5. Whole-of-society
This chapter provides a commentary on the principle of whole-of-society contained within the OECD Recommendation of the Council on Public Integrity, describing how governments can partner with the private sector, civil society and individuals to help promote a culture of integrity. Particular attention is paid to how governments can support companies in implementing responsible business conduct and anti-bribery practices to uphold public integrity. Strategies are presented for ensuring that the legal environment enables civil society organisations to apply integrity practices in their organisations. The roles of awareness-raising campaigns and civic education programmes are also explored, emphasising how individuals are critical actors in supporting public integrity. In addition, the chapter addresses the challenge posed by the entrenched social norms that undermine public integrity, and provides guidance to governments on how to address these issues when engaging the whole-of-society.
Public integrity is not just an issue for the public sector: individuals, civil society and companies shape interactions in society, and their actions can harm or foster integrity in their communities. A whole-of-society approach asserts that as these actors interact with public officials and play a critical role in setting the public agenda and influencing public decisions, they also have a responsibility to promote public integrity. At the most basic level, individuals’ choices have an impact. Witnessing the costs of corruption, they can choose to ignore them and become victims, or recognise violations and actively contribute to strengthening public integrity.
The OECD Recommendation on Public Integrity states that adherents should “promote a whole-of-society culture of public integrity, partnering with the private sector, civil society and individuals, in particular through:
a. Recognising in the public integrity system the role of the private sector, civil society and individuals in respecting public integrity values in their interactions with the public sector, in particular by encouraging the private sector, civil society and individuals to uphold those values as a shared responsibility;
b. Engaging relevant stakeholders in the development, regular update and implementation of the public integrity system;
c. Raising awareness in society of the benefits of public integrity and reducing tolerance of violations of public integrity standards and carrying out, where appropriate, campaigns to promote civic education on public integrity, among individuals and particularly in schools;
d. Engaging the private sector and civil society on the complementary benefits to public integrity that arise from upholding integrity in business and in non-profit activities, sharing and building on, lessons learned from good practices” (OECD, 2017[1]).
Public integrity refers to the “consistent alignment of and adherence to, shared ethical values, principles and norms for upholding and prioritising the public interest over private interests in the public sector” (OECD, 2017[1]). A “whole-of-society” approach to public integrity requires companies, civil society organisations and individuals to ensure that their engagement with the public sector respects the shared ethical norms, principles and values of society. How this materialises depends on the role each actor has in society. For companies, it can involve complying with environmental and human rights standards when carrying out their business activities, paying their fair share in taxes, refraining from offering bribes, and ensuring that lobbying activities align with the long-term sustainability goals set by the company. For civil society organisations, it can include ensuring that they adhere to standards of public integrity when acting as a service provider or advocating for policy issues. For individuals, it can mean respecting the rules governing interactions with public officials and access to public monies, including respecting public property, not engaging in fraudulent social benefit schemes or avoiding taxes, and reporting corruption and fraud when they encounter it.
The following features are essential components to cultivate a whole-of-society approach:
Public integrity standards are established and implemented in companies.
Public integrity standards are established and implemented in civil society organisations.
Public integrity values are established and accepted as a shared responsibility by individuals.
Relevant stakeholders are engaged in developing, updating and implementing the public integrity system.
5.2.1. Public integrity standards are established and implemented in companies
The role of governments in working with companies to uphold public integrity is recognised at the international level through conventions, standards and related guidelines.1 Governments can support public integrity in companies by ensuring the relevant legislation is in place. This not only covers anti-corruption measures, but also includes responsible business conduct, such as protecting human rights, the environment and consumer interests, and ensuring international labour standards, taxation standards, and corporate governance structures are in place. Moreover, public integrity in companies includes public integrity issues of how companies participate in the policy-making process through lobbying and political financing (e.g. “responsible influence”).
The current approach is to establish separate legislative initiatives dealing with anti-corruption, responsible business conduct and public integrity, which then translate into separate policies and measures within companies. For example, many governments have legislation in place requiring companies to establish an anti-bribery compliance programme, which includes anti-corruption corporate policies, capacity building, reporting channels, risk management and internal control functions. The US Foreign Corrupt Practices Act and the UK Bribery Act were vanguards in this area, with other governments following suit. Most recently in France, the law Sapin II requires companies to establish an anti-corruption programme to identify and manage corruption risks, and includes sanctions for non-compliance. The law also establishes the French Anti-Corruption Agency (AFA), which can hold companies liable for failure to implement an efficient anti-corruption programme even if no corrupt activity has taken place. Likewise, governments use legislation to support companies in applying due diligence measures for other responsible business conduct issues; recent legislation passed in Australia (Modern Slavery Act, 2018), France (Duty of Vigilance Law, 2017), and the United Kingdom (Modern Slavery Act, 2015), are examples.
Responsible influence is also often considered separately in both government legislation and internal company policy. Responsible influence is concerned with ensuring that public integrity values are upheld when companies interact with government, in particular through their lobbying and political financing practices, as well as in movement between the public and private sectors (i.e. the “revolving door”). Through legislation and policy measures, governments can incentivise companies to have in place policies on lobbying, political financing and post-public employment. In Spain for example, the legal framework is used to encourage companies to comply with post-public employment legislation (Box 5.1). Similarly, the federal public procurement body in Canada uses debarment from public contracts as a sanction for companies that have violated the federal Lobbying Act (Government of Canada, 2017[2]).
In Spain, Law 9/2017 on public sector contracts reinforces the obligation to post the employment activities of high-ranking officials in order to minimise conflicts of interest. In particular, companies that have hired any person breaching the prohibition on providing services in private companies directly related to the competencies of the position held during the two-year cooling-off period are prohibited from contracting with any public administration provided that the breach has been published in the Official State Gazette. The prohibition on contracting will remain for as long as the person is hired, with the maximum limit of two years from their termination as high-ranking official.
Source: Information provided by the Office of Conflicts of Interest, 2019.
To be effective however, public integrity requires that anti-corruption efforts, responsible business conduct and responsible influence are seen to be mutually supportive and complementary. As such, governments could consider providing policy guidance to companies on how these separate regimes complement one another, to avoid overlaps and gaps. This builds on emerging good practice from due diligence, which recognises that such functions within companies should not be isolated from one another, but should connect a number of departments and functions, including (but not limited to) human resources, operations and production, legal, compliance/ethics, procurement, sales and marketing, external affairs, risk management and audit, as well as senior management and the board/owners. As will be discussed below, governments could also consider incorporating an “integrity culture” perspective to support the effective implementation of such programmes.
Establishing a coherent legislative framework for public integrity is only part of the solution to support integrity in companies. Implementation of such measures is also key. As a starting point, governments can raise awareness of integrity standards among companies (for more, see Chapter 4). Governments can also encourage implementation through a combination of sanctions and incentive regimes. Sanctions should be effective, proportionate and dissuasive, and can include monetary fines, incarceration, confiscation of proceeds, contract remedies, suspension and debarment, denial of government benefits, and liability for damages (UNODC, 2013[3]). Incentives are used to recognise companies’ commitment to good corporate citizenship, and can include preferential access to government benefits (e.g. tax or export credits) and business opportunities (e.g. white-listing companies with demonstrated good integrity practices), as well as penalty mitigation (UNODC, 2013[3]).
Beyond sanctions and incentive regimes, governments can also issue guidance for companies on establishing public integrity compliance programmes. Such programmes can be beneficial, with evidence showing a strong correlation between companies that have diligent sustainability practices and economic performance (Clark, Feiner and Viehs, 2015[4]). Such companies have been found to demonstrate better operational performance, with prudent sustainability practices having a positive influence on investment practices (Clark, Feiner and Viehs, 2015[4]).
However, looking at past experience from anti-bribery and responsible business conduct compliance programmes, there is evidence that these programmes can become legalistic, rules-based measures that do little to create a culture of integrity within companies. As noted above, compliance programmes often operate in silos, separated from the core operations of the company and seen as an add-on. There is also the view that compliance programmes are cosmetic, focused on “ticking the box” to meet government regulations and avoid strong sanctions, rather than addressing the organisational culture issues that lead to integrity violations (Langevoort, 2016[5]; Krawiec, 2003[6]). Coupled with this are findings from behavioural sciences that show that an overemphasis on control and sanctions can crowd out intrinsic motivation for integrity, leading to diminished capacity for ethical behaviour (Lambsdorff, 2015[7]).
To support companies in mainstreaming public integrity compliance programmes into core business operations, governments could incorporate an “integrity culture” perspective into their guidance. This entails moving beyond a focus on formal compliance, and encouraging companies to address the informal aspects of their organisational culture that could undermine public integrity. Such aspects include management example and commitment, rewards and bonus structures, organisational voice and silence factors, internal team dynamics, and external relationships with stakeholders (Taylor, 2017[8]). Table 5.1 provides further details on each of these factors.
Governments can support companies in adopting this perspective by making it a part of reporting requirements. For example, in the financial regulatory sector, the United Kingdom and the United States require financial services to incorporate a “cultural perspective” in their oversight measures. The FINRA (the broker-dealer regulatory organisation) in the United States requires companies to report on culture, as does the Office of the Comptroller of Currency, where bank executives and directors are required to integrate oversight on cultural commitments into their ongoing activities (Filabi and Bulgarella, 2018[9]).
A growing practice for some governments is to require external verification of a company’s compliance programme before granting access to public contracts and other public goods. If requiring external verification, governments could consider including language in the prepared guidance that clarifies for companies that certification does not eliminate the risk of breaches of public integrity, nor does it have an impact on decisions to investigate and prosecute cases of corruption. For example, in the UK Adequate Procedures Guidance, the Ministry of Justice suggests that organisations consider obtaining external verification or assurance of their anti-bribery system and include a clarifying measure to remind companies that accreditation is not a magic bullet for preventing unethical behaviour (UK Ministry of Justice, 2010[10]).
This practice, however, may prove difficult for small and medium-sized enterprises (SMEs), which will likely require additional support in order to implement such programmes. Given that across the OECD, SMEs account for 99% of all businesses and provide over half of all business sector employment (OECD, 2019[11]), governments could considering stratifying reporting requirements to ensure that they are inclusive to enterprises across sectors and industries. When it comes to the above mentioned sanctions and incentive regimes, governments could consider adjusting the benefits awarded to respond to the needs of SMEs, while also providing additional guidance and capacity-building opportunities.
5.2.2. Public integrity standards are established and implemented in civil society organisations
Civil society organisations (CSOs) play a critical role in promoting the public good. Mission-oriented and purpose-driven, CSOs have traditionally addressed gaps in society where neither government nor business were active. In recent years the role of civil society has evolved, and CSOs actively demonstrate their value as facilitators, conveners and innovators, as well as service providers and advocates (World Economic Forum and KPMG International, 2013[12]). They are also a genuine actor in domestic and international affairs, collaborating with both government and business to address key challenges.
To carry out their functions, CSOs often receive special status, such as tax exemption and other benefits, as well as access to public contracts. They also receive funds from companies or private individuals. CSOs are expected by government, business and the general public to act in alignment with their mission, show integrity and be trustworthy, and display exemplary behaviour across the organisation. Public integrity is therefore not only a concern for governments and companies, but also key for ensuring the legitimacy of CSOs. Violations of public integrity and good governance can have negative impacts, jeopardising the legitimacy of CSOs in the eyes of government and the public, and undermining the sustainability of their activities and access to funding. For these organisations, an integrity system provides assurance to public and private donors, as well as the broader society, that the funds received are used in a cost-effective way.
To support public integrity standards in CSOs, governments need to ensure that a clear legal context exists for them to operate in (for more, see Chapter 13). In addition, governments can use the legislative framework to promote public integrity in CSOs, such as through subjecting them to anti-corruption laws where they constitute legal persons, and requiring them to have a sound governance structure. This structure can include clear lines of accountability, integrity standards, internal control and risk management measures, and transparency in activities and the use of funds.
Beyond legislative and policy measures to support public integrity, civil society organisations also need to have effective accountability structures. Principles under the Recommendation on Public Integrity such as strategy, leadership, capacity building, openness and risk management can also be applied to build and sustain integrity in CSOs.
One concrete tool to support their integrity is the “Global Standard for CSO Accountability”, which was developed by a group of CSOs specialised in accountability. It lays out twelve commitments and provides guidance to CSOs for improving their accountability practices (Table 5.2).
To support implementation of each of these commitments, detailed guidance is provided (see an excerpt in Box 5.2) around the following:
1. Processes, policies and structure identify the internal organisational activities that enable CSOs to fulfil the accountability commitment.
2. Stakeholder feedback helps CSOs consider how their actions impact stakeholders; guidance is provided on how to collect and evaluate stakeholder input.
3. Guiding questions encourage a deeper reflection within CSOs to identify the challenges faced and solutions to address these challenges.
An excerpt from the guidance dealing with “well-handled resources” is detailed below.
“10. Well-handled resources: we will handle our resources responsibly to reach our goals and serve the public good.
The efficient, effective and ethical use of financial and other resources is essential for CSOs to manage programmes, achieve results and to develop trust from stakeholders. CSOs must follow generally recognised financial accounting standards, ensure the implementation of strict financial controls and reduce the risk of misuse of funds by handling resources responsibly.
Key actions: Acquire resources in ways that align with values and goals, manage resources responsibly and comply with professional accounting standards, ensure strict financial controls to reduce the risk of corruption, bribery, misuse of funds, and conflicts of interest, report openly and transparently about who provides our resources and how they are managed.
Does your organisation…
1. … have effective guidelines and procedures for ethical fundraising, procurement, and use and management of resources, with provisions for: sourcing and allocation of funds and in-kind donations, fraud prevention, handling of suspected and proven corruption and misuse of resources, and conflicts of interest?
2. … use funds according to the budget and for the intended purposes to achieve strategic goals?
3. … ensure expenditure is monitored regularly, independent financial audits using professional accounting standards are completed and published, and recommended changes are implemented?
4. … purchase goods and services that follow competitive and transparent bidding procedures?
5. … openly provide information on the sources and allocation of funds?”
Source: (Global Standard for CSO Accountability, n.d.[13]).
5.2.3. Public integrity standards are established and accepted as a shared responsibility by individuals
In addition to companies and civil society organisations, individuals play a key role in upholding a culture of integrity in society. By setting standards for public integrity in the legislation and raising awareness of the costs of corruption and benefits of public integrity, governments can cultivate commitment among society and reduce tolerance for public integrity violations.
Setting integrity standards for individuals
Individuals’ interactions with the public sector are vast, and include access to public services, receipt of social benefits and public funds, and use of public spaces and goods (such as public parks or public transportation). Recognising their responsibility within the public integrity system requires ensuring the necessary legislation is in place to prohibit taking part in corrupt acts such as bribery or trading in influence, and to govern payment of taxes, receipt of social benefits, and use of public space and services, among other things.
Awareness-raising campaigns cultivate commitment to public integrity
Awareness-raising campaigns are one of the primary methods by which governments can increase individuals’ understanding of public integrity issues. Awareness-raising campaigns seek to highlight a specific issue and reach a designated audience, whether internally within an organisation or group, or externally to reach the wider society. Campaigns can take different forms, ranging from traditional media (radio, television, print) to new forms of social media (YouTube, Twitter, Facebook, etc.), sometimes a combination of both.
Raising awareness about integrity and anti-corruption efforts can have negative effects however: perceptions of rampant corruption, increasing citizen apathy and reducing motivation to uphold public integrity norms. As such, when developing campaigns it is helpful to ensure that the campaign messages are informed by an understanding of the integrity challenges facing society, and to avoid sensationalising the issue (Table 5.3). Employing credible and authentic evidence can also enable recipients to identify with the core messages (Mann, 2011[14]).
Public sector institutions may want to use awareness-raising campaigns to challenge the notion that unethical behaviour is justified, by creating a conscious link between an individual’s view of his or her own integrity and the wider public benefit. While the vast majority of people do not like to harm others (Camerer, 2011[15]), in the case of unethical behaviour the damage done by the individual often remains abstract and not directly linked to another individual, thereby permitting them to justify the behaviour (Barkan, Ayal and Ariely, 2015[16]). Challenging these behaviour patterns therefore requires linking awareness raising to actual dilemmas, so that individuals understand how their actions can have a negative impact on other individuals, groups and the wider public interest of the community.
Public sector institutions may also consider using campaigns to offer tangible solutions for individuals to uphold public integrity. Small norm prompts can positively influence the actions of an individual who is faced with a corrupt scenario (Köbis et al., 2015[17]). Such prompts could include offering different solutions (such as how to report corruption or how to partner with public officials to uphold integrity) and identifying alternative behaviours to corruption (Box 5.3).
The High Level Commission Against Corruption #Peruanosdeverdad Campaign in Peru
The High Level Commission against Corruption (CAN Anticorrupción) in Peru launched the campaign #PeruviansForReal (#Peruanosdeverdad) in 2016 as part of its integrity strategy. The campaign, which includes a YouTube video, aims to counteract the norms that undermine the integrity of Peruvian society by providing new, positive norms to promote change. The video begins with a series of integrity breaches, ranging from paying bribes to breaking traffic rules, to other forms of civil disruption such as assault and petty theft. The statement, “The change that Peru needs begins with oneself” follows the images. Citizens are then seen with messages for integrity, including #PeruviansForReal: comply with the law, and #PeruviansForReal: we don’t pay bribes. Citizens of all ages are included in the video, and a Peruvian footballer delivers the final message: “How can we expect the authorities to act with integrity and make the country better when we do not do those things ourselves?”
Source: (OECD, 2018[18]; CONFIEP, 2016[19]).
Policy makers can also use awareness-raising campaigns to build citizens’ trust and engagement in ongoing public integrity efforts. For example, an annual “Government Open Doors Day” is held in Germany, which gives citizens the opportunity to meet with federal ministers and state secretaries, and discuss policies and issues (Berlin.de, 2018[20]). The government also uses Government Open Doors Day to raise awareness about integrity and anti-corruption policies.
Civic education programmes cultivate the knowledge, skills and behaviour to uphold public integrity
Engaging the school system is critical for inspiring norms for integrity at a young age, as the school system supports dialogue and exploration about how students, as future citizens, can protect public integrity. Education for public integrity is concerned with inspiring ethical behaviour and equipping young people in both primary and secondary schools with the knowledge and skills to resist corruption. The way in which education for public integrity is disseminated differs across countries, with factors such as curriculum preferences, stakeholder engagement (including political and financial support) and co-operation between the education and integrity bodies and other stakeholders influencing young people’s experience and exposure to integrity education.
Most countries either mainstream public integrity values through the curriculum or deliver education for public integrity by the public integrity/anti-corruption body (OECD, 2018[21]). Countries that incorporate education for public integrity into the curriculum generally use two methods: i) integrating modules into existing courses and/or ii) providing support through teacher manuals and additional materials to be used at the time of the school’s choosing. For example, Hungary uses the first method, integrating concepts about integrity and anti-corruption into the existing ethics curriculum (OECD, 2018[21]). In Chile, the Council for Transparency uses the second method, with a trivia game that tests the knowledge of pupils from ages 10 to 16 about transparency and democracy and promotes co-operation and competition among them. In other countries, the integrity or anti-corruption authority has responsibility for carrying out the education programmes (Box 5.4).
In Portugal, the Council for the Prevention of Corruption (CPC) developed a set of projects for teachers, adults and students (aged 6-18). These projects aim to raise awareness of the causes and consequences of corruption, and support the development of skills and values for the fight against it. The Council provides training to teachers, school staff and students’ parents to clarify concepts related to corruption and bribery, and to help them think about their role in upholding public integrity and reflect on corruption’s impact on the social, economic and political development of society.
The CPC uses a series of contests for students to increase their awareness of and support their engagement in fighting corruption. One of the contests is “Images against corruption’’ (Imagens contra a Corrupção). Students discuss issues related to fraud, corruption and bribery under the guidance of their teachers, and produce outputs showing the lessons they learned. The best student works are selected by a national jury, and awarded a prize.
Another project is “To prevent is better” (Mais Vale Prevenir). Each year, the CPC partners with schools in providing training to school staff on the impacts of corruption on societies, and encourages them to help young students develop knowledge and skills. Guided by their teachers, students read different kinds of texts and discuss everyday life situations related to corruption. They are then asked to produce outputs demonstrating what they have learned and understood about issues related to fraud, bribery and corruption. A national jury selects the final products and the best ones are awarded.
Source: Conselho de Prevenção da Corrupção (2018) Educational Projects (unpublished).
Regardless of how a government chooses to integrate education for public integrity, policy makers can identify and make use of synergies in the existing curriculum to avoid overload. For example, educators could link lessons on public integrity to materials about human rights, rule of law, and the structure of government. Educators could also introduce public integrity education into any language and literature class by having lessons designed around students reading and then writing about governance issues.
In addition to classroom learning, “learning by doing” helps to develop young people’s skills and competencies in safeguarding public integrity, increase their participation in decision-making processes, and support their role as change-makers (Schulz et al., 2016[22]). Educators could engage students in real life integrity projects, such as submitting a request for access to information or monitoring a public works process (Box 5.5). Indeed, linking projects to existing learning outcomes; incorporating the voice of youth in the design and selection of the activities; and providing a space for students to reflect on the experiences afterwards not only raise awareness about the necessity of integrity within public life, but also enable young people to build skills through practice (Ceilo, Durlak and Dymnicki, 2011[23]).
In Italy, the Ministry of Cultural Heritage collaborated with Action Aid Italy to engage 90 local citizens, including students, to conduct civic monitoring of the two major science and cultural projects in the archaeological park of Sybaris. The project aimed at engaging citizens and helping them understand and monitor the basic features of a tender. Citizens were given the opportunity to study public contracts, monitor the public procurement process, and learn how technology can improve the quality of public investment.
Source: (Quintili, 2018[24]).
Training for educators – equipping them with the skills and knowledge to address issues such as corruption – needs to be a core component of any education for integrity programme (OECD, 2018[21]). Training can range from courses taken during teacher trainee programmes or in-service training, to seminars and resource kits prepared by government institutions or civil society actors. Training in education for public integrity could also help educators build skills to address difficult ethical and moral questions in the classroom. Improving educators’ ethical and moral reasoning skills can be achieved in part through courses that incorporate abstract and theoretical content, and that encourage teachers to stretch themselves cognitively through critical reflection (Cummings, Harlow and Maddux, 2007[25]).
Beyond educating young people and educators, it is necessary to implement measures to evaluate the impact of education for public integrity. Although the full effects of such measures will not be visible immediately, it is valuable to systematically collect and analyse data to assess the short- and medium-term results, as well as long-term impact. Policy makers could design an accompanying evaluation framework, with indicators to measure student knowledge and skills relating to integrity and anti-corruption throughout their involvement in the education programme, as well as the future impact of the programme. Possible evaluation approaches include:
Applying regression discontinuity analysis to measure differences in attitudes toward integrity and anti-corruption between students who participated in the education for public integrity programme and students who did not.
Applying qualitative and participatory research methods for evaluating the programme’s effects on the value perceptions of educators and students. This would draw on participants’ experiences and perceptions to provide narrative testaments of the change participants have experienced because of the programme.
Using behavioural insights to assess the effects of the education programme on short-term behaviour change (Gächter and Schulz, 2016[26]). This could include a measurement of students’ propensity towards cheating behaviour at the beginning and end of their participation (OECD, 2018[21]).
5.2.4. Relevant stakeholders are engaged in developing, updating and implementing the public integrity system
Governments can also engage stakeholders in developing, updating and implementing the public integrity system (OECD, 2017[1]). Engaging stakeholders not only ensures policy makers have a clear, concise and grounded understanding of the integrity challenges facing society in a rapidly evolving context; it also supports up-to-date and tailored solutions. Gathering information from key stakeholders can also help to avert unintended impacts and avoid practical implementation problems associated with integrity policies.
Governments could consider ensuring that engagement is institutionalised, inclusive and transparent (see Chapter 13). Institutionalising stakeholder engagement means that governments would establish formal requirements to consult on new integrity policies, with the necessary resources (financial, human and technical) to carry out the consultations assigned (Box 5.6). For example, to support implementation of the integrity system, the French Anti-Corruption Agency (AFA) carried out a broad public consultation with companies, trade federations, consultants, audit firms, lawyers, public authorities, universities and civil society organisations. These stakeholders provided 450 contributions, which were incorporated into an anti-corruption toolkit, guidelines and solutions to support public and private legal persons in preventing and detecting integrity breaches.
In Mexico, the National Anticorruption Policy was developed through an ongoing participative process and discussion involving civil society, academia, business chambers, public institutions and experts from all over the country. First, a Consultative Council (Consejo Consultivo de la Política Nacional Anticorrupción) was established by the National Anti-Corruption System’s (Sistema Nacional Anticorrupción, SNA) Citizen Committee and Executive Secretariat to collect inputs from and promote dialogue with experts from civil society organisations, academia, the business sector, public institutions (including at the sub-national level) and international organisations. Second, a parallel public consultation process collected citizens’ opinions and perceptions related to the causes and effects of and possible solutions to the problem of corruption in Mexico (Consulta Ciudadana). Third, the consultation process involved the sub-national level, with eight regional forums organised throughout the country to include local needs and challenges in the development of national policy.
Source: (OECD, 2019[27]).
Engaging stakeholders in developing regulations can lead to higher compliance with and acceptance of the regulations, in particular when stakeholders feel that their views were considered; when they understand how their comments were taken into account; and when they feel they are treated with respect (Lind and Arndt, 2016[28]). For more on the relationship between stakeholder engagement, integrity and policy making, see Chapter 13.
Building a whole-of-society culture of integrity is not without its challenges. Individual and collective expectations related to public integrity evolve. In a dynamic context, these changes redefine social norms and what is tolerated or not throughout time. This may take the form of a growing individual and collective disapproval of certain breaches and behaviours. However, social norms may also be affected when integrity breaches become common and a collective action problem emerges, in which it is considered irrational for any one person to uphold the public good, because no one else is (Persson, Rothstein and Teorell, 2013[29]). An example would be a city where most individuals avoid buying a ticket for public transport. Such an action may be legally recognised as an integrity breach, with penalties existing for those who break the rules, but there is no severe moral stigma in avoiding the fare, because everyone else is doing it. In societies where respecting integrity norms no longer benefits those who adhere to it, integrity breaches become more acceptable (OECD, 2018[30]). When surrounded by a culture that justifies integrity breaches, evidence has found that individuals are more tolerant of corruption breaches themselves (see for example (Gächter and Schulz, 2016[26]; Barr and Serra, 2010[31]) (Fisman and Miguel, 2008[32])).
Developing and implementing effective integrity policies therefore requires challenging the social norms that justify integrity breaches, and promoting public integrity norms and values. The normative role of public policy suggests that governments can draw on policy tools to invoke and sustain change. While governments cannot expect to transform entrenched social norms overnight, demonstrating commitment to addressing pressing integrity challenges has a powerful signalling role (Muers, 2018[33]). Building on this commitment, implementing policy tools such as mandatory business compliance programmes, awareness-raising campaigns and civic education programmes – and ensuring that these efforts are sustained over time – can break the collective action trap, by creating “tensions” between what was acceptable behaviour and what is now acceptable behaviour (Collier, 2016[34]). While beyond the scope of analysis for Principle 5, effective enforcement regimes are also a necessary tool to ensure that a culture of public integrity is upheld (for more, see Chapter 11).
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Note
← 1. See for example the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions; the 2009 OECD Recommendation for Further Combating Foreign Bribery; the OECD Guidelines for Multinational Enterprises; the 2019 OECD Guidelines on Anti-Corruption and Integrity in State-Owned Enterprises; the United Nations Convention against Corruption; the United Nations Guiding Principles on Business and Human Rights; and the International Labour Organization’s Tripartite Declaration.