Associazione Nazionale Comuni d'Italia Sezione Lombardia

A. Problem Analysis

 1. What was the problem before the implementation of the initiative?
A significant level of corruption for a long time has affected Italy. Our country scores 60/100 on 177 countries worldwide as for the level of corruption perceived. Corruption represents a huge drawback to develop the standards of public services, it affects citizen’s trust in our institutions and has a negative impact on free market and investments. Such a consistent amount of corruption is a consequence of the lack of transparency of public organizations and of the relationship between central government and citizens and between citizens and private companies. In 2012, Italian Parliament passed a law on anti-corruption (190/2012) in public administration, which set obligations in terms of transparency and established a national anti-corruption authority. In 2016 Italy adopted a FOIA that gave citizens a chance to get to know public administration’s data and documents. Unfortunately, applying to local communities the strategy to prevent corruption and to promote transparency set by our Government it’s a real challenge. And the risk is to focus merely on a set of top-down imposed rules and to get lost in the intricacies of bureaucracy. Corruption is a very complex phenomenon, which involves rules, ethics, social perceptions and it’s influenced by organizational dynamics and by the lack of balance between public and private sector. Moreover, transparency could be an effective way of tackling corruption only if it’s intended as accountability. As a consequence, an effective anti-corruption strategy couldn’t be top-down imposed, but must be able to involve citizens and local institutions to improve their awareness of risks and to build up a more transparent and credible relationship with citizens and to set more convincing processes. In recent times, DARA (Department of Regional Affairs and Autonomies) of The Presidency of the Council of Ministers activated a series of actions to spread all over the country best practices and multilevel governance tools to fight and prevent corruption. Within the E Government Laboratory, founded by DARA, Invitalia (National Agency for the Attraction of Investments) and the School of Management of Politecnico Milan, the Department has played a crucial role in the development of ReteComuni. The Laboratory promotes a series of actions to analyze, verify and spread the results of the programs activated in the local communities following the guidelines of the Department within the ELISA program (System Innovation of Local Communities). The aim of these actions is enhance, sustain and improve existing structures and services, in a long term perspective of renewal of the Public Administration. The Laboratory is a vital supporter under a technical and practical perspective for Anci Lombardia, coordinator of ReteComuni. ReteComuni is a network of local administrations which collects and develops, in collaborative perspective, best practices to improve efficiency and effectiveness in the government of local municipalities. Through this network, various internal and external professionals have joined the team, so to develop a 360 degrees strategy to enhance legality. Within the network, corruption prevention and transparency match with the activities related to fight money-laundering and to fight tax fraud and all the mafias.

B. Strategic Approach

 2. What was the solution?
ReteComuni engages local communities in research and training activities that collect from the bottom up the needs of civil servants and public employees. ReteComuni’s training, consultancy and research approach is conceived to capitalize on the existing skills and tools, raising awareness on their importance to fight against corruption and to promote transparency. Existing tools and skills are strengthened through innovative measures on internal checking of the information flow and process management. Best practices in public administration are then transformed into a standard, to facilitate the dissemination of the outputs all over the country.

 3. How did the initiative solve the problem and improve people’s lives?
The intervention strategy of ReteComuni brings out existing skills and tools, so to set out a customized plan, without a worsening or any kind of influence on the processes. Corruption prevention is intended for those involved in local communities’ management: politicians, civil servants, and public employees. And its main focus is on those processes with a major outer impact: purchase departments, welfare, security, tax fraud and tributes. All these areas are interested by specific training seminars, self-analysis focus groups on existing risks and support to redefine the process’ organization. Being actively involved, the staff of the offices more at risk of corruption creates a cooperative environment, so to build up shared plans and to create a favourable environment for legality. Moreover, by being attentive to transparency intended as accountability and to integrity, intended as a new way of interacting with others, there’s much more motivation for the staff. This motivation of the civil servants is really important in Italy, as their role is often neither appreciated nor recognized on a social basis. Even if a good and proper relationship between citizens and central government is not based only on legality and transparency, a clearer view of the processes with a direct influence on citizen’s everyday life and an improvement of the role of civil servants is certainly a good way to a better interactions between all those involved.

C. Execution and Implementation

 4. In which ways is the initiative creative and innovative?
Anti-corruption strategies and transparency rules are usually one way, missing a concrete overview: sometimes they are focused merely on rules, some others corruption is intended only under an ethical perspective, as if it was only a matter of personal choices and still corruption is considered an organizational problem, or a practice to penalize. Our approach is different, as it aims at keeping altogether different contributions, with bottom-up interventions able to involve citizens and local administrations, which are more sensible to this issue. In this way ReteComuni wants to improve the awareness of the risks and to capture the risk perceived by civil servants, to make public administration, process management and the relationship with the citizens more transparent. Every single intervention of ReteComuni is a cocktail of ethics, successful planning and application of rules. Each ingredient is wisely mixed in accordance with needs and dispositions.

 5. Who implemented the initiative and what is the size of the population affected by this initiative?
ReteComuni is the organization through which the program is administered. It is powered by financing quotas from its associates and by external loans, such as those from Fondazione Cariplo. ReteComuni’s projects have been also implemented thanks to the contribution of civil servants and consultants; these projects are spread on a national basis thanks to Laboratorio E Government, which is a part of DARA and can count on the media support of Strategie Amministrative, official magazine and website of Anci Lombardia. Between 2014 and 2016 between 130 and 160 local administrations in Lombardy have been involved in ReteComuni’s projects, i.e. more than 5.000 public employees.
 6. How was the strategy implemented and what resources were mobilized?
Given the complexity to coordinate different contributions and various levels of local government, DARA through the community ReteComuni has set up a coordination board which has directed the projects, has scheduled single interventions and meetings with local communities, on a multi-subject and multi-level plan.

 7. Who were the stakeholders involved in the design of the initiative and in its implementation?
Here’s a list of those who contributed to the design and implementation of the initiative: - DARA, Department of Regional Affairs, Ministry of Economy, ( - Invitalia, National Agency for the attraction of investments and development ( - Regione Lombardia ( - Comune di Milano ( - Uni-ISO, National Board of Standardisation ( - Autorità Nazionale Anticorruzione, National Anti-Corruption Authority ( - Assolombarda, Organisation of Lombardy Enterprises ( - Avviso Pubblico, Local association for fighting against the mafias ( - Fondazione Etica, Board for the promotion of public ethics ( - Ordine dei Commercialisti, Institute of Chartered Accountants ( - Transparency International ( -Politecnico di Milano (

 8. What were the most successful outputs and why was the initiative effective?
We could list various outputs to illustrate the success of the initiative. Please find them attached. - General guidelines - Specific guidelines for the Unions of Municipalities - Specific training for junior high schools - Flow chart analysis on existing corruption risk - Legalità in Comune, editorial area on (

 9. What were the main obstacles encountered and how were they overcome?
There are three main problems that were encountered during the implementation: - scarcity of the financial resources local communities can invest in prevention activities - problems in involving citizens on legality issues - basic level of digital literacy in local communities and no process digitalization They were overcome as follows: - We asked for private and public forms of funding. We promoted two projects to increase the chance to get financial support: Agenda 190 2014-2016 and Legalità in Comune 2017) and we are going to promote more projects on the European Union program 2014-2020 - We organized activities of training in junior high schools, as students are tomorrow’ citizens - As it was difficult to manage internal audits and data and document diffusion, we organized a new project, Legalità in Comune which intends to match with ReteComuni and its integration between legality and digitalization (process analysis, risk audit and procedures update, integration between transparency and e-government, identification of process-generated data and their use for transparency and diffusion/access to the information).

D. Impact and Sustainability

 10. What were the key benefits resulting from this initiative?
ReteComuni’s actions towards legality protection promoted a revision of the existing processes and increased the awareness of how valuable is the job of local communities. This reduced the risk of corruption and increased the ability of every Common to tend more and more precisely towards stakeholder’s needs. In detail: - managing the risk of corruption during audit activities allowed optimizing and making more transparent the different monitoring and controlling activities. - in the purchase department, managing the risk of corruption improved the quality of the supplying system and favoured free competition between economic operators. From 2017, with the new project Legalità in Comune the strategy of protection of legality will be more and more integrated into all the others project of ReteComuni and especially with those focused on tax fraud, combating money laundering and promote innovation and digitalization of public services, so to promote citizen’s access to public services.

 11. Did the initiative improve integrity and/or accountability in public service? (If applicable)
Determining the impact of corruption-prevention strategies is much more difficult than doing that on policies to combat illegality. For what we are aware of, none of the local communities interested by ReteComuni’s trainings and consultancy have been interested by phenomenon of corruption. Yet, the absence of offences has no specific significance and one can guess that the wideness of corruption is higher than the number of criminal convictions. That’s why ReteComuni doesn’t intend legality as the absence of criminal convictions but rather as a mindful management of the res publica. Local communities involved in ReteComuni’s activities develop a more proactive and less bureaucratic approach to anti-corruption and transparency. Moreover, from 2014 to 2016 the number of local communities, which have requested ReteComuni’s support, has increased from 10 in 2014 to 160 nowadays. If we want to measure the impact of this initiative, we can compare the quality of anti-corruption plans adopted in Lombardy, versus the quality of those adopted on a national basis. In 2016 Anac (National Anti-Corruption Authority) conducted a survey on the standards of the anti-corruption plans and Anci Lombardia did the same, focusing on the local communities in Lombardy (118 communes, 7,7% of the national relevance, 90% reliability). What emerged from Anac’s survey was that 53,8% of the communes was late in adopting the three-year plan stated by law, while instead in Lombardy only 22% was late on the due date (Jan, 31 2016). On a national basis, Anac noticed an increase in the ability to involve the stakeholders; on a local basis, according to Anci Lombardia, 84,7% of communes promoted public form of consultation for the citizens, asking for suggestions and contributions on two issues: anti-corruption and transparency. Moreover, the existing prevention tools on a national level were not specific and not customized on precise risks, while according to Anci Lombardia 58% of the communes have introduced customized measures of prevention, in addition to those stated by law.

 12. Were special measures put in place to ensure that the initiative benefits women and girls and improves the situation of the poorest and most vulnerable? (If applicable)

Contact Information

Institution Name:   Associazione Nazionale Comuni d'Italia Sezione Lombardia
Institution Type:   Local Government  
Contact Person:   Stefano Toselli
Title:   Project Manager  
Telephone/ Fax:   02.72629672
Institution's / Project's Website:  
Address:   Via Rovello 2
Postal Code:   20121
City:   Milano
State/Province:   Mi

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