Developing an effective internal anti-corruption system that meets international standards. Why does it matter? Three levels of engagement needed for success. Common pillars of anti-corruption standards. Policy + proper assignment of duties. Corruption risk management. Trainings + informative package. Procedure for dealing with corruption proposals and suspiсions. Communication matters.

1. 1
Developing an effective
internal anti-corruption system
that meets international standards
2nd Anti-Corruption Week, NDU, Kiev, 21 – 25 November 2016
Maciej Wnuk
Member of the expert Anti-Corruption Advisory Committee

2. 2
Why does it matter?
Anti-corruption – whose duty is it?
National / governmental
level
Level of particular state
and local institutions
Internal anti-corruption systems,
units and programmes
Education, monitoring,
expertise, cooperation
Civil society
level
National anti-coruption strategy,
Central anti-corruption agencies
Three levels of engagement needed for success:

3. 3
Institutional anti-corruption standards (examples)
British
Anti-Bribery
Management
System BS 10500
Polish
Corruption Threat
Counteracting
System
International
Anti-Bribery
Management
System ISO 37001
Common pillars

4. 4
Key pillars of internal anti-corruption system
Corruption risk management
All to be adopted to the character of organisation
Trainings + informative package
Policy + proper assignment of duties
Procedure for dealing with
corruption proposals and suspiсions

5. 5
Corruption risk management
Systematic corruption risk assessment,
Risk treatment (= what to do?)
Defining priorities
(as resources are always limited)
Several methodologies…
…most appropriate to be chosen and adopted
Action plan
When repeated annually
Progress
measure

6. 6
Trainings = working on attitudes
Psychological denial of risk.
„Nothing has been proven against anybody”, „It is a duty of NABU”,
„I need to trust my colleagues”, „It was just facilitation payment”.
Disregarding
Pro-active
Action after corruption has been revealed. Reforms after damage has
occurred. Criminal and disciplinary measures.
Reacting to minor irregularities in order to prevent greater ones.
Raising standards and reducing risk before damage.
Retro-active
Which attitude is desirable?

7. 7
Top management
Proper assignment of duties + awareness
• Clear „zero tolerance” message and policy
• Enforcement of disciplinary measures
• Own example.
Anti-corruption
coordinator or unit
• Planning, coordinating, advising, assisting
• No capacity to control everything
Middle-level
management
• Its engagement is key for success
• Ensuring integrity of directed units
• Reacting on fraud and corruption symptoms
Employees • Awareness of risk, proper attitude.
External experts • Support (trainings, analysis, assistance)
!
Inspection and
audit units
• Detecting fraud and systemic weaknesses,
• Creating an early warning system.
Formal policy + tailored trainings

8. 8
2. To whom report proposals and allegations?
Challenge: luck of trust to internal procedures
Procedure for dealing with
corrutpion proposals and allegations
Personally, in writing, hot-line, e-mail
4. Protection of whistleblowers Anonymization…
5. Who investigates and what way?
1. How to respond to corruption proposals? Refuse first!
3. How?
Legal restrictions
6. Who approves the results?
7. What actions to be taken?

9. 9
Communication matters
Audit
Inspec-
tion
Manage-
ment
Employ-
ees
Anti-
corruption
unit
Effective
detecting
Permanent
improvement
Early warning
system

10. 10
Thank you!
Questions?
maciej.wnuk@opoczta.pl