Integrity Policy, Flemish government authorities

OECD, 24th March 2015Working Party of Senior Public Integrity Officials

(SPIO)Session 3 Implementation at the organisational

level

www.bestuurszaken.be

About me

• Degrees: Dutch & English, Medieval Studies, Business Communications, Italian Studies• September 2002: started working

for Flemish Government Autorities• October 2010: Integrity Officer • Chairwoman Integrity Office• 2 co-workers: Josefien De Wachter

(integrity policy assistant) &Annelies Antheunis (policy well-being at work)

My organization: Flemish government authorities

Flanders: Dutch-speaking northern part of Belgium. Self-governing region with its own parliament and government.

Flemish government authorities:27,547 employees (2014, scope integrity)13 policy domains (to be reduced to 11)72 entities 158 locations Belgium + 73 abroad (49 countries)

Integrity policy at Flemish government authorities

Genesis: aftermath credit card scandal city of Antwerp

2005: Flemish government decides to build proper integrity policy + appointment integrity officer (founding internal audit, Ombudsman)

2006: first integrity officer, second code of conduct

2006-2010: many key players, initiatives, roles… but no integrated policy or approach

15th March 2012: official start Integrity Office

Very broad definition & scope

proper use of means+ proper behaviour towards people (well-being, equality, non-discrimination)

personnel + organisation

Founded on 3 pillars

PreventionDetection/Control Reaction/Sanction

-> balance in 3 pillars+ Multidisciplinary approach

(4th pillar needed: aftercare)

Multidisciplinary approach

Integrity

Well-being

Social services

Internal audit

Complaints manage-ment

Diversity

HRRules & Regulations

OmbudsService

Proces flow (linking 3 (4) pillars)

Prevention

Evaluation

Detection

Aftercare

Reaction

Wide array of instrumentsInstruments Competent division Pillar

Code of conduct, ICT code Integrity Officer (et al) Prevention, control

Dilemma training, train the trainer, made to measure advice

Agency for government personnel (training & support)

Prevention

Management code Agency for government personnel

Prevention, control

Unique centre of complaints (Spreekbuis)

(virtual) Integrity Office Detection

Guidelines integrity policy for entities (maturity scoring)

Interal Audit Prevention (control, detection)

Manual identification vulnerable functions

Integrity Officer Prevention

Detection audits (based on fraud risk analysis)

Internal Audit Detection (prevention)

Forensic audits Internal Audit Reaction

Whistleblowers protection act Ombudsman Detection

Personnel charter Flemish government authorities/ employment contracts

Management Reaction

HR instruments: personnel questionnaire, bottom up evaluation, competence management

Management Prevention

Relevant rules and regulations EU legislation, federal & Flemish governments, entities

Prevention

Many key-players central and in entitiesdifferent: responsibilities & competences Central key players Players in entities

Integrity Officer Integrity contact persons

Internal Audit Managers

Organisational development experts

Ombusman Complaints managers

Social Services

Well-being at Work

Trusted intermediaries

Diversity Diversity contact persons

Training and Education HR experts

706 HR-specialists

240 superiors

84 integrity contact persons 89 trusted

intermediaries

6 forensic auditors

8 social services experts

1 Ombudsman1 Integrity officer

26 well-being experts

Integration central key players & instruments: (virtual) Integrity office

Main goals: integrity – 3 pillars: prevention, detection, reaction /sanction

Standard activities (core activities):Policy adviceDeveloping integrity toolsMeasuring and evaluation of policy resultsCentre of integrity expertiseCommunications

Main projects & results to date

3rd version code of conduct (communications campaign) 2011 + ICT code of conduct 2014Central point of contact to report wrong doings (Spreekbuis + 1700)Uniform registration cases (online application)Internal network integrity contact persons1st integrity network event 10/4/2014

(210 attendants) Regular network gatherings (twice a year)

From central policy to entity practice

Integrity practice in entities: responsability of top manager

Internal Audit: audit screenings on 10 themes incl. integrity -> resulting in ‘maturity’ scoring and advice/recommendations for improvement

Results reported to competent ministers and part of appraisal top managers

Follow up of advice/recommendations Internal Audit -> often on integrity policy & plan of action (support by Integrity officer and relevant experts)

Towards local governments (cities and municipalities)

Municipality decree, article 112: all cities and municipalities must have code of conduct

Since 1st January 2014: Internal Audit conducts audits at local governments (same as at Flemish government authorities)

More and more local governments turn to Integrity officer for advice and support

Challenges & wishesChallenges

No judicial framework (professional secrecy vs discretion)No budget (only 2 full time employees for integrity policy and coordination) Scope & delimitation/professional boundaries (many players)Commitment

Wishes4th pillar: aftercareProject career long integrity (ethical leadership)Measuring results (parameters)

Contactintegriteit@vlaanderen.be

www.bestuurszaken.be/integriteithttp://governance-flanders.be/integrity-0

kristien.verbraeken@bz.vlaanderen.beTel +32 499 77 20 88

Twitter: @javamokaLinkedIn: be.linkedin.com/in/kristienverbraeken