While public integrity laws and regulations are often well drafted, many countries in Latin America and the Caribbean (LAC), as in other regions, suffer from an implementation gap. An implementation gap is a difference between de jure policy requirements and de facto compliance with these regulations and translating them into practices. However, impact is only achieved if the regulations on paper are leading to an actual change in practices and behaviour.
Many factors can explain such an implementation gap. Identifying and understanding these factors is key to overcoming the challenges. Among those, two are crucial. First, an effective implementation may be thwarted due to a lack of a clear institutional responsibility for public integrity within public organisations. Similarly, reaching the subnational level may be difficult if local governments do not have entities or units dedicated to integrity policies. Second, the implementation of integrity policies can be hampered because of a lack of incentives to include public integrity objectives into the strategic and operational plans of public organisations at the central level or into the public policies of subnational governments.
Although integrity is ultimately the responsibility of all individuals within an organisation, dedicated “integrity actors” in public entities can play a key role in overcoming the implementation gap. International experience suggests the value of having a dedicated and specialised officer or unit that is responsible and accountable for the internal implementation, coordination and promotion of integrity regulations and policies. Nonetheless, while having the potential to become drivers of implementation, the mere existence of such dedicated integrity actors does not guarantee bridging the implementation gap, as their impact depends crucially on their mandate, responsibilities and available resources. According to the OECD Questionnaire on Public Integrity in Latin America 2018, 78% of the surveyed LAC countries are already opting for the implementation of dedicated integrity units or persons at ministry levels in central government. At the time of the data collection, Argentina and Chile were in the process of moving towards having such dedicated units or persons as well.
While integrity is a concern at all levels of government, opportunities for certain types of corruption can be more pronounced at subnational level. Subnational governments’ responsibilities for the delivery of a large share of public services, such as education, health, security/justice, waste management, utilities, granting licences and permits, increase the frequency and directness of interactions between government authorities and citizens and firms, and thus increases the risks of corruption. At the same time, reaching effectively the sub-national level and ensuring implementation of national policies at all levels of government is a challenge. In LAC, dedicated integrity actors that could promote the local implementation of integrity policies exist currently in only slightly less than half of the surveyed countries.
Finally, moving from an ad hoc and reactive “culture of cases” to a more proactive “culture of integrity” focusing on systemic prevention requires vision, insight and foresight, and as such both strategic and operational planning. Strategies that commit the government to concrete, ambitious but feasible outcomes can be a message to the citizens and public officials alike emphasising that the promotion of public integrity is a serious endeavour. The existence of plans is also essential to enable an effective monitoring and evaluation of the implementation of integrity policies. The OECD Questionnaire on Public Integrity in Latin America 2018 shows that eight LAC countries had a strategy at national level, Argentina was in the process of developing one that has been adopted since the data collection. Such strategies are more likely to be effective when they have to be operationalised at organisational levels and reach all levels of government. Out of the 8 countries with a strategy, 6 countries require this strategy has to be mainstreamed into organisational planning processes, while only 5 countries require an application at subnational levels.
