Prevention of corruption is one of the most significant institutional challenges in public and private sector all around the world, which receives substantial interest and high degree of scrutiny both on national and international level. There are various preventive and repressive mechanisms to reduce and eliminate corruptive activities, which requires effective planning and implementation in practice. Corruption is especially damaging in public sector, because state recourses and budget are used for private gain and not for public interests. Therefore, state government and other external stakeholders (media, civil society organizations, active citizens and etc.) should closely monitor possible corruptive activities and establish effective mechanisms for its prevention inside and outside public institutions.
How to develop an efficient integrity policy and which integrity mechanisms may reshape an organizational culture?
Institutional integrity policy is one of the essential tools for a public institution to fight against corruption, increase transparency and accountability, improve the citizen participation and gain public trust towards the civil service. International organizations recognize an institutional integrity policy as an essential part of public administration reform. The newly developed Principles of Public Administration by SIGMA/OECD states that a coherent and comprehensive public sector integrity system minimizes the risks of corruption and public institutions should establish strategic objectives to reduce the risks of corruption and threats to integrity, based on risk analysis and data.
The development of institutional integrity policies is highly recommended by Anti-Corruption Network of OECD in the report on Anti-Corruption Reforms in Georgia adopted during the fourth round of monitoring of the Istanbul Anti-Corruption Action Plan in 2016. According to the report, “further efforts are needed inside state institutions to develop internal corruption risk assessment, action plans and implementation mechanisms to help mobilize political will and resources and to coordinate and monitor actions necessary for effective implementation of anti-corruption reforms at the sectoral level.” To fulfill this recommendation, the National Anti-Corruption Council took the commitment to improve institutional anti-corruption policy in the National Anti-Corruption Strategy (2019-2020) and adopted Corruption Risk Assessment methodology in 2019 as an instrument to conduct integrity risk assessment inside the public institution.
This article defines the importance of principle of integrity for civil service, explores the process of integrity policy-making and presents the experience of Georgian public institutions in this area.
The importance of principle of integrity for civil service.
Integrity is an essential principle in the process of establishing professional, transparent and accountable civil service. The principle of integrity implies acting in accordance with relevant moral and ethical values, legal norms and codes of conduct existed in the civil service. More specifically, it obliges a civil servant to act only within the limits of his/her authority and official position, to put the public interest above the private interest and respect ethical standards in professional activities.
Integrity principle covers personal and institutional dimensions. Personal integrity may cover various ethical dilemmas, including: conflict of interest, accepting gift, revolving door, using administrative recourses for personal gain and etc. Institutional integrity is associated with the organizational readiness and sustainability towards the integrity risks, which includes internal regulations, management processes and monitoring systems. Integrity policy should consider both personal and institutional dimensions of integrity principle to develop an organizational approach regarding prevention and repression of integrity violations, contribute awareness raising of integrity principle and improve ethical environment in a public institution.
Integrity principle is guaranteed by Georgian legislation regulating the civil service. The Georgian Law on Civil Service states, that “the law aims to establish a legal basis for the formation and functioning of a stable, unified public service in Georgia based on career promotion, merit, integrity, political neutrality, impartiality and accountability.” These principles create the legal foundation for the establishment and functioning of the unified civil service as well as guarantee the stability and continuity of public administration system.13 Besides, integrity principle is an essential part of an official oath of a civil servant in Georgia. The oath of a civil servant represents his/her personal commitment towards civil service values and strengthens its connection to his/her official duties. Therefore, a civil servant understands integrity principle from the very beginning of his/her professional activities.
The process of integrity policy-making in civil service
The process of integrity policy-making covers the same policy cycle as drafting other policy documents. First, public institution conducts situational analysis based on the methodology of integrity risk assessment and identifies vulnerable functions, integrity risks and risk factors. Then, public institution establishes institutional priorities, goals and objectives of integrity policy. Furthermore, public institution defines various defense mechanisms for mitigating integrity risks and incorporates them in the drafts of integrity strategy and action plan. On the last stage, public institution publishes working documents of integrity strategy and action plan and ensures participation of external stakeholders such as Civil Society organizations, professional unions, beneficiaries of various public services and ordinary citizens. As a result, public institution creates risk registry, adopts institutional integrity strategy and action plan and starts its implementation in practice.
Institutional integrity strategy may have three main purposes: a) prevention of integrity risks; b) monitoring and punishment of integrity violations; c) awareness raising of civil servants on integrity issues. The objectives of the integrity strategy can be defined as increasing public trust in the public institution, ensuring transparency and accountability, improving internal organizational processes and organizational culture. The action plan of the strategy should contain detailed indicators for the performance of the defined tasks, assign the responsible departments/persons, and determine the timeframe and the amount of human and financial resources. It is important that the indicators defined by the action plan are realistic, measurable and achieve the objective of the task.
Integrity risk management requires to define preventive and repressive defense mechanisms.
| Preventive mechanisms | Repressive mechanisms |
| Improvement of legal norms and internal regulations; | Improvement of the effectiveness of the internal audit and monitoring system; |
| Improvement of organizational processes and management style; | Conducting disciplinary procedure and imposing sanctions |
| Improvement of working environment and working conditions; | Development of internal accountability forms and mechanisms |
| Improvement of internal and external communication | Creation and support of internal and external complaints mechanisms |
| Raising awareness of civil servants on the issues of ethics and integrity | Increasing the whistleblowers’ protection in the legal regulations and in practice |
The effective implementation of integrity policy also requires an active involvement and participation of all civil servants, holding managerial and non-managerial positions. Public institution should establish a consultative mechanism on integrity issues and appoint an integrity officer to provide relevant advices and recommendations for civil servants. Integrity officer should have sufficient professional knowledge and working experience on the ethics and integrity issues. Furthermore, public institution should strengthen human recourse management and internal audit and monitoring units in the direction of integrity policy implementation.
The Georgian experience on integrity policy-making in civil service
The implementation of integrity risk assessment and creation of integrity policy documents has started in Georgia by the support of donor organizations, such as European Union and USAID. From 2019-2023, under the EU Project, “Support to the Public Administration Reform of Georgia,” six public institutions have adopted integrity policy documents, institutional integrity strategy and action plan on the central level in Georgia. These public institutions are Ministry of Environmental protection and Agriculture; Ministry of Education and Science; LEPL Technical and Construction Supervision Agency; LEPL Labor Inspection Office of Georgia; Special Investigative Service and LEPL Civil Service Bureau.[8] Besides, on the local level, by the support of USAID and Transparency International Georgia, six Municipalities have also conducted integrity risk assessments, created integrity risk registry and prepared Integrity Action Plans. These Municipalities are Tbilisi, Lagodekhi, Ozurgeti, Senaki, Telavi and Zugdidi.
Analyzing the reports of integrity risk assessment of targeted public institutions shows that they identified the following supportive and main functions vulnerable to integrity-related risks.
| Supportive functions | Main functions |
| Human resource management; | Issuance of licenses, permits and certificates |
| Public procurement, management of finances and property of the institution; | Providing state grants, funding or subsidies |
| Review of administrative complaints and representation in court; internal monitoring and disciplinary supervision; | Providing public services |
| Access to public information and proactive publishing;
Protection of secret information and personal data; |
Exercising state monitoring and control over the citizens, public and private sector |
| Communication with society and media; internal organizational communication and ethical standards. | Conducting investigations of crimes |
According to the reports of integrity risk assessment of targeted public institutions, the following integrity-related risks were mentioned: abuse of position or authority for personal interest; incomplete performance of professional duties; conflict of interests and receiving gifts; discriminatory and unethical treatment of citizens; failure to follow the legal procedures and management processes and etc.
Analysis of integrity policy documents illustrates that public institutions have established three main directions of institutional integrity strategies such as: a) increasing transparency; b) improving accountability and c) improving organizational culture and ethical environment. Analyzing the action plans indicates that they have used both preventive and repressive defense mechanisms for integrity risk management, including adopting code of ethics, managing conflict of interest and receiving gifts, supporting whistleblower mechanisms, conducting integrity trainings for civil servants and etc.
The main challenges of the implementation of institutional integrity policy is lack of professional expertise and sufficient financial recourses in Georgia. To fulfill the commitments, public institutions need external expertise, especially in the area of preparing internal regulations, guidelines and methodologies as well as conducting trainings on integrity and ethics issues for civil servants.
Conclusion
Analyzing the experience of Georgian public institutions illustrates that institutional integrity policy is a new tool for prevention of corruption and establishing ethical organizational culture in Georgian civil service, which requires further improvement and effective implementation in practice in the future. It is essential, that more Georgian public institutions are involved in this process and consider conducting integrity risk assessment, that will become foundation of institutional integrity strategy and action plan.
The ultimate objective is clear: create an evidence-based institutional integrity policy, that is realistic, measurable and efficient. In doing so, public institutions will be able to establish a transparent, accountable and honest organizational culture in civil service. As a result, trust of citizens will increase towards functioning of public administration system.
About the author:
Nino Tsukhishvili is Doctor of Law, public administration and integrity expert. Her research interests are public administration, civil service and anti-corruption reforms. She has more than 15 years of working experience in civil society organizations, civil service and various international organizations in Georgia.
References:
Regional Cooperation Council, 2015. Corruption Risk Assessment in Public Institutions in South east Europe, Comparative Research and Methodology, available at: CRA_in_public_ins_in_SEE-WEB_final.pdf (rai-see.org), 12.
The Principles of Public Administration, developed by SIGMA and the OECD, 2023, principle 18, available at: https://www.sigmaweb.org/publications/Principles-of-Public-Administration-2023.pdf
OECD Anti-Corruption Network for Eastern Europe and Central Asia, 2016. Anti-Corruption Reforms in Georgia: Fourth Round of Monitoring of the Istanbul Anti-Corruption Action Plan, available at: OECD-ACN-Georgia-Round-4-Monitoring-Report-ENG.pdf.
Ibid, 21.
The Government decree #484 on adoption National Anti-Corruption Strategy and Action Plan of Georgia (2019-2020), adopted 04.10.2019, available at: საქართველოს ეროვნული ანტიკორუფციული სტრატეგიისა და საქართველოს ეროვნული ანტიკორუფციული სტრატეგიის განხორციელების 2019-2020 წლების სამოქმედო გეგმის დამტკიცების შესახებ | სსიპ ”საქართველოს საკანონმდებლო მაცნე” (matsne.gov.ge)
Anti-Corruption Council of Georgia, Corruption Risk Assessment Methodology (Footnote 4).
Turava, Paata, Ana Firtskhalashvili, Maia Dvalishvili, Ia Tsulaia, Ekaterine Kardava, Zura Sanikidze, Elguja Makalatia, 2018. The Commentary of the Georgian Law on Civil Service, available at: კანონის-კომენტარები.pdf (csb.gov.ge), 13.
EU project, Support to Public Administration Reform in Georgia, Project number: 404-675, 2019-2023; available at: EU Project page – EU for Georgia (eu4georgia.eu); https://www.facebook.com/EUforPARinGEORGIA.
USAID, Tetra Tech ARD, Strengthening Corruption Risk Assessment Capacities of Batumi, Gori, Lagodekhi, Ozurgeti, Senaki, Tbilisi, Telavi and Zugdidi, 2021, available at: Strengthening Corruption Risk Assessment Capacities of Batumi, Gori, Lagodekhi, Ozurgeti, Senaki, Tbilisi, Telavi and Zugdidi Municipalities – საერთაშორისო გამჭვირვალობა – საქართველო (transparency.ge).
