6.17. Maturity Assessment of the Organisation’s' Corruption Prevention System

 

The self-evaluation based analysis may also be an alternative to an external evaluation of the efficiency of the organisation’s anti-corruption programme. The major purpose of such evaluation is to enable the management of the organisation to evaluate:

  • the main structural elements of corruption prevention (the fact of their existence at their organisation),
  • the principles and efficiency of their application in the organisation,
  • the need and directions for improvement  of the current system.

 

It is necessary to emphasize that each organisation is free to choose and decide on the best ways of implementation of the elements of its anti-corruption system and the level of efforts the organisation will devote  to the automation, documentation and efficiency evaluation of this process (this might be determined by such objective factors as the size and economic branch of the organisation’s operations, the complexity of its processes, etc.); however, the corruption prevention elements listed below are to be regarded as the key integral parts of the  anti-corruption system at any organisation, for the latter is deemed to be full and efficient:

  1. A defined strategy for managing corruption / fraud / illegal actions;
  2. Transparency of activities is clearly and publicly defined as one of the most relevant activity areas/principles of the organisation;
  3. The organisation has a code of ethics in place;
  4. The organisation has clearly-defined procedures for reporting and managing cases of corruption / fraud / illegal actions;
  5. The organisation conducts risk assessments  of corruption / illegal actions / fraud on a regular basis;
  6. The organisation conducts  internal and/or performance audits on corruption/illegal actions/fraud in the most risk-sensitive activity processes;
  7. The organisation has a unit/position, responsible specifically for managing corruption / fraud / illegal actions;
  8. The organisation conducts  training on how to identify and manage the risks of corruption / illegal actions / fraud on a regular basis;
  9. The organisation has a "trust line" or other tools/measures for active involvement of employees, promoting  transparency of its activities;
  10. The organisation has an adequately-regulated incentive-penalty system  ensuring proper and efficient corruption / performance transparency risk management.

 

Provided below is the maturity assessment model of the corruption prevention system, which includes the main elements of the corruption prevention system and different maturity levels of the development of these elements  in the organisation.

 

 
Elements of corruption prevention systems Levels of maturity of corruption prevention systems
1 2 3 4
1. Does your organisation have a strategy for managing corruption / fraud / illegal actions? Yes, the strategy is prepared, formalised and actively implemented. Yes, the strategy is prepared and formalised, but not really effective and / or implemented Yes, there is a strategy, but it is informal and undocumented. No, there is no such strategy.
2. Is your organisation's transparency clearly and publicly defined as one of the most important principles / areas of the organisation's activities? Yes, transparency is one of the key principles of our activity — it is clearly defined in our mission and strategy, and consolidated by employees, contractors as well as other contracts and agreements as the major and key condition for our organisation's cooperation. Yes, transparency is one of the key principles of our activity — it is clearly defined in our mission and strategy; however it is not consolidated by employees, contractors as well as other contracts and agreements as the major and key condition for our organisation's cooperation. Yes, transparency is important, but it is not one of the documented or explicitly and publicly communicated principles of our activities. No, transparency is not one of our key priorities / principles.
3.     Does your organisation have and use a code of ethics? Yes, the code of ethics is prepared, formalised and actively implemented by all departments. Yes, the code of ethics is prepared and formalised, but not really effective and / or implemented. Yes, there is a code of ethics, but it is informal and undocumented. No, we do not have a code of ethics.
4. Does your organisation have clearly-defined procedures of reporting and managing corruption / fraud / illegal actions? Yes, the procedures are prepared, formalised and actively implemented. Yes, the procedures are prepared and formalised, but not really effective and / or implemented. Yes, we do have certain procedures, but they are informal and undocumented. No, there are no such procedures in our organisation.
5.     Does your organisation conduct periodic assessments of risks of corruption / illegal actions / fraud? Yes, we have periodic risk assessments at the organisation (at least once a year), which involve all organisation's processes, the assessment of factual incidents and qualitative measurements. Yes, we have periodic risk assessments at  the organisation (at least once a year), but they lack sufficient structure and are based on the principles of qualitative / expert assessments. Yes, we have risk assessments, but they are not documented in detail — carried out as discussions with top management instead. No, we do not have periodic risk assessments.
6.     Does your organisation conduct periodic internal and / or performance audits regarding corruption / illegal actions / fraud in the most risk-sensitive processes? Yes, we have periodic audits related to the management of these risks (at least once a year), which include the most sensitive processes and are based on the principles of data analysis. Yes, we have audits related to the management of these risks (at least once a year), but they lack sufficient structure and are based on the principles of expert evaluations. Yes, we have audits related to the management of these risks, but they are not documented in much detail or assessed, being limited to identifying the most significant risks. No, we do not have periodic audits related to the management of these risks.
7.     Does your organisation have a department / office, responsible specifically for management of corruption / fraud / illegal actions? Yes, our organisation has a department / office, responsible specifically for management of corruption / fraud / illegal actions. Yes, our organisation has a person, responsible for management of corruption / fraud / illegal actions, but this is not his/her) main function (e.g. combined with internal audit and / or general risk management). Yes, our organisation has a person, responsible for management of corruption / fraud / illegal actions, but this is his/her secondary function. No, we do not have such a department / function.
8.     Does your organisation conduct periodical training on how to identify and manage risks of corruption / illegal actions / fraud? Yes, we have periodic training related to the management of these risks (at least once a year) and they involve ALL representatives of the organisation. Yes, we have periodic training related to the management of these risks (at least once a year), but they do not involve ALL representatives of the organisation. Yes, we have training related to the management of these risks, but they are not periodic, implemented according to the need and do not involve ALL representatives of the organisation. No, we do not have periodic training related to these risks.
9.     Does your organisation have a "trust line" or other measures / tools, actively used by the employees and promoting the issues of transparency? Yes, we do have such measures / tools at our organisation and use them actively in solving issues of corruption / distrust related to transparency challenges. Yes, we do have such measures / tools at our organisation and use them, but they are not convenient and effective for use and / or solving reported issues. Yes, but these measures are almost never used or I am not aware of any cases. No, we do not have such tools / measures.
10.     Does your organisation have an appropriate system of incentives-punishments, ensuring appropriate and effective corruption / transparency risk management? Yes, our organisation has a motivational system, it is effective and motivates all employees to stand together in fighting corruption / distrust / transparency risks at our organisation. Yes, our organisation has a motivational system, but it is not very effective and / or related to the results of performance audits and / or risk analysis of possible illegal actions. Yes, officially our organisation does have a motivational system, but in recent years there was not a single case of any punishments applied to our organisation's employees for known cases of possibly non-transparent activities. No, our organisation does not have such measures / motivational system.

 

It should be noted  that the model for evaluation of the maturity of the corruption prevention system provided above may be adjusted and expanded, should there be such a need.