description
Once a year on average, the Committee on Standards in Public Life

undertakes a public inquiry into a policy area related to standards of
conduct in public life where there have been or are ongoing public
concerns. The purpose of these inquiries is to make evidence-based
policy recommendations to address those areas of concern and to
ensure the highest standards of propriety and conduct in public life.
Background
and aim
The Committee on Standards in Public Life was established in October

1994 by the then prime minister in response to concerns about
standards in public life. These concerns arose from damaging
allegations about the behaviour of members of parliament, ministerial
patronage in public appointments and the unregulated exodus of
ministers from public office to private sector directorships.
The committee was given wide-ranging terms of reference to examine
current concerns about standards of conduct of all holders of public
office (elected and appointed; central and local government). These
terms of reference were widened by the then prime minister in
November 1997 to cover the funding of political parties. Its status as a
standing committee allows it to re-visit past areas of inquiry and
review the implementation of its recommendations and assess the
impact and outcomes of its work. It has, where necessary, proposed
changes to initial recommendations in light of experience and events.
Content
and process
The committee is free to choose subjects of inquiry, but only after

consultation with the Cabinet Secretary, on behalf of the Prime
Minister (to whom the Committee reports). Inquiries are conducted
using a rigorous, evidence-based and entirely open approach with
written submissions posted on the Committees popular and muchused web-site, public hearings held throughout the United Kingdom
and a final public report with its recommendations and including all of
the evidence collected during the inquiry.
Committee Inquiry Reports are presented to the prime minister and
through him to parliament as a published Command Paper. The
government then publishes its response to the committees
recommendations, again through a Command Paper (ideally within
three months) and this is often subject to a debate in both Houses of
Parliament.
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4
Content
and process
The fact that the committee reports directly to the prime minister,
who is ultimately accountable for standards of conduct in government
and across the wider public sector, has been key to its effectiveness.
Although the committee has no statutory powers, the fact that its
advice is given publicly and that it is free to choose its own topics of
inquiry - albeit after consultation with the government - has added to
this effectiveness.
The committee consists of a chairman and nine members and is
supported by a small secretariat of five civil servants, which includes
the Secretary, Assistant Secretary, Secretariat Manager, Secretariat
Co-ordinator, and a SPS to the Chair and Secretary. The committee
works with a budget of 500,000, to conduct an annual inquiry and
produce an annual report, and every two years carries out a repeat
national survey of public attitudes towards standards of conduct of
public office-holders.
Results
Since its establishment in 1994, the committee has fulfilled its remit
by:
publishing eleven Inquiry Reports which together cover, and have
had a significant impact upon, virtually all public-office holders and
most of the public sector;
reviewing the progress with, and effectiveness of, the
implementation of its own recommendations;
undertaking research into public attitudes to explore whether the
committees Seven Principles reflect the general publics priorities in
relation to the conduct of public office-holders; and to gauge public
opinion on how well public office-holders measure up to the
Principles;
reviewing key standards issues every year for the past three years as
part of a standards check in its annual report.
Lessons
learned
Since the publication of reports on standards in public life has had a

significant impact upon virtually all public-office holders and most of
the public sector in the UK a committee such as the CSPL might prove
useful for other countries.
Part of
government
The Committee is an independent advisory Non-Departmental Public

Body (NDPB) of the Cabinet Office. In practical terms this means that it
exists under the prerogative of the prime minister of the day and has
no formal statutory basis or powers to compel witnesses to give
evidence or the government to accept its recommendations. The prime
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4
Part of
government
minister appoints its ten members for renewable periods of up to

three years. Seven members are appointed through open competition
and three members from nominations by the leaders of the main
political parties, which ensures the Committees independence and
rigour in tackling politically sensitive subjects.
Contact
Name of organization: The Committee on Standards of Public Life

Name of contact: Dr Richard Jarvis, Secretary to the Committee
Address of organization: 35 Great Smith Street, London SW1P 3BQ
Telephone: +44 (0) 20 7276 2595
Fax: +44 (0) 20 7276 2585
Email: public@standards.x.gsi.gov.uk
Website: www.public-standards.gov.uk
Committee on Standards in Public Life: Contribution to Policy
Development, Committee on Standards in Public Life, April 2006
The Frank Stacey Memorial Lecture: Standards of Conduct in Public
Life, September 2006, Public Policy and Administration
2. Whistleblowing (speaking up) - the raising of a genuine

workplace concern about serious malpractice
Brief
description
The Public Interest Disclosure Act (PIDA) 1998 sets out a clear and
simple framework for raising and addressing genuine concerns about
malpractice by guaranteeing full protection to workers who raise such
issues in accordance with the act. The independent, self-funding nongovernmental organization Public Concern at Work (PCaW) played a
leading role in developing this act. One of the purposes of PCaW is to
enhance individual responsibility and organizational accountability by
giving staff who are concerned about malpractice a safe alternative to
silence.
Background
and aim
It is widely recognized that whistleblowing is an important tool in

uncovering and deterring all types of wrongdoing, including corruption.
Even before PCaW was formally launched, the European Parliament
had asked those involved in setting it up to report on the role of
whistleblowers in controlling financial malpractice in Europe. Whistleblower protection for workers both in the public and private sectors is
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4
Background
and aim
obligatory under the Council of Europes Civil Law Corruption

Convention (Article 9). Wide whistleblower protection is also
encouraged under the UN Convention Against Corruption (Article 33).
The work of PCaW began following major disasters, bank failures and
political scandals in the UK in the 1980s. The official inquiries that
followed these events showed that workers had been aware of the
danger but had been too scared to sound the alarm or had raised the
matter with the wrong person or in the wrong way. PCaW was set up
in 1993 as an independent charity. In 1995 the work was endorsed by
the UK Committee on Standards in Public Life, which accepted the
view of PCaW that unless staff thought it safe and acceptable to raise
concerns internally, the likely result was that they would stay silent or
leak the information. PCaW was closely involved in determining the
scope and detail of the Public Interest Disclosure Act 1998, which sets
out a clear and simple framework for raising and addressing genuine
concerns about malpractice by guaranteeing full protection to workers
who raise such issues in accordance with the act. The act adopts a
wide definition of malpractice that includes criminal offences and
breaches of legal obligations.
Content
and process
98
Strategy
PCaW, a limited company, is an independent charity that started
operating in 1993 under the guidance of an influential Board of
Trustees. It has drawn up a 10-year strategy with eight main points:
to promote the positive aspects of whistleblowing and to seek a shift
away from the negative meaning of the word;
to promote individual responsibility by encouraging workers and
people generally to speak up about things they think are wrong and
thereby improve the ways in which organizations are and are seen
to be accountable;
to give legal and practical advice and help (free of charge) to people
concerned about serious malpractice in the workplace;
to promote legislation to protect public interest whistleblowers;
to encourage employers to view whistleblowing as welcome and
positive;
to persuade employers to set up safe and effective whistleblowing
procedures and to promote them actively to their workforce;
to establish PCaW as the recognized source of independent expertise
and authority in this area;
to encourage insurers to offer premium discounts to organizations
which implement effective whistleblowing procedures.
4
Content
and process
Whistleblowing law
As part of this strategy PCaW played a leading role in developing the
Public Interest Disclosure Act 1998. It was helped by the Campaign for
Freedom of Information and by parliamentarians from all sides. In
1995 PCaW was asked to draft a whistleblower protection law and the
bills proposals were widely supported among consultees, including
the Committee on Standards in Public Life. The bill was introduced as
a private members measure (i.e. non-government), and was backed by
the incoming Labour government in 1997. It was passed in 1998 and
came into force in 1999. The essential features of the law are:
setting out a step by step approach which encourages internal
whistleblowing where possible, facilitates disclosures to statutory
regulators and allows wider disclosures even to the press when
justified;
allowing whistleblowers who have suffered any detriment to go to a
tribunal the Employment Tribunal which deals with cases quickly;
removing the limit on the compensation which may be ordered by
the tribunal if a whistleblower suffers detriment;
making dismissal and victimization for whistleblowing automatically
unfair.
Within the EU, the UKs is the only example of a whistleblowing law
which extends across public and private sectors. Its effect has been to
encourage employers to develop internal whistleblowing systems that
can promote accountability and effective risk management.
Public sector
As regards the public sector, the Committee on Standards in Public
Life, drawing on the experience of PCaW, has set out the essential
elements of effective internal reporting systems and recommended
that these be adopted by all public bodies. These essential elements
are:
leadership from the top to demonstrate that the organization takes
the issue seriously;
giving staff the option of raising concerns outside line management;
enabling staff to seek advice from an independent body;
a commitment to respect confidentiality when requested;
advising staff when and how they may raise a concern outside the
organization;
making clear it is a disciplinary matter either to victimize a good
faith whistleblower or to maliciously make a false allegation;
ensuring that staff are aware of and trust the whistleblowing
process;
continually reviewing how the procedures work in practice.
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Content
and process
PCaW costs about 300,000 a year to run and has the equivalent of 7-8
full-time staff, most of whom are qualified lawyers. Although its work
has, historically, been funded through charitable donations, its
consultancy, training and promotional work with employers has
enabled it to become self-funding.
Results
In the latest two years for which there are figures (2003-5), PCaW dealt
with 1,500 whistleblowing concerns. Of these, 79% had raised their
concerns openly, 20% had done so confidentially and only 1%
anonymously. PCaW believes this demonstrates that the culture of
open whistleblowing is gaining ground. Also 30% of those who
contacted PCaW were informed of the existence of PCaWs helpline in
their workplace.
Surveys show that 90% of those who call that helpline consistently
said they would recommend it.
There is no measure of benefits against costs, but the PCaW is felt to
have met or exceeded the targets it set itself in its 1993 strategy, with
the exception of the final point. It is clear that more and more
organizations, public and private, recognize the value of sound
whistleblowing policies. PCaW considers that the culture has changed
and that whistleblowers are more likely to be believed and to have
their concerns acted on by their employer than was the case before
the 1998 Act. Significantly, the act retains the support of business,
unions and professional and regulatory interests in the UK.
It is also evident that the business sector in the UK has to say the
least - not experienced any downturn in this period, and the fact that
major private sector clients (including some Irish companies) seek our
advice in setting up systems reflects their view that our advice can
contribute to sustaining their own success.
Over the period 2003-2006, the number of PIDA claims recorded in
Employment Tribunals was 2,223 (this represents only about 1% of
claims to the tribunals). Of these, 1,541 were withdrawn or settled, 151
were successful at hearing and 378 were unsuccessful at hearing it is
impossible to say whether those withdrawn or settled would have met
with success at a tribunal hearing. The average award from a tribunal
is not large, but such awards clearly indicate to employers that it is in
their interest to have an effective whistleblowing policy in place and to
handle concerns properly.
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4
Lessons
learned
PCaW thinks that other EU countries could benefit from thinking

about what measures may best contribute to enhancing a
whistleblowing culture in their particular circumstances. This may or
may not include adopting a law on the lines of PIDA. Japan and South
Africa have adopted laws based on the UK model, showing that it can
be useful in very different circumstances. PCaW has also given advice
to other countries that have draft laws at various stages of
development. Ireland also has a draft bill based on the UK model but
the current (Fianna Fail) government has made it clear that it will not
enact the bill even though the two main opposition parties support it.
In 2007 Norway brought into effect a law which embodies basic
principles similar to those underlying the UK approach but in a less
detailed format, which leaves much more discretion to the civil courts
which will hear the cases.
It is essential to bear in mind that changing the culture is crucial,
rather than changing the law. In the UK situation, PCaW has provided
an essential spark and continues to provide a useful service while
funding itself. Such an organization might prove useful in other EU
countries.
Part of
government
PCaW is an independent, self-funding non-governmental organization

dedicated to public interest whistleblowing.
Contact
Name of organization: Public Concern at Work

Name of contact: Anna Myers
Address of organization: Suite 301, 16 Baldwin Gardens, London EC1N
7RJ, United Kingdom
Telephone: 00 44 207 404 6609
Fax: 00 44 207 404 6576
Email: am@pcaw.co.uk
Website: www.pcaw.co.uk
A wealth of documentation (including the text of the 1998 Act,
commentaries on it, and case law) is available on PCaWs website
www.pcaw.co.uk
101
5.1 Introduction
One way of looking at the contributions from an integrated perspective
is by fitting them into a model, that covers different aspects of integrity.
Although there are other existing integrity models, such as the one of
the OECD, we have chosen to fit the contributions in the Integrity
Infrastructure. The Infrastructure was developed by The National
Office for Promoting Ethics & Integrity in the Public Sector (BIOS), which
was initiated by the Ministry of the Interior and Kingdom Relations in
the Netherlands and can be viewed on the website
www.integriteitoverheid.nl. The Integrity Infrastructure Model covers
every aspect of integrity in a systematic and coherent way and
consequently offers a solution for the fragmentation of integrity policy,
which is often a problem in governmental organizations. The
Infrastructure can be viewed on the website www.integriteitoverheid.nl.
This fragmentation is often due to the dispersal of responsibility for
integrity policy in public authorities over various disciplines and
departments. The communication between the people involved often
leaves a lot to be desired, which can make the policy less cohesive than
it should be. It is precisely the integrated nature of integrity policy that
the Integrity Infrastructure Model emphasizes and this in turn
highlights the areas in which integrity policy can be shaped. The model
is intended for managers, staff officers and integrity coordinators
within the public authority responsible for the development,
implementation and enforcement of the integrity policy. Governmental
organizations can use the model to develop new policy and to review
existing policy.
Two layers
The Integrity Infrastructure Model is built around themes, areas of
attention and instruments. The models core is formed by the concept
of integrity and the themes that can give rise to integrity issues. The
first layer around that core consists of the six areas of attention for
which integrity policy can be developed. The key principle here is that
integrity policy can be effective only if equal attention is paid to all six
areas. The second layer contains existing tried-and-tested instruments.
102
The six areas of attention in the model represent a logical cycle:

starting with the role of senior management (1), relevant core values
and standards (2) are mapped. These form the basis of structures and
processes (3) that make the organization less vulnerable. In the next
step, attention is given to personnel and the organizational culture (4).
Unfortunately, incidents happen (5); every organization has to be well
prepared to handle them. In the final step, the integrity policy and its
instruments are monitored and evaluated (6). In this way, a learning
process is started which makes improvement possible.
This chapter uses the promising practices featured in this catalogue to
illustrate the different areas of attention in the model. This then gives a
general impression of how member states might assess their anticorruption and integrity measures. The various promising practices can
serve as an inspiration or even as concrete alternatives. The texts in
this chapter refer to the website of the National Office for the
Promotion of Integrity in the Public Sector (BIOS) of the Ministry of the
Interior and Kingdom Relations, www.integriteitoverheid.nl.
5.2 Role of top management
103
An ethics policy can only succeed when the organizations

management attaches importance to the issue and is prepared to make
the necessary investments. In addition, the senior management needs
to formulate an explicit vision of the required policy and how that
policy is to be implemented. An effective ethics policy requires
customization; the policy needs to be compatible with the specific
organization and a standardized policy for the entire public

administration is therefore inappropriate. The senior managements
duty and responsibility is to develop a specific viewpoint on ethics and
ethical policy for the organization and to actively convey this policy to
everyone involved.
The management needs to set a good example by stressing that ethics
is an important issue, both in word and deed; in word by regularly
emphasizing the importance of ethics; in deed by developing and
formally adopting the organizations ethics policy. Moreover, it is
essential that the management makes clear who is responsible for the
coordination of the ethics policy, which actors are involved and the
managements role in the process.
An interesting practice in this respect is the role of the Coordinator of
Integrity Care in Belgium. One of the tasks of this function within the
Flemish government is to coordinate existing measures and so produce
a general system of integrity management. Slovenia offers the
promising practice of implementing integrity plans. Not only can
implementing these plans be regarded as an expression of the
administrative managements commitment, it is also a systematic
and thus an integral - effort. An aspect of the practices from Hungary
and Latvia is their concern with national programmes against
corruption.
5.3 Core values and standards

Customization implies that the design and implementation of ethics
policy takes account of the specific organizational culture.
Consequently, it is necessary to begin by making an inventory of the
organizations guiding values and standards to obtain an insight into
the organizations principles, i.e. the principles for which it is prepared
to be called to account. These values and standards constitute the
underlying philosophy on which the ethics policy is based. They also set
out moral principles which the staff can use to test their personal
subjective professional opinions. The formulation of explicit values and
standards results in a more detailed specification of intrinsically
abstract concepts such as ethics and the conduct expected of good civil
servants. In recent years a large number of administrative
organizations have developed codes of conduct. In addition, a range of
guidelines and national and international codes of conduct have been
published in recent years that can serve as a source of inspiration and
provide assistance.
104
Several countries contributed codes of conduct to this catalogue,

including Italy, Spain and Poland. Denmarks promising practice
describes the process of establishing a code of conduct and Germanys
describes recommendations issued for implementing the Federal

Government Directive. One of the promising practices from Sweden
describes the importance of openness for democracy and for preventing
corruption. The discovery of values is the subject of the promising
practice Values to be part of the Daily Job from Finland. One of the
practices from the European Commission offers guidelines for applying
staff regulations on the financial liability of officials.
5.4 Structures and processes

Core values and standards are supported by the organizations
structures and processes which are deigned to promote ethical conduct.
The organizations structures and processes encompass the totality of
formal rules, procedures, regulations and working agreements that
determine how the organization conducts its operations, what duties
the staff are expected to carry out, how they carry out their duties and
the responsibilities and powers that are assigned to them. Examples of
measures include the separation of duties, rotation of staff, designation
of vulnerable duties, examinations of antecedents and regulations
relating to the acceptance of gifts or favours, outside activities, financial
interests and securities transactions.
Examples of organizational structures and processes are the reward
system for whistleblowing by police officers in Estonia, the
requirements for the disclosure of interests in Ireland, the Public
Administration Probity in Decision-Making Act in the Netherlands, the
act regulating conflicts of interest in Spain and the stages of
implementing integrity plans in Slovenia. Both examples of police
networks from Sweden and the Netherlands can also be regarded as
structures designed to fight corruption and promote ethical conduct.
5.5 Culture and personnel policy
105
Ethics are manifested in the form of the civil servants actions.

Consequently, the personnel constitute a major issue for attention. The
organizations culture is a complex issue which exerts a major
influence on its ethics. It embraces the entirety of standards and values
that determine the organizations working methods. The organizational
culture gives shape to the conduct of staff members, their mutual
relationships and their contacts with third parties, and consequently it
constitutes a major assurance mechanism for ethics. The objective is to
achieve a culture in which the staff regards discussion of difficult issues
as self-evident and are prepared to engage in those discussions, either
when requested to do so or on their own initiative. This enables them to
jointly explore and determine the substance and limits of their
responsibilities and to clarify and test their shared standards and
values. In addition, an open culture also enables colleagues to call each

other to account for their conduct. An open culture can be promoted by
allowing scope for doubts or criticism, by making staff problems at
work or in private life open to discussion, by the managements
devotion of attention to ethics, by communication on ethical issues, by
furthering openness with third parties, by devoting attention to ethical
issues during toolbox meetings and job performance interviews and by
dealing with violations of ethics in an open manner.
The promising practices of Austria and the European Commission are
interesting examples of this area of attention. Both consist of training,
workshops and standards for control aimed at raising ethical
awareness among employees. Because of its prevention activities, the
Corruption Prevention and Combating Bureau in Latvia can be regarded
as a practice in the field of culture and personnel policy. The Integrity
Cube from the Netherlands is another example: the goal of this
instrument is to stimulate discussion of integrity within government
organizations. And by formulating shared values in government
organizations, the promising practice from Finland could also be
regarded as an example in this field.
5.6 Incidents
Unfortunately, no ethics policy is able to prevent incidents. Any group
of employees will always include individuals who seek personal gain or
deliberately act in contravention of the rules. Incidents are situations in
which members of staff contravene the organizations standards and
values. However, it has to be realized that the effect of such incidents is
not incidental, since the public does not make a distinction between
different sections or tiers of public administration: every incident
damages public confidence in the entire administration. For this reason,
dealing with (suspicions of) abuses must be an essential element of any
ethics policy. Carefully-considered and powerful investigations of
violations demonstrate that great importance is attached to ethics, and
in turn reduce the risk of future violations. Failure to take action
against violations or dealing with violations in a half-hearted manner
can incite similar conduct by others. In addition, the failure to take
action against violations that are initially minor can lead to escalation
into major violations. The management must make it clear that
conduct of this nature will not be tolerated and do so by taking
consistent and conscientious action against all minor and major
violations and communicating its actions. Procedures designed to deal
with incidents constitute an important element of ethics policy. The
registration of notifications of unethical behaviour and the way they are
dealt with is one procedure which has been introduced on a wide scale
in recent years.
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Procedures for whistleblowing not only offer a way to report incidents

(and protection for the whistleblower), but also offer a structure for
dealing with incidents in organizations. The activities of the non-profit
organization Public Concern at Work in the United Kingdom can be
regarded as a promising practice in this field.
5.7 Evaluation and reports

In conclusion, all ethics policies need to extend to an evaluation of the
instruments, procedures, rules and guidelines developed to address the
various issues. Evaluations and reports are forms of management
information about the performance, effectiveness and efficiency of the
ethics policy. Questions of relevance to the evaluation of an ethics
policy include: Has the policy been implemented? Are the rules and
procedures observed? Are the targets realistic and have they been
achieved? Does the policy yield the required result? Are the measures
still adequate? Are the original reasons for implementing a measure
still relevant? Do any measures constitute a source of new
vulnerabilities and infringements of ethical standards? Could any
measures addressing specific vulnerabilities be replaced by more
effective or economical measures? This information may identify the
need to make extra investments in one or more of the above issues. It is
also very important that the policy can be amended as required.
The annual reports on fraudulent and corrupt practices of the Central
Service for the Prevention of Corruption in France, the inquiries into
policy issues relating to standards of conduct by the Committee on
Standards in Public Life in the United Kingdom, but also the annual
reports that are part of the Code of Good Governance in Spain can be
regarded as promising practices in this field.
5.8 Reflection
Obviously, the overview of practices in this model (see diagram) does
not give a complete picture of the situation with respect to anticorruption and integrity measures in the EU. It gives an impression of
existing instruments and hence of solutions to specific problems. So we
should be aware that we are dealing with a selection of the supply side
of anti-corruption and integrity measures. A discussion of this model
might be a good place to look at the demand side of these measures.
107
In general, when anti-corruption and integrity measures are initiated,

the first steps taken are to formulate standards and values and develop
structures and processes: codes of conduct and value statements are
established and formal rules and procedures are put in place. These
steps are generally initiated by the administration and made public in
an ethics policy. Part of the policy, but in most cases only after these
first steps have been taken, is attention for culture and personnel
policy. Workshops, training programmes and other awareness-raising
instruments are examples of this. This leaves two areas of attention
and one overall issue that are covered less intensely: in the literature,
but also during the discussions of the informal working parties in this
project, there are still question marks surrounding the topics of how to
deal with instruments, how to measure corruption and integrity and
how to integrate the different topics.
Questions
The first question (and one on which there is a demand for practices) is
how to deal with incidents. This question goes beyond formal
procedures for whistleblowing. It concerns very practical and pragmatic
issues of how to start an investigation, what and how to communicate
internally and externally, how to learn and what measures to take
afterwards. In a way, it relates to the management of crises.
The second question is how to measure anti-corruption and integrity.
With all the attention for corruption and integrity, it is logical to ask
what effect the measures taken have. However, besides counting and
categorizing cases of corruption and integrity breaches, there are no
instruments that can help to measure the effect of measures.
Lastly, there is the overall question of how to integrate and coordinate
the different areas of attention and the instruments designed to
address them. An integrated effort is of course important in fighting
corruption and fostering integrity effectively and efficiently. This
catalogue offers two potentially promising solutions to this problem.
The first is offered by Belgium, where the task of the newly created
position of Coordinator of Integrity Care is to coordinate existing
instruments within the Flemish government. Another solution is
offered by some new member states, which have established central
bureaus that combine the fight against corruption with the fostering of
integrity, presumably with the intention of making a big leap forward.
Latvias Corruption Prevention and Combating Bureau is an example of
this.
So although progress has been made, there are still areas of attention
that need to be further explored and developed. Hopefully, this will be
reflected in the next edition of this catalogue. It is now time to look
back and to look forward.
108
109
The Integrity Infrastructure Model:

promising practices per area of attention
1. Role of senior management

Coordinator of Integrity Care (Belgium)
Implementing Integrity Plans (Slovenia)
National Anti-Corruption Action Plan
(Hungary)
National Programme for Corruption
Prevention and Combating (Latvia)
6. Evaluation and reports

Annual Reports of the Central Service for
the Prevention of Corruption (France)
Inquiries of the Committee on Standards of
Public Life (United Kingdom)
Annual Reports as Part of Code of Good
Governance (Spain)
Integrity
5. Incidents
Whistleblowing (United Kingdom)
4. Culture and personnel policy

Anti-Corruption Awareness Raising (Austria)
Ethics Day (European Commission)
Internal Control Standards (European
Commission)
Values to be Part of the Daily Job (Finland)
Training on Ethics and Integrity (European
Commission)
Corruption Prevention and Combating
Bureau (Latvia)
Integrity Cube (Netherlands)
110
2. Standards and values

Code of Conduct (Italy, Poland)
Code of Good Governance (Spain)
Process of Establishing Code of Conduct (Denmark)
Guidelines for Application of Staff Regulation on Financial
Liability of Officials (European Commission)
Recommendations for Implementing Code of Conduct
(Germany)
Values to be Part of the Daily Job (Finland)
Openness as a Means for Democracy and for Preventing
Corruption (Sweden)
3. Structures and processes

Reward System for Whistleblowing by Police Officers (Estonia)
Requirements for the Disclosure of Interests (Ireland)
Public Administration Probity in Decision-Making Act (Netherlands)
Act Regulating Conflicts of Interest (Spain)
Implementing Integrity Plans (Slovenia)
Network Against Corruption (Sweden)
The National Office for Promoting Ethics and Integrity in
the Public Sector (Dutch acronym: BIOS) (Netherlands)
111
This catalogue gives a general impression of local practices that are in place in
the member states of the European Union. It shows a range of working
instruments that as a whole, depending on the integrity infrastructure, cover
all the necessary areas of attention.
Useful results
A few observations can be made about the contributions. Firstly,
although many of the practices are relatively new, some have already
produced positive results. For instance, in the case of the Coordinator of
Integrity Care in Belgium and in the case of the use of the Principles of
Police Ethics at every level of police training in Poland.
Another observation is that quite a number of practices can be traced
directly to the acquis; Italy, Germany and Denmark are examples of
countries that have established and monitor codes of conduct in the
public sector (Commissions Communication on a Comprehensive EU
Policy against Corruption). But the Advisory Board for a Corruption-Free
Public Life in Hungary and the Corruption Prevention and Combating
Bureau in Latvia are other examples of preventive anti-corruption
bodies (UN Convention against Corruption). The acquis accordingly
serves a function and is taken seriously by member states.
A related observation is that new member states like Estonia, Latvia,
Slovenia and Hungary can use the acquis as a guide in taking major
steps to establish a comprehensive approach to tackling corruption and
fostering integrity. In this way, these member states could gain an
advantage over member states whose approach has evolved over a long
period and is consequently often fragmented.
Catalogue as living document
Since this catalogue is not a systematic study of promising practices
and/or member states it is difficult to compare practices and/or
member states or to make recommendations about when or where
specific practices can best be used. On the other hand, that is not the
purpose of this catalogue.
The goal of this catalogue is to offer a source of inspiration and a
practical handbook that will be used by member states in fighting
corruption and fostering integrity. This catalogue is also a work in
progress. It represents a snapshot of the situation at a certain moment
in time. Our hope is that it will become a living document, a document
that will be actively used and further developed in the future.

In this respect, it is worth noting that all the member states have a
major stake in one anothers ethical conduct. After all, crime and
corruption do not respect national borders. Integrity is a basic condition
for scrupulous adherence to Community agreements, whether at
central, regional or local level.
This brings us to the next steps. As mentioned in the introduction, one
of the next steps will be to update this catalogue periodically. In this
way it can serve as a starting point for a common learning process in
which member states of the EU can share their experiences in fighting
corruption and fostering integrity. It would therefore be a welcome
development if one of the member states were to adopt this project and
organize a third informal working party. Given the enthusiasm of the
contributors to this catalogue and the participants of the working
parties, this catalogue can be regarded as a promising practice in itself.
113
Annex 1: Overview of EU Acquis of Anti-corruption and Integrity

measures
Indicative list of conventions and instruments to which the new member states
must accede in accordance with the Act of Accession.
European Union
Convention of 26 July 1995 on the protection of the European
Communities Financial Interests (OJ C 316 of 27 November 1995, p.49)
Protocol of 27 September 1996 to the Convention on the Protection of
Community Financial Interests (OJ C 313 of 23 October 1996, p.2)
Second Protocol to the Convention on the protection of the European
Communities financial interests (OJ C 221 of 19 July 1997, p.12)
Protocol on the interpretation, by way of preliminary rulings by the
Court of the European Communities, of the Convention on the
protection of the European Communities financial interests (OJ C 151
of 20 May 1997, p.2)
Convention of 26 May 1997 on the fight against corruption involving
officials of the European Communities or officials of Member States of
the European Union (OJ C 195 of 25 June 1997, p.2)
Communication of 28 May 2003 from the Commission to the Council,
the European Parliament and the European Economic and Social
Committee on a comprehensive EU policy against corruption
(COM(2003)317)
Council Decision 2003/642/JHA of 22 July 2003 concerning the
application to Gibraltar of the Convention on the fight against
corruption involving officials of the European Communities or
officials of Member States of the European Union (OJ L 226 of 10
September 2003, p. 27)
Council Framework Decision 2003/568/JHA of 22 July 2003 on
combating corruption in the private sector (OJ L 192 of 31 July 2003,
p 54)
Indicative list of international agreements, conventions and protocols to which

the new Member States must indirectly accede.
Council of Europe
Council of Europe Conventions
Criminal Law Convention on Corruption, opened to signature on 27
January 1999
Civil Law Convention on Corruption, opened to signature on 4
November 1999
114
This list can be supplemented by:

Additional Protocol to the Criminal Law Convention on Corruption,
15 May 2003
Committee of Ministers
Recommendation No. R(2003)4 on common rules against corruption in
the funding of political parties and electoral campaigns, 8 April 2003
Recommendation No. R(2000)10 on codes of conduct for public
officials, 11 May 2000
Resolution (97)24 on the 20 guiding principles for the fight against
corruption, 6 November 1997
Resolution (98)7 on Statute of the Group of States against corruption
(GRECO), 5 May 1998
Resolution (99)5 on establishing the Group of States against
corruption (GRECO), 1 May 1999
United Nations
UN Convention against Transnational Organized Crime, 15 November
2000
UN Convention against Corruption, 31 October 2003
This list can be supplemented with:
International Code of Conduct Public Officials, 12 December 1996
(Resolution 51/59)
Organization for Economic Cooperation and Development
Convention on Combating Bribery of foreign public officials in
International Business Transactions, of 17 December 1997
This list can be supplemented with:
Recommendation on Guidelines for Managing Conflict of Interest in
the public service, June 2003
115
Annex 2: Format of promising practices
EU Catalogue
of promising practices
in the field of integrity,
anti-corruption and
administrative measures
against organized crime
revised version, 21-07-2006
116
Why this format?

Good practices are descriptions of tried-and-tested measures and tools,
the executive organizations and the context in which these measures
and tools work. The aim of these descriptions is to make the knowledge
and experience gathered accessible to other organizations in a clearly
understandable way.
A format has been developed for describing good practices in the field
of anti-corruption, integrity and administrative measures against
organized crime. The aim of this format is to allow contributors to
provide clear descriptions of good practices for the EU Catalogue.
You can use this format to send in your own good practices. The format
is purely intended as an aid for presenting your good practices. You are
therefore free to choose whether or not to use this format when
submitting your good practice. However, the questions in the format
give a clear impression of the information that is needed to make a
good practice accessible to other member states in a clearly
understandable way. If you already have documents in which the good
practice is clearly described (e.g. an action plan), you can simply refer to
these documents in the format and enclose them with the description.
You can then use the format to add any missing information. The
format includes a list of guiding questions which can help you identify
good practices in your own country.
If you use the format for submitting a good practice, please complete it
in English.
117
Form for submitting promising practices on anti-corruption, integrity

and administrative measures against organised crime.
In which Member State does this example of a good practice take

place? Please add some information about your organization (part of
your government).
What is the name of the practical example?

Give the practical example an appropriate name that is informative and
immediately identifiable for the outside world. Use no more than one line of
text for this.
To which category do you think your practical example applies?

(You can give more than one answer.)
Acquis anti-corruption (EU, OECD, Council of Europe, UN, EUPAN)
Transparency / confidentiality and accountability at central and
decentralized level
Anti-corruption measures
Administrative vigilance
Public procurement
Integrity codes for public officials (in the widest sense of the word)
Preventive measures; compliance instruments
Preventive measures; awareness raising of staff
Legal incompatibilities
Conflicts of interest
118
Other good practices
119
Brief description of practical example

Describe the core of the practical example in no more than four lines. Make
sure you include the purpose of the practical example.
Background and aim

Briefly describe the reason why this example was initiated. You can also
mention the problems to be solved with the practical example, the aims, the
expected results and the period within which you hope to achieve the results.
The aims can be qualitative or quantitative. Add if possible the political or
legal basis of the initiative.
How did you tackle it?

Describe the content- and process-related aspects of your practical example.
State how you set about it and how you generated support for the approach.
You can also mention the sources of inspiration and players involved. If
possible, also state the costs involved, including manpower and the duration
of the project. What sets your example apart from similar projects in similar
organizations?
120
What (interim) results have been achieved?

Describe what qualitative and quantitative results have already been
achieved or are likely to be achieved in the future with the practical example.
Have there also been any unexpected outcomes? What is the balance between
yield and cost? If an evaluation was performed which could be useful for
other organizations, please indicate this in the description. Also indicate in
what way the example has helped improve the situation.
What can others learn from your practical example? Who has adopted
your practical example, either in full or in part?
Describe what others can learn from your practical example from a content or
process point of view. What are the good lessons and what are the bad
lessons? If other organizations have adopted your project, name the
organizations.
Is there any supplementary documentation?

Do you have any documentation which might help other organizations gain
an even better understanding of the significance of your practical example
and what they can learn or copy from your example? You can enclose such
documentation (action plan, description of results, evaluations, expert
opinions, articles in specialist publications etc.) with this format.
10
Name and contact details of the organization, including the name of a

contact person and the address, telephone and fax number, email
address and website of the organization, if available.
Name of organization:
Name of contact:
Address of organization:
Telephone:
Fax:
Email:
Website:
I hereby grant permission for this good practice to be included in the EU

Catalogue, placed on the website www.integriteitoverheid.nl and
discussed at the international conference.
Thank you very much for submitting your practical example.
121
Appendix: Guiding questions

Anti-corruption, integrity and administrative measures against
organized crime in the public service cover different aspects of public
administration. As a guide to help you to identify promising practices in
this field that you wish to share with other member states, we have
listed some guiding questions.
1. General principles of good administration codified

What are the main principles of good administration in the legislation of
your country?
2. Transparency and confidentiality at central and decentralized level
How does your country reconcile the organizational interest (i.e. image of
government) and the interests of transparency (that citizens can check
government)? How is unethical behaviour within government in your
country dealt from this perspective ?
3. Anti-corruption measures and administrative vigilance
What concrete action can administrative bodies take in the fight against
organized crime? What other administrative measures can be listed as a
promising practice?
4. Public procurement
How are public procurement activities organized in your country? What
measures are taken to prevent conspiracies by interested parties during
tender procedures?
5. Integrity codes for public officials
How is desirable behaviour of civil servants in your country made explicit?
How are norms and values codified and what efforts are taken to make
codes work?
6. Preventive measures: compliance instruments and awareness raising
of staff
What kinds of instruments are used in your country to help identify
weaknesses and prevent repetition of norm deviation in the future (i.e.
internal and external assessments, organizational risk analysis)?
7. Legal incompatibilities and other forms of conflicts of interest
What public or private outside activities are considered illegal for a civil
servant to combine with his or her regular work as a civil servant? And
what measures are helpful in dealing with the balance of public and private
interests, for example in unravelling public policy from private or partypolitical interests?
122
123
8. Financing of political parties and/or electoral campaigns

How are political parties financed (from public funds or left to private sector
sponsorship)? What choices were made in your country and why?
Annex 3: Overview of promising practices by category
AT
BE
DK
1. General principles of good

administration codified
2. Transparency / confidentiality
and accountability at central and
decentralised level
3. A) Anti-corruption measures
3. B) Administrative vigilance
EE
EU-A EU-B EU-C EU-D
FI
FR
4. Public procurement
5. Integrity codes for public officials

(in the widest sense of the word)
6. Preventive measures:
A) Compliance instruments
B) Awareness raising of staff
7. Legal incompatibilities and other

forms of conflicts of interest:
A) Legal incompatibilities
B) Conflicts of interest
8. Financing of political parties

and/or electoral campaigns
9. Special cases
Other good practices
124
HU
IE
IT
LV
NL-A NL-B NL-C PL-A PL-B
125
S-B UK-A UK-B
SP-A SP-B S-A
SI
Annex 4: Literature
Anechiarico, F. and J. Jacobs, The pursuit of absolute integrity: How

corruption control makes government ineffective, Chicago: University of
Chicago Press, 1996.
Corruption Fighters Tool Kit. Civil society experiences and emerging strategies,
Berlin: Transparency International, 2002.
Demmke, C., Working towards common elements in the field of Ethics and
Integrity, Maastricht: EIPA, 2004.
Demmke, C. and D. Bossaert, Ethics in the Public Service of the European
Union Member States, Maastricht: EIPA, 2004.
Kreutner (ed.), M., The Corruption Monster. Ethik, Politik und Korruption,
Vienna: Czermin Verlag, 2006.
Kudrycka (ed.), B., Combating Conflict of Interest in Local Governments in the
CEE Countries, Budapest: Open Society Institute, 2004.
Managing Conflict of Interest in the Public Service: OECD Guidelines and
Country Experiences, Paris: OECD, 2005.
Maor, M., Feeling the heat? Anticorruption Mechanisms in Comparative
Perspective, Governance: An International Journal of Policy, Administration,
and Institutions, January 2004, pp. 1-28.
Micheal, B., Anti-corruption training programmes in central and eastern
Europe, Strasbourg: Council of Europe, 2004.
Paine, L. Sharp, Managing for Organizational Integrity, Harvard Business
Review, March-April 1994, pp. 106-117.
Principles of Good Administration in the Member States of the European Union.
Sweden: Statskontoret, 2005.
Public Sector Integrity: A Framework for Assessment, Paris: OECD, 2005.
Villoria-Mendieta, M., Conflicts of Interest Policies and Practices in Nine EU
Member States: A Comparative View, SIGMA, 2005.
Whistleblowing Rules: Best Practices; Assessment and Revision of Rules
Existing in EU Institutions, Brussels: European Parliament, 2006.
126
127
Colophon
Publication
Ministry of the Interior and Kingdom Relations of the Netherlands
Public Service Labour Affairs Department
NL-PO Box 20011
2500 EA The Hague
info@minbzk.nl
www.minbzk.nl
Research and analyses

Utrecht School of Governance
Bijlhouwerstraat 6
3511 ZC Utrecht
and
National Office for the promotion of Integrity in the Public Sector (BIOS)
Ministry of the Interior And Kingdom Relations
www.integriteitoverheid.nl
Publishing coordination
Direct Dutch Publications
www.directdutch.nl
Editing
Hugh Quigley
Design
Gerard Bik bno
Production and print

Directie Communicatie en Informatie/
Grafische en Multimediale Diensten
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Catalogue of

Commissioned by the Ministry of the Interior and

Chapter 1: Introduction .............................................................................7

Chapter 2: Acquis of Anti-corruption and Integrity measures ............10

2.2 Content of the Acquis

2.3 EUPAN Ethics Framework document 2004

Chapter 3: Three ways to read this catalogue .......................................15

3.2.1 Contributions by member states

3.2.2 Contributions by the European Commission

General principles of good administration codified

Integrity codes for public officials

Transparency / confidentiality and accountability on central and decentralised level

Preventive measures: compliance instruments and awareness raising of staff

Anti-corruption measures and administrative vigilance

Legal incompatibilities and other forms of conflicts of interest

Financing of political parties and/of electoral campaigns

Special innovative cases

3.4 Specific themes

Compliance and integrity

Prevention and Anti-corruption

Public Administration and Police

Organizations and networks

Chapter 4: Promising practices ...............................................................29

Anti-Corruption Awareness Raising within Austrian Law Enforcement Entities

Coordinator of Integrity Care

Drafting a Code of Conduct for Public Employees

Reward System for Whistleblowing by Police Officers

4.6 European Commission

1. Training on Ethics and Integrity in the Commission

2. Ethics Day Seminar

3. Guidelines for Applying Article 22 of the Staff Regulations on the Financial

4. Internal Control Standards for Effective Management

Values to be Part of the Daily Job

Annual Reports on Fraudulent and Corrupt Practices

Recommendations for implementing the Federal Government Directive Concerning

Anti-Corruption Coordination Board

Requirements for the Disclosure of Interests

Code of Conduct for Government Employees

The Corruption Prevention and Combating Bureau

4.14 The Netherlands

1. Public Administration Probity in Decision-Making Act (BIBOB): Promotion of

3. The Integrity Cube: a Multimedia Dilemma and Training Instrument

1. Ethical Principles of Police Officers

2. Moral Integrity in the Work of a Police Officer as a Public Official

Implementing Integrity Plans

1. National Network Against Corruption

2. Openness as a Means for Democracy and for Preventing Corruption

4.19 United Kingdom

1. Inquiries into Policy Issues Relating to Standards of Conduct by Elected and

2. Whistleblowing (speaking up) - the raising of a genuine workplace concern about

Chapter 5: The Integrity Infrastructure Model.....................................102

5.2 Role of top management

5.3 Core values and standards

5.4 Structures and processes

5.5 Culture and personnel policy

5.7 Evaluation and reports

The Integrity Infrastructure Model: promising practices per area of attention

Chapter 6: Looking back and ahead .....................................................112

Annex 2: Format of promising practices

Annex 3: Overview of promising practices by sections

This catalogue is the result of a commitment made by the Netherlands during

Mrs G. ter Horst

2.2 Content of the acquis

and an indicative list of international agreements, conventions and