Anti-Corruption and Integrity Outlook 2024

2. Strategy

Introduction

A strategic approach to anti-corruption and integrity allows governments to identify challenges, establish priorities and objectives, define specific actions for achieving desired outcomes, set responsibilities and build consensus around objectives and activities, and facilitate effective implementation through monitoring and evaluation processes based on indicators for measuring success. In short, a strategic approach, usually through the development of strategic documents, can shift a country’s focus from ad hoc anti-corruption and integrity policies relating to, for instance, lobbying, office holders’ personal interests, or internal control and audit, to a coherent and comprehensive integrity system (OECD, 2020[12]). This chapter examines how far countries are adopting this strategic approach to corruption.

In particular, it explores how far countries are achieving one of the central ambitions of the OECD Recommendation on Public Integrity – to take a whole-of-society approach, involving the private sector, to curbing the most serious and detrimental forms of corruption such as undue influence, political and grand corruption. Development of integrity and anti-corruption strategies should be transparent and inclusive. Yet, only 48% of countries have ensured that integrity strategies went through standard public consultation and many have not included non-state actors in working groups to develop or amend integrity strategies. A more evidence-based and inclusive approach can improve the quality of strategies and increase trust in government.

The chapter also assesses how far countries’ strategies are being implemented. High-quality strategies are statistically associated with the existence of comprehensive action plans and ex-ante analysis of corruption risks. However, such comprehensive action plans and monitoring reports based on reliable sources and pre-established indicators are often missing. The average implementation rate of planned activities stands at 67% meaning that around one-third of the planned activities were not yet carried out. And, 60% of countries with a strategy do not track the implementation rate at all.

Overall, the chapter has three main findings:

• The majority of OECD countries have a strategic approach to corruption.

• Most countries’ strategies remain focused on traditional areas, and only a minority of countries target new risks.

• About two-thirds of the planned activities in countries’ strategies are implemented in practice.

The majority of OECD countries have a strategic approach to corruption

In recent years, OECD countries have intensified efforts to develop a strategic approach for mitigating corruption risks. Since, 2020, many OECD countries have developed an anti-corruption or integrity strategy for the first time, such as Costa Rica, Finland, France, Switzerland, and the United States, and 71% of OECD countries now have a strategy in place (Figure ‎2.1).

Figure ‎2.1. OECD countries with a strategic approach to mitigate corruption risks

Note: Data for country values for strategic approach were based on the following seven criteria: “Strategic objectives are established for mitigating public integrity risks in human resource management, including violations of public integrity standards”, “Strategic objectives are established for mitigating public integrity risks in public financial management, including reducing fraud and financial mismanagement”, “Strategic objectives are established for mitigating public integrity risks in internal control and risk management”, “Strategic objectives are established for mitigating public integrity risks in public procurement”, “Strategic objectives are established for reducing fraud and other types of corruption across the public sector”, “Strategic objectives are established to mitigate public integrity risks in the private sector, public corporations, state-owned enterprises or public-private partnerships”, “Strategies for any of the following sectors have at least one first-level objective aimed at mitigating public integrity risks: (a) infrastructure, (b) housing, (c) health, (d) education, (e) taxation, (f) customs.”

Source: OECD (2024[7]), OECD Public Integrity Indicators Database.

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The adoption of an anti-corruption and integrity strategy can be an expression of political will (Box ‎2.1), but only when developed and adopted by a whole-of-government approach. Some countries have an anti-corruption and integrity framework at institutional level, developed and adopted by individual ministries and agencies. Yet, only strategies adopted by the Council of Ministers or equivalent mechanisms can be considered a whole-of-government strategic approach and are likely to foster wider political support. Only when adopted at this highest level, following a discussion by and among various ministries or ministers and members of the government, will the strategy achieve a greater recognition of corruption risks and policy solutions across the political spectrum and the public administration. In recent years, Chile and Greece have upgraded their anti-corruption strategies from an institutional level to a whole-of-government strategic approach.

Box ‎2.1. Anti-corruption and integrity strategy as a proxy of political will

Principle 3 of the OECD Recommendation on Public Integrity calls for countries to take a strategic approach to mitigating integrity risks in the public sector. Countries should use reliable data and indicators for evaluation of the risks. Once identified, countries should develop a strategy outlining objectives and priorities, with adequate institutional set up, action plans, monitoring and evaluation.

Other principles of the Recommendation reinforce the need for a comprehensive approach:

• “Commitment” (Principle 1) – under which top-level management is expected to “set the tone from the top” and display high standards of personal propriety.

• “Responsibilities (Principle 2) – under which public sector organisations co-ordinate well with each other, with well-defined responsibilities making clear “who does what”.

• “Whole of society” (Principle 5) – promote a society-wide culture under which businesses, individuals and non-governmental actors uphold public integrity and do not tolerate corruption.

An effective strategic approach to fighting corruption should be developed in consultation with key stakeholders, adequately implemented and monitored. It should cover high-risk areas and aim to reduce fraud and other types of corruption across the whole public sector. A key indication of political commitment is the adoption of a strategic framework by the Government, defined as the highest political level (often called “Council of Ministers”).

The OECD Public Integrity Indicators on Strategy take into account all of the above aspects.

Source: (OECD, 2020[12]).

Most countries’ strategies remain focused on traditional areas, and only a minority of countries target new risks

Strong anti-corruption and integrity strategies aim to cultivate a culture of integrity across the whole of society. Strong anti-corruption strategies include elements to mitigate corruption risks in private and public corporations, state-owned enterprises, and public-private partnerships as they are central actors for a whole-of-society culture (OECD, 2020[12]). Moreover, these actors are increasingly being recognised as encompassing high-risk areas for corruption (Shaheer et al., 2019[13]; Castro, Phillips and Ansari, 2020[14]). However, only eighteen OECD countries mitigate corruption risks in the private sector, public corporations, state-owned enterprises or public-private partnerships. National anti-corruption and integrity strategies continue to focus on traditional areas, such as human resource management, public procurement, fraud and internal control and risk management. In short, the private sector is covered in two-thirds of anti-corruption and integrity strategies, even if there is widespread agreement that effective responses to future corruption risks, such as the green transition will require a whole-of-society approach, notably including the private sector (Figure ‎2.2).

Figure ‎2.2. OECD countries’ anti-corruption strategies remain centred on traditional areas

Note: Fraud and corruption in this chart means strategies have a general strategic objective to curb fraud and corruption. Data for ‘Other areas’ are based on country values for the criterion “Strategies for any of the following sectors have at least one first-level objective aimed at mitigating public integrity risks: (a) infrastructure, (b) housing, (c) health, (d) education, (e) taxation, (f) customs”.

How to read: 78% of anti-corruption strategies in place across OECD countries contain strategic objectives on public procurement.

Source: OECD (2024[7]), OECD Public Integrity Indicators Database.

Of the 27 OECD countries that have a strategy, only 18 OECD countries are using evidence-based problem analysis and diagnostics tools when developing strategic objectives for anti-corruption (OECD, 2021[15]). Moreover, national authorities should invest more in broader consultation on strategies to benefit from insights from civil society and private sector actors, including on emerging risks in new policy areas such as the green transition and AI. 48% of strategies underwent basic public consultation, 56% of strategies had extended consultations, such as town hall meetings, and non-state actors were part of a working group to develop the strategy in 56% of cases. The lack of an evidence-informed and inclusive approach to strategy development and objective setting can help explain why emerging, high-risk areas are not prioritised and a whole-of-society approach is still not the norm.

About two-thirds of the planned activities in countries’ strategies are implemented in practice

Monitoring, evaluation and implementation of strategic frameworks needs to be improved. On average across all OECD countries that have an anti-corruption and integrity strategy, of the countries which collect this information, 67% of planned activities are implemented in practice (Zuzana Smidova, Agnès Cavaciuti and Jesper Johnsøn, 2022[16]). OECD countries must address this implementation gap. The reasons for the lack of implementation may vary depending on context, but experience shows that they usually relate to resource constraints, shifting political attention or support, or inadequate implementation structures (Figure ‎2.3).

Only 40% of OECD countries monitor whether the strategy is being implemented. And 14 countries are not evaluating and drawing lessons learnt at the end of the strategy reporting period. These omissions make it difficult to gauge levels of implementation, and to be sure that strategies are actually mitigating corruption risks.

Countries with high-quality strategic frameworks invest not only in the design stage of the strategy cycle, but produce solid action plans and monitoring reports. The quality of action plans and monitoring reports matter most for the overall quality of the strategic framework (Figure ‎2.3).

Figure ‎2.3. Implementation factors matter most for the overall quality of the strategic framework

Note: The ‘quality of strategy’, represented by the blue bar, is based on the number of criteria fulfilled in the PIIs relating to strategic framework, excluding the implementation rate. The circle represents the aggregate, which includes the implementation rate. The most recent data (2020 or 2023) has been used.

How to read: As measured against OECD standards, Latvia fulfils 81% of criteria on quality of strategic framework, 79% on implementation of strategy, and 87% on action plans and monitoring reports.

Source: OECD (2024[7]), OECD Public Integrity Indicators Database.

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