Anti-Corruption and Integrity Outlook 2024 – Country Notes: Turkiye

Contextual factors

 

State structure	Executive power	Legislative system	Legal system
Unitary	Presidential	Unicameral	Civil law

Strategy and institutions on anti-corruption and public integrity

The 11^th Development Plan (2019-2023), which is the first development plan after the change to a presidential system, was adopted at the central government level and covers five main policy target areas: i) stable economy ii) competitive production iii) qualified individuals, strong society iv) sustainable environment v) rule of law, democratisation, and good governance. The policy targets for good governance include objectives related to violations of integrity in human resource management, internal control and risk management, public procurement, education, and customs.

In terms of institutions, the Ministry of Treasury and Finance is the central government body responsible for the internal control system, while the Internal Audit Coordination Board is responsible for the internal audit system. The Constitutional Court of Türkiye oversees the financing of political parties and election campaigns in addition to its broader mandate, but does not have a budgetary autonomy. Additionally, the Court of Accounts – the supreme audit institution – assists the Constitutional Court by auditing acquisitions, revenue and expenditure of political parties, and the Supreme Election Council is an independent authority that supervises elections. In terms of conflict-of-interest, Türkiye has a decentralised approach and there is no centralised body responsible for collection and verification of interest or asset declarations. Regarding access to information, the Board of Review of the Access to Information issues decisions on requests for access to public information. Additionally, the Digital Transformation Office is responsible for open data policy and mediates the delivery of e-government services. However, there is neither legislation regulating lobbying nor an institution responsible for overseeing lobbying activities.

Overview

 

Greatest strengths	Areas to improve
Corruption risk management and audit	Conflict of interest - regulation
Transparency of public information - implementation	Political Finance
Anti-corruption strategy	Lobbying

Anti-corruption strategy

Türkiye fulfils 27% of criteria regarding the quality of the strategic framework according to OECD standards, and fulfils 13% on the implementation of strategy, compared to the OECD average of 45% and 36%, respectively.

The strategic framework establishes strategic objectives for mitigating public integrity risks in human resource management, internal control and risk management, public procurement, education, and customs. Despite wide coverage of strategic objectives, the 11th Development Plan does not include a situation analysis, contain outcome-level indicators for public integrity objectives, or set target values for outcome-level indicators. Furthermore, Türkiye does not collect data on the implementation rate of the strategic objectives. Including a situation analysis and identification of existing public integrity risks in the strategies is crucial for ensuring strategies can mitigate public integrity risks.

Corruption risk management and audit

As measured against OECD standards on risk management, which includes internal control and internal audit, Türkiye fulfils 56% of criteria for regulations, and 26% for practice, compared to the OECD average of 67% and 33% respectively. The regulatory framework defines internal control and internal audit according to international standards, establishes managerial responsibility for the implementation of internal control and internal audit, and stipulates the independence of the internal audit function in determining the scope of internal auditing, performing work, and communicating results. Furthermore, the Public Internal Control Guide covers risk management and establishes the processes and procedures for addressing risks and actions that management must take.

In practice, the Court of Accounts conducts annual reviews of the internal control system, and all central budget organisations covered by internal control have provided a self-assessment report regarding the maturity of their internal control systems during the latest calendar year. However, while all central budget organisations are also covered by internal audit, Türkiye does not collect data on the adoption of internal audit recommendations and their implementation.

Lobbying

Türkiye does not fulfil any criteria on regulations and practice to mitigate corruption risks related to lobbying, as there is no legislation in this area. On average, OECD countries fulfil 38% of criteria for regulations and 35% for practice.

Regulating lobbying activities is essential to avert capture of public policies by special interests. A regulatory framework that establishes clear definitions for lobbying can help to ensure that lobbying enhances rather than inhibits effective policymaking. Additional disclosure requirements such as a lobbying register increase transparency, thus enabling public awareness of the actors influencing policy.

Conflict of interest

As measured against OECD standards on conflict of interest, Türkiye fulfils 56% of criteria regarding regulations but does not track the necessary data in practice. On average, OECD countries fulfil 76% of criteria for regulations, and 40% for practice.

Members of the Government, parliament, and High Court must submit an interest declaration, as a minimum upon entry and any renewal or change in public office. However, Türkiye has not provided data on the submission of conflict-of-interest declarations for these officials in practice. Collecting and centralising information on the submissions of interest declarations is essential to monitor and enforce compliance with conflict-of-interest regulations. Declarations are also not verified via a risk-based approach and are not submitted electronically.

Political finance

As measured against OECD standards on political finance, Türkiye fulfils 40% of criteria regarding regulations, and 43% regarding practice, compared to the OECD average of 73% and 58%, respectively.

Regulations define proportional sanctions for breaches of provisions on the financing of political parties and election campaigns and ban anonymous donations and donations from publicly owned enterprises, foreign states and foreign enterprises. However, regulations do not set a ceiling for electoral campaign expenses or a threshold for personal contributions to candidates’ campaigns. They also do not establish requirements for political parties to make their financial reports public or report their finances during electoral campaigns. In practice all political parties represented in parliament have submitted annual accounts within the timelines defined by national legislation for the past five years. However, financial reports from all political parties are not publicly available, and the body with the mandate to oversee the financing of political parties - the Constitutional Court of Türkiye – is not independent as it is not directly financially accountable to parliament.

Transparency of public information

As measured against OECD standards on public information, which includes access to information and open data, Türkiye fulfils 44% of criteria for regulations and 54% for practice compared to the OECD average of 67% and 62%, respectively.

It has a central government unit responsible for open data policy and a supervisory body responsible for public information issues. However, it has not published key datasets necessary to ensure government transparency, such as agendas of ministers and Government sessions, interest and asset declarations of high-level public officials, and the register of businesses.