4. Proposals for action to implement integrity systems in the Peruvian regions

Abstract

This Chapter provides an overview of the actions proposed in the report to implement integrity systems at the regional level in Peru. The overview is organised in two tables. One table includes the recommendations aimed at enhancing integrity in regional governments, in particular through the integrity function. The second table reports the recommendations related to the strengthening of the Regional Anticorruption Commissions. For each recommendation, the tables clarify the responsible actors(s) and, when relevant, those with whom co-ordination should be established.

    

The OECD Recommendation of the Council on Public Integrity (OECD, 2017[1]) underlines the need to establish a risk-based integrity system at all levels of government to strengthen integrity and prevent corruption effectively. While co-ordination is key, it is also vital that the integrity system reflects specific integrity challenges and opportunities. In principle, the creation of the CRAs and the establishment of the integrity function in the regional government have the potential to address corruption risks and integrity challenges at the regional level in co-ordination with the national level, However, further efforts are necessary to strengthen the CRAs and institutionalise the integrity function to ultimately effectively promote integrity and fight corruption at the regional level.

Table 4.1. Overview of the key recommendations respective to the integrity function and integrity in the regional government more broadly
Recommendation	Actor in charge
Strengthening a strategic approach to integrity based on evidence, the regional governments, in co-ordination with the SIP, could: 1. identify priorities based on a diagnostic tool assessing the internal strengths and weaknesses and external opportunities and threats of the regional government (also known as SWOT-analysis); and 2. build on the diagnostic, select the priorities for strengthening integrity, determine the entity or unit responsible for defining a plan to implement such priorities and develop indicators to monitor advances in that area.	Regional governments in collaboration with SIP
Responding to the specific challenges and opportunities in every region, an incremental approach for the integrity function could be developed. Regions would be categorised according to: size, which may also serve as proxy for the level of institutional capacities, available resources and support needed exogenous or environmental integrity risk levels and typologies of each region. The tasks fulfiled by the integrity function should as a minimum be related to risk assessment, integrity policy and monitoring of the integrity model’s implementation.	SIP (developing incremental approach in co-ordination with regional governments)
To mainstream integrity effectively, the integrity function in regional governments should articulate and contribute to the implementation of the various components of the integrity model by performing the roles of: Leadership in: Entity strategy Monitoring of the integrity model Oversight Advice/support on: Risk management Training Disciplinary monitoring Code of ethics implementation Co-ordinating on complaints with Technical Secretariat for the Disciplinary Administrative Process Attorney General Office Office of Institutional Control	Integrity function in regional governments
Supporting the integrity function, the SIP could scale up both direct and indirect support, through: Mobilising high-level commitment by making the case for integrity; e.g. during events such as the Executive GORE. Similarly, the PCM – through the SD and SIP, and the support of the ANGR – could promote the organisation of an annual Integrity GORE (GORE Integridad) along the model of Digital GORE (GORE Digital). Supporting and building capacities of staff working in the regions’ integrity function, through training events by cluster of regions, in addition to e-learning material and activities. • Promoting dialogue between the integrity functions via an intranet platform or yearly meetings, to ensure coherence, exchange of experiences, mutual learning and support in the design and implementation of the activities and plans.	SIP
Creating awareness among regional governments, the SIP could provide ad-hoc training to Governors (and possibly the closest advisors) through an induction training at the beginning of the term on public integrity.	SIP in co-ordination with Secretariat of Decentralisation
Providing valuable evidence on integrity, efforts should continue in monitoring the ethical climate among public officials at the regional level.	SERVIR in co-ordination with SIP
Ensuring coherence and knowledge transfer between the national and the regional levels, an effective co-ordination mechanism leveraging IT tools and platforms between the CAN and the regional level, namely the CRAs and integrity function could be institutionalised. This could also include a web-based platform to submit information on progress or public integrity indicators to enable a public monitoring and benchmarking.	CAN
The PCM could lead efforts to promote co-ordination on integrity among actors in the executive with direct influence on integrity policies and those leading entities in key risk integrity areas such as public procurement. It could propose the establishment of an inter-ministerial working group focused on developing tools and methodologies to support the identification and mitigation of integrity risks in procurement processes at regional level. Such group could include representatives from Ministry of Finance (OSCE and Peru Compra) together with PCM’s entities such as the SIP and Secretariat for Decentralisation. At the same time, the group could build on the OSCE’s recent report on ‘Assessment and Strategy for Risk-management in Public Procurement’ (‘Diagnóstico y Estrategia para la Gestión de Riesgos en Contratación Pública’), which identifies 81 risks affecting the efficiency, competition as well as integrity of the public procurement cycle.	PCM, in collaboration with OSCE and Peru Compra
Promoting integrity in the RDAs, the PCM could pilot the following approach: 1. Entrusting the integrity function of the Regional Government to provide the RDAs with advice in articulating and co-ordinating relevant integrity initiatives. 2. Defining minimum internal integrity policies addressing the inherent risks of capture of the RDAs, e.g. a conflict-of-interest disclosure policy for those taking key decisions.	PCM in collaboration with regional governments
Promoting and creating incentives for the implementation of integrity systems at the regional level, the SIP could develop a regional monitoring and benchmarking for the regional governments´ “integrity” performance through indices related to issues such as the implementation of the integrity function (for the government) and of the CRA (for the regions as a whole). In this way, progress could also be communicated to citizens and political and social pressure created to implement reforms in case of regions lagging behind.	SIP

Table 4.2. Overview of the recommendations respective to the CRAs
Recommendation	Actor in charge
Strengthening the adoption of a risk-based approach, CRAs could consider involving – either as invitees or permanent members – additional regional actors overseeing key processes and risks such as the decentralised offices of the OSCE or the Regional Development Agencies. In addition, relevant insights on risks at the municipal level could also be considered by inviting local representatives of municipal associations such as AMPE (Asociacion De Municipalidades del Perú) and REMURPE (Red de Municipalidades Urbanas y Rurales del Perú).	CRAs
Supporting the institutionalisation of the CRAs not only among the public institutions, but also among the population, the organisational structures and operation of the CRAs could be standardised. The SIP, in line with its function to provide technical support to the High-level Commission against Corruption (CAN), could develop a model for internal rules of procedures to be adopted. Furthermore, the CAN could consider establishing a reasonable time period in which ordinary meetings have to be held to ensure regularity in the activities of the CRAs.	SIP and CAN
Facilitating the presence of all institutions at meetings, the internal rules of procedures could include the possibility to nominate an alternative representative. This representative should be of high rank and be given the power to vote in decisions of the CRA. Furthermore, absences without the nomination of a representative should be communicated to the public to build external accountability.	SIP and CRAs
The internal rules of procedures could mandate each member of the CRA to nominate a permanent contact point to engage members of the CRA to contribute actively with proposals and suggestions. The contact point would be responsible for preparing the discussions in the CRA, providing all necessary information, follow up on commitments undertaken and on any tasks as foreseen in the Regional Anti-corruption plan, and report progress for the respective entity. In addition, contact points could create a network to exchange information.	SIP
Building capacities, the SIP could train staff from the technical secretariat of the CRAs. Efforts could be supported by the members of the CAN. These training activities should focus on operational aspects of the CRA’s functioning, including risk assessment, prioritisation, planning, and internal procedures.	SIP (in collaboration with members of CAN)
Providing the CRAs with adequate financial resources, the internal rules of procedure of the CRAs could require each member of the CRAs to commit a certain budget to the technical secretary to guarantee operations and build their capacities	SIP in co-ordination with CRAs
Allowing for the exchange and generation of information, the SIP could implement a virtual platform for the CRAs. This could provide opportunities for cross-regional learning and policy making in specific areas, for example, to improve the design and implementation of regional anti-corruption plans.	SIP
The Integrity function could assume the role of technical secretary of the CRAs ensuring co-ordination between the CRA and the regional government.	CRAs
Raising awareness of integrity and the mandate of the CRAs, the CRAs, in close collaboration with local universities and active actors from civil society, could promote on-line training courses on the social benefits of issues related to public integrity such as the culture of legality and civic responsibilities.	CRAs
Promoting and creating incentives for the implementation of integrity systems at the regional level, the CAN could develop an index measuring the performance of the CRAs. In this way, progress could also be communicated to citizens and political and social pressure created to implement reforms in case of regions lagging behind.	CAN

References

[1] OECD (2017), OECD Recommendation of the Council on Public Integrity, OECD/LEGAL/0435, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0435.