This chapter analyses the Slovak Republic's measures to foster a culture of public integrity in the public sector. In particular, this chapter explores the necessity of clear contact points for public integrity in each ministry and agency, and identifies where gaps in the existing conflict-of-interest and post-public employment regimes could be closed. This chapter also explores the potential of technology to improve efficiency and reduce error through the processing of asset declarations. Additionally, this chapter identifies measures to strengthen integrity skills and knowledge, as well as merit-based recruitment and integrity leadership. This chapter furthermore highlights how a code of ethics for political and senior officials, with appropriate oversight functions, can help strengthen integrity standards at the political level. Finally, this chapter reflects on the role of the Office for the Protection of Whistleblowers in raising awareness, fostering institutional co-operation, and optimising systems for anonymous reporting.
OECD Integrity Review of the Slovak Republic
2. Cultivating a culture of integrity in the public sector in the Slovak Republic
Abstract
Introduction
Cultivating a culture of integrity in the public service requires clarifying common values and concrete standards of conduct, and setting out the necessary mechanisms and tools to support implementation. To help public officials personalise and adopt integrity values and norms, socialisation and communication measures can be adopted. In doing so, governments can help ensure a common understanding of the behaviour public officials are expected to observe in their daily tasks, especially when faced with ethical dilemmas or conflict-of-interest situations.
The OECD Recommendation on Public Integrity sets out the building blocks for cultivating a culture of interest in the public sector, including:
assigning clear and coherent integrity responsibilities
setting clear standards and procedures
investing in integrity leadership and a merit-based recruitment
raising awareness and building capacity for public integrity
ensuring an open organisational culture and clear guidance for the protection of whistleblowers (OECD, 2017[1]).
To support the Slovak Republic in cultivating a culture of public integrity, this chapter examines the legal framework and associated policies and tools. Specifically, it will examine responsibilities for public integrity, standards, with particular emphasis on conflict of interest and asset declarations, training, merit-based recruitment and whistleblower protection.
Assigning clear and coherent responsibilities for public integrity
Assigning clear responsibilities to the actors in the integrity system facilitates co-operation, avoids overlaps and prevents fragmentation. Responsibilities include developing, implementing, monitoring and evaluating integrity standards and tools, and are carried out by actors across the whole-of-government (legislative, executive, judicial) and across levels of government (national and subnational). Responsibilities for public integrity are also found within each public sector organisation. Moreover, all public officials at all levels of government are expected to carry out their duties in the public interest (OECD, 2020[2]).
To prevent fragmentation and overlap in the public integrity system, the OECD Recommendation on Public Integrity recommends that adherents “clarify institutional responsibilities across the public sector to strengthen the effectiveness of the public integrity system, in particular through:
establishing clear responsibilities at the relevant levels (organisational, sub-national or national) for designing, leading and implementing the elements of the integrity system for the public sector
ensuring that all public officials, units or bodies (including autonomous and/or independent ones) with a central responsibility for the development, implementation, enforcement and/or monitoring of elements of the public integrity system within their jurisdiction have the appropriate mandate and capacity to fulfil their responsibilities
promoting mechanisms for horizontal and vertical co-operation between such public officials, units or bodies and where possible, with and between sub-national levels of government, through formal or informal means to support coherence and avoid overlap and gaps, and to share and build on lessons learned from good practices” (OECD, 2017[1]).
The Slovak Republic could consider merging the functions of Ethics Advisors with the functions of the Anti-Corruption Coordinators
In the Slovak Republic, the responsibilities for designing, leading and implementing the integrity system are laid out in the Anti-Corruption Policy of the Slovak Republic. The Corruption Prevention Department (CPD) of the Office of the Government is the central contact point in the field of corruption prevention for all authorities and levels of public administration. The CPD performs a co‑ordinating function and oversees the implementation of the Slovak Government’s anti-corruption agenda. Box 2.1 provides an overview of the CPD’s key responsibilities.
Box 2.1. Responsibilities of the Corruption Prevention Department
The CPD is the main body responsible for co-ordinating anti-corruption measures amongst public administration bodies. In particular, the CPD is responsible for:
proposing measures and guidelines to prevent corruption, in particular by identifying and removing factors, opportunities and conditions that facilitate corruption and corruption-related practices
co‑operating with relevant expert departments in identifying, assessing and evaluating corruption risks and designing effective measures to reduce and eliminate them
assessing and proposing measures to deter both natural and legal persons from committing corruption, corrupt-related practices and creating conditions for corruption
assisting in ensuring an effective and functioning legal system to prevent corruption
establishing an adequate mechanism for introducing, implementing and monitoring corruption prevention measures, in particular the measures’ effectiveness and efficiency
involving public and private sector organisations as well as civil society organisations in corruption prevention activities
enhancing and promoting a culture of public integrity in public authorities, in particular by supporting harmonisation of personal ethical values, principles and standards with the common ones and encouraging their incorporation into the exercise of public authority
contributing to raising anti-corruption awareness of the harmful effects of corruption and on corruption prevention
monitoring the effectiveness of practical trainings/education organised by individual public administration bodies
organising the Anti-Corruption Coordinators Board’s activities.
Source: Anti-Corruption Policy of the Slovak Republic for 2019-2023
At the organisational level, the Anti-Corruption Strategy requires each ministry and central body to assign an Anti-Corruption Co-ordinator, who is responsible for co-ordinating the corruption prevention activities, including risk management, within its respective institution. The key responsibilities of the Anti-Corruption Co-ordinator include:
co-ordinating anti-corruption activities
preparing the sectoral anti-corruption programme and catalogue of corruption risks
supporting senior management in promoting and implementing the organisation’s anti-corruption programme and demonstrating a ‘tone from the top’
taking part in regular trainings provided by the Corruption Prevention Department
providing advice and guidance in the following areas: corruption risks, corruption prevention and public integrity
Receiving reports on breaches of Slovak and EU Law.
In addition to the Anti-Corruption Coordinators, a second integrity function – the Ethics Advisor – exists. The Civil Service Act assigns responsibility to Ethics Advisors for assessing the compliance of civil servant’s conduct in line with the Code of Ethics. Moreover, Ethics Advisors can propose measures to facilitate ethical behaviour in the civil service and prevent breaches to the Code of Ethics. While their responsibilities are set out in the Civil Service Act, it is not mandatory for departments or agencies to appoint an Ethics Advisor. In practice, this means that Ethics Advisors serve on a voluntary basis, and often carry out their functions part-time. The Civil Service Council, which is responsible for implementing the Code of Ethics, oversees the functions of Ethics Advisors. Currently, there are 70 appointed Advisors, about one third of the target of 200. These advisors are usually located in the human resources office of the respective organisation.
Having two functions with similar responsibilities for anti-corruption and public integrity within an organisation, who report to different central bodies, can create confusion amongst staff and lead to duplication in roles. Given the mandatory requirement to appoint Anti-Corruption Co-ordinators, the institutional anchorage with the Corruption Prevention Department, and the broad scope of their existing responsibilities, the Slovak Republic could consider merging the functions of the Ethics Advisors with the functions of the Anti-Corruption Co-ordinators, and renaming the function to “Ethics and Integrity Co-ordinator”. In addition to the responsibilities currently held by the Anti-Corruption Co-ordinator, the new Ethics and Integrity Co-ordinator function could also be responsible for providing ethical advice on integrity issues, including managing and preventing conflicts of interest and conducting integrity training and awareness raising (see below). Depending on the size of the organisation, one full time staff member, or several could carry out the function. A dedicated budget and appropriate human resources should be assigned to ensure implementation. Box 2.2 provides an overview of similar integrity functions in Germany and Austria.
Box 2.2. Establishing integrity functions within ministries: examples from Germany and Austria
Germany’s Contact Persons for Corruption Prevention
Germany, at federal level, has institutionalised units for corruption prevention as well as a responsible person that is dedicated to promoting corruption prevention measures within a public entity. The contact person and a deputy have to be formally nominated.
The “Federal Government Directive concerning the Prevention of Corruption in the Federal Administration” defines these contact persons and their tasks as follows:
A contact person for corruption prevention shall be appointed based on the tasks and size of the agency. One contact person may be responsible for more than one agency. Contact persons may be charged with the following tasks:
serving as a contact person for agency staff and management, if necessary without having to go through official channels, along with private persons
advising agency management
keeping staff members informed (e.g. by means of regularly scheduled seminars and presentations)
assisting with training
monitoring and assessing any indications of corruption
helping keep the public informed about penalties under public service law and criminal law (preventive effect) while respecting the privacy rights of those concerned.
If the contact person becomes aware of facts leading to reasonable suspicion that a corruption offence has been committed, he or she shall inform the agency management and make recommendations on conducting an internal investigation, on taking measures to prevent concealment and on informing the law enforcement authorities. The agency management shall take the necessary steps to deal with the matter.
Contact persons shall not be delegated any authority to carry out disciplinary measures; they shall not lead investigations in disciplinary proceedings for corruption cases.
Agencies shall provide contact persons promptly and comprehensively with the information needed to perform their duties, particularly with regard to incidents of suspected corruption.
In carrying out their duties of corruption prevention, contact persons shall be independent of instructions. They shall have the right to report directly to the head of the agency and may not be subject to discrimination as a result of performing their duties.
Even after completing their term of office, contact persons shall not disclose any information they have gained about staff members’ personal circumstances; they may however provide such information to agency management or personnel management if they have a reasonable suspicion that a corruption offence has been committed. Personal data shall be treated in accordance with the principles of personnel records management.
The Austrian Integrity Network
In Austria, the Federal Bureau to prevent and fight corruption (Bundesamt zur Korruptionspraevention und Korruptionsbekaempfung, BAK) created the Austrian Integrity Network (Integritaetsbeauftragten-Netzwerk) with the purpose to strengthen integrity by firmly anchoring integrity as a fundamental element in public sector. To this end, the BAK trains civil servants to become experts in the field of integrity and corruption prevention within the framework of the Integrity Network. These integrity officers provide advice and guidance in their entities to strengthen integrity within specific entities. The integrity officers can access further information on compliance, corruption, ethics, integrity and organisational culture.
In addition to the Internet platform, the BAK also offers regular follow-up meetings for integrity officers on specific topics such as risk management and ethics and values. For example, during the meeting on ethics and values, participants presented their existing values model. After a discussion in break-out groups and in plenary session, the participants identified good practices for the process of implementing a values statement in an entity.
Source: German Federal Ministry of the Interior “Rules on Integrity”, https://www.bmi.bund.de/SharedDocs/downloads/EN/publikationen/2014/rules-on-integrity.pdf?__blob=publicationFile; Austrian Federal Bureau of Anti-Corruption https://integritaet.info/
There are several benefits to combining the roles into a signal function: first, establishing a single ethics and integrity function will facilitate clarity for staff, for example in terms of who to bring their ethical inquiries to. Second, having a single function facilitates a coherent and comprehensive approach to public integrity and helps allow for genuine accumulation of expertise within the function, as recommendations, insights and good practices are gathered in one point within the organisation (OECD, 2009[3]). Finally, from a cost effectiveness perspective, empowering a single function is less costly and more efficient in terms of training, exchange of information, network meetings, monitoring, and reporting. To reflect the broad scope of the role, the Slovak Republic could also consider renaming the function to “Ethics and Integrity Co-ordinator”. While seemingly innocuous, given the negative connotations with corruption, changing the name can help make the function more approachable amongst staff.
The Corruption Prevention Department could provide guidance on where ministries and agencies should establish the function of the Anti-Corruption Coordinator
Currently, all ministries and agencies have appointed an Anti-Corruption Co-ordinator, however there is significant diversity in where these functions are established. Some Anti-Corruption Coordinators are linked to the internal control function within the ministry; others are positioned in the cabinet of the Minister. Some line ministries, such as the Ministry of Environment, have created a dedicated unit; other ministries, such as the Ministry of Justice, only have a part-time staff. This is a result of the discretionary power of the line ministers and central authorities to create position with their existing structures, as stipulated in the Anti-Corruption Policy, Section 8.5. “The statutory body shall decide on the incorporation of the position of a co‑ordinator into the entity’s organigram/organisational structure. […] The state entity may decide to establish a separate unit for the performance of the co‑ordinating task.”
The lack of consistency in where the Anti-Corruption Co-ordinators are established and the resources attributed to the function may lead to incoherent implementation of certain aspects of their role. For example, an appointment within the Cabinet of the Minister may be subject to discontinuity in case of a ministerial change or to political interference. Likewise, establishing the function within the internal audit function may be suitable for risk management activities but perhaps less adequate for anti-corruption training or awareness raising. Given the cross-cutting nature of the function and the required institution leverage, the position of Anti-Corruption Coordinator should ideally be situated in the proximity of the senior management of the ministry or central authority, for example in the office of the Secretary-General.
In order to promote more coherence, the Corruption Prevention Department could review where the functions have been established to identify good practices and challenges ministries and agencies have encountered. This stocktaking could inform updates and amendments of the Anti-Corruption Policy, in particular by setting out clear criteria and guidance on where ministries and agencies should situate the Anti-Corruption Co-ordinator. On an ad hoc basis, the Corruption Prevention Department could also advise ministries and agencies on where to establish the Anti-Corruption Coordinator function.
The Corruption Prevention Department could provide guidance for the job description and recruitment of Anti-Corruption Coordinators
The selection and recruitment of the Anti-Corruption Coordinators is conducted independently by the respective line ministry or central authority, in line with the Anti-Corruption Policy, which stipulates that “the method of selecting the Coordinator falls within the competence of the relevant statutory body or state entity, regardless of the size of the sector” (Anti-Corruption Policy, Section 8.5). This practice has led to a diversity in selection and nomination processes, as in some ministries the co‑ordinator is appointed directly by the Minister, whereas in other ministries there is an open recruitment and selection procedure. Moreover, this also resulted in diversity in the profiles of the Anti-Corruption Coordinators in terms of seniority and familiarity with anti-corruption policy. This diversity could lead to incoherent implementation of certain aspects of the Anti-Corruption Policy, especially in cases where the Anti-Corruption Coordinator does not hold sufficient institutional leverage or experience to fulfil the required tasks.
In order to support the selection of Anti-Corruption Coordinators, the CPD could identify minimum requirements related to the experience and qualifications of candidates as well as minimum requirements related to the job description and workload in terms of full-time equivalent. In practice, this could take the form of sample terms of reference that could be shared with line ministries and central authorities.
The CPD could also advise line ministries and central authorities on the selection and recruitment of the Anti-Corruption Coordinator on an ad-hoc basis or participate in the selection or recruitment procedure. For example, one challenge that line ministries and central authorities face is identifying suitable candidates. The CPD could help advertise the position within its network and raise awareness among potential external candidates.
The Slovak Republic could expand the membership of the Board of Anti-Corruption Co-ordinators and consider renaming it to clarify its role
To facilitate co-ordination and coherence of the work of the Anti-Corruption Co-ordinators across public organisations, the Slovak Republic has established a Board of Anti-Corruption Coordinators via the Anti-Corruption Policy. This Board is composed of the anti-corruption co‑ordinators from line ministries and other central authorities, as well as representatives from the Slovak National Public Prosecutor’s Office, the National Criminal Agency, the Office of the Government’s Plenipotentiary for the Development of Civil Society, the Judicial Council of the Slovak Republic, and the Association of Towns and Municipalities. The CPD is the informal secretariat to the Board. The responsibilities of the Board include:
Participating in preparing the Government policy papers on corruption prevention.
Recommending the adoption of anti-corruption measures, in particular to line Ministries, other central authorities and national administrations.
Issuing opinions, where appropriate, on anti-corruption documents and measures drawn up and adopted particularly by the Ministries and other central authorities.
Initiating, where necessary, through the competent authorities, updates and reviews of the anti-corruption documents and measures.
Initiating, through the competent authorities, justified amendments to selected applicable legislation to improve corruption prevention and fight against corruption.
The Board is a critical function for ensuring coherence and co-ordination of the sectoral anti-corruption policies across the government. Through knowledge sharing, exchange of tools and good practices, and mutual support, the Board also serves as a platform to support the Anti-Corruption Coordinators in addressing common challenges and obstacles. Moreover, through the multi-sectoral perspective, the Board can identify emerging risks or systemic obstacles related to the implementation of the anti-corruption agenda. It is worth noting that the Civil Service Council, a key actor in the public integrity and anti-corruption landscape is not represented on the Board. Given the Civil Service Council’s mandate to oversee the implementation of the Code of Ethics, it can bring useful insights related to integrity risk areas. To that end, the Board’s membership could be expanded to include the Civil Service Council.
The CPD serves a central role in the Board by convening the meetings and activities, setting the agenda, and providing ad-hoc support for the implementation of activities and instruments such as the risk management tool. Looking ahead, CPD may increasingly facilitate the institutional learning process within the network by taking stock of and communicating about learnings from operational successes and challenges.
The Anti-Corruption Policy uses two terms to refer to the network of Anti-Corruption Coordinators, one is the official “Board of Anti-Corruption Coordinators” and the other is the term “Working Group” (Anti-Corruption Policy, Section 8). As the term “board” may hold a connotation of high-level strategic decision making, which is not the role of the network, it may provide more clarity to systematically use a term reflecting the more operational role of the network, such as “Working Group” or “network”. Beyond a semantical issue, this points to the absence of a high-level strategic decision-making platform.
Setting clear public integrity standards for conflict of interest
Public integrity is institutionalised and mainstreamed through standards that set clear expectations for the behaviour and professional conduct of public officials. These integrity standards are set out in the legal, regulatory and integrity frameworks and provide a foundation for the government to stimulate ethical behaviour. In particular, integrity standards cover issues such as bribery, fraud, trading in influence, money laundering, managing and preventing conflict of interest, asset declaration, managing gifts and gratuities, and pre- and post-public employment. Integrity standards also set out functions related to whistleblower protection, integrity and transparency in lobbying, and financing democracy and political parties (OECD, 2020[2]).
Preventing and managing conflicts of interest is a central feature of standards on public integrity. When conflict-of-interest situations are not identified and managed, they can seriously endanger the integrity of organisations. Managing conflicts of interest helps level the playing field and ensure stakeholders’ fair and adequate access to policy makers and policy-making processes.
In rapidly changing public sector environments, managing conflicts of interest can be challenging. A too-strict approach to controlling the exercise of private interests may conflict with other rights, or be unworkable or counter-productive in practice by deterring experienced and competent potential candidates. A modern approach to conflict-of-interest policy seeks to strike a balance by:
Identifying risks to the integrity of public organisations and public officials.
Prohibiting specific unacceptable forms of private interest.
Making public organisations and individual officials aware of the circumstances in which conflicts can arise.
Ensuring that effective procedures are deployed for the identification, disclosure, management, and promotion of the appropriate resolution of conflict-of-interest situations.
In the Slovak Republic, the integrity standards on conflict of interest are set out in the following legislative acts:
Constitutional Act No. 357/2004 on the Protection of the Public Interest in the performance of offices by public officials, as amended by Constitutional Act 545 (2005) (e.g. “Act on Conflict of Interest”) (Government of Slovak Republic, 2004[4]).
Act 55 (2017) on Civil Service and on Amendment to Certain Acts (e.g. “Civil Service Act”) (Government of Slovak Republic, 2017[5]).
Act 552 (2003) on Performance of Work in Public Interest (e.g. “Public Service Act”) (Government of Slovak Republic, 2003[6]).
Table 2.1 details the integrity standards set out in the Act on Conflict of Interest, the Civil Service Act and the Public Service Act. Together, these three acts cover three main categories of public officials: elected officials and political appointees (Act on Conflict of Interest); civil servants (Civil Service Act); and public employees (Public Service Act).
Table 2.1. The legislative framework for conflict of interest in the Slovak Republic
|
Act |
Scope |
Integrity provisions |
|---|---|---|
|
Act on Conflict of Interest (Constitutional Act on the Protection of Public Interest in the Exercise of the Public Officials’ Office 357 (2004), as amended by Constitutional Act 545 (2005)) |
Political appointees in public sector Elected officials |
|
|
Civil Service Act (Act 55/2017 on Civil Service and on Amendment to Certain Acts)) |
High level political and management employees (certain provisions) Civil servants |
|
|
Public Service Act (Act 552 (2003) on Performance of Work in Public Interest) |
Public sector employees |
|
The Slovak Republic could consider strengthening standards on pre- and post-public employment in the Act on Conflict of Interest and the Civil Service Act, and could develop tailored guidance to support implementation
Another area of concern for public integrity is conflicts of interest arising from employment before and after the tenure of public officials. Such situations fall under the so-called “revolving-door” phenomenon of mobility between the private and public sectors. On the one hand, it is in the interest of the public and government to attract an experienced and skilled workforce. On the other hand, the revolving door can undermine the integrity of the decision-making process, exposing public officials to the risk of making decisions in the interests of private employers before or after their tenure in public service. Major post-public employment problem areas involve public officials when they seek future employment outside the public service; lobby government institutions; switch sides in the same process; use “insider information”; or are re-employed in the public service, for example, to do the same tasks they performed in the private or non-profit sectors (OECD, 2010[7]). To avoid conflicts of interest arising before or after public employment, many OECD countries have instituted provisions governing the periods before and after public employment.
There are two frameworks for regulating post-public employment in the Slovak Republic. The first is outlined in the Act on Conflict of Interest, and includes a one-year cooling-off period for senior officials including the President, members of the government, presidents, vice-presidents and secretaries-general of public organisations, as well as presidents of territorial units and mayors. The provisions are narrowly defined and restrict public officials from obtaining employment from those with whom they had particular dealings while in office (e.g. proving subsidies to, taken particular decisions regarding, issuing a public contract to, etc.) within the previous two years. The Act allows for exemptions to the restrictions to be granted, if it is clear that instituting a ‘cooling‑off’ period would be disproportionate to the risks. The authority in charge of enforcing the post-public employment measures is the National Council.
The second framework is contained in the Public Service Act, which refers to the related Labour Code provisions. In particular, the Labour Code establishes an option in the employment contract to agree on “competition clause” that contains the restrictions for the employee after termination of his/her contract not to perform the activity (for a maximum of 1 year) that has a “competitive character” for an employer. The Act on Civil Service, which covers advisors, senior civil servants, and civil servants generally, does not include any pre- or post-public employment restrictions.
To address these gaps, the Slovak Republic could consider strengthening pre- and post-public employment restrictions in the Act on Conflict of Interest. This could include expanding the scope of officials and activities covered, to situations where a senior public official moves from or to a sector covered by their portfolio or where they had previous influence over government decisions. This will help address enhanced risks related to undue lobbying or misuse of insider information (see also Chapter 5 for detailed recommendations on strengthening pre- and post-public employment lobbying regulations).
The Slovak Republic could also clarify the rules regarding exemptions to the restrictions. Currently, the National Council, which is comprised of Members of Parliament, decides on the application of post-public employment restrictions. It is not clear what criteria is used to inform decisions on exemptions, aside from a general statement in the law regarding disproportionality. This lack of clarity leaves gaps for broad interpretations of the rules.
The Slovak Republic could also consider including provisions on pre- and post-public employment in the Civil Service Act, which has remit over advisors and senior civil servants who are not covered by the Act on Conflict of Interest, as well as public officials who have regular contact with the private sector, including officials working in public procurement, regulatory policy, inspections, tax and customs. The provisions could indicate the categories of officials covered, and length of the cooling-off period, taking into account factors such as whether the time limits are fair, proportionate and reasonable, considering the seriousness of the potential offence. In applying restrictions, the Slovak Republic could also ensure a balanced approach – for example, bans on lobbying may be appropriate for a specific period of time, while restrictions related to certain insider information could be applied until the sensitive information becomes public (if at all).
As part of the development of a broader post-employment policy framework, the Corruption Prevention Department and the Civil Service and Public Service Department of the Government Office could develop guidance for public sector organisations to strengthen the effective implementation of the post-public employment measures. This may include explanatory notes about the policy measures, information about the exceptions, appeal procedures and sanctions, and case studies. While responsibility for implementation would rest with the senior management of each department and agency, the Ethics and Integrity Co-ordinator function could be responsible for providing advice and guidance within their respective ministries and agencies. Box 2.3 highlights the Government of Canada’s Application Guide for Post-Employment.
Box 2.3. Post-Employment measures in Canada and the Application Guide
In Canada, post-employment measures in included in the Policy on People Management and the Directive on Conflict of Interest to reinforce the integrity of the public service by preventing public servants from improperly benefiting themselves or others after they leave their positions with the government.
As a general principle, all public servants have a responsibility to minimise the possibility of real, apparent or potential conflict of interest between their responsibilities within the federal public service and their subsequent employment outside the public service. Before leaving their employment with the public service, all public servants are to disclose their intentions regarding any future outside employment or activities that may pose a risk of real, apparent or potential conflict of interest with their current responsibilities and discuss potential conflicts with their manager or seek guidance from their designated senior official. If a post-employment risk is determined, public servants must report the risk to their deputy head in accordance with their organisation’s procedures.
Public servants may be subject to limitations if the employment outside the public service may constitute a conflict of interest with their public service duties. A “cooling‑off” period of one year may be applied in order to limit contacts between the former public servant and private sector organisations with which that person had business dealings.
The online Application Guide for Post-Employment provides detailed information about the policy measures, the risk-based approach, and the responsibilities and duties of staff and managers. Furthermore, the Guide provides guidance on enforcement and sanctions and contains a number of case studies.
The Slovak Republic could consider strengthening institutional capacity to process, verify and audit asset declarations for political, senior and at-risk public officials
In the Slovak Republic, the Act on Conflict of Interest was revised on 1 January 2020. The new law expands the scope of public officials who are subject to the Act on Conflict of Interest to the President and members of supervisory boards of legal persons in which the state has a majority interest and city mayors. The new law also extended the scope of assets to be declared by public officials, to include the use of movables and immovables belonging to third parties and the specification of gifts received.
With regards to asset declaration, the Act on Conflict of Interest requires political and senior level officials to submit an asset declaration within thirty days of taking up office, and following that, on an annual basis. Control of these declarations is carried out by the Incompatibility of Functions Committee of the National Council. The administrative capacity to check and verify the completeness of asset declarations is low and insufficient to process all declarations in a timely manner. The capacity to conduct risk-based audits of asset declarations is largely absent, and there have been no reported cases in which illicit enrichment has been detected through asset declarations. Nevertheless, there have been a number of sanctions because of missing information in the declaration, for example related to external employment.
The Slovak Republic has recognised these weaknesses, and the Government Office and the National Council are conceptualising a proposal to establish a unified office for asset declarations (European Commission, 2021[8]). A dedicated working group has been established with representatives of relevant state authorities, including the Judicial Council, the General Prosecutor’s Office and the National Council as well as two NGOs (European Commission, 2020[9]). The intention is to establish an independent office with a mandate to receive and verify the asset declarations. In considering the structure of the office, the Slovak Republic could ensure that the office is independent of government, has wide scope of coverage for receiving and verifying asset declarations, and is afforded sufficient human, financial and technical resources. To avoid overlap with other integrity bodies, including the Corruption Prevention Department and the Civil Service Council, the new office should have clearly defined roles concerning the receiving and processing of asset declarations, and a mandate to provide guidance to political and senior management regarding the implementation of the conflict of interest and asset disclosure measures. As explored further below, the new office could also be tasked with responsibility for overseeing compliance with integrity standards for political and senior officials. The French High Authority for Transparency in Public Life (HATVP) may serve as an example of an independent institution implementing a broad public integrity mandate, including asset declarations (Box 2.4).
Box 2.4. Preventing, detecting and managing conflicts of interests in France
Mandate and independence
The High Authority for Transparency in Public Life aims at promoting public integrity in France and was established in 2014. The High Authority controls the integrity of the highest-ranking French public officials, who are required to disclose their assets and interests when taking up their official duties. The High Authority is also in charge of preventing conflicts of interest and monitoring « revolving doors » of certain public officials.
Under French public law, the High Authority is an “independent administrative authority”: it is a permanent body in the administrative structure responsible for guaranteeing integrity amongst French public officials, but it cannot be instructed nor ordered to take specific actions by the Government. The High Authority is affiliated to the Government for budget matters, but has financial autonomy. The institution is not answerable to the executive power and is solely subject to audit by the Supreme Court of auditors and the Parliament (e.g. auditions, parliamentary investigation committees) and control of administrative and judicial courts.
To guarantee its independence, the High Authority is composed of a collegial body of thirteen members responsible for taking the main decisions of the institution. In addition to its President, appointed by the President of the French Republic following a procedure entrenched in the Constitution, six members of France’s highest judicial bodies (Supreme Court of auditors, Court of cassation, Council of State) are elected by their peers. In addition, the President of the National Assembly, the President of the Senate and the Government each appoints two qualified individuals. The High Authority’s members are appointed according to the principle of gender parity. They serve a non-renewable and non-revocable mandate, and can neither receive nor seek orders or instructions from the Government.
Asset declarations
The French High Authority for Transparency in Public Life (HATVP) collects declarations and verifies the exactitude and completeness of the assets and interests declared by the high-ranking public elected and non-elected officials falling within its scope as they enter and leave their functions; these officials number close to 16 000. The High Authority’s yearly control plan is based on risk exposure, the functions occupied and the seniority of the different categories of public officials. It is also guided by legal publication deadlines for the public officials, whose declarations must be published on the website of the authority. All declarations are checked but some are subject to more thorough review.
The effectiveness of verification procedures relies notably on direct access to some of the tax administration databases, and partnerships with the tax administration, the anti-money laundering service, financial magistrates, etc. to gather and cross-check all available information. In cases of potential conflicts of interest, this verification system allows defining of specific case-by-case proportionate measures that can be adopted by public officials to solve the situation. For the aforementioned 16 000 public officials, not following the HATVP injunction to resolve a conflict-of-interest situation may result in a one-year prison sentence and a EUR 15 000 fine. At all stages, to clarify any step or requirement in the disclosure procedures, a dedicated hotline is available to answer public officials’ questions. Beyond the questions on declarative obligations per se, public officials can also benefit from the ethical advice role of the HATVP. The institution must answer any question within 30 days.
Source: High Authority for Transparency in Public Life (2021), https://www.hatvp.fr/en/
The new office on asset declaration could have the capacity to receive and process asset declarations digitally, to improve efficiency and reduce error
The current asset declaration system in the Slovak Republic is partly digitalised but there are still a number of steps that are not automated. Online or electronic submission of asset declarations is possible, however paper submissions via postal mail to the National Council are still accepted. The verification process is manual, mainly focusing on compliance and completeness. The declarations are currently not subject to any audits or deeper analysis against other databases (land and property register, tax register, etc.). All declarations are printed and scanned to obtain an electronic format. Although there is a legal obligation to publish asset declarations online, due to a lack of human and technical resources, this is currently not a priority and public scrutiny is limited.
In considering the functions and capabilities of the new office, the Slovak Republic could consider moving to an electronic-based filing system and digitalising the entire process of asset declaration. The declarations could include information from various government databases, such as the tax register and the land and property register. In this way, the annual declaration will be easier for both sender and recipients, as the form will be nearly complete from the beginning, and only additional information needs to be added. Indeed, the benefits are numerous: moving to an electronic system allows for coverage of a broader scope of declarants, simplifies the submission process by making the declaration form more user-friendly, reduces the number of mistakes made in the forms, facilitates further analysis, auditing and verification of declarations, and improves data management and security. Electronic systems have also been shown to increase compliance, and open new possibilities for disclosing data to the public and promoting better accountability and transparency (Kotylar, 2019[10]). Box 2.5 showcases the Public Ethics Total Information (PETI) system in Korea.
Box 2.5. Korea’s Public Ethics and Transparency Initiative (PETI) system
In Korea, public officials liable for property registration include state public officials in political service, such as the President, the Prime Minister, members of the State Council, members of the National Assembly, and public officials in political service for local governments, such as the heads of local governments and members of local councils. For property registration, persons liable for registration should access the Public Ethics and Transparency Initiative (PETI) System and report their current personal and family details, as well as property, online.
in order to provide convenience for property registration to persons obliged to register property and to efficiently support property review work of the person in charge of ethics affairs, the property registration system and property review system were established and operated respectively in 1999, which later evolved into the Public Ethics and Transparency Initiative (PETI) System. Currently, most of registrants (91%) are registering with accuracy owing to a web-based system, PETI. With the PETI system, property registration and review can be processed at the same time, linking HR, finance and real estate data together. It has become more important to analyse the flow of annual asset changes and gather unidentified information on property. Also, diversification of techniques for asset examination is required as circumstances of property registration change.
Source: Government of Korea - PETI (2020) https://www.peti.go.kr/indexEn.do
In transitioning to an online declaration system, the Slovak Republic could consider the legal and practical issues that are essential to successful implementation. First, to ensure exchange of data and information between institutions, both from a technical and data compatibility point of view as well as from a strategic policy perspective, the Slovak Republic could ensure that policy dialogue between institutional stakeholders are conducted both at the policy and technical level.
Second, building an online disclosure system requires designing skills and tools. Challenges may emerge from strategic choices with regard to using in-house skills, resources and instruments or externalising the design and creation of the electronic declaration system (Network for Integrity, 2020[11]). To that end, the Slovak Republic could determine what skills and IT tools are needed, and who will be responsible for providing them.
Third, the Slovak Republic could consider including in the legal framework the mandate to disclose assets via the online system. For example, some countries have a provision in their legislation to mandate online disclosure, which can help incentivise compliance (Network for Integrity, 2020[11]).
Finally, in setting up the system, the Slovak Republic could be cognisant of data security challenges, and ensure that the appropriate safeguards are in place to protect data. Such safeguards include:
Data integrity: by adding a “stamp” or digital signature on a declaration, the system can ensure that the data was not altered after its submission.
Data security: disk encryption, software-based mechanisms to detect malicious programmes, data masking and backups can help better secure information from unauthorised disclosure or loss.
Data protection: by tracking all processing operations with data in the system and keeping detailed logs, electronic systems can be used to ensure that information is processed lawfully and in compliance with other personal data protection principles and rights of the declarants (Kotylar, 2019[10]).
Box 2.6 highlights how the HATVP in France has instituted measures to ensure the security of asset declarations.
Box 2.6. Ensuring data security of asset declarations in France
In France, multiple safety measures are implemented to protect public officials’ private data on the web-based application for asset and interest declarations (ADEL). To ensure the right people are making the declarations, declarants have to prove their identity when registering, by providing identity documents, by confirming personal information already present in their file, or through a phone call.
Declarations then remain on the online declaration server for a maximum of seven days while public officials are filling them out. This server uses symmetric encryption to secure the data.
Once a declaration is filed, it is removed from the first server and stocked on a secure HATVP server. A detection mechanism prevents intrusions and the internal information system cannot be accessed remotely. Declarations are protected by asymmetric encryption when they are sent to the HATVP, which means intercepting a declaration would not allow ill-intentioned individuals to access the data without the HATVP’s private key.
Once they are received by the HATVP, only a few staff members can consult the declarations. Accessing the internal web-based tool for the management of the declarations submitted (ULYSSE) requires an individual certificate, and users are divided into groups with different levels of access corresponding to their role at the HATVP. Every access to the data on this application is traced and recorded.
The Slovak Republic could enhance coherence of integrity standards across the public sector by offering guidance on developing sectoral codes of conduct and codes of conduct for at-risk positions
Codes of ethics clearly present and illustrate the diverse legal and regulatory frameworks, and are a useful tool to guide behaviour. A code is clear and simple, logically structured, and linked to all other related documents or legislation that form part of the wider integrity system (Bacio Terracino, 2019[12]). Including an explicit reference to the formal chain of responsibility and what protection is available in cases of exposing wrongdoing is also recommended. Involving stakeholders in the drafting and validation process helps build a common understanding of expected standards of conduct, and improves the clarity and ownership of the code. In addition to a general code of conduct, standards can be adapted to sensitive sectors and roles within the public administration through tailored codes.
To facilitate implementation of the integrity standards, different codes of ethics exist in the Slovak Republic. The main code of ethics – which covers civil servants – was established with the adoption of Decree No. 400/2019 Coll., and entered into force in January 2020. This code is the guiding integrity framework for approximately 35 000 civil servants at both national and subnational levels, and the body responsible for overseeing its implementation is the Civil Service Council. The Code contains provisions on various risk areas, such as conflict of interest, non-discrimination, gifts and benefits, and use of information. To facilitate implementation of the Code, the Civil Service Council published Guidelines on Code of Ethics for Civil Servants (Civil Service Council, 2019[13]).
While the new Code of Ethics, and resulting guidelines, contribute to strengthening integrity standards in the Slovak Republic, several gaps remain. For example, public employees who fall under the Public Service Act are not covered by the Code of Ethics for Civil Servants, and the Public Service Act does not include its own code of ethics. Employees covered by the Public Service Act include a range of functions, from drivers and cooks to IT staff, and depend on the ministry. Some ministries have however developed their own code of ethics for those employed within their ministry under both regimes. For example, the Government Office implemented a Code of Ethics in 2003 which covers both civil servants and public employees. Similarly, the Ministry of Labour, Social Affairs and Family adopted a Code of Ethics in 2013, which covers all public employees working within the ministry. Despite these measures, the lack of formal requirements to establish a code of ethics leads to ad hoc coverage for public employees, and also leads to situations where there are different integrity standards in the same ministry or agency. Moreover, there is no designated entity that such employees can bring their integrity questions or concerns to, or from whom they can seek guidance.
In order to enhance coherence of integrity standards across government-employed staff, the Office of the Government, in particular the Department for Corruption Prevention and the Civil Service and Public Service Department, could provide guidance to line ministries and agencies, by:
Mapping the various codes that are already in place, and identifying the institutions that have not yet developed a code.
Providing a blueprint or template for a code of ethics with a proposed list of content reflecting recurrent integrity issues (such as gift policy, conflict of interest, external activities, corruption reporting and whistleblowing), as well as standard provisions on these issues.
Providing a methodology to develop a code of conduct, including for a risk-based approach (through an integrity risk assessment) and a consultative multi-stakeholder approach.
Providing a risk assessment methodology and sample provisions for integrity standards for at risk professions.
Providing advisory services to line ministries and public sector organisations in the process of developing integrity standards.
The Slovak Republic could introduce a code of ethics for political and senior levels and establish appropriate institutional arrangements to oversee adherence to integrity standards
Integrity at the highest political and management level is essential to set the right tone across the public administration. Clarifying integrity expectations in the relevant legislative framework, and ensuring that those responsible for upholding them understand them, are essential for facilitating integrity. Moreover, such expectations should be reinforced by clear and credible sanctions for noncompliance.
In the Slovak Republic, the applicable integrity standards for the political and senior management levels include the Constitutional Act No. 357/2004 Coll or the “Conflict of Interest Act”. State secretaries are covered by the Conflict of Interest Act, as well as Civil Service Act, which has led to confusion over which standards apply (GRECO, 2019[14]). Moreover, the existing integrity standards remain high level, couched in legal terms with limited guidance to facilitate implementation (GRECO, 2019[14]).
To address this gap and facilitate implementation of integrity standards at the highest political and senior management levels, the National Council is currently developing a code of ethics. The drafting process was postponed with the election of the new government, as well as challenges related to the COVID-19 pandemic. Going forward, the National Council could ensure that the new code of ethics applies to all political and appointed positions, including ministers, state secretaries, advisers and senior civil servants closely associated with government decision making. The code could cover all pertinent issues (conflict of interest, incompatibilities, gifts, contacts with lobbyists and third parties, post-employment restrictions, asset declarations, confidential information, etc.) (GRECO, 2019[14]). An example of such a code is the UK Ministerial Code (Box 2.7).
Box 2.7. UK Ministerial Code
The Ministerial Code sets out the standards of conduct and provides guidance to Ministers on how they should act and arrange their affairs in order to uphold these standards and to comply with the law and to abide by the Seven Principles of Public Life, a set of ethical standards which apply to all holders of public office. It also lists the rules which may apply in particular situations, such as related to employment of advisors, conflicts of interest, and impartiality vis-a-vis the civil service. It applies to all members of the Government and also covers Parliamentary Private Secretaries.
If there is an allegation about a breach of the Code, and the Prime Minister, having consulted the Cabinet Secretary, feels that it warrants further investigation, he may ask the Cabinet Office to investigate the facts of the case and/or refer the matter to the independent adviser on Ministers’ interests.
New versions of ministerial codes are usually published at the start of each new administration, although in certain circumstances it is updated more frequently.
Source: UK Cabinet Office, Ministerial Code (2019), https://www.gov.uk/government/publications/ministerial-code
To support effective implementation of the new code, the administrative structure for overseeing integrity of political officials could be strengthened. Currently, the Committee of the National Council of the Slovak Republic for Incompatibilities of Functions is responsible for reviewing conflict of interest declarations by Members of the National Council. They could also be tasked with receiving reports on breaches of the new code of ethics and determining sanctions. To facilitate a robust oversight structure that builds public confidence, the Slovak Republic could consider assigning responsibilities to the proposed new office on asset declarations to receive and investigate alleged misconduct by political officials. The office could have powers assigned to it in the Act on Conflict of Interest legislation that would enable it to receive complaints of misconduct in relation to the new Code as well as the Act on Conflict of Interest from other members of parliament and the public, and initiate an investigation. To ensure that the independence of the National Council is preserved, the office could be required to report its findings to the Committee of the National Council for Incompatibilities of Functions, who would have enhanced responsibilities for determining appropriate sanctions (OSCE, 2012[15]). Box 2.8 provides an example of a similar body in the United Kingdom.
Box 2.8. Overseeing integrity standards for politicians in the UK
Parliamentary Commissioner for Standards (UK)
The Parliamentary Commissioner for Standards is an independent officer of the House of Commons. The Commissioner investigates allegations that MPs have breached the rules found in paragraphs 11-18 of the House of Commons’ Code of Conduct for Members. UK Parliamentary Commissioners’ serve a non-renewable five-year term.
The duties of the Commissioner are embodied in Standing Order No. 150. The Commissioner can provide advice to MPs, investigate allegations that MPs have broken the Code of Conduct, hold a register of Members’ Financial Interests, and keep the MP’s Code of Conduct under review. The Commissioner cannot accept anonymous allegations for formal inquiry. They must additionally ensure that all investigations are conducted in an independent, impartial, thorough and fair manner. Once an inquiry has finished, the Commissioner decides whether or not an MP has broken the rules.
The Code of Conduct for MPs describes the responsibilities that MPs have as Members of the House and is based on a set of values called the Seven Principles of Public Life, or the Nolan Principles. The code pertains to MPs’ obligations to register and declare their financial interests and the restrictions on lobbying for reward or consideration. In July 2018, the House amended the Code of Conduct to include the Independent Complaints and Grievance Policy aimed at tackling bullying, harassment and sexual harassment by MPs.
Parliamentary Standards Committee
The Committee on Standards is a cross-party committee that was appointed in December 2012 under Standing Order No. 149, with the role of overseeing the work of the Parliamentary Commissioner for Standards. It is made up of seven Members and seven lay members. Lay members may take part in proceedings of the committee and of any sub-committee to which they are appointed and may ask questions of witnesses, but lay members may not move any motion or any amendment to any motion or draft report, and may not vote.
The committee’s responsibilities include reviewing the content and form of the Register of Member’s Financial Interests and any other registers of interest established by the House, to consider any complaints made in relation to the registering or declaring of interests, and to consider any matter relating to the conduct of Members, including complaints in relation to alleged breaches of the Code of Conduct. The Code contains a clause which mandates its review every five years, which is a process that is initiated by the Committee.
The Committee on Standards cannot take on complaints about Members of Parliament. Instead, these are directed to the Parliamentary Commissioner for Standards. The Commissioner for Standards works closely with the Committee, and updates the Committee on a monthly basis to inform it of the Commissioner’s proceedings. In the case of investigations into the conduct of MPs, the Commissioner for Standards writes a report that is submitted to the Standards Committee which then reviews and decides on appropriate sanctions.
Sources: UK Parliamentary Commissioner for Standards,
Committee on Standards, https://committees.parliament.uk/committee/290/committee-on-standards/role/;
Raising awareness and building capacity for public integrity through training
In order to institutionalise integrity standards and duly integrate them as part of the organisational culture, a number of communications, awareness raising and guidance instruments can be used. Well-designed guidance and training equip public officials with the knowledge and skills to manage integrity issues appropriately. Building individual capacity contributes to cultivating commitment among public officials, motivating behaviour to carry out their public duties in the public interest. The OECD Recommendation on Public Integrity calls on adherents to “provide sufficient information, training, guidance and timely advice for public officials to apply public integrity standards in the workplace, in particular through:
Providing public officials throughout their careers with clear and up-to-date information about the organisation’s policies, rules and administrative procedures relevant to maintaining high standards of public integrity.
Offering induction and on-the-job integrity training to public officials throughout their careers in order to raise awareness and develop essential skills for the analysis of ethical dilemmas, and to make public integrity standards applicable and meaningful in their own personal contexts.
Providing easily accessible formal and informal guidance and consultation mechanisms to help public officials apply public integrity standards in their daily work as well as to manage conflict-of-interest situations” (OECD, 2017[1]).
Building knowledge and skills on ethics and anti-corruption is an essential element of a strategic approach for public integrity. To be effective, the timing, content and delivery methods, and target audiences need to be considered. For example, integrity training should be both part of the on-boarding or induction process of new recruits, as well as take place regularly throughout a public official’s career to refresh knowledge and address new or emerging integrity issues. Integrity training should also be interesting and engaging, with different methods used to reach learners (see Table 2.2). Finally, integrity training should be tailored to the audience at hand – for example, to new recruits or those in high-risk positions.
Table 2.2. Main training methods for integrity
|
Method |
Approach |
Description |
|---|---|---|
|
Lecture |
Rules-based |
Public officials are offered lecture-format courses on integrity standards, rules and administrative procedures to reinforce their understanding of ethical concepts and principles of public service. Trainers are mainly the ones intervening. |
|
E-learning module / online course or massive open online course |
Rules-based |
Public officials are offered online courses or modules through an online platform or website on ethical standards, rules and administrative procedures to reinforce their understanding of ethical concepts and principles of public service. Trainers are mainly the ones intervening. |
|
Coaching and mentoring |
Combined |
Through peer feedback and discussions, junior public officials are given the opportunity to partner with a senior manager with proven ethical conduct, motivating ethical behaviour and helping to develop ethical awareness to foresee and resolve dilemmas. |
|
Ethical dilemma case studies and discussions |
Combined |
Based on a described situation or scenario or on non-didactic support such as a video, public officials are encouraged to identify integrity and ethical issues and discuss how to address and avoid them. The trainer acts as a facilitator with the trainees, sharing views and discussing the dilemmas. |
|
Simulation game, role-playing and scenario |
Values-based |
Public officials are given a scenario, an issue to deal with or a specific function and they are asked to perform it as if they were in a real case situation. The trainer acts as a facilitator only and trainees do most of the work, acting in an inductive way. |
Source: (OECD, 2020[2])
The Civil Service Council and the Corruption Prevention Department could develop a joint training programme for integrity and anti-corruption to avoid duplication and gaps
In the Slovak Republic, the Civil Service Council and the Corruption Prevention Department are the main providers of integrity and anti-corruption training. The Civil Service Council focuses primarily on ethics training related to the Code of Ethics, with particular reference to topics such as conflict of interest, post-employment activities, gifts, information security and sharing, social media communication and critical communication, political neutrality, as well as interpersonal relationships. These trainings are voluntary, and to date have been provided for:
Office of the President of the Slovak Republic (onsite training)
Ministry of Foreign Affairs and European Affairs of the Slovak Republic (onsite training)
Office of the Public Defender of Rights (onsite training)
Office for the Regulation of Network Industries (online training)
Value for money department of the Ministry of Finance of the Slovak Republic (onsite training)
Nuclear Regulatory Authority (onsite training, 4 trainings)
The Antimonopoly Office of the Slovak Republic (online training)
The Corruption Prevention Department also carries out trainings on corruption prevention on a by-request basis. In the period of 2017-2019, the Corruption Prevention Department organised 17 voluntary trainings for a total of 962 participants from different Ministries:
in 2017: 7 seminars for 370 participants – officials from different Ministries
in 2018: 4 seminars for 235 participants in total, of which 185 were State officials from different Ministries and public bodies and 50 participants from the Financial Administration of the SR
in 2019: 6 seminars for 357 participants – officials from different Ministries.
The Ministry of Interior has also developed several anti-corruption and integrity training programmes, including an anti-corruption e-learning programme developed by the National Crime Agency of the Police Force Presidium. The Ministry of Interior is currently developing an integrity training with the CSO Stop Corruption Foundation.
While the various training provided by the CSC, the CPD and the Ministry of Interior contribute to strengthening integrity knowledge and capacity in the public sector, the initiatives are relatively scattered, with little connection between them. To facilitate a co‑ordinated approach to integrity training, the CSC, as key training provider, and the CPD, as responsible body for corruption prevention, could consider developing a joint programme on integrity and anti-corruption training.
Together, the CSC and the CPD could map the different training mandates and initiatives, to identify existing good practices and gaps. The CSC and CPD could also prepare joint training materials, including training handbooks, case studies, presentations, videos, terms of reference for training providers, and online training modules. Adopting a more coherent approach to integrity training development and delivery has a number of benefits, including:
stronger alignment by both CPD and CSC with the broader strategic framework on corruption prevention
cost reduction for training development and delivery, through sharing of training content
potential for institutional learning from feedback from past training initiatives.
Moreover, a coherent approach could also help both institutions target high-risk sectors or professions with tailored training and avoid duplication and redundancies. The CPD and CSC could also consider partnering with academic institutions and civil society organisations operating in the area of corruption prevention, to engage their expertise for training design and delivery.
The Ethics and Integrity Co-ordinators could support implementation of the conflict of interest regime through awareness raising and capacity building
As has been discussed already, the legal framework and the Code of Ethics are essential aspects of an effective conflict of interest framework. The conflict of interest regime in the Slovak Republic for civil servants is outlined in the Act on Civil Service. According to Article 111 (1d), civil servants must refrain from actions that could lead to a conflict of interest and Article 111 (2c) requires them to report without any undue delay any real or potential conflict of interest to their respective ministry. The Code of Ethics elaborates on these responsibilities and associated guidance has been developed to support implementation. The extent to which civil servants in the Slovak Republic have knowledge about the concept of conflict of interest, and their personal responsibility to prevent and mitigate their conflict of interest, remains limited. To effectively manage and prevent conflicts of interest, civil servants need to know about the policy and have the skills to identify and manage their conflicts-of-interest. Moreover, managers require knowledge and skills to support staff in identifying and managing their conflicts of interest effectively. The Civil Service Council is working to address these limitations through tailored implementation guidance on the Code of Ethics, which includes a section on conflict of interest. Through specific scenarios, the guidance further details what a conflict of interest is, what can lead to conflict of interest, and what civil servants can do to prevent or manage conflicts of interest when they arise.
While the guidance is a helpful resource for raising awareness and building capacity on conflict of interest across the civil service, the Slovak Republic could introduce additional measures to build civil servant’s understanding about the concept of conflicting interests, and capacity to identify when they are in a conflict of interest situation. For example, the Civil Service Council, together with the Corruption Prevention Department, could prepare tailored trainings on conflict of interest. The expanded and renamed Ethics and Integrity Co-ordinator function within organisations could be responsible for delivering the training. While the training should raise knowledge about the concept of conflict of interest and the measures in place to manage it, a core focus of the training could be building capacity amongst participants to recognise when they are in a potential conflict of interest situation. As such, the proposed training method could be the ethical dilemma case studies approach (see Table 2.2). Target audiences could include managers (who receive declarations of conflict of interest), civil servants (who are required to declare their conflicts of interest) and new entries to the civil service. The Ethics and Integrity Co-ordinators, could also prepare tailored training for civil servants in at-risk positions, as determined by the corruption risk assessments carried out. A regular training schedule should be prepared to accompany the training, to ensure that both managers and civil servants are reminded of their obligations to manage and prevent conflict of interest.
Beyond training, awareness raising material that reminds civil servants of the value of identifying and management conflict of interest could be developed by the Civil Service Council and the Corruption Prevention Department. These materials would serve as regular reminds for civil servants in between training sessions, and could take the form of posters, brochures, desktop alerts, or intranet campaigns. Measures to raise awareness about managing and preventing conflict of interest could incorporate findings from behavioural insights.
Strengthening merit-based recruitment and integrity leadership
The Civil Service Council and the Civil Service and Public Service Department of the Government Office could strengthen integrity standards in public employment and promote integrity leadership
A public service selected and managed based on merit, as opposed to political patronage and nepotism, presents many benefits. Hiring people with the right skills for the job generally improves performance and productivity, which translates into better policies and better services, which in turn make for happier, healthier and more prosperous societies. Meritocracy has also been shown to reduce corruption. Having merit systems in place reduces opportunities for patronage and nepotism (OECD, 2020[2]). While the creation of fake or “ghost” jobs for allies or relatives is rare in OECD countries, a more common version of nepotism may exist in some member countries when managers or politicians appoint people to positions based on their personal ties, rather than on skills and merit.
To address these issues and to promote integrity in public employment, the OECD Recommendation on Public Integrity recommends that adherents “promote a merit-based, professional, public sector dedicated to public service values and good governance, in particular through:
Ensuring human resource management that consistently applies basic principles, such as merit and transparency, to support the professionalism of the public service, prevents favouritism and nepotism, protects against undue political interference and mitigates risks for abuse of position and misconduct.
Ensuring a fair and open system for recruitment, selection and promotion, based on objective criteria and a formalised procedure, and an appraisal system that supports accountability and a public service ethos” (OECD, 2017[1]).
In the Slovak Republic, it is prohibited to employ any close relatives in mutual direct subordination or superiority of the close relatives, or if they would be subjected to the control of the financial operations or the control of accounting operations by a close relatives (Act No. 552/2003 Coll., Act No. 55/2017 Coll., Act No. 73/1998 Coll.). Nevertheless, the issue of nepotism in public and semi-public entities remains an area of key concern and relates mainly to political nominations and interference in recruitment procedures, for example in the judiciary. This problem is acknowledged in the 2019-2023 Anti-Corruption Policy of the Slovak Republic which includes an objective to “permanently create conditions to prevent abuse of power, influence and position, clientelism, nepotism and favouritism” as well as to “reduce corruption risks through a fair valuation of the staff proportionally to their allocated responsibilities and performance”.
To achieve these objectives, the Civil Service Council and the Civil Service and Public Service Department of the Government Office could strengthen integrity standards in public employment and promote ethical leadership. A starting point could be to carry out an in-depth study of the strengths and weaknesses of the current public employment practices. To inform this analysis, the following essential components of a merit-based civil service could serve as benchmarks:
Predetermined appropriate qualification and performance criteria for all positions.
Objective and transparent personnel management processes which assess candidates against the predetermined qualification and performance criteria.
Open application processes which give equal opportunity for assessment to all potentially qualified candidates.
Oversight and recourse mechanisms to ensure a fair and consistent application of the system.
Beyond the personnel management processes for selection and promotion, another key feature of integrity in public employment is ethical leadership. Senior civil servants at all levels exemplify and transmit the public service and organisational values. The leadership fosters credibility in the norms and standards by making the values in the code of conduct applicable to the daily work and acting according to these. Above all, it can build trust in the processes (OECD, 2020[2]).
To strengthen ethical leadership in public employment, the Civil Service Council and the Civil Service and Public Service Department of the Government Office are preparing a programme to promote the concept of leadership in the civil service. A component of this programme could include reviewing the professional objectives for leaders at all levels in the public sector, and ensure that integrity is formally part of the recruitment, on-boarding, performance appraisal, and career development process of managers, supervisors and team leaders (see for example Box 2.9). Moreover, beyond setting the objectives, the Civil Service Council and the Civil Service and Public Service Department of the Government Office could develop an integrity training programme to help leaders implement integrity objectives.
Box 2.9. Ethical leadership as one of the key leadership competences in the Canadian Public Service
One of the key leadership competences Canadian executives and senior leaders are measured against is to ‘Uphold integrity and respect’. This signifies that leaders model ethical practices, professionalism and integrity. They build an open organisational culture in which employees are confident to seek advice, express diverse opinions and uphold collegiality. Examples of effective and ineffective behaviour to uphold integrity and respect for the different levels are given:
Deputy Minister
Values and provides authentic, evidence-based advice in the interest of Canadians.
Holds self and the organisation to the highest ethical and professional standards.
Models and instils commitment to citizen-focused service and the public interest.
Builds and promotes a bilingual, inclusive, healthy organisation respectful of the diversity of people and their skills and free from harassment and discrimination.
Exemplifies impartial and non-partisan decision making.
Engages in self-reflection and acts upon insights.
Assistant Deputy Minister
Values and provides authentic, evidence-based advice in the interest of Canadians.
Holds self and the organisation to the highest ethical and professional standards.
Models and builds a culture of commitment to citizen-focused service and the public interest.
Builds and promotes a bilingual, inclusive, healthy organisation respectful of the diversity of people and their skills and free from harassment and discrimination.
Exemplifies impartial and non-partisan decision making.
Engages in self-reflection and acts upon insights.
Director General
Values and provides authentic, evidence-based advice in the interest of Canadians.
Holds self and the organisation to the highest ethical and professional standards.
Models commitment to citizen-focused service and the public interest.
Creates opportunities that encourage bilingualism and diversity.
Advances strategies to foster an inclusive, healthy organisation, respectful of the diversity of people and their skills and free from harassment and discrimination.
Exemplifies impartial and non-partisan decision making.
Engages in self-reflection and acts upon insights.
Director
Values and provides authentic, evidence-based advice in the interest of Canadians.
Holds self and the organisation to the highest ethical and professional standards.
Models commitment to citizen-focused service and the public interest.
Creates opportunities that encourage bilingualism and diversity.
Implements practices to advance an inclusive, healthy organisation, respectful of the diversity of people and their skills and free from harassment and discrimination.
Exemplifies impartial and non-partisan decision making.
Engages in self-reflection and acts upon insights.
Manager
Values and provides authentic, evidence-based advice in the interest of Canadians.
Holds self and the organisation to the highest ethical and professional standards.
Models commitment to citizen-focused service and the public interest.
Supports the use of both official languages in the workplace.
Implements practices to advance an inclusive, healthy organisation, that is free from harassment and discrimination.
Promotes and respects the diversity of and their skills.
Recognises and responds to matters related to workplace well-being.
Carries out decisions in an impartial, transparent and non-partisan manner.
Engages in self-reflection and acts upon insights.
Supervisor
Values and provides authentic, evidence-based advice in the interest of Canadians.
Holds self and the organisation to the highest ethical and professional standards.
Models commitment to citizen-focused service and the public interest.
Supports the use of both official languages in the workplace.
Implements practices to advance an inclusive, healthy organisation, that is free from harassment and discrimination.
Promotes and respects the diversity of people and their skills.
Recognises and responds to matters related to workplace well-being.
Carries out decisions in an impartial, transparent and non-partisan manner.
Engages in self-reflection and acts upon insights.
Source: Government of Canada, Key Leadership Competency profile and examples of effective and ineffective behaviours, https://www.canada.ca/en/treasury-boardsecretariat/services/professional-development/key-leadership-competency-profile/examples-effectiveineffective-behaviours.html
Ensuring effective protection of whistleblowers
As a safeguard for public integrity, an effective whistleblower framework is a core component of any public integrity system. Effective frameworks for whistleblower protection have several common characteristics: clear reporting channels, prohibition of formal and informal work-related sanctions, clear types of protection guaranteed, effective reviews and investigation of complaints, and awareness-raising measures. Whistleblower protection frameworks are a compliment to broader open organisational cultures, where public officials feel safe actively identifying, raising questions, concerns or ideas about, and responding to potential violations of public integrity (OECD, 2020[2]).
In the Slovak Republic, the whistleblower framework is outlined in Act No. 54/2019 Coll., on the Protection of Whistleblowers (herein the Act on Whistleblowing). Adopted with effect on 1 March 2019, the Act on Whistleblowing replaces the former Act No. 307/2014 Coll., on Measures Related to the Reporting of Anti-Social Activities. The Act on Whistleblowing covers a wide range of functions exercised within the public sector and applies to public servants working in both national and local governments. It also broadens the definition of “complaint” beyond specific corruption offences, and provides clarity to the requirement to report in good faith. Moreover, it increases coherence in the protection accorded to different categories of officials, clarifies the options for simultaneous internal and external reporting channels, and introduces a new set of administrative offences for those who breach certain obligations of the Act (European Commission, 2020[9]; Pališin, n.d.[16]).
The Act on Whistleblowing also formally established a new Office for the Protection of Whistleblowers, which is responsible for overseeing compliance with obligations under the Act. The Office became operational in September 2021. It provides guidance on the procedures for making a complaint and supports public administrations and the private sector in setting up effective internal reporting units. Moreover, the Office has an awareness-raising function as well as a mandate to inform legislative and other reforms to improve the public integrity system in the Slovak Republic. Given its recent establishment, it is too early to determine the effectiveness of the Office. Several areas however should be the focus of the Office, and more broadly, the Government of the Slovak Republic, to ensure effective implementation of the new whistleblower protection framework.
The Office for the Protection of Whistleblowers could raise awareness about the whistleblower protection measures in place under the new law
Under the Act, public organisations are required to establish a dedicated unit responsible for administering internal complaints, as well as raise awareness about the disclosure procedures. The Office for the Protection of Whistleblowers, as mentioned above, has a mandate to support public organisations in establishing these units. It is not clear how many line ministries and public agencies have established a dedicated unit, nor how this function will co-ordinate with the existing Anti-Corruption Co-ordinator or Ethics Advisor. To that end, the Office for the Protection of Whistleblowers, with support from the Civil Service Council and the Corruption Prevention Department, could work with all line ministries and agencies to establish an internal unit with the appropriate human and financial resources.
Once established, the Office for the Protection of Whistleblowers could support the internal units to raise awareness about their existence and role within the public organisation. This could be realised through (a) trainings for staff and (b) tailored awareness-raising campaigns. In terms of trainings for staff, the Office for the Protection of Whistleblowers could prepare and deliver a training programme for all government staff employed in the internal units on good practices in complaints handling.
The Office’s efforts could also focus on supporting the internal units to raise awareness about the protections afforded to whistleblowers and how, when and where to report. Currently, awareness raising initiatives within line ministries and government agencies are carried out in an ad-hoc and unco‑ordinated basis. While government departments do indicate on their websites modalities for whistleblower protection, not all websites contain up-to-date information about the new law or existence of the Office. As a result, many public and civil servants are not aware of the exiting reporting opportunities and of the protection that whistleblowers enjoy. To address these gaps, the Office for the Protection of Whistleblowers could develop a systematic approach to awareness raising and information. The systemic approach could have two focus areas: first on raising awareness within the public sector about existing channels and protections, and second on raising awareness more broadly in society about the measures through which individuals can report on corruption. Good practice from OECD countries on awareness-raising measures can be found in Box 2.10.
Box 2.10. Raising awareness on whistleblower protection: Good practice from OECD countries
United States
The Office of the Whistleblower (OWB) of the US Securities and Exchange Commission (SEC) participates in public engagements aimed at promoting and educating the public concerning the US SEC’s whistleblower programme. Target audiences include potential whistleblowers, whistleblower counsel, and corporate compliance counsel and professionals. The OWB also aims to promote and educate the public about the whistleblower programme through its website (www.sec.gov/whistleblower). The website contains detailed information about the programme, copies of the forms required to submit a tip or claim an award, a listing of enforcement actions for which a claim for award may be made, links to helpful resources, and answers to frequently asked questions.
Korea
The Korean Anti-Corruption and Civil Rights Commission (ACRC) Since the entry into force of Korea’s Public Interest Whistleblower Act, the Anti-Corruption and Civil Rights Commission (ACRC), the body responsible for its implementation, has undertaken several awareness-raising initiatives, including both in the general anti-corruption context, such as through the annual ACRC Policy Roundtable for Foreign Businesses in Korea, where the ACRC Chairperson invites leaders of foreign businesses operating in Korea to discuss Korea’s anti-corruption policy; and in whistleblower protection-focused contexts, including:
workshops on dealing with whistleblower reporting and protection in the public and private sectors (2012, 2014)
lectures tailored to different groups in society to raise awareness of public interest whistleblowing and protection: public organisations, businesses, and the general public (about 3 500 participants in 2011, 2012)
yearly distribution of promotional materials since 2013, including TV commercial, posters, leaflets, banners on internet portals, on-board video materials for train cabins
update and distribution of PPT materials on whistleblower reporting and protection for training of employees of public organisations (2012, 2013, 2014, 2016)
distribution and operation of online training on public interest whistleblowing (2014, 2016)
distribution of the whistleblower protection guide for companies (2015)
newspaper commercials (2014), e-book on public interest reporting best practices (2015), radio commercials (2016). The ACRC also made efforts to raise awareness on public interest whistleblowing among the youth by publishing web-cartoons and mobile messenger emoticons (2012). About 16% of the public were aware of the whistleblower protection system in 2011, and the figure jumped to 23.6% in 2012 and 28.4 in 2016.
Ireland
Integrity at Work Initiative Partnerships between government and civil society can also promote whistleblower reporting and protection. A recent example of such collaboration is Ireland’s Integrity at Work (IAW) Initiative, which aims to assist employers to comply with the Protected Disclosures Act (2014) and foster workplaces where people feel safe to speak up about wrongdoing. The IAW along with Ireland’s Transparency Legal Advice Centre (TLAC) – an independent law centre established by TI Ireland that provides free specialist legal advice on protected disclosures – are run by TI Ireland with funding from the Irish Department of Public Expenditure and Reform and Department of Justice and Equality.* Members of the IAW programme come from all sectors: public, private and not-for-profit. To date, 24 organisations have joined or signalled their intention to join IAW. Two IAW Forums (seminars and workshops) have been delivered to over 100 participants between December 2016 and June 2017, focusing on providing expert guidance to employers on important issues such as assessments and investigations, complying with the Protected Disclosures Act, and related topics. As a result, there has been an increase of over 200% in the proportion of whistleblowers calling the Speak Up helpline since it was established in 2011. TLAC has also been providing free legal advice to clients since March 2016. TLAC’s clients are (or were) employed in a variety of sectors including health, social care and government.
Sources: (OECD, 2014[17]); United States, www.sec.gov/whistleblower, Transparency International Ireland, http://transparency.ie/integrity-work; (OECD, 2014[18])
The Office for the Protection of Whistleblowers could enhance institutional co‑operation and knowledge management on corruption reporting and whistleblowing
By indicating where vulnerabilities exist within the public sector, reports on corruption and other integrity breaches are a useful data source for governments to inform broader integrity and anti-corruption policies and measures. To capitalise on this data source, the Office for the Protection of Whistleblowers could support internal units in establishing data collection methods to inform the broader strategic approach to corruption prevention. In particular, these units could collect data on the number of reported cases, the nature of the cases (e.g. bribery, fraud, nepotism), the outcome of the report/investigation, and the management response (e.g. how the reports have led to structural changes beyond the individual handling of the case). The internal units could share this information with the Office for the Protection of Whistleblowers to inform necessary improvements to the system. The Office for the Protection of Whistleblowers could produce an annual report with an overview of the number and nature of corruption reports, together with the respective management responses and the follow-up in terms of further improvements required. This report will not only demonstrate the institutional follow up to corruption reports, it may also encourage whistleblowers to step forward. The Office for the Protection of Whistleblowers could also share the data collected from the internal units with the Corruption Prevention Department, who can use the data to inform its’ broader strategic approach to corruption prevention in terms of awareness raising and training, as well as risk assessments.
The Slovak Republic could optimise its system for anonymous reporting
Enabling individuals to report anonymously can help encourage reporting on wrongdoing and strengthen trust in the reporting system. Anonymous reporting is currently possible in the Slovak Republic: for example, through its Anti-corruption Hotline, the Government Office received 69 anonymous reports in 2020; 31 anonymous reports in 2019; and 36 anonymous reports in 2018. However, the current modalities do not allow government entities to follow-up with the anonymous whistleblower for further information or to inform on the status of investigations and sanctions. Moreover, the Law does not currently provide protection for those who make anonymous reports. To facilitate anonymous reporting, the Slovak Republic could consider amending the law to allow for anonymous reporting via an online portal. This portal could allow anonymous whistleblowers to submit their information using a pseudonym and employ encryption technology for follow-up to ensure that the whistleblower remains anonymous. The example of the corruption hotline using double-encryption technology in Austria may serve as an example (see Box 2.11).
Box 2.11. The Austrian portal for corruption reporting
In 2013, the Federal Ministry of Justice in Austria launched a portal to enable individuals to report wrongdoing. The portal can be also be accessed via a link on the Federal Ministry of Justice homepage, where individuals can find and download further information on the portal. The portal is operated by the Central Public Prosecutor’s Office for Combating Economic Crimes and Corruption (CPPOCECC).
The whistleblowing system is an online anonymous reporting system, which is especially suited for investigations in the area of economic crimes and corruption. The whistleblower (or “discloser”) may report anonymously any suspicion that a crime in the general remit of the CPPOCECC pursuant to section 20a of the Code for Criminal Procedure (CCP) was committed; the investigation authority in turn may make inquiries with the whistleblower, while maintaining his or her anonymity in order to verify the value of the information. Any reports within the focus set forth by section 20a CCP, but outside the CPPOCECC remit, are forwarded to the competent authority (mostly financial authorities).
To ensure that anonymity is guaranteed, when setting up a secured mailbox, the whistleblower is required to choose a pseudonym/user name and password. The anonymity of the information disclosed is maintained using encryption and other security procedures. Furthermore, whistleblowers are asked not to enter any data that gives any clues as to their identity and to refrain from submitting a report through the use of a device that was provided by their employer. Following submission, the CPPOCECC provides the whistleblower with feedback and the status of the disclosure through a secure mailbox. If there are issues that need to be clarified regarding the case, the questions are directed to the whistleblower through an anonymous dialogue. Such verified reports can lead to the opening of investigations or raise concrete suspicions requiring the initiation of preliminary investigations.
As of 31 May 2017, the introductory page of the electronic whistleblowing system was accessed 343 0296 times. A total of 5 612 (possible) criminal offences were reported, less than 6% of which were found to be completely without justification. A total of 3 895 of the reports included the installation of a secured mailbox. About 32% of the reports fell into the scope of other (especially financial) authorities and were forwarded accordingly.
Source: Austrian Federal Ministry of Justice, www.bkmssystem.net/wksta and https://www.bkms-system.net/bkwebanon/report/clientInfo?cin=1at21&c=-1&language=eng
Proposals for Action
Assigning clear and coherent responsibilities for public integrity
The Slovak Republic could consider merging the functions of Ethics Advisors with the functions of the Anti-Corruption Co-ordinators.
The Slovak Republic could expand the membership of the Board of Anti-Corruption Co-ordinators and consider renaming it to clarify its role.
Setting clear public integrity standards for conflict of interest
The Slovak Republic could consider strengthening standards on post-public employment in the Act on Conflict of Interest and the Civil Service Act, and could develop tailored guidance to support implementation.
The Slovak Republic could consider strengthening institutional capacity to process, verify and audit asset declarations for political, senior and at-risk public officials.
The proposed new office on asset declaration could have the capacity to receive and process asset declarations digitally, to improve efficiency and reduce error.
The Slovak Republic could enhance coherence of integrity standards across the public sector by offering guidance on developing sectoral codes of conduct and codes of conduct for at-risk positions.
The Slovak Republic could introduce a code of ethics for political and senior officials and establish appropriate institutional arrangements to oversee adherence to integrity standards.
Raising awareness and building capacity for public integrity through training
The Civil Service Council and the Corruption Prevention Department could develop a joint training programme for integrity and anti-corruption to avoid duplication and gaps.
The Ethics and Integrity Co-ordinators could support implementation of the conflict of interest regime for civil servants through awareness raising and capacity building.
Strengthening merit-based recruitment and integrity leadership
The Civil Service Council and the Public Service Department of the Government Office could strengthen integrity standards in public employment and promote integrity leadership.
Ensuring effective protection of whistleblowers
The Office for the Protection of Whistleblowers could raise awareness about whistleblower protection measures in place under the new law.
The Office for the protection of Whistleblowers could enhance institutional co‑operation and knowledge management on corruption reporting and whistleblowing.
The Slovak Republic could optimise its system for anonymous reporting.
References
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