Preventing and combating corruption in the public service
Independent Commission Against Corruption

The Problem

The integrity, legitimacy and functioning of public bodies suffer when corrupt practices occur. However, whilst corruption is not an inevitable operational cost, public bodies have had a reactive rather than proactive approach to corruption prevention viewing it as a collateral activity given due consideration only upon occurrence. Corruption opportunities were not systematically identified and measures to support organisations in increasing their orientation to the principles of integrity, transparency and accountability were lacking.

The Independent Commission Against Corruption (ICAC) was established under the Prevention of Corruption Act (PoCA) 2002 to fight corruption in Mauritius. It is mandated to:

(i) Educate the public against the dangers of corruption
(ii) Conduct investigation on complaints of corruption
(iii) Exercise vigilance and superintendence on integrity systems

For the purpose of the Award, two public sector organizations, namely the Civil Status Division (CSD) and the Mauritius Police Force (MPF), have been chosen to reflect the implementation of the Public Sector Anti-Corruption Framework (PSACF). The CSD is responsible for vital registration (registration of birth, death, marriage) and issue of civil status certificates whilst the MPF is responsible for, amongst others, law enforcement with respect to road traffic offences.
Complaints of alleged corruption received at the ICAC regularly involve public officials of the CSD and MPF, amongst others. As from 2006, the number of complaints received is as follows:

2006 2007 2008 2009 2010 2011
MPF 2 4 9 7 11 9
CSD 4 3 12 6 6 3

The recurrent corruption opportunities prevailing at these institutions are:
1. High autonomy and demands from the public leading to bribery for:
• prompt certificate delivery;
• celebration of marriages. Screening of offenders from punishment against gratification with respect to road traffic offences
2. Abuse of office for gratification to celebrate marriage of minor less than 16 years (which is illegal in Mauritius). Bribery in the issue of contraventions due to high discretionary power of officers
3. Favouritism in posting officers to offices where registration of marriage between foreigners is high. Non-recording of contraventions issued against gratification
4. Misuse of office in regional offices due to unlimited autonomy and discretion of officers in the exercise of their functions Absence of a comprehensive database on contraventions leading to bribery in the processing of contraventions
5. Inefficient use of the computerized system leading to tampering of data for gratification

The corruption risks affect the population as they are denied of a free and fair public service. Moreover, corruption distorts government revenue and poses significant threats to public lives as it hinders the effective enforcement of road traffic laws.

Hence, Corruption Prevention Reviews (CPRs) are usually conducted by the ICAC to identify corruption risks and develop appropriate anti-corruption measures to address the identified loopholes. However, CPRs involve much ICAC resources in terms of manpower thus focus was limited to addressing specific problem areas.
Consequently CPRs were found to be time consuming and sustaining corruption resistance depended heavily on ICAC rather than the public body.

Solution and Key Benefits

 What is the initiative about? (the solution)
The achievement implemented is the integration of the Public Sector Anti-Corruption Framework (PSACF) at the CSD and the MPF in the year 2010. Top management of both organisations signed an Anti-Corruption Commitment to implement the PSACF through which corruption prevention is now thoroughly incorporated in structures and processes of organisations and in behaviours of its employees so that genuine and sustainable action against corruption is achieved.

The PSACF provides a strategic approach to corruption prevention in public bodies. It formalizes their commitment to fight corruption and enables them to take up ownership of building corruption resistance. It provides the foundation for developing, implementing and sustaining anti-corruption initiatives in public organisations and contains necessary policies, systems and plans to combat corrupt practices. The objective of the ICAC behind the development of the PSACF was to provide coverage in terms of corruption prevention to the overall public sector.

The initiative is being driven by an anti-corruption committee (ACC) set up at the level of the public body.
The ACC is responsible, amongst others, for:
• Formulation of an anti-corruption policy (ACP)
• Development of a corruption prevention plan
• Development and implementation of an integrated corruption risk management (CRM) plan
• Overseeing and coordinating implementation of corruption prevention strategies
• Implementation of the recommendations proposed by the ICAC in CPRs
• Building and sustaining an ethical culture to promote integrity of staff within the organization
• Reporting achievements through the Chief Executive of the Ministry/Department to the Director-General of the ICAC twice yearly

Both the CSD and the MPF have set up their respective ACC which meet on a monthly basis. The Commissioner of Police and the Deputy Registrar of Civil Status are chairing the ACC for both organisations respectively. The ACC sets the priorities, provides advice when ethical issues arise and communicate the ACP to all levels of management and staff.

The workings of the ACCs have led to the development and adoption an anti-corruption policy in both organisations. Each policy is available on the corporate website of the respective organisations. The ACCs are now embarking on a CRM exercise and are monitoring the implementation of the recommendations proposed in CPRs in their respective organisations.

The impact of integration of the PSACF in the structures and processes of the CSD and the MPF is being assessed through different means such as
1. The reporting mechanism of the ACC who reports twice yearly to the ICAC through its management
2. Follow-up on implementation of anti-corruption initiatives
3. Number of complaints received against each organisation
4. Types of complaints received, for example police officers are now reporting members of the public who give bribe
5. In-house research study about perception of corruption. As compared to previous years, the MPF is perceived by the public to be less corrupt.
6. Testing of the system by ICAC officers
The population at large who are clients of the CSD and the MPF benefitted from this corruption prevention culture in terms of a fair and clean service.

Actors and Stakeholders

 Who proposed the solution, who implemented it and who were the stakeholders?
Due to limited resources coupled with pressing demands for system reviews from public bodies, the need was felt for a self-administered, holistic and proactive tool to detect and prevent corrupt practices in organisations. Numerous requests to build corruption prevention infrastructure from organizations were received. Enquiries also revealed numerous areas for intervention. Hence, a tool had to be developed to empower public bodies to take up ownership of building corruption resistance in their organisations. The aim being to create the necessary capacity for public bodies to develop, implement, lead and sustain their own anti-corruption initiatives in their respective organisations.
Thus, the ICAC developed the PSACF to facilitate and accelerate the dissemination and integration of a culture of corruption prevention across the public service.
It is important to highlight that the implementation of the PSACF in public bodies has benefitted from government support. It is clearly spelt out in the Government Programme 2010 – 2015 under paragraph 38 that the Government intends to provide the public sector with an anti-corruption framework.
Top management from the CSD and MPF worked together with ICAC officers to put in place the PSACF in their respective organisations. The ICAC acted as a facilitator for the project. In this endeavour, the ACCs of the CSD and the MPF were assisted by an ICAC representative who was present as an ex-officio member on the committee. His role was to provide expert advice and to ensure proper implementation of the framework in these organisations.

(a) Strategies

 Describe how and when the initiative was implemented by answering these questions
 a.      What were the strategies used to implement the initiative? In no more than 500 words, provide a summary of the main objectives and strategies of the initiative, how they were established and by whom.
The PSACF is in fact a culmination of our previous corruption prevention efforts such as CPRs. CPRs were conducted at the CSD and the MPF to enhance systems integrity in the year 2007 and 2008 respectively. The objectives of the CPRs were to identify the systemic loopholes which lead to corruption risks and to come up with appropriate anti-corruption measures to plug in the identified loopholes. These CPRs served to create an anti-corruption momentum in the organizations which facilitated the acceptance and implementation of the PSACF.
Implementation of the PSACF is a foremost priority for the ICAC. To instill and promote a culture of corruption prevention and integrity at the CSD and MPF and for ensuring effective implementation of the framework, the ICAC came forward with the following strategies:
• Dissemination of the PSACF
Presentations on the PSACF were conducted by the ICAC to apprise top management of both the CSD and the MPF of the different elements and modalities of the project in order to enlist their support and collaboration for its successful implementation.
Both organizations received copies of the PSACF manual.
• Signing up of Anti-Corruption Commitment
To formalize their intentions and to demonstrate their firm commitment to prevent corruption through the PSACF, the Management of CSD and MPF were required to sign an Anti-Corruption Commitment.
• Setting up of an In-house Implementation Coordinating Committee
An In-house Implementation Coordinating Committee was set up at the level of the ICAC with the following objectives:
-To coordinate and monitor the overall implementation of the framework
-To develop materials and components (such as model anti-corruption policy, risk assessment templates etc) necessary for the proper implementation of the project.
-To brainstorm and take cognizance of benefits as well as impediments in the implementation of the framework
• Delegation of an ICAC officer as an ex-officio member on the ACC
An ICAC representative was delegated as an ex-officio member on the ACC to provide expert advice and assistance in the implementation of the framework.
• Development of anti-corruption tools
With a view to provide maximum assistance and guidance for facilitating the implementation of the PSACF, the ICAC has come up with several corruption prevention tools including Guidelines on the setting up of the ACC, a Model Anti-Corruption Policy and Corruption Risk Management Guide.
• Capacity Building Programme
The ICAC organized an in-house Capacity Building Programme for public officers to empower the public officers with the necessary corruption prevention principles and skills to help in the implementation of the framework in their respective organisations. It also aimed to promote a better understanding of the PSACF among public officers.
• Integrity Building Programmes
The ICAC also focused on the people’s aspect to foster organizational integrity through the conduct of numerous education sessions and programmes at the CSD and the MPF. Education sessions and programmes aimed at sensitizing public officers about corruption and the offences under the Prevention of Corruption Act 2002 and on ethical obligations to achieve organisational integrity.

(b) Implementation

 b.      What were the key development and implementation steps and the chronology? No more than 500 words
In line with its mandate to advise and assist public bodies in addressing and managing risks of corruption, the ICAC developed the PSACF which was launched in December 2009 by the Secretary to Cabinet and Head of Civil Service. To enable public bodies to take ownership to fight against corruption, the ICAC issued a copy of the framework to management of all public bodies including the CSD and the MPF in January 2010.
The implementation of the PSACF benefitted from government support in June 2010 as it was integrated in the Government Programme 2010-2015, as announced by the President of the Republic of Mauritius. The government reiterated its commitment to the fight against corruption and required that public bodies be provided with an Anti-Corruption Framework to help build trust and confidence in public institutions.

For effective implementation of the PSACF, the ICAC adopted a structured and step-wise approach. The main steps for implementing the framework involved the setting up of ACC and approval of Terms of Reference ACC, formulation of the anti-corruption policy, and conduct of the CRM exercise. The ICAC acted as facilitator in the implementation and developed several corruption prevention tools which include the Model ACP, CRM Guide and a Guide on Managing Conflict of Interests to provide its support throughout the implementation process.

To facilitate the implementation of the project at the CSD and MPF, a presentation on the framework to management was organised to apprise them of the modalities for implementing the framework. Management of both the CSD and MPF were called upon to sign the Anti-Corruption Commitment to demonstrate their firm commitment to implement the framework.

The CSD and the MPF were invited to designate a committed person preferably at management level to head the project and to set up its ACC. A representative of the ICAC was also designated to form part of the ACC to provide assistance and guidance to the ACC.

Following the successful establishment of the ACC by the CSD and the MPF in their respective organisations, the ACCs were requested to formulate their own ACP which formalizes management commitment to fight against corruption and signals management intention to adopt a zero-tolerance stance towards corruption and other malpractices. The ACP developed by the CSD and MPF were further disseminated to staff, management and stakeholders to ensure their effective implementation through their websites.
The ACCs of the CSD and the MPF have embarked on the CRM, which is an essential part of the Corruption Prevention Plan. CRM is the process of recognising and analysing risks of corruption and developing methods to both minimise and manage the risks. This process involves the following four steps:
• Identifying the risks
• Analysing, evaluating and prioritising the risks
• Managing, treating or eliminating the risks
• Monitoring and review

Following the CRM, corruption prevention strategies would be elaborated, implemented and monitored by the ACC. The ACC has also taken over the responsibility for any corruption prevention initiative already started.

(c) Overcoming Obstacles

 c.      What were the main obstacles encountered? How were they overcome? No more than 500 words
Although the PSACF manual contains invaluable information and materials to prevent and combat corruption in an organisation, some difficulties were encountered in the implementation of the PSACF throughout the public sector organisations. These include the lack of expertise and technical knowhow on corruption prevention of members of the ACC and inadequate staffing both at the level of the implementing organisations and the ICAC.

The ICAC spearheaded an in-house Capacity Building Programme for public officers of public bodies including the CSD and the MPF. The objectives of the programme for capacity building were to promote a better understanding of the PSACF and empower the public officers with the necessary corruption prevention skills to help in the implementation of the framework in their respective organisations.
The Capacity Building Programme has focused on the corruption prevention principles and the essential elements that are important for undertaking the PSACF. It basically included presentation and discussion sessions on the following topics:

• Corruption offences under PoCA 2002 - To create better awareness and understanding on corruption offences amongst public officers.

• Ethical Behaviour for Organisational Integrity- To emphasise on importance of an ethical culture and the ways for promoting ethical behaviour.

• Presentation of the Public Sector Anti-Corruption Framework – To present the salient features of the framework and the modalities for implementation in order to ensure better understanding of the same.

• Development of the Anti-Corruption Policy - To highlight the importance of formalising management intention to fight against corruption and contents of the policy.

• Corruption Prevention Principles - To give an overview of the underlying principles of corruption prevention namely accountability, transparency and fairness and the ways of promoting these principles.

• Corruption Risk Management – To apprise participants of the different steps involved in the corruption risk management exercise.

• Case studies and brainstorming session- Participants were provided with case studies on corruption scenarios and requested to identify the systemic loopholes, corruption risks and appropriate strategies to mitigate the corruption risks identified to ensure that they have grasp the essence of the corruption prevention techniques.

To cater for the problem of inadequate staffing, additional Capacity Building Programmes will be provided to more public officials in the forthcoming year so as to facilitate the workings of the ACC.

(d) Use of Resources

 d.      What resources were used for the initiative and what were its key benefits? In no more than 500 words, specify what were the financial, technical and human resources’ costs associated with this initiative. Describe how resources were mobilized
The development and implementation of the PSACF involved mostly technical and human resource costs. The conceptualization and design of the PSACF manual mobilized most personnel of the Corruption Prevention and Education Division of the ICAC. In-house expertise was crucial for the development of the elements included in the PSACF.
It took around a year to formalize the framework. By using internal resources, the ICAC avoided the financial costs of outsourcing to any consultant and made effective and efficient use of the experiences and corruption prevention skills of its staff.
The PSACF did not require much financial costs except for the printing costs of the manuals and the running of Capacity Building Programmes. The costs of development and publication of the PSACF was funded by both the annual budget and the European Union under the Decentralized Co-operation Programme. However, the costs of dissemination and ensuring its sustainability were borne only by the ICAC.
Dissemination was carried out through workshops organized by the ICAC. The framework was also promoted through our newsletters and on ICAC’s website. Here again, the ICAC made a substantial saving since outsourcing of the tool’s promotion and marketing was not required.
ICAC officers were also involved in the monitoring of the project to ensure sustainability. This allowed for prompt remedial actions to be taken whenever needed and to ensure the smooth implementation across the public sector.
At the level of the CSD and MPF, the effective implementation of the PSACF further required the commitment and involvement of top and middle management.

Sustainability and Transferability

  Is the initiative sustainable and transferable?
The dynamic nature of corruption warrants a sustainable and transferable corruption prevention culture across the public sector. The PSACF sustains corruption prevention through its in-built mechanisms and a ‘service d’accompagnement’ offered by the ICAC. The following elements ensure sustainability of the PSACF:

• Formalising Management Commitment: Management is firstly required to demonstrate its engagement to implement and sustain the project by signing the ‘Public Sector Anti-Corruption Commitment’.

• Setting up of Monitoring Committee: The whole initiative is driven and coordinated by an ACC with an approved ‘Terms of Reference’ for continuity. The ACC is not an ad-hoc committee but rather a permanent structure within the organisation.

• Review and Evaluation of Major Elements of the PSACF: The ACP, the Corruption Prevention Plan, the CRM process as well as Corruption Prevention Strategies are subject to regular evaluation and review.

• Development of Performance Indicators: There is the requirement to develop performance indicators to measure effectiveness of strategies and to report to Management.

• Reporting Mechanism of the ACC: ACC is required to report progress to the ICAC.

• Desk Officer from the ICAC: Implementing organisations are assisted by an ICAC representative. The latter is also an ex-officio member of the ACC and provides advice on the functioning and sustainability of the framework.

• Empowerment from the ICAC: The ICAC has conducted workshops with public officers to facilitate the understanding of the framework and to keep them abreast of new challenges in the fight against corruption.

According to the Government Programme 2010-2015, all public bodies are required to implement the Anti-Corruption Framework to help build trust and confidence in public institutions.
The objective of the ICAC behind the development of the PSACF was to provide coverage in terms of corruption prevention to the overall public sector. Therefore, all elements have been included in the framework with a view to make it applicable to most public organisations.
Corruption prevention strategies have been provided for high risk areas which are generally present in public institutions namely Procurement, Contract Administration, Recruitment and Selection among others.
With a view to boost up implementation, the launching of the PSACF has been made in the presence of top management of public bodies by the Head of the Civil Service. Moreover, a copy of the framework was issued to them in January 2010 and the document was uploaded on ICAC’s website.
The implementation of the PSACF at the MPF was promoted in our newsletters and through a public intervention by a representative of MPF in a forum organised by the ICAC. Moreover, Capacity Building Programmes have been organised and tools (CRM guide, Model ACP) developed with a view to replicate the implementation across the public sector.
As at to date, ten other public bodies are embarking on the implementation of the PSACF.
On the international scene, the ICAC was also invited to share its experience on the PSACF with some African countries.

Lessons Learned

 What are the impact of your initiative and the lessons learned?
The impact of the implementation of the PSACF includes:
1. Both the CSD and MPF have taken public commitment to curb corruption by signing the anti-corruption commitment. The corruption prevention culture is now embedded in both organizations.
2. Establishment of the ACC which is a permanent structure to deal with corruption prevention and other ethical issues.
3. Both organisations have developed and adopted an anti-corruption policy which articulates a firm commitment towards a zero-tolerance stance towards corruption.
4. The ACP is publicly available on the website of each implementing organizations.
5. Both CSD and MPF will shortly embark on a CRM exercise thus giving effect to the proactive approach in fighting corruption.
6. Number of complaints for the CSD has gone down while that of the MPF has gone up due to the fact that now, according its ACP, complaints of corruption concerning the MPF are required to be made to the ICAC rather than the MPF.
7. Staff of the MPF are demonstrating higher level of integrity by reporting members of the public who offer gratification
8. The MPF has applied the PSACF to the whole police force. Initially, the proposal was to adopt it for the Traffic Branch only but the Commissioner of Police extended it to the entire police force through its integration in the National Policing Framework of the MPF.
9. An additional 10 public sector bodies have already set up their ACCs. Other organizations are about to implement it with the assistance of the ICAC.
10. Follow-up on recommendations following CPRs are regularly made. The salient improvements noted are:

1. Maximum use of computerisation to reduce opportunities for corruption which has enabled immediate delivery of certificates. The MPF is implementing its e-business plan, contravention database and the penalty point system.
2. A rotation policy has been put in place so that every officer is given a fair chance to celebrate marriage between foreigners. Fixed and mobile cameras are being used to reduce opportunities to screen offender from punishment against gratification.
3. Senior officers are responsible to conduct regular site visits at regional offices. Supervisory control over the reporting of contraventions has been tightened.
4. A code of conduct for staff has been developed and disseminated to all

The key elements that made the initiative a success:
• Strong management commitment
• Government commitment
• Capacity-building
• Dissemination and communication on the PSACF
• Assistance in terms of provision of anti-corruption tools

The lessons learnt are:
• Total involvement of the implementing organization is requisite. Management commitment is crucial to drive the initiative. Without management commitment, implementation of the PSACF would not have been possible.
• It is crucial for the ICAC to set the tone and create a drive to urge public bodies implement the PSACF
• Close collaboration with some key ministries such as Ministry of Civil Service and the Ministry of Local Government could have accelerated the application of the PSACF across the public service.

Contact Information

Institution Name:   Independent Commission Against Corruption
Institution Type:   Government Agency  
Contact Person:   Rashida Bibie Domah
Title:   Director, Corruption Prevention and Education Div.  
Telephone/ Fax:   2066600/2171597
Institution's / Project's Website:
Address:   68, Harbour Area, Port Louis
Postal Code:  
City:   Port Louis
Country:   Mauritius

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