Please provide a brief summary of the initiative including the problems/challenges it addressed and the solutions that the initiative introduced (300 words maximum)
Our society is to a great extent affected by corruption. System corruption directly affects the destabilization of the government, causes damages to trade, investment, and environment and encourages violation of human rights. Every year corruption in Serbia impedes construction and acquisition of 500km of new roads and 7500 medical apparatus. Its consequence are devastating, while manpower and mechanisms to effectuate changes become weaker. However, working together in a coordinated and long-term manner, state institutions and citizens can bring about positive results. The Anti-Corruption Agency of the Republic of Serbia was established in order to efficiently and systematically plan and implement, together with a society, measures for reduction of corruption and strengthening integrity of institutions at the national level. One of the competences of the Agency is to introduce integrity plan as a preventive mechanism in the fight against corruption in the public sector of the Republic of Serbia. The integrity plan is designed as an anti-corruption mechanism based on the institutions' self-assessment of the corruption risks and other irregularities, evaluation and critical review of their work and implementation of measures which should lead to elimination of any perceived risks. Its ultimate goal is to ensure efficient and effective functioning of state institutions and improve the quality of services provided to citizens.
a. What are the overall objectives of the initiative?
Please describe the overall objectives of the initiative (200 words maximum)
The Integrity Plan as a preventive mechanism aims to enable each state institution to assess its own corruption risks and other irregularities, and to take appropriate measures for their reduction and elimination. The assessment is supposed to clear out if the causes institutional malfunctioning are lack of regulation or bad regulation, the personnel who perform the given tasks or the organization itself.
If an institution has no clear rules and procedures, standards of conduct and ethical rules, the chances of bribery increase.
An idea is to use risk assessment and implementation of proposed measures to introduce necessary standards, procedures, limit discretionary decision making, strengthen ethics, introduce efficient control system, eliminate inefficient practices and unenforceable regulations, so as to ensure the ultimate goal of transparent and accountable functioning of public authority institutions, and to improve the efficiency and quality of services provided to citizens.
b. How does the initiative fit within the selected category?
Please describe how the initiative is linked to the criteria of the category (200 words maximum)
Development of the integrity plans strengthens the anti-corruption capacity of public authority institutions and their integrity, which also indirectly leads to improvement of transparency, accountability and quality of services they provide to citizens, and contributes to achievement of objective no. 16 SDG, which is precisely related to the establishment of efficient, accountable and inclusive institutions at all authority levels.
The Anti-corruption Agency (ACAS) has developed very innovative integrity plan mechanism based on a special application (software) used by public authority institutions for development of their own integrity plans. This application incorporates a draft (model) of integrity plan which contains areas/processes mostly exposed to corruption risks and other irregularities and automatically proposes measures to be implemented by the institution if it determines high level of corruption risks in the particular area/process.
The mechanism is innovative and participative. By using the applicative software, all the employees can anonymously participate in the process of risk assessment – and answer the questions. This is the opportunity for the employees to turn attention to weaknesses of the procedures, without being afraid of sanctions. This approach can improve the functioning of public institutions so that the citizens, including members of vulnerable groups, who suffer from corruption and unequal access to public services, can only benefit from it. It can be stated that so far, until the possibility given by integrity plans, public servants were not in a legal position to suggest to decision makers what are the problems in a working process and effects of procedures and decisions they brought.
The initiative should improve people’s lives, notably by enhancing the contribution of public services to the implementation of the 2030 Agenda for Sustainable Development and the realization of the SDGs
a. Please explain how the initiative improves the delivery of public services (200 words maximum)
Integrity plan mechanism considers that each state institution in the Republic of Serbia has an obligation to assess the corruption risks in the areas of public procurement, finances, human resources management, IT security, ethics and specific eligible areas, and to propose measures to reduce them.
For example, all higher education institutions were required to assess the corruption risks in a number of areas and processes including enrollment of students who belong to particularly sensitive groups (ethnic minorities, disabled, etc.). Each of these institutions had to answer the questions e.g. Are there any officially prescribed and publicly available conditions for enrollment of students who belong to particularly sensitive groups? Are the evidences needed to substantiate the conditions (status) of a student eligible to be enrolled under a special procedure prescribed? Is there a possibility of filing complaint against a decision approving/refusing enrollment of a student under the special procedure? If the higher education institution provides an answer “no” to any of these questions, the integrity plan application is self-generating suggestion for introduction of a clear procedure and transparent criteria for enrollment of students from particularly vulnerable groups. Implementation of these measures will improve the conditions for access to education, especially for sensitive social groups, and the Agency is the one to supervise whether the proposed measures were actually implemented.
The initiative must impact positively a group or groups of the population (i.e. children, women, elderly, people with disability, etc) and address a significant issue of public service delivery within the context of a given country or region.
a. Please explain how the initiative has addressed a significant issue related to the delivery of public services (200 words maximum)
As we have already mentioned on the basis of a draft (model) of integrity plan adjusted to different types of institutions (69 different models in the first cycle and 42 models in the second cycle) all public authority institutions have an obligation to assess the corruption risks in the areas of public procurement, finances, human resources management, IT security, ethics and specific eligible areas, and to propose measures to reduce them.
Model of integrity plan for gerontology centers among others includes a specific process that relates to the accommodation of the elderly. Namely, all gerontology centers are required to assess the risk of corruption in the following process and to answer the following questions: Are the information on the conditions and available capacities of gerontology center transparent - published on the website of the institution and/or information board? Is this information updated regularly? Are the information on the required documents for admission to the institution, posted on the website of the institution? Does the institution apply the act which lays down the conditions and criteria for admission of beneficiaries? If any of the gerontology centers replies on these questions with “no”, integrity plan software application is automatically suggesting measures to be implemented. Implementation of these measures improves transparency and the availability of necessary information for the use of services to the elderly, and the Agency is the one to supervise whether the proposed measures were actually implemented.
In a similar way were developed model of integrity plans for different health care institutions (hospitals, ambulances, etc), judiciary institutions and other public-sector institutions.
b. Please explain how the initiative has impacted positively a group or groups of the population within the context of your country or region (200 words maximum)
As indicated in the examples given above, the application of these measures improves the integrity of institutions, which contributes to improvement of their functioning, transparency, efficiency and inclusiveness.
In 2015 the Agency also conducted visits to 25 institutions from different public systems (political, judicial, local-self governance, culture, sport, public enterprises) in 5 cities of the Republic of Serbia to check if the selected institutions had implemented the measures proposed in their integrity plans. It was found out that out of 1203 measures envisaged by 25 institutions 360 were implemented (30%). Analysis of data also revealed that the greatest number of measures were implemented in the field of public procurement (50%) and public finances (41%). The minimum rate was conducted in the field of documentation management (15% of the proposed measures was implemented) and human resources management (16%). A detailed report of the results was announced on official site of ACAS.
System of education: in the sampled institutions a total of 193 measures were supposed to be implemented. Of these, 81 measures were implemented in the various risky processes (management of public finances, employment, enrollment of students, etc ).
System of social policy: in the sampled institutions a total of 195 measures were supposed to be implemented. Of these, 31 measures were implemented in different risky processes (management of public finances, employment, admission of elderly people in the institution. etc.)
The initiative must present an innovative idea, a distinctively new approach, or a unique policy or approach implemented in order to realize the SDGs in the context of a given country or region.
a. Please explain in which way the initiative is innovative in the context of your country or region (200 words maximum)
This mechanism is highly innovative since it is based on a special application (software) used by public authority institutions for development of their own integrity plans. This application incorporates a draft (model) of integrity plan which contains areas/processes mostly exposed to corruption risks and other irregularities and automatically proposes measures to be implemented by the institution if it determines high level of corruption risks in the particular area/process.
The way the Anti-corruption Agency (ACAS) approaches this mechanism is innovative, because it has created a special application (Software) for its development which contains a draft (model) Integrity Plan, it contains the areas/processes that are most exposed to corruption and other irregularities risks, as well as a proposal for measures to be implemented if the institutions estimate that there is a high level of rick.
By using the applicative software, all the employees can anonymously participate in the process of risk assessment – and answer the questions. This is the opportunity for the employees to turn attention to weaknesses of the procedures, without being afraid of sanctions. This approach can improve the functioning of public institutions so that the citizens, including members of vulnerable groups, who suffer from corruption and unequal access to public services, can only benefit from it. It can be stated that so far, until the possibility given by integrity plans, public servants were not in a legal position to suggest to decision makers what are the problems in a working process and effects of procedures and decisions they brought.
The entire process of drafting and implementation of integrity plans was designed, starting with the creation of methodology, modes of drafting, implementation and supervision. For the purpose of drafting the integrity plans in the first cycle, the following activities were conducted: drafting of Guidelines for Development and Implementation of Integrity Plans; drafting of Manual for Development and Implementation of Integrity Plan; production of 3 educational videos with tutorials about developing and implementation of integrity plan, etc.
b. Please describe if the innovation is original or if it is an adaptation from other contexts (If it is known)? (200 words maximum)
Preparation and implementation of integrity plans (i.e. corruption risk assessment) based on draft (models) for various types of institutions from different systems (69 and 42 models) containing risk areas/processes with the corresponding check list, risk impact assessment and proposed measures, monitoring of the implementation of measures, including the software application with the user name and password being assigned to each institution as to assess its model integrity plan stands for an original approach. This methodology of drafting integrity plans was introduced in the public sector for the first time in 2012 but it is fully applicable in all other contexts.
c. What resources (i.e. financial, human , material or other resources, etc) were used to implement the initiative? (200 words maximum)
Financial and human resources were used for development of software application, education in various cities, drafting materials (manuals, guidelines, educational movies-tutorials).
Some activities related to integrity plans, as one of the ACA competences, could not have been funded through the core budget allocated to the ACA on annual basis. In that regard, Royal Norwegian Ministry of Foreign Affairs recognized the importance of this anti-corruption tool and supported related activities in the period 2011-2016 (software, educational activities, supervision...).
The initiative should be adaptable to other contexts (e.g. other cities, countries or regions). There may already be evidence that it has inspired similar innovations in other public-sector institutions within a given country, region or at the global level.
a. Has the initiative been transferred to other contexts?
According to the Law on the Anti-Corruption Agency of the Republic of Serbia, only state institutions are obliged to draft an integrity plan, i.e. to conduct corruption risk assessment. Nonetheless, in its second cycle (2016), the integrity plan was also developed by four private sector institutions. Оther countries from the region (Montenegro, Bosnia and Herzegovina) came to see our model of the integrity plan, and by model on our methodology and model of integrity plan, developed their integrity plans.
The initiative should be able to be sustained over a significant period of time.
a. Please describe whether and how the initiative is sustainable (covering the social, economic and environmental aspects) (300 words maximum)
The initiative is sustainable, because its implementation enhances the anti-corruption capacities of the state institutions as well as their transparency and accountability, being directly reflected on all aspects of society (social, economic, environmental, human rights and all groups of the population, etc.).
b. Please describe whether and how the initiative is sustainable in terms of durability in time (300 words maximum)
The initiative is sustainable in terms of durability in time, because the fight against corruption with all its available preventive mechanisms is a long term process and requires comprehensive involvement of all actors in society, both in public and private sector, including the engagement of civil society and citizens.
The initiative should have gone through a formal evaluation, showing some evidence of impact on improving people’s lives.
a. Has the initiative been formally evaluated?
If yes, please describe how the initiative was evaluated? (200 words maximum)
On the basis of drafted integrity plans in 2012 and its statistical and content analysis (through the application), the Agency prepared a report with an overview of the status of each system (judiciary, education, health-care, social policy, etc.) including vulnerable and corruption prone areas and the recommendations for each system, which indicated to decision-makers how and in which areas proper response is needed as to reduce corruption and improve the work of state institutions (whether by adopting or implementing a regulation, establishing or strengthening the monitoring and control mechanisms related to work processes, etc.).
In addition, as of February until December 15, the Agency conducted direct control in 25 institutions from different systems (political system, judicial system, local self-government system, health-care system, education and science system, culture and sport system and public enterprises system), i.e. five towns throughout the Republic of Serbia, as to check whether the institutions implemented the measures that they indicated in their integrity plan.
b. Please describe the outcome of the evaluation of the impact of the initiative (200 words maximum)
Based on the results of direct control conducted in 25 institutions from different systems (political system, judicial system, local self-government system, health-care system, education and science system, culture and sport system and public enterprises system), i.e. five towns throughout the Republic of Serbia, it was determined that out of total number of envisaged measures, majority was implemented in the area of public procurement (50%) and public finances (41%). The least implemented measures relate to the area of documents management (15%) and the area of human resources management (16%). A detailed report was published at the website of the Anti-Corruption Agency.
c. Please describe the indicators that were used (200 words maximum)
The Agency team conducted a direct control of the implementation of the integrity plan in the 25 selected institutions on the basis of questionnaire that followed the structure of an integrity plan and on the basis of which interview with the employees of the selected institution was conducted, as to collect information on whether and how the improvement measures indicated in the integrity plan were carried out in due time, and if not, what are the reasons for failure to implement measures in due time.
For example, if the measure was related to the need to adopt the Code of Ethics, as an evidence the ACA requested the respective document or if the measure was related to the need to publish certain document, the ACA checked the website of the respective institution as to determine whether this has been done or not.
After the interview with the employees of the selected institution, the insight into internal acts and other documents created in the framework of the implementation of the integrity plan, as well as the insight into institution's website, the ACA team drafted report for each institution with the corresponding recommendations.
The initiative must demonstrate that it has engaged various actors such as from other institutions, civil society, or the private sector, when possible.
a. The 2030 Development Agenda puts emphasis on collaboration, engagement, coordination, partnerships, and inclusion. Please describe what stakeholders were engaged in designing, implementing and evaluating the initiative. Please also highlight their roles and contributions (300 words maximum)
For the first cycle of integrity plan (2012-2015) 69 draft (model) integrity plans were prepared for different types of institutions. Representatives of various state institutions-109 (health care, judiciary, social policy, police, defence, etc.) participated in preparing the content, identifying risk areas and processes relevant for different models and together with the representatives of the ACA worked for one year in order to identify the areas and work processes which are relevant for functioning of institutions and most exposed to corruption risks (such as finance management, public procurement, human resources management, IT security, ethics, etc.). In each of the mentioned areas, risk processes and specific risks were identified followed by the proposal of measures to mitigate the risks.
In addition, in order to improve the content of the draft (model) integrity plan for the second cycle in 2016, checklist for the area of IT security was introduced with the questions focused on checking the security of information. This checklist was drafted as a result of cooperation within the Ethics and Integrity Network (consisting of representatives of Western Balkan anti-corruption institutions) and E-Government Network (IT experts in the region) within the ReSPA (Regional School for Public Administration). A comparative study "Abuse of Information Technologies" was also used.
On the basis of the mentioned check list, which is an integral part of the integrity plan of 2716 public institutions in Serbia, the risk of corruption in the field of IT security has been assessed.
In order to assess the integrity plans, the ACA has included Serbian Chapter of Transparency International as a result of the public competition for the allocation of funds to civil society organizations in the area of fight against corruption.
The project is called "Integrity Plans - between Corruption Risks and Anti-Corruption Practices”. The aim of the project is to determine whether 32 observed public authorities, which dealt with corruption related cases in previous years, have taken measures to prevent such cases and whether these cases have been taken into account when drafting the integrity plan, whether they had assessed it as risky and defined adequate measures for prevention. Preparation of the report on the above mentioned research is in progress.
a. Please describe the key lessons learned, and any view you have on how to further improve the initiative (200 words maximum)
Seven-years experience in drafting and implementing the integrity plan as a corruption prevention mechanism, which is to be used by a large number of public authorities and organisations (over 4000 in the Republic of Serbia), indicates that, when first applying any mechanism, the following issues should be taken into consideration:
- it is necessary to draft certain models with the content that will be applicable to many different types of institutions;
- draft the user-friendly methodology;
- develop the application (software) given that it is the only way to monitor huge number of institutions, collect and analyze collected data;
- conduct as much trainings as possible on the importance and purpose of this mechanism;
- ensure the support of civil society, international and other organizations;
- monitor implementation in order to determine whether they have any effect and what are these effects.
In our case it is necessary to improve the content of the draft (models of the) integrity plans in the next cycle as well as the current software application in order to enhance the efficiency of monitoring the implementation of integrity plan for each institution and its effects for beneficiaries - citizens.