2. Laying the foundations of a national integrity system in Ecuador
This Chapter describes the responsibilities of key national actors with integrity-related functions in Ecuador, which are assigned to different branches of the State. It illustrates the co-operation mechanisms set up between them, and how the creation of a National Integrity and Anti-corruption System could address their limits and enable national dialogue and co-operation across state´s branches and levels of administration on public integrity. The Chapter also analyses the integrity objectives which have been formulated in the National Development Plan 2017-2021 and in the National Public Integrity and Anti-corruption Plan 2019-2023 but have not generated the expected impact. It thus considers how to develop, in a progressive and participative manner, a strategic approach steered by the National Integrity and Anti-corruption System and leading to a long-term integrity vision for Ecuador.
Institutional responsibilities on public integrity are assigned to different actors across the five-state branches
An integrity system, whether at the country (national and sub-national) or organisational level, includes different actors with responsibilities for defining, supporting, controlling and enforcing public integrity. While the institutional arrangements to define and assign such responsibilities depend on the institutional and jurisdictional setup of a country, a set of functions should be part of an integrity system according to the OECD Recommendation on Public Integrity (Table 2.1).
In Ecuador, these responsibilities are assigned to various institutions belonging to five branches – also known as functions (funciones) of the state – which are the Executive, Legislative, Judicial, Electoral as well as the Transparency and Social Control branches, in line with the separation of powers set in the national Constitution (Constitución de la República del Ecuador). The President of the Republic is the head of the State and in charge of the whole public sector (Figure 2.1).
Source: National Assembly of Ecuador (2008[13]), Constitution of Ecuador, https://www.asambleanacional.gob.ec/sites/default/files/documents/old/constitucion_de_bolsillo.pdf (accessed on 12 April 2021).
Executive branch
In the Executive branch, the anti-corruption and integrity function has been assigned to various specialised anti-corruption bodies that have succeeded in the past years. (Box 3.1). Most recently, in 2019, the Anti-corruption Secretariat (Secretaría Anticorrupción) was created through the Executive Decree No. 665 of February 6, 2019 with the following responsibilities:
Proposing guidelines for the development of public policies and actions that facilitate the report of high-impact acts of corruption committed in the public administration.
Monitoring the actions against corruption committed in the public administration.
Mainstreaming the implementation of anti-corruption policies within the Central Government entities.
Establishing co-operation between government institutions, control agencies, judicial entities and all those involved in the investigation, prosecution and punishment of acts of corruption respecting the division of powers.
Approving instruments for the systematisation and delivery of supplies or official documentation to the competent bodies through a corresponding route for the fight against corruption.
Articulating with the Ministry of Foreign Affairs the implementation of existing international agreements that have been acquired by Ecuador in favour of the fight against corruption.
Proposing to the President of the Republic anti-corruption initiatives.
The Anti-corruption Secretariat was dissolved with the Executive Decree No. 1065 of May 21, 2020 and, although no entity has formally succeeded in its functions, the General Secretariat of the Presidency (Secretaría General de la Presidencia) has been promoting public integrity initiatives as part of its work on open government issues.
Next to the Presidency, the Ministry of Labour (Ministerio del Trabajo) has key competences in Ecuador integrity system as it is responsible for policies on employment and human resources in the public sector, including recruitment, promotions, capacity building and disciplinary aspects.
From a whole-of-society perspective to public integrity, another key actor is the Ministry of Education (Ministerio de Educación), which guarantees access and quality of primary and secondary education and could build a greater role in Ecuador’s public integrity system by raising awareness on public integrity and promoting values and knowledge on the exercise of citizenship in Ecuador.
Another relevant institution within the Executive is the Financial and Economic Analysis Unit (Unidad de Análisis Financiero y Económico, UAFE), an autonomous technical entity of the Ministry of Economy and Finance (Ministerio de Economía y Finanzas), which is responsible for the collection of information, reporting, as well as for the implementation of policies and national strategies for the prevention and identification of money laundering and crimes financing.
Transparency and Social Control branch
The Transparency and Social Control branch of Ecuador (Función de Transparencia y Control Social) is entrusted by the Constitution to promote and encourage the control of public sector entities and bodies, as well as natural or legal persons from the private sector that provide services or carry out activities of public interest, so that they perform them with responsibility, transparency, and equity. Its mandate also includes the promotion and encouragement of citizen participation; to protect the exercise and fulfilment of rights; and to prevent and fight corruption. Most relevant responsibilities are:
Formulate public policies on transparency, control, accountability, promotion of citizen participation and the prevention and fight against corruption.
Co-ordinate the action plan of the entities of the Transparency and Social Control branch (plan de acción de las entidades de la Función de Transparencia y Control Social), without affecting their autonomy.
Articulate the formulation of the national anti-corruption plan.
Submit to the National Assembly (Asamblea Nacional) proposals for legal reforms within the scope of their competencies.
Report annually to the National Assembly the activities related to the fulfilment of its functions, or when it requires it to do so.
The Transparency and Social Control branch is formed by institutions, to which the Constitution assigns relevant duties and responsibilities for Ecuador’s public integrity system. They are the Council for Citizen Participation and Social Control (Consejo de Participación Ciudadana y Control Social), the Ombudsman's Office (Defensoria del Pueblo), the Comptroller General's Office (Contraloría General del Estado) and the Superintendencies (Superintendencias) (Table 2.2).
Legislative branch
Other institutions with integrity-related responsibilities belong to other branches of the State. In the Legislative branch, the functions of the National Assembly include the supervision of the acts of the Executive, Electoral and Transparency and Social Control branches, and of the other organs of public power, as well as to request public officials the information it considers necessary.
Judicial branch
Within the Judicial branch, whose governing body is the Judicial Council (Consejo de la Judicatura), the Office of the Prosecutor General (Fiscalía General) directs pre-trial investigations and criminal proceedings, bringing and sustaining cases in front of judges. Within the Office, two Specialised Units deal with corruption-related crimes:
The Transparency and Anti-corruption Unit (Unidad de Transparencia y Lucha contra la Corrupción), which leads criminal investigation of acts of corruption and those that undermine transparency in public life.
The Public Administration Unit (Unidad de Administración Pública), which investigates crimes of embezzlement, bribery, illicit enrichment and extortion.
Electoral branch
Lastly, the Electoral branch (Función Electoral) has crucial responsibilities in relation to the transparency and integrity of election processes and political financing. Firstly, the National Electoral Council (Consejo Nacional Electoral), whose functions include organising, directing, overseeing and guaranteeing the transparency of the electoral processes; controlling the electoral propaganda and expenditure, including budgets submitted by political organisations and candidates; guaranteeing the transparency and legality of the internal electoral processes of political organisations. Appeals against the acts of the National Electoral Council are decided by the Electoral Disputes Tribunal (Tribunal Contencioso Electoral), which can also impose sanctions for non-compliance with regulations on financing, propaganda, electoral expenditure and, in general, for violations of electoral regulations.
Current institutional arrangements do not enable effective co-operation among institutions with responsibilities for integrity policies at the national level and across State levels
To ensure that the various actors that are part of an integrity system work towards shared goals, taking advantage of synergies and avoiding gaps or overlaps, it is essential to establish co-operation among them. This is the case both among actors at the central level, but also between levels of government. In this sense, the OECD Recommendation on Public Integrity calls countries to “promote 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[6]).
While some co-operation mechanisms related to integrity matters have been put in place in relation to enforcement or between institutions within the same branch of the state, Ecuador does not have either formal or informal institutional arrangements on public integrity bringing together relevant actors belonging to all the State’s branches in a comprehensive and systemic way.
Cross-branches initiatives
Co-ordination initiatives have been attempted in the past, but they did not manage to institutionalise themselves. The Anti-corruption Inter-institutional Roundtable (Mesa interinstitucional para combatir la corrupción), promoted by the President of the Republic in 2018, gathered representatives from all state’s branches but it did not lead to any specific initiatives. Earlier on, the Front for Transparency and the Fight against Corruption (Frente de Transparencia y Lucha contra la Corrupción), consisting of representatives from the executive branch and civil society, was established by Executive Decree No. 21 of June 5, 2017, to propose the President strategies and mechanisms for the prevention of corruption in the public and private sector, as well as policies and regulations for transparency and the fight against corruption. The Front produced a report with recommendations, and among those, it was stressed the need to strengthen co-ordination mechanisms through the creation of a National System of Co-ordination and Control (Box 2.1), However, these recommendations did not lead to any normative or institutional reforms, including with regards to the development of comprehensive and permanent co-ordination mechanisms.
The final report produced by the Front for Transparency and the Fight against Corruption noted that several of the institutional and implementation challenges in the fight against corruption could be addressed by strengthening co-ordination mechanisms, which emerged as one of the priorities. In that sense, it also proposed the constitution of a National Control System, bringing together all relevant institutions and consisting of two co-ordination groups, one related to prevention and one to enforcement.
In relation to the co-ordination needed on prevention, the Front stressed that the objective should be to harmonise regulations, to clarify competencies, to develop and improve control tools, to unify information, to enhance sectoral controls and to establish indicators and standards for managing and evaluating progress, as well as to focus on strategic sectors such as oil and mining activities.
Source: Front for Transparency and the Fight against Corruption (2017[14]), Proposals, https://www.cenae.org/uploads/8/2/7/0/82706952/versio%CC%81n_final_151017_propuestas_finales_ftlc.pdf (accessed on 12 April 2021).
Enforcement-related initiatives
With regards to enforcement, an Inter-Institutional Co-operation Agreement to strengthen the fight against corruption and asset recovery was signed in 2019 by the heads of the Judicial Council (Consejo de la Judicatura), the Anti-corruption Secretariat (Secretaría Anticorrupción), the Comptroller General Office (Contraloría General del Estado), the Office of the Prosecutor General (Fiscalía General del Estado), the Office of the Attorney General (Procuraduría General del Estado) and the Financial Analysis Unit (Unidad de Análisis Financiero, UAFE). This agreement established several inter-institutional co-operation mechanisms, including the exchange of information, the collaboration in investigations and recovery of assets, the development of joint research and innovation projects as well as the implementation of professional training programmes. As part of this agreement, in January 2021, an "Inter-Institutional Roundtable for the Fight against Corruption" (Mesa Interinstitucional de Lucha contra la Corrupción) was created by the Judicial Council together with the National Court of Justice (Corte Nacional de Justicia), the Office of the Public Defender (Defensoría Pública), the Ministry of Government (Ministerio de Gobierno), the police and the Financial Analysis Unit . The objective of the roundtable is to implement inter-institutional co-operation mechanisms enabling the co-ordination of actions that address critical bottleneck and structural problems in the exercise of the criminal action. Plus, the roundtable is intended to facilitate the analysis of specific cases and the establishment of suitable protocols for the correct development of the justice service. The Inter-institutional Anti-Corruption Roundtable will meet regularly once a month and extraordinarily when the situation warrants it, and will establish deadlines, processes, a work schedule and periodic follow-up of the results.
Another operational mechanism for co-ordination has been set up in 2019 to facilitate and obtaining timely and effective results in asset recovery processes through the establishment of the Asset Recovery Inter-Agency Liaison Group (Grupo de Enlaces Interinstitucionales para la Recuperación de Activos, GEIRA), which is composed of 11 institutions: the Office of the Prosecutor General, the Office of the Attorney General, the Citizen Participation Council, the Financial Analysis Unit, the Ministry of Foreign Affairs and Human Mobility (Ministerio de Relaciones Exteriores y Movilidad Humana), the Anti-Corruption Secretariat, the Internal Revenue Service (Servicio de Rentas Internas), the Public Real Estate Secretariat (Inmobiliar), the Strategic Intelligence Centre (Centro de Inteligencia Estratégica), the National Court of Justice and the Judicial Council.
Co-ordination mechanisms within state's branches
As for co-ordination mechanisms internal to the state´s branches, the Transparency and Social Control branch counts with a co-ordinating body, the Co-ordination Committee, composed by the head of each of the entities that comprise it, who each year elect the president of the branch from among its members. This committee has the responsibility, among others, to formulate public policies on transparency, social control, accountability, promotion of citizen participation, prevention and fight against corruption; co-ordinating the branch’s entities action plans and the formulation of the National Plan for the Prevention and Fight against Corruption; presenting to the National Assembly proposals for legal reforms within the scope of its competence. In turn, the implementation and operationalisation of the work, policies and plan of the Co-ordination Committee are carried out by the Technical Secretariat, whose Secretary is appointed by the Committee out of three candidates proposed by the president. While formally these institutional arrangements could promote co-ordination within the Transparency and Social Control branch, the information provided highlighted that the capacity of the Technical Secretariat is de facto extremely limited because of the number of staff working in it, amounting to three public officials next to the Secretary.
Within the Executive, the Anti-corruption Secretariat dissolved by Executive Decree No. 1065 of May 21, 2020, was meant to mainstreaming the fight against corruption within the Executive branch. While the General Secretariat of the Presidency of the Republic has been transferred the documents and archives and has been promoting integrity initiatives as part of its work on open government, the former mandate and competences of the Anti-corruption Secretariat have not been formally transferred to any institution. In fact, the focus of the Anti-corruption Secretariat’s activity was not on prevention but rather on the investigation of possible corruption cases (PADF; FCD; CSIS, 2020[15]) and this focus on investigations seems to have been one of the key reason that eventually led to its dissolution (El Comercio, 2020[16]). As a consequence, there is currently no co-ordinating entity on integrity and corruption prevention issues within the Executive, leading to a substantial institutional gap. This situation poses challenges to promote, co-ordinate and implement policies not only within public institutions and entities of the Executive (e.g. ministries, secretaries and state-owned enterprises), but also to co-ordinate actions with other state branches and society more broadly.
Co-ordination between the central and subnational entities
The lack of comprehensive co-operation mechanisms does not only concern the state’s branches but also the different sub-national levels of the public administration, which are the Decentralised Autonomous Governments (provinces, cantons, and rural parishes). Some meaningful initiatives had been taken in the past, but they were either bilateral or they did not involve all relevant bodies and branches.
The Government of the Municipality of the Metropolitan District of Quito – through its integrity body Quito Honesto – had signed an agreement with the Anti-Corruption Secretariat created on February 6, 2019, to co-ordinate integrity and anti-corruption policies, but eventually this could not have been fully implemented because of the dissolution of the latter with Executive Decree No. 1065 of May 21, 2020.
The Council for Citizen Participation and Social Control developed the Model for Transparent and Participatory Territories (Modelo de Territorios Transparentes y Participativos), which defined action plans, products, tools and instruments to be implemented by GADs based on their context and reality in six components:
institutional co-ordination (Council for Citizen Participation and Social Control of Ecuador, 2016[17]).
Similarly, no comprehensive initiatives have been taken to promote information exchanges or mutual learning between bodies with integrity or anti-corruption mandate within the GADs, neither by institutions at the state level nor by local co-ordination bodies such as the Consortium of provincial autonomous governments (Consorcio de Gobiernos Autónomos Provinciales del Ecuador, CONGOPE), the Association of Ecuadorian Municipalities (Asociación de Minicipalidades Ecuatorianas, AME) and the National Council of Rural Parish Governments of Ecuador (Consejo Nacional de Gobiernos Parroquiales Rurales del Ecuador, CONAGOPARE).
Ecuador could establish a National Integrity and Anti-corruption System to promote strategic co-operation and dialogue among the five state branches, between levels of administration and with the contribution of civil society, academia and private sector
According to the OECD experience, countries have been adopting various mechanisms to ensure co-operation on public integrity:
Formal mechanisms to ensure coherent decision making and enable support, communication and information sharing.
Informal mechanisms to enable horizontal exchange and support.
Mechanisms tailored to national and sub-national levels in line with the country’s governance framework (OECD, 2020[12]).
While there is no single model to address the co-operation challenges, some lessons which have been observed in the OECD work with countries in Latin America (Table 2.3) are relevant for the Ecuadorian context, namely:
It is essential to create spaces for dialogue, reflection and co-operation between the branches and autonomous bodies which, while respecting their autonomy, enable taking advantage of common efforts to implement coherent public integrity agendas in all public domains, with a view to increasing its credibility and trust. While entities outside the executive branch often have the autonomy to implement their own integrity policies, it is vital to seek co-operation mechanisms that allow for the transfer of knowledge and support for their implementation. Some countries have multi-stakeholder co-ordination bodies, in which executive or control entities usually participate although their membership varies. In other cases, as in Colombia, Mexico and Peru, representatives of the judiciary participate as well. Only the co-ordination bodies in Colombia and Peru also include the participation of the legislative branch.
For formal mechanisms to work, the following elements are necessary:
Leadership (will): particularly from the highest authority within the mechanism.
Management: they should set visible tasks, commitments and targets leading to high impact products and have operational or implementing units that are responsible for implementing and following up on the commitments that emerge.
Capacity: Implementing units need authority to guide and follow up co-ordination, this may include, for example, drafting legislation and policies, leading the development of a National Integrity and Anti-Corruption Strategy, and/or monitoring and evaluating integrity policies.
It may be difficult to have a single co-ordination mechanism, or to include all relevant actors in it. This could be solved by establishing alternate, but integrated co-ordination spaces that feed into a core group (inter-institutional working groups or commissions with rotating leadership, for example).
Although in most of the experiences there is no direct participation of civil society in the co-ordinating units, there is a growing trend to increase the formal involvement of civil society and the participation of non-governmental actors in the integrity system. For example, in Colombia and Mexico there are particular mechanisms for including civil society representation. On the one hand, in Colombia, the 2011 Anti-Corruption Statute created the National Citizen Commission for the Fight against Corruption (Comisión Nacional Ciudadana para la Lucha Contra la Corrupción, CNCLCC), which is the body representing Colombian citizens to evaluate and improve policies that promote ethical conduct and curb corruption in the public and private sectors. On the other hand, in Mexico, the National Anti-Corruption System (Sistema Nacional Anticorrupción) established in 2015 has among its governing bodies a Citizen Participation Committee (Comites de participación Ciudadana), which aims to be the body that links with social and academic organisations related to the matters of the National System. In Peru, the co-ordinating body on integrity and anti-corruption issues, the High-level Commission against Corruption (Comisión de Alto Nivel Anticorrupción, CAN), is also made up of non-governmental actors, including representatives of private business entities, trade union organisations, universities, the media and religious institutions (OECD, 2019[1]).
Considering the institutional set-up of the country and the lessons learnt from countries in the LAC region, Ecuador could consider establishing a National Integrity and Anti-corruption System to address the weak co-operation among all actors with a public integrity and anti-corruption mandate. This system should bring together relevant institutions from all branches of the State and levels of the public administration and have the key mission to ensure continuous dialogue and define co-operation initiatives with due consideration of the role and responsibilities assigned to each of them by the Constitution. Such a system would be coherent with a similar proposal made by an expert group in the past (Box 2.1) and would make use of a model of co-operation which is successfully used in other policy areas such as violence against women and public procurement (Box 2.2).
The Comprehensive National System to Prevent and Eradicate Violence against Women (Sistema Nacional Integral para Prevenir y Erradicar la Violencia contra las Mujeres) is defined as the organised and co-ordinated group of institutions, norms, policies, plans, programmes, mechanisms and activities aimed at preventing and eradicating violence against women, through prevention, care, protection and comprehensive reparation of the rights of victims.
The law establishing the system defines its scope, which is to prevent and eradicate violence against women through the design, formulation, execution, supervision, monitoring and evaluation of norms, policies, programmes, mechanisms and actions, in all instances and at all levels of government, in an articulated and co-ordinated manner. Furthermore, it defines the governing body, which is the Secretariat of Human Rights. The following members have the obligation to articulate and co-ordinate among themselves and with other relevant actors all related actions:
Council for Regulation and Development of Information and Communication;
One representative elected by the assembly of each associative body of the Decentralised Autonomous Governments.
The Organic Law of the National Public Procurement System (Ley Orgánica del Sistema Nacional de Contratación Pública) establishes that the National Public Procurement Service (Servicio Nacional de Contratación Pública) is the governing body of the National Public Procurement System (Sistema Nacional de Contratación).
The Board of the National Public Procurement Service – which is responsible for planning, prioritising, proposing and issuing the national public procurement policy, establishing the public procurement sector rules or policies for public entities; and adopting the regulations for the organisation and operation of the National Public Procurement Service – consists of:
The Minister responsible for Production, Employment and Competitiveness
The Mayor appointed by the General Assembly of the Association of Municipalities of Ecuador
The Prefect appointed by the Consortium of Provincial Councils of Ecuador
The highest authority of the body responsible for economic inclusion
The General Director of the National Public Procurement Service, who acts as Secretary of the Board of Directors but cannot express vote.
Source: (National Assembly of Ecuador, 2018[18]); (National Assembly of Ecuador, 2008[19]).
Ecuador could take the opportunity to include the development of such a National Integrity and Anti-corruption System as one of the priority objectives on public integrity of the National Development Plan 2021-2025, which could also set the foundations on which to build a strategic approach and vision for public integrity. Learning from past attempts to establish co-operation mechanisms but also considering the experience collected during the fact-finding mission, this National Integrity and Anti-corruption System should build on a dialogue phase among all relevant actors, which would ensure legitimacy of the process as well as ownership and commitment of all institutions. This dialogue should also include spaces for civil society and the private sector to share ideas, inputs and priorities in shaping the system. As highlighted by interviews during the fact-finding mission, it is also important that the National Integrity and Anti-corruption System is established in a law – rather than an executive decree – and explicitly mentions the duty to co-operate of each participating institution in order to ensure compliance and the sustainability of the system.
With regards to the governance of the National Integrity and Anti-corruption System, it is recommended that the President of the Republic, as head of the State, (Figure 2.1) leads and presides it. This would show the highest level of commitment to integrity and anti-corruption issues and ensure proactive institutional co-operation among all five branches of the State, while respecting their constitutional roles and functions. Such institutional arrangement would also take into account the OECD experience, as often the co-ordinating role of such formalised arrangements requires the highest degree of influence, authority and leadership and is located at a visible and central place to signal its importance, such as in the president’s office, or under the council of ministers. Next to the President, this system should include all relevant institutions from the five State branches, as well as representatives from Regional Decentralised Authorities in order to ensure coherency and leverage synergies between respective policies and initiatives (Box 2.3).
The National Assembly of Ecuador (NA) has set a website (www.asambleanacional.gob.ec/es/leyes-aprobadas) to strengthen legislative transparency and oversight of processes carried out by the NA, which is one of the objectives of its Institutional Strategic Plan 2019 - 2021. The National Assembly is also implementing an Anti-Bribery Management System based on the 37001 standard of the International Organization for Standardization (ISO) and as part of this process it has adopted an Integrity Manual that defines a strategy based on the promotion of integrity and transparency aiming at improving management and institutional reputation. In August 2019, the Legislative Administration Council (Consejo de Administración Legislativa), through Resolution CAL-2019-2021-083, amended the Organic Functional Regulations of the National Assembly of Ecuador to create the General Co-ordination of Integrity and Prevention.
The Judicial Council, through its Judicial Service School, has developed and disseminated educational tools for justice operators with the aim of strengthening judicial integrity and preventing corruption in the judicial system, in accordance with the requirements of article 11 of the UNCAC and the Bangalore Principles of Judicial Conduct. To further implement these commitments, it joined the Global Judicial Integrity Network on 14 May 2020.
The Municipality of the Metropolitan District of Quito (MDMQ) is working on an anti-corruption plan, through the metropolitan Commission for the Fight against Corruption (Quito Honesto), an entity in charge, according to its competences, of preventing, controlling and investigating possible acts of corruption. Furthermore, examples of initiatives that have been developed as mechanisms to mitigate corruption are:
Training and Education Plan developed jointly with the Municipal Training Institute (ICAM) aiming to ensure understanding of the responsibilities and ethical rules governing the activities of municipal public officials as well as strengthening values and principles to promote an institutional ethical culture in the fulfilment of their functions.
Review of control mechanisms and strategies adopted by municipal entities, which are classified according to the products and services they deliver.
Creation of a link in all portals of the MDMQ so that citizens can file complaints about possible cases of corruption within municipal entities.
Source: Answers to OECD questionnaire; (UNDOC, 2020[20]).
The law creating the National Integrity and Anti-corruption System should identify roles and a set of functions which are coherent with the constitutional mandates and the priorities, as discussed and defined during the dialogue phase. Considering the previously-identified weaknesses, it should as a minimum:
Ensure the participation and contribution of all actors in the design of the National Integrity and Anti-corruption Strategy as well as of national integrity and anti-corruption policies.
Co-ordinate the implementation of integrity and anti-corruption policies, and in particular the National Integrity and Anti-corruption Strategy.
Monitor and communicate activities of all actors which are part of the System and their progress in the implementation of integrity and anti-corruption policies, in particular of the National Integrity and Anti-corruption Strategy.
Develop studies building on data and knowledge of various institutions to identify fraud and corruption risk areas, trends, priorities for possible co-ordinated action.
Generate communication and awareness campaigns about public integrity and the National Integrity and Anti-corruption System.
As for the operational functioning, the System should gather the heads of the participating institutions in annual plenary meetings to report on the activities, while close advisors of the head of the institution should be appointed to co-ordinate the work at more technical level.
Civil society organisations should not only be part of the dialogue phase leading up to the National Integrity and Anti-corruption System, but also participate in the system itself, at least with the possibility to be invited to meetings, to bring proposals, and to monitor the activities of the system. For this purpose, Ecuador could benefit from the input of the organisations that have participated in the development of the open government plan (Box 2.5) as well as other co-ordination initiatives from civil society and the private sector (Table 2.4).
Ecuador could embrace a strategic approach to public integrity
A public integrity strategy is essential for supporting and sustaining a coherent and comprehensive integrity system as well as the actions of the institutions that form part of it. This does not only include the document itself, but also the process for its development, which is perhaps as important as the resulting strategy. Thanks to an inclusive and participative process and a solid evidence base, a strategy can be legitimised, identify the most impactful risks and agree on meaningful strategic objectives for the country. Strategies are also a way of demonstrating commitment but can also erode trust and credibility of public authorities if they do not lead to actions or their progress is not subject to monitoring and evaluation (OECD, 2020[12]). In line with this approach, the OECD Recommendation on Public Integrity states that adherents should “develop a strategic approach for the public sector that is based on evidence and aimed at mitigating public integrity risks, in particular through:
Setting strategic objectives and priorities for the public integrity system based on a risk-based approach to violations of public integrity standards, taking into account factors that contribute to effective public integrity policies.
Developing benchmarks and indicators and gathering credible and relevant data on the level of implementation, performance and overall effectiveness of the public integrity system” (OECD, 2017[6]).
While Ecuador does have some strategic objectives defined in the National Development Plan 2017-2021 and the National Public Integrity and Anti-corruption Plan 2019-2023, both planning instruments have not been able to generate the expected impact.
The National Development Plan 2017-2021
Ecuador has declared the fight against corruption a national priority and included integrity-related objectives in its National Development Plan for 2017-2021 “Toda una Vida” (Plan Nacional de Desarrollo 2017 – 2021 Toda una Vida). However, this has not generated visible results. The National Plan for Good Living 2017-2021 (Plan Nacional para el Buen Vivir 2017 – 2021) established six actions aimed at strengthening transparency and the fight against corruption in the public and private sectors, as part of objective no. 8 on “Promoting transparency and co-responsibility for a new social ethic” (Promover la transparencia y la corresponsabilidad para una nueva ética social) that was developed also based on the proposals of the Front for Transparency and the Fight against Corruption:
Promote a new social ethic, based on solidarity, co-responsibility, equity and social justice, as principles and values that guide the behaviour and actions of society and its various sectors.
Strengthen the transparency of public policies and the fight against corruption, with better access to high-quality public information, optimising the accountability policies and promoting participation and social control.
Promote measures for the prevention of conflicts of interest and opacity in State contracts.
Combat impunity by strengthening inter-institutional co-ordination and the effectiveness of processes for the detection, investigation, trial, sanction and execution of sentences.
Promote an international ethical pact to achieve tax justice, the elimination of tax havens, and the fight against tax evasion and avoidance.
Strengthen transparency in the private and popular sector, promoting the adoption of integrity tools that strengthen the principles of co-operativism and corporate governance, discouraging the commission of acts that undermine national development objectives.
To support the implementation and the monitoring of the Plan, a Strategic Cabinet (Gabinete Estratégico) and four Sectoral Cabinets (Gabinetes Sectoriales), were established. However, information available online and collected in the interviews manifested the lack of any continuous monitoring of the Plan, raising concerns over the rate of implementation and the results achieved by public entities in relation to those objectives, which touched upon some key issues as inter-institutional co-ordination and conflict of interest.
The National Public Integrity and Anti-corruption Plan 2019-2023
The Transparency and Social Control branch developed and adopted the National Public Integrity and Anti-corruption Plan for 2019-2023 (Plan Nacional de Integridad Pública y Lucha contra la Corrupción 2019-2023) (Transparency and Social Control Function of Ecuador, 2019[21]) based on the analysis of the national context as well as data on emblematic corruption cases and perception of corrupt practices among citizens. The Plan identifies key causes of corruption and actions to address them, aiming to achieve the following strategic objectives:
promote integrity in the public and private management of public resources
strengthen citizen action in all its organisational forms so that it generates impact in public life
strengthen public and private inter-institutional co-ordination and co-operation mechanisms that develop preventive and anti-corruption initiatives and actions.
Each strategic objective has an indicator and consists of different strategies, which in turn correspond to a project, various activities and a set of responsible entities.
The Plan builds on an analytical framework, which includes reference to the OECD definition of public integrity (OECD, 2017[6]), and defines a matrix with objectives and goals as well as a list of projects, activities and responsible entities. However, the document and the interviews during the fact-finding mission evidenced that the involvement of public entities outside the Transparency and Social Control branch as well as of representatives from civil society was very limited in the development process.
Furthermore, the matrix makes only minor reference to entities from other branches, whereas many key actions such as the development of a Code of Conduct for the public sector and of risk management mechanisms to prevent corruption and unethical conduct, the implementation of a training programme for public officials and education curricula for students, as well as the strengthening of inter-institutional co-ordination mechanisms cannot be fully implemented without the involvement and co-responsibility of other public entities, especially from the Executive branch (e.g. Presidency of the Republic, Ministry of Labour, and Ministry of Education). The inward-looking perspective of the Plan may explain the limited advancement in its implementation, which interviewees also attributed to the difficulties caused by the COVID-19 pandemic and to the limited resources and capacity of the body in charge of promoting and co-ordinating its implementation, which is the Technical Secretariat of the Transparency and Social Control branch’s Co-ordination Committee. Furthermore, interviewees pointed out the lack of continuous engagement and commitment among the members of the Transparency and Social Control branch itself. Regardless of the specific causes, the Plan demonstrated to have had very limited impact so far and most actors from the public sector, civil society and private sector interviewed during the fact-finding mission had little or no awareness of the existence of the Plan and of its actions.
The National Development Plan 2021-2025 could set the roadmap for the progressive and participative development of a National Integrity and Anti-corruption Strategy
Although efforts have been made to define integrity-related objectives and activities, they do not provide relevant institutions and the public with a clear and evidence-based strategy addressing risk areas and priorities. As a result, representatives from various institutions interviewed during the fact-finding mission indicated the lack of a national “vision” on integrity and anti-corruption matters as one of the most significant challenges of the country. Indeed, this is considered one of the main causes of the fragmented and incoherent initiatives of the last year, which in turn contributed to the low levels of public confidence in the anti-corruption efforts and government action more broadly.
This challenge is closely linked with the weakness related to co-operation, which is a pre-requisite in so far as a strategy needs the contribution and participation of all relevant entities across different branches, whose acceptance and active engagement is critical for the strategy to succeed. At the same time, the implementation process of a strategy can also further reinforce and promote co-operation and synergies when it comes to assigning the shared responsibility to implement objectives to two or more relevant actors, or to an actor in close co-ordination with other ones.
Ecuador should take advantage of the National Development Plan 2021-2025 not only to set the creation of a National Integrity and Anti-corruption System as an objective, but also to define a roadmap with progressive steps and objectives aiming and leading towards a National Integrity and Anti-corruption Strategy. While reflecting the priorities of the President of the Republic in relation to public integrity, such a strategy should aim at going beyond the government in turn and contribute to build a vision for the country (Figure 2.2).
Source: Elaborated by the OECD based on the recommendations.
Including this objective on the National Integrity and Anti-corruption Strategy - as well as the one creating the National Integrity and Anti-corruption System - into the National Development Plan has various key advantages. First, the National Development Plan has the highest constitutional legitimacy and status since national development planning is one of the essential constitutional duties of the State (Article 3 of the Constitution) and because Article 280 of the Constitution establishes that it is the strategic document that informs:
public policies, programmes and projects, including the integrity and anti-corruption ones
and the investment and allocation of public resources (Box 2.4).
Second, the National Development Plan is approved and monitored by the National Planning Council (Consejo Nacional de Planificación), which is a broad participative mechanism presided by the President of the Republic and including representatives from subnational levels of government. The work of the National Planning Council, including the development of the National Development Plan is supported by the Technical Secretariat “Planifica Ecuador” (Secretaría Técnica Planifica Ecuador), an entity part of the Presidency of the Republic which succeeded to an independent, Ministry-level entity, the National Secretariat for Planning and Development (Secretaría Nacional de Planificación y Desarrollo, SENPLADES), following Executive Decree No. 732 of May 13, 2019.
Third, the observance of the National Development Plan is mandatory for all institutions in the public sector, which would also promote and ensure the engagement of all branches of the State.
The decentralised national participatory planning system organises development planning. The system is made up of a National Planning Council, which integrates the different levels of government, with citizen participation, and has a technical secretariat, which co-ordinates it. This council has the objective of dictating the guidelines and policies that orient the system and approving the National Development Plan, and is presided over by the President of the Republic.
The National Development Plan connects short and medium-term public policies with a long-term vision in line with the Constitution. The Plan informs any public action, programme and project, the public budget and debts, international co-operation, state-owned enterprises and social security. At the same time, plans of decentralised autonomous governments should also be defined in the framework of the National Development Plan. This shall also incorporate the long-term national public policy policies that have been established through popular consultation.
The National Development Plan is approved by the National Planning Council, which is the body in charge of the decentralised national participatory planning system (Sistema nacional descentralizado de planificación participativa). Such Council is presided by the President of the Republic, has a technical secretariat (Technical Secretariat “Planifica Ecuador”, Secretaría Técnica Planifica Ecuador), includes all levels of government and provides for citizens’ participation mechanisms.
The National Development Plan lasts for a period of four years based on the government programme of the President-elect, and in consideration of the general objectives of the plans of the other functions of the State and the development plans of the Decentralised Autonomous Governments, within the scope of their competencies. The development of the Plan must ensure citizens participation.
Source: National Assembly of Ecuador (2010[22]), Planning and Public Finance Organic Code, https://www.gob.ec/sites/default/files/regulations/2020-06/C%C3%93DIGO_ORG%C3%81NICO_DE_PLANIFICACI%C3%93N_Y_FINANZAS%20-%20diciembre%202019.pdf (accessed on 12 April 2021).
In view of taking advantage of already existing initiatives taken by Ecuador and considering the 4-year validity of the National Development Plan, the roadmap to be laid down could aim at developing a National Integrity and Anti-corruption Strategy in two sequenced steps (Figure 2.3):
As the first step, starting in 2022 and following the creation of the National Integrity and Anti-corruption System recommended above, the National Development Plan could give the mandate to this System to co-ordinate the development of an Action Plan to implement some key priority actions of the National Public Integrity and Anti-corruption Plan 2019-2023 adopted by the Transparency and Social Control Function. In spite of the limited results and involvement of relevant actors, the National Public Integrity and Anti-corruption Plan 2019-2023 identifies some areas of intervention where weakness have also been identified by the present report, such as on code of ethics, risk-management, training. Plus, using the existing plan would send a positive message to citizens, civil society and the private sector showing an effort to ensure the continuity of integrity and anti-corruption policies. However, the Action Plan should focus on a set of priorities, rely on the support of National Integrity and Anti-corruption System to ensure a broader involvement of all branches of the State in its design and implementation, as well as receive feedback and comments from civil society. Such an action plan should focus on addressing high-risk areas, realistic objectives, and also achieving some visible results to regain trust of the public. In this sense, the OECD experience suggests laying emphasis on the communication of the action plan, which should be kept simple and enable readers from outside the public administration to understand actions, responsibilities and expected results.
As a second step, starting in 2022, the National Development Plan could envisage the development of a new National Public Integrity and Anti-corruption Strategy for the 2023-2026 term, making it a state strategy going beyond the term of the government mandate (2021-2025) and thus contributing to building continuity over political changes. In turn, the Strategy could be implemented through two Action Plans covering a two-year period each (2023-2024; 2025-2026). Based on the experience of OECD countries, the National Public Integrity and Anti-corruption Strategy could consider the following methodological steps of the process:
Problem analysis: risk identification, analysis and mitigation.
Strategy design: prioritising the objectives, policy consultation and co-ordination.
Development of indicators with baselines, milestones and targets.
Drafting of the action plan, distributing responsibilities and costing activities.
Implementation, monitoring, evaluation, and communication of the results of monitoring and evaluation, including evaluation prior to implementation (OECD, 2020[12]):
Among the inputs to consider throughout this process, the Strategy and Action Plans could also build on the analysis and recommendations from a potential OECD Integrity Review of Ecuador.
Source: Elaborated by the OECD based on the recommendations.
Given the multiplicity of institutions with integrity-related responsibilities in Ecuador, the development process of this National Public Integrity and Anti-corruption Strategy should be supported by adequate institutional arrangements to ensure co-ordination, participation and contribution of all relevant actors in its design and implementation. For this purpose, Ecuador would ideally assign the co-ordination of this process to the National Integrity and Anti-corruption System as recommended above. This would be in line with the practice of some OECD countries that delegated the responsibility for developing a strategy to a small committee composed of representatives from key relevant bodies in each branch of the State and from subnational entities. This drafting committee is ideally chaired by an individual with recognised stature, expertise, legitimacy and political influence to act as an effective “champion” for the drafting body, and ultimately for the strategy itself (UNODC, 2015[23]). For example, the UK Anti-corruption Strategy was drafted by the Joint Anti-Corruption Unit (JACU) in the Home Office, and the anti-corruption strategy in Finland was developed by a cross-government group that included police, local government and CSOs (Pyman, Eastwood and Elliott, 2017[24]).
To ensure the quality of the Strategy and Action Plans, Ecuador could also consider building capacities amongst the members of the National Integrity and Anti-corruption System in relation to strategic and operational planning with the technical support and methodologies of the Technical Secretariat “Planifica Ecuador”. This would help building a common understanding of the challenges, priorities and key elements of integrity and anti-corruption policies, following international conventions and standards, such as the OECD Recommendation on Public Integrity.
The involvement of organisations from civil society and the private sector, which in Ecuador are active on a wide range of integrity-related issues, should also be ensured since it would help increase the legitimacy of the strategy and be essential to build a common vision (UNODC, 2015[23]). Such a common understanding is very much needed according to the interviews conducted during the fact-finding mission. In this sense, Ecuador could ensure a participative and inclusive methodology taking inspiration from the co-creation methodology used for the first Open Government Action Plan which was considered a successfully inclusive practice by many actors interviewed during the fact-finding mission (Box 2.5), as well as from methodologies used in other countries in the LAC region to develop their integrity and anti-corruption strategies (Box 2.6). In line with the model proposed for the National Integrity and Anti-corruption System, civil society organisations, private sector, the media, academics and the public, in general, could also be involved in the monitoring and evaluation of the strategy (UNDP, 2014[25]). Furthermore, the document should also be discussed by the broader population through a public consultation process, making available to the public all supporting documentation and clarifying how comments provided by the public and organisations have been considered in the final version of the strategy, including explanations for those comments not taken on board.
The process of co-creation of Ecuador's first Open Government Action Plan started with the establishment of the Core Group, which is the space designed for the co-ordination, support and monitoring of the results of the co-creation process and the implementation of the Open Government Action Plan. Such space aimed to promote participation and co-operation between various actors as well as debate, consensus, balance and a plurality of voices. The members of the Core Group - institutions and entities from the academia, civil society and public sector - were selected according to their background, responsibilities and experience, and hold regular meetings to promote open government actions in the country. From the side of the public sector, the General Secretariat of the Presidency of the Republic is the Ministerial contact point responsible for co-ordinating the Open Government Partnership´s activities at the national level and one of the public sector actors that contributed to the co-creation of the country’s Open Government Action Plan by being part of the Open Government Core Group.
The methodology for the development of the Open Government Action Plan was based on co-creation at all stages in consideration of the key role of participation and collaboration in the design and implementation of responses to fundamental problems of society. Based on that, no decision related to the Plan could be taken exclusively by a governmental authority or by any of the members of the Core Group.
The methodology of the co-creation model aimed to guarantee three levels of participation: the general public; the Open Government Working Group and the Core Group. Plus, the process benefitted from learning experiences from other countries such as Argentina, Uruguay and Costa Rica.
As for its steps, the methodology consisted of the following ones:
1. Reception of ideas and proposals from citizens, civil society organisations, academia, government, and the private sector through the official Open Government website of Ecuador as well as territorial co-creation roundtables.
3. Evaluation of proposals according to their feasibility and relevance.
4. Selection of proposals with the highest potential to be included in the Open Government Action Plan, both in terms of their feasibility of implementation and their relevance or impact for Ecuador.
5. Validation by the highest authorities of the represented entities to ensure the feasibility of the proposals’ implementation. After validation and confirmation, they become commitments of the Action Plan.
6. Creating accountability through a follow-up report in Ecuador’s Open Government website on the proposal’s selection as well as through an online communication campaign.
7. Formal adoption of the Action Plan through public presentation in Ecuador and to the Open Government Partnership.
Source: Open Government Ecuador (2019[26]), Open Government Action Plan of Ecuador 2019-2022, https://www.opengovpartnership.org/wp-content/uploads/2020/01/Ecuador_Action-Plan_2019-2021.pdf (accessed on 12 April 2021).
Anti-corruption National Plan of Argentina 2019-2023
An open public consultation was promoted by the Anti-corruption Office, through the portal of the Secretariat of Government of Modernisation. As a result of this process, several proposals were received related to institutional strengthening, citizen participation, integrity in the private sector, and school education on ethics.
Anti-corruption National Policy of Mexico (2020)
The public consultation process consisted of three pillars. The first was an advisory council, which was conceived as a space for high-level dialogue, in which representatives of civil society organisations, academia, the private sector, public institutions and international organisations participated, contributing studies, reports and research that were considered for the development of the policy proposal. The second pillar was the online citizen consultation through 64 interviews with different actors asking ask citizens and specialists about their perceptions of the causes, effects and possible solutions to the problem of corruption. The third pillar of the citizen consultation was implemented through eight regional forums to gather opinions and proposals from academics, civil society organisations and public officials from the country's state entities. The information gathered in this phase of the consultation provided a regional and local perspective on the phenomenon of corruption.
National Integrity, Transparency and Antic-corruption Plan of Paraguay 2021-2025
A broad participatory process was carried out to gather ideas from a large and varied group of sectors and individuals linked to the public service (120 authorities and civil servants from 81 public institutions) regarding possible barriers and facilitators to implement the National Plan. This included nine workshops and consultations with representatives of different sectors of civil society. Three of the workshops were held with officials from the three branches of government, including officials from the Comptroller General's Office, the Office of the Prosecutor General, the Central Bank of Paraguay and Itaipú Binacional. Three other meetings were held with government officials from Municipalities and Departments, and the three more with officials in charge of the Transparency and Anti-Corruption Units (Unidad de Transparencia y Anticorrupción, UTA) of public institutions. In general, the results of the consultative process aligned with the previous findings and the challenges identified in existing studies on the degree of development of Paraguay's institutional integrity system show.
National Integrity and Anti-corruption Policy of Peru (2017)
The development of the "National Integrity and Anti-Corruption Policy" was performed through a participatory process carried out by the High Level Anti-Corruption Commission (Comisión De Alto Nivel Anticorrupción, CAN) through its General Co-ordination, through the systematisation, analysis, design and prioritisation of the comments, contributions and suggestions obtained from various public entities and the private sector.
A technical workshop that allowed for the analysis and discussion of the content of the future national policy.
A discussion of the first draft of the national policy with the contact points of the public and private entities represented in the High Level Anti-Corruption Commission and the representatives of all the ministries of the Executive branch, also through a virtual platform in place for the CAN contact points.
Reception and contribution from the National Assembly of Regional Governments (Asamblea Nacional de Gobiernos Regionales) and the Association of Municipalities of Peru (Asociación de Municipalidades del Perú).
Technical advice provided by the National Centre for Strategic Planning (CEPLAN), the Co-ordination Secretariat (Secretaria de Coordinación) and the Public Management Secretariat (Secretaría de Gestión Pública), so that the content and structure aligned to the Strategic Plan for National Development (Plan Estratégico de Desarrollo Nacional).
Source: (Government of Argentina, 2019[27]); (Anti-corruption System of Mexico, 2020[28]); (Government of Paraguay, 2020[29]); (Government of Peru, 2017[30]).
After the adoption of the Integrity and Anti-corruption Strategy for the 2023-2026 term, Ecuador could discuss and develop a long-term Integrity and Anti-corruption state policy linked to the Constitution and the Sustainable Development Goals
The experience, processes, participative methodologies and strategic approach for developing the National Integrity and Anti-corruption Strategy for the 2023-2026 term could lay the basis for a further step to consolidate and institutionalise a national integrity and anti-corruption vision in Ecuador. Once the Integrity and Anti-corruption Strategy is adopted, Ecuador could consider the development of a long-term state policy (”Política de largo plazo”) on integrity and anti-corruption, which is a strategic planning tool provided for in its legal framework informing the priorities of all following National Development Plans (Technical Secretariat Planifica Ecuador, 2019[31]). This policy would allow to further address the challenges of institutionalisation, continuity and sustainability of integrity and anti-corruption policies, which have been raised as one of the priorities during the fact-finding interviews.
The Technical Standard of the National Decentralised System for Participative Planning (Norma Tecnica del Sistema Nacional Descentralizado de Planificación Participativa) defines these long-term policies as state policies established based on a broad national agreement and the development of a common project for the future, based on constitutional duties and long-term international commitments. Accordingly, the long-term Integrity and Anti-corruption state policy could use the participative methodology developed for the strategy and envision its ratification through a popular referendum, which would increase its democratic legitimacy and demonstrate the state’s commitment and engagement. Content-wise, the policy should contribute to fulfil one of Ecuador’s key constitutional duties, which is to guarantee its inhabitants the right to a culture of peace, to integral security and to live in a democratic society free of corruption (Article 3 of the Constitution of Ecuador). It would also contribute to the implementation of internal commitments such as the United Nations Convention against Corruption and the Sustainable Development Goal no. 16 on Peace, Justice and Strong Institutions which is part of the 2030 for Sustainable Agenda and includes the target to substantially reduce corruption and bribery in all their forms and to develop effective, accountable and transparent institutions at all levels. The legal framework defines the structure and process for the adoption of such a long-term policy and sets its validity for a period of at least 20 years (Box 2.7). In developing its long-term policy, Ecuador could consider the national policy adopted by Peru in 2017, which sets the integrity and anti-corruption vision of the country and informs its plans and efforts (Box 2.8).
The Technical Secretariat of the National Decentralised System of Participatory Planning (Secretaría Técnica del Sistema Nacional Descentralizado de Planificación Participativa) co-ordinates the development of the long-term policies proposals for their validation by the National Planning Council (Consejo Nacional de planificación). The process of formulation and/or updating of the long-term policies includes co-ordination with the entities of the State and civil society through citizen participation bodies.
The long-term policies shall contain at least:
National Long-Term Development Goals: These are the national goals agreed upon in participatory processes that reflect the structural change desired to achieve development within the framework of a common project for the future. Given that future challenges are diverse, the identification of national development objectives necessarily implies a prioritisation exercise.
Long-term National Goals: Establishes the quantitative levels to be achieved in a given period of time. They must contain expressions with terms associated with quantity and time and are constructed with impact indicators that show a change or discontinuity with respect to the initial situation. Long-term goals must contribute to the achievement of the National Development Goals and are the basis for monitoring and evaluation.
Long-term Territorial Model: Territorial expression of the Long-term Policies and their long-term goals and targets. It contains territorial guidelines that are orientations for the application of long-term policies in the territory.
Source: Technical Secretariat Planifica Ecuador (2019[31]), Technical Standard of the National System for Participative Planning, https://www.planificacion.gob.ec/wp-content/uploads/downloads/2019/12/Norma_Tecnica_del_Sistema_Nacional_de_Planificacion_Participativa.pdf (accessed on 27 March 2021).
The National Integrity and Anti-corruption Policy (Política Nacional de Integridad y Lucha contra la Corrupción), adopted with Decree Nº 092-2017-PCM of September 14, 2017, is a state policy that encompasses all levels of government and public actors, constituting a guide and orientation for the private sector as well. The policy builds on the mandate of the Constitution and of other national strategic and development policies (Acuerdo Nacional; Plan Bicentenario: el Perú hacia el 2021; Política Nacional de Modernización de la Gestión Pública). Furthermore, the policy is linked to the implementation of the SDGs and other international instruments such as the UNCAC and the OAS Inter-American Convention against Corruption. It also confirms Peru´s commitment to participate in other international fora such as the OECD, the APEC, the CELAC and the Summit of Americas.
The development of the policy was co-ordinated by the High-level Commission against Corruption (CAN) – the national co-ordination mechanism on integrity and anti-corruption issues - and provides for a comprehensive diagnostic of corruption and its causes in Peru and defines three themes of priority actions: preventive capacity, risk identification and management, and enforcing capacity. Each of these themes consists of specific objectives with related responsibilities and guidelines. Furthermore, the policy defines minimum standards on various issues such as culture of integrity, conflict of interest and electoral systems, for example.
Source: Government of Peru (2017[30]), National Integrity and Anti-corruption Policy, https://cdn.www.gob.pe/uploads/document/file/45986/Politica-Nacional-de-Integridad-y-Lucha-contra-la-Corrupcio%CC%81n.pdf (accessed on 12 April 2021).