8. Capacity building
This chapter provides a commentary on the principle of capacity building contained within the OECD Recommendation of the Council on Public Integrity. It clarifies how core activities – such as providing timely and relevant information on integrity policies and standards, as well as carrying out regular, tailored integrity training – can build commitment to public integrity. It identifies the core components for effective integrity advisory functions, and discusses how these guidance and consultation mechanisms can support public officials in understanding and applying integrity standards in their daily activities. The chapter addresses commonly faced challenges, including using innovative and interactive training formats, dedicating time and resources to capacity building and guidance, and ensuring effective co-ordination of agencies responsible for training. It also discusses the challenges associated with integrity advisors, including the risk that other actors may relinquish their integrity responsibilities, or misuse the advice and guidance of advisors.
Raising awareness, building knowledge and skills, and cultivating commitment to integrity are essential public integrity elements. Raising awareness about integrity standards, practices and challenges helps public officials recognise integrity issues when they arise. Likewise, well-designed training and guidance equip public officials with the knowledge and skills to manage integrity issues appropriately, and seek out expert advice when needed. In turn, raising awareness and building capacity contributes to cultivating commitment among public officials, motivating behaviour to carry out their public duties in the public interest.
The OECD Recommendation on Public Integrity calls on adherents to “provide sufficient information, training, guidance and timely advice for public officials to apply public integrity standards in the workplace, in particular through:
a. providing public officials throughout their careers with clear and up-to-date information about the organisation’s policies, rules and administrative procedures relevant to maintaining high standards of public integrity;
b. offering induction and on-the-job integrity training to public officials throughout their careers in order to raise awareness and develop essential skills for the analysis of ethical dilemmas, and to make public integrity standards applicable and meaningful in their own personal contexts;
c. providing easily accessible formal and informal guidance and consultation mechanisms to help public officials apply public integrity standards in their daily work as well as to manage conflict-of-interest situations” (OECD, 2017[1]).
There are a number of tools and mechanisms that governments can use to provide information, training and guidance to public officials. The following features are essential elements:
Information about integrity policies, rules and administrative procedures is up-to-date and available.
Induction and on-the-job integrity training take place regularly to raise awareness and develop skills for public integrity, and evaluation measures are in place to assess effectiveness.
Guidance and consultation mechanisms for consistently applying integrity standards in public officials’ daily work are in place, well known, and accessible.
8.2.1. Information about integrity policies, rules and administrative procedures is up-to-date and available
Making sufficient information available for public officials is key to raising awareness and understanding of integrity policies, standards, rules and administrative procedures. The methods and messages will depend on whether the aim is to raise awareness about integrity standards that are applicable across the public sector, or integrity rules applicable in specific institutions or contexts. If the focus is on raising awareness about government-wide integrity standards, governments can issue communications about values and principles in the civil service. This may include sending public officials a copy of the code of conduct or code of ethics and presenting its content when they join the public service, as well as asking them to sign, upon entry or when they change their functions, a statement that they have read, understood and agree to adhere to the code of conduct or code of ethics. The legal value of such an act is usually limited, but its symbolic meaning can be considerable if it is embedded within the broader integrity system (OECD, 2009[2]).
Public organisations may use additional means of diffusing integrity standards such as posters, computer screen savers, employee boards, banners, bookmarks and printed calendars (among other things), to raise awareness about integrity rules. For example, in Mexico the Ministry of Public Administration (Secretaría de la Función Pública [SFP]) diffused posters on the constitutional principles, explaining what each specific public service value means (legality, honesty, loyalty, impartiality and efficiency) (Figure 8.1). If the focus is on raising awareness about specific integrity rules in a specific sector, then governments may consider producing and disseminating tailored messages. The US Customs and Border Protection Agency and the Australian Department of Home Affairs have both introduced integrity videos and agency-wide emails to clarify sector-specific expectations and conduct within their agencies (OECD, 2017[3]).
Source: Unidad de ética, Integridad Pública y Prevención de Conflictos de Intereses (2018), “Principios
Constitucionales”, Secretaría de la Función Pública.
Using messages that contain concrete examples about what these values mean will encourage public officials to reflect on and internalise them. For example, the poster of the Standards of Integrity and Conduct of New Zealand (Figure 8.2), which is displayed both within public organisations and publicly for citizens, offers concrete examples of what the values mean.
Source: State Services Commission Standards of Integrity & Conduct, www.nzals.co.nz/assets/Policy-Forms/Code-of-Conduct-Policy.pdf (accessed 25 February 2020).
Simply displaying integrity rules does not necessarily guarantee public officials will give due consideration to the information at their disposal. As such, whatever tools and messages are chosen, regularly promoting integrity policies, rules and procedures can help public officials remember them when facing ethical situations (OECD, 2017[4]). As noted in (OECD, 2019[5]), moral reminders have been shown to be an effective tool to counteract unethical behaviour, by reminding people of ethical standards at the moment of decision making (Mazar and Ariely, 2006[6]; Bursztyn et al., 2016[7]). Inconspicuous messages, such as “Thank you for your honesty” can have a striking impact on compliance with integrity standards (Pruckner and Sausgruber, 2013[8]), although to achieve the desired impact the interventions have to be timed closely before the moment of decision making (Gino and Mogilner, 2014[9]).
A concrete policy measure derived from these findings could involve including a sentence to be confirmed by a procurement official just before taking the decision on a procurement contract. The sentence could read: “I will take the following decision according to the highest professional and ethical standards”. By signing, the procurement official implicitly links their name to ethical conduct (OECD, 2017[10]). Other concrete policy measures could include requiring signature boxes at the beginning of government reporting forms (Box 8.1).
In the United States, federal vendors who make sales through federal supply schedules are required to pay the industrial funding fee, which is calculated based on the fraction of the total sales made. To calculate the fee, vendors must self-report the quantity of their total sales. To increase compliance with self-reporting, the Government Services Administration (GSA) piloted an electronic signature box at the beginning of its online reporting portal. As a result of the pilot, the median self-reported sales amount was USD 445 higher for vendors signing at the top of the form. This translated into an extra USD 1.59 million in Industrial Funding Fee (IFF) paid to the government in a single quarter.
Source: (SBST (Social and Behavioural Sciences Team), 2015[11]).
8.2.2. Induction and on-the-job integrity training take place regularly to raise awareness and develop skills for public integrity, and evaluation measures are in place to assess effectiveness
From a capacity-building perspective, a strategic approach to public integrity requires integrity training to be integrated into the wider skills development framework of any public service. Across OECD countries, skills development is a core part of public service management. The institutional oversight, as well as who is responsible for promoting, co-ordinating and administrating learning, varies based on a country’s institutional framework (OECD, 2017[4]). The key structures could include a central ministry or a national public service school, or responsibility could be delegated to individual line ministries (OECD, 2016[12]). Learning and skills development plans may be built around the development of individual public officials in order to address skills gaps in public organisations, or focused on the whole-of-government level (OECD, 2017[4]).
Regardless of the approach or approaches used and in what combination, training in integrity should be a component. Governments can consider the following features when designing and implementing integrity training: the target audience, the timing and frequency of the training, the scope of the training, and the main methods to carry out the training. In addition, governments can consider measures related to co-ordinating the key actors who prepare and deliver training, as well as to monitoring and evaluating the training outcomes.
Training audience
New public officials are a key audience for integrity training, with induction training serving as the first opportunity to set the tone for integrity standards upon entry into the public service. This is a prime opportunity to raise awareness and build knowledge on rules and values. For instance, Canada, the United States, Lithuania and Turkey have made integrity training a mandatory component of induction training. Within the mandatory curriculum for new public officials, the Canada School of Public Service provides an induction course on values and ethics. In the United States, all new federal employees must follow an ethics induction training course designed and provided by their Designated Agency Ethics Official. In Lithuania, ethics training is indirectly made mandatory: all new public officials are required to take part in induction training, which includes time dedicated to integrity issues. Basic core components of these induction integrity courses include the concepts of values and ethics, but also managing and preventing conflicts of interest, ethical dilemmas and accountability issues in the workplace.
Specific integrity training opportunities can also be designed for public officials, to provide them with support and tailored, up-to-date content to perform their daily functions. In the United States, in addition to the mandatory induction training, certain categories of employees (e.g. presidential appointees, the executive office of the president, certain contracting officers, etc.) are required by the Code of Federal Regulation to follow additional annual ethics training. Many US agencies have extended this requirement to all staff. In France, while there is no legal obligation for ethics officers’ training, the High Authority for Transparency in Public Life (HATVP) provides a training course specifically designed for ethics officers of the semi-public companies of the City of Paris (HATVP, 2019[13]). An ethics guide designed for them also provides guidance and tools (HATVP, 2019[14]).
Moreover, as a way to internalise training, participants can be encouraged to draft their own integrity action plan in which they identify integrity risks and challenges in their workplace. Follow-up training can then be used to discuss implementation of their personal plan, including the barriers faced in implementing specific actions, as well as to share ideas and solutions.
Within each public administration, there are specific categories of public officials who operate in positions exposed to higher risks of corruption. Such positions include those responsible for public contracting, those in tax and customs, and those public officials working in regulatory bodies. To ensure that these public officials have the tools to address the integrity risks that arise, training programmes can be tailored to their specific needs. For example, since 2001 the German Federal Procurement Agency requires all new staff members to participate in workshops to gain knowledge of corruption prevention, whistleblowing and ethical behaviour. The programme has since been expanded, with all public procurement officials required to take part. Between 6 and 7 workshops per year are organised to train on average 70 officials (OECD, 2016[15]). In 2017-19, 313 officials participated in relevant management training, induction training and particular corruption prevention workshops. In Estonia, in addition to the four ethics courses in the central training programme, each agency may also provide internal programmes adapted to the needs of their officials. For example, the Tax and Customs Board in Estonia has introduced its own ethics module tailored to the needs of tax and customs officials.
Timing of training
Laws, rules, codes and expectations change over time, and new forms of integrity breaches and ethical dilemmas may emerge. Regular updates on integrity rules and standards can help ensure that public officials have the required skills, knowledge and capacity to respond.
However, given all the public sector topics being considered, a limited amount of time is dedicated to training. As shown in Figure 8.3, between 2010 and 2016 more governments reported 1 to 3 days of training, with a noted decline in those offering 7 to 10 days. Given the number of topics and areas of training that public officials are expected to undertake, the time dedicated to integrity training in particular may be even more limited.
Source: (OECD, 2016[12]).
The regularity of training in integrity for public officials varies and depends on the overall size of the public service, the human and financial resources dedicated to capacity building, and whether integrity training is mandatory or voluntary, or targeted at categories of public officials exposed to specific risks. Even if resources dedicated to integrity training are limited, governments can capitalise on timing opportunities for the training. These include the periods following reforms in ethics or public service acts, establishment of new rules or functions, and changes in general codes of conduct and/or in “higher-risk” functions (political appointees, procurement, tax, customs, etc.) or sectors.
Scope of training and methods used to deliver training
While content will vary based on country context, at a minimum training in integrity can include modules on integrity standards, rules and values, administrative procedures (such as financial management and public procurement), transparency and accountability instruments, and measures and controls to manage integrity risks. Training could also cover what integrity risks are and how to identify them; what ethical reasoning is and how to apply it to abstract ideas; and what ethical dilemmas are and how to manage them.
For both induction and in-service training, there are a number of methods available to support delivery of integrity training (see Table 8.1 for the types of main training trends). Methods should be tailored according to the training’s objectives, as some methods may not be the most effective for every circumstance. Traditional teaching methods such as lectures but also e-learning modules, courses and massive open online courses can be used for imparting knowledge about specific integrity standards, rules and administrative procedures that exist to guide integrity in the public sector (e.g. “rules-based” training). For example, the United States Office of Government Ethics (OGE) used the first of three “train-the-trainer” sessions of a massive open online course (MOOC) to introduce the statute and regulations of post-government employment restrictions. The course was complemented by values-based scenarios and exercises for participants to perform as if they were confronted with real ethical dilemmas. Values-based training focuses on developing attitudes and behaviours in response to potential integrity issues that will occur as public officials carry out their duties. It can be delivered through more interactive forms, including case studies, simulation games, card or board games, and role-playing. For example, in Austria the Federal Ministry of Interior uses an interactive game called “Fit 4 Compliance – Find Your Values” to discuss personal values and how public service values may guide public officials in addressing difficult situations and handling ethical dilemmas. Such interactive and situational methods are used to challenge trainees and allow them to reflect on key dilemmas, as well as on the consequences of a lack of or breaches to integrity; a debriefing follows the experience.
Dilemma training is an example of combined rules-based and values-based approaches, as it involves situations where there is no obvious choice among the different alternatives available. For example, the Agency for Government Employees in the Flemish Government offers dilemma training to public officials; trainees are given practical situations in which they face an ethical dilemma with no clear path to resolution with integrity. Similarly, the OGE in the United States offers in-person training with a series of scenarios aimed at fostering ethical reasoning and discussing ethical dilemmas (US Office of Government Ethics, 2016[16]). The purpose of dilemma training is to convey that such situations are inevitable, and to stress the message that public officials should seek support when they face such situations (OECD, 2009[2]). Dilemma training also runs less risk of being perceived as naïve or as a mere formal requirement; it may yield greater results if it is interactive and allows participants to be confronted with realistic situations that generate a personal commitment to integrity (Bazerman and Tenbrunsel, 2011[17]). As such, focusing dilemma training on public officials’ working situations helps stimulate participants’ moral awareness, contributes to their level of moral reasoning, and provides methods to help improve the moral quality of their actions.
Co-ordinating training actors
The content of integrity training programmes may be limited if it is developed exclusively by either integrity bodies without knowledge of effective teaching methods, or specialised training bodies without specific knowledge of integrity issues. As such, involving both integrity experts and training specialists in developing and implementing integrity training can support a holistic and relevant approach. It also helps define and target the right audience for each type of training. In Canada the central body, the Treasury Board Secretariat, works closely with the Canada School of Public Service to develop integrity training for public officials. Recently, based on this co-operation, the Canada School of Public Service updated the induction course for public officials on values and ethics, which as mentioned above, is part of a mandatory curriculum for new arrivals. The course is also used by federal departments as a refresher for existing employees, to ensure they understand their responsibilities under the Values and Ethics Code for the Public Sector (OECD, 2017[10]). Similarly, in Germany the Federal Ministry of Interior, Building and Community recently developed a new training concept with tailor-made modules for different target groups (management staff, staff with jobs particularly vulnerable to corruption, contact persons for corruption prevention, staff working in corruption prevention units). The timing, content and means of training are clearly defined. Experts in the field of corruption prevention, internal audit, training and human resources management collaborated on the content. In addition the Ministry and the Federal Academy for Public Administration are jointly developing an e-learning programme, taking into account current pedagogical insights and technical trends.
Monitoring and evolution of training
As shown in Figure 8.4, most OECD countries monitor and evaluate the quality of all training activities; as a rule they do not, however, measure their impact (Pearson, 2011[18]). This can be explained by the fact that there are few methodologies that allow for measuring the effectiveness and organisational change arising from training (Van Montfort, Beck and Twijnstra, 2013[19]). Coupled with this, the many variables that can influence the integrity of public officials who participated in training activities make measuring the outcomes of training complex (Pearson, 2011[18]).
Source: OECD, (2016[12]).
One of the commonly acknowledged models for assessing training is the Kirkpatrick “Four Levels Model” (Kirkpatrick, 1994[20]), outlined as follows:
level 1 – Reaction, the immediate impressions of the participants and trainers, what they thought and felt about the training
level 2 – Learning, the development of knowledge, skills and attitudes resulting from the training
level 3 – Behaviour, the extent of behaviour and capability improvement, and demonstrated application of the new learning within the work setting
level 4 – Results, the impact on work results; the return on the training investment (Kirkpatrick, 1994[20]).
Most integrity training evaluation methods focus on the level 1 “reaction” that participants have from the training, and do not take into account levels 2, 3 or 4 of the training. To address this gap, public organisations could measure behaviour change through pre- and post-training assessments in the form of a multi-rater assessment, such as a 360-degree assessment, along with a control group (McGivern and Bernthal, 2002[21]). Such assessments can gather useful data about whether integrity training is helping the organisation achieve its objectives, as well as justify training costs and inform adjustments to the integrity training strategy.
Measuring level 4 “results” requires assessing potential changes against a baseline established prior to initiating training activities. In the context of integrity in public organisations, potential indicators may include the following:
number of cases where public officials have sought integrity advice on specific integrity issues (which may be accounted for separately), and the outcomes of such cases
number of disclosures of potential conflicts of interest to the relevant authorities, and the mitigation measures implemented
perceptions about the level of integrity and openness of the organisation
number of reports from citizens and businesses where public officials did not behave with integrity in providing public services
level of satisfaction of citizens and businesses about the quality of the services delivered by public officials.
However, while carrying out level 4 assessments, public organisations must bear in mind that the uncontrolled, non-laboratory setting of public organisations make it difficult to completely isolate the impact of a specific programme. Thus, it is best to track assessment results over a longer period to identify trends in the impact of integrity training provided.
8.2.3. Guidance and consultation mechanisms for consistently applying integrity standards in public officials’ daily work are in place, well known, and accessible
Although integrity is ultimately the responsibility of all public officials, a dedicated integrity body or unit or dedicated personnel can support shaping integrity (OECD, 2009[2]). Institutionalisation of an integrity advisory function can take different forms: within a central government body, such as the case in Australia (discussed below); through an independent or semi-independent specialised body; or through integrity units or advisors integrated within line ministries. An example of an independent advisory function can be found in France, where the HATVP provides individual confidential advice upon request to the highest ranking elected and non-elected public officials falling within its scope, and provides guidance and support to their institution when one of these public officials requests it. An example of designating dedicated integrity units, officers or advisors within line ministries can be found in Poland, where integrity advisors may be appointed in ministries and other government administration offices. Their role is to provide advice on solving ethical dilemmas and to support public officials in understanding the rules and ethical principles of the civil service. In addition, integrity advisors support leadership in disseminating knowledge about principles and promoting a culture of integrity in the office.
Regardless of the institutional makeup, the key tasks of an integrity advisory function are providing advice on content upon request; providing integrity advice about what is acceptable in specific circumstances; and preparing guidance on what the organisation’s guidelines should be on key integrity issues (OECD, 2009[2]). Using forms of written communication – such as mail, e-mail or through an online portal – to contact integrity advisors can support clarity in the response and avoid the risk of misinterpreting oral advice. Setting out clear procedures for contacting the advisory body, including contact details, hours of operation and expected response times, can help facilitate access. Moreover, specifying the limits of integrity advice (e.g. it does not necessarily equal a legal opinion) can protect both the integrity advisors and employees from misusing or misinterpreting the advice. Specific attention should be given to respecting confidentiality of the exchanges between the advisor and the public officials (e.g. a dedicated and/or encrypted email address, limited access to a specific platform or webpage, etc.). In Australia the Ethics Advisory Service within the Australian Public Service Commission is made available to all public service employees. The website clearly indicates how employees can access the service, with options including e-mail and phone, and sets service delivery standards and privacy standards. The website also details what employees can and cannot expect in terms of advice from the Ethics Advisory Service (Australian Public Service Commission, 2019[22]).
Beyond advice, tools such as questions and answers guidance can inform public officials on values and behaviours, as well as on commonly addressed concerns. In addition, the advisory function can provide regular communication on overall conclusions and the type of guidance and support provided to public officials. This may be done through an annual activity report or by publishing on the advisory function’s website summaries or conclusions drawn from advice requested over a specific period or for recurring systemic or sector-specific issues (e.g. parliamentary ethics, public procurement, etc.).
An integrity advisory function may also be tasked with other integrity, transparency and openness mandates. As identified focal points in the workplace, integrity advisors are in a position to facilitate co-ordination of integrity and transparency policies within the organisation themselves, as well as in co-operation with other organisations and jointly with other integrity actors. Given their position, they may be able to provide support to risk owners in assessing and managing risks within their organisation; diffusing integrity-related information and procedures; and designing tailor-made training sessions or awareness-raising actions in the specific context of their workplace. For example, in Germany the integrity contact persons are tasked with keeping staff members informed regarding integrity and corruption prevention (e.g. by means of regularly scheduled seminars and presentations) and with assisting them with training. Experiencing the same workplace as the colleagues they advise, and having thorough knowledge of public service standards, integrity policies and responsibilities, they may guide colleagues through appropriate reporting procedures and may also be a reporting channel (Box 8.2). What is key is that these bodies should not be responsible for investigating or applying sanctions, as this can seriously curtail their access to public officials with integrity concerns. Moreover, integrity advisors may also supervise and monitor the implementation of these policies and practices (e.g. awareness-raising campaigns, integrity training plans, availability of written resources and guidance, data related to integrity questions and requests, etc.), report on it, and be held accountable for results (OECD, 2017[23]).
In France, the Law on Ethics and the Rights and Obligations of Civil Servants, adopted in April 2016, and its application Decree published in April 2017, created the right for every public official to have access to integrity advice, and provided for the appointment of designated ethics officers (référent déontologue) in every public organisation. The ethics officers have the mission to advise civil servants on questions they may have regarding their integrity obligations in the course of their duties. This requirement has also spread to other levels of government, with an increasing trend of ethics officer appointments in regions and major French cities.
The référent déontologue of the territorial civil service management centre of the Rhône and Lyon métropole published its first activity report in May 2019 highlighting trends in advice and guidance provided to public officials. Guidance recalls for instance in which cases a secondary activity can be pursued and how to proceed in such cases, and reasons why a future private function may impact the functioning of the former organisation and services if the functions are close to the ones that were performed by the public official. A selection of anonymised cases is annexed to the report. It is worth noting that this ethics officer also acts as a whistleblowing focal point for the same jurisdiction.
Source: Loi relative à la déontologie et aux droits et obligations des fonctionnaires (20 April 2016); Centre de gestion de la fonction publique territorial du Rhône et de la métropole de Lyon, Premier rapport d’activité du référent déontologue de Centre de gestion de la fonction publique territorial du Rhône et de la métropole de Lyon, Année 2018, Lyon, https://extranet.cdg69.fr/referent-deontologue.
It is recommended that integrity advisors have the appropriate profile, are trained to listen to staff dilemmas, set a personal example, are not rotated often, and are able to establish trust with employees. A few guiding questions can help facilitate the appointment of the appropriate individual to an integrity advisor role (OECD, 2009[2]):
Does the individual know what behaviour is expected?
Does the individual act with integrity?
Does the individual have a well-defined duty of professional discretion? Specifically, do they know what their duties and rights are when they hear about forms of wrongdoing that are so serious there might be an ethical imperative to break their professional discretion?
Are they sufficiently supported by a unit or a network?
Although challenges may vary depending on national contexts, those most common in several countries include the following:
fostering interest through innovative and interactive training formats
dedicating time and resources to integrity capacity building and guidance
ensuring effective co-ordination of agencies responsible for integrity training
ensuring clear responsibilities for integrity and avoiding misuse of advice from integrity advisors.
8.3.1. Fostering interest through innovative and interactive training formats
Integrity training content and format matter in generating interest. An emphasis on definitional aspects, outdated or identical courses throughout time, and theoretical approaches rather than practical content may limit interest and participation in the training. Moreover, the absence of interaction, discussion and experimentation, as well as limited feedback and evaluation, may undermine the quality and impact of training content, the interest, and potential turnout.
In order to foster interest and participation, training content and formats should allow participants to share their experiences and the specific risks they face in their workplace, to act as if in real situations, and to discuss and try to solve existing and recurrent dilemmas. This may result in designing training for specific at-risk functions or sectors, as mentioned above, and in using different formats and tools.
The availability and accessibility of training content can be addressed through online platforms and solutions, which enable public officials who cannot physically join training opportunities to access courses, practical case studies and forums to discuss ethical dilemmas and those studies. However, it should be emphasised that online training does not replace interactive in-person training, reflection, discussions or experience.
8.3.2. Dedicating time and resources to integrity capacity building and guidance
Capacity-building activities require time and resources to co-ordinate actors; design, implement and evaluate content; and adapt format based on feedback. Similarly, diffusing guidance and training materials, whether on line or through posters, leaflets, screen savers, podcasts, etc., may rely on using existing channels (websites, intranet, emails, paper-based communication), but also may require developing new systems, such as online platforms. The agencies responsible for implementing training and guidance material require the appropriate mandate, as well as the financial and human resources.
8.3.3. Ensuring effective co-ordination of agencies responsible for integrity training
Allocation of functions for oversight, promotion, co-ordination and administration of learning opportunities in the public sector varies, and can involve a myriad of actors. Lack of co-ordination of actors responsible for integrity training may arise from a preference to “work in silos” due to different institutional cultures and governance structures. Fragmentation of integrity training may result in designing programmes with diverging objectives and methodologies, leading to different interpretations and explanations of values and expected conduct across the public sector.
Co-ordination functions – such as a designated lead organisation or an online platform for all public sector training material – and inter-agency collaboration may ensure existing programmes are coherent and aligned. For instance, a designated lead organisation for integrity training can communicate all integrity training material and ensure the content is valid, updated and adapted to risks at both an organisational and individual level.
8.3.4. Ensuring clear responsibilities for integrity and avoiding misuse of advice from integrity advisors
There are several challenges associated with the role of integrity advisor:
The function of the integrity advisor could undermine the sense of responsibility of other actors in the organisation for managing integrity.
Conflicting guidelines that may be given by the integrity advisor and the line management within the organisation.
Cases where previous integrity advice was sought may be used by individuals in their future decisions, even if details in the situation may differ and would have therefore resulted in different advice.
To address these challenges, measures can be set to clarify that integrity advisors can be consulted when other actors (e.g. the supervisor or senior management) are not able to provide satisfactory advice, and to ensure that their advice is shared (where appropriate) with the leadership and managers to avoid conflicting guidelines for public officials (OECD, 2009[2]).
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