Integrity Policy, Flemish government authorities OECD, 24th March 2015 Working Party of Senior Public Integrity Officials (SPIO) Session 3 Implementation at the organisational level

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 : 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 Prevention Detection/Control Reaction/Sanction -> balance in 3 pillars + Multidisciplinary approach (4th pillar needed: aftercare)

Multidisciplinary approach Integrity Well- being Social service s Internal audit Complaints manage- ment Diversity HR Rules & Regulations Ombuds Service

Proces flow (linking 3 (4) pillars) PreventionEvaluationDetectionAftercareReaction

Wide array of instruments InstrumentsCompetent divisionPillar Code of conduct, ICT codeIntegrity Officer (et al)Prevention, control Dilemma training, train the trainer, made to measure advice Agency for government personnel (training & support) Prevention Management codeAgency for government personnelPrevention, control Unique centre of complaints (Spreekbuis)(virtual) Integrity OfficeDetection Guidelines integrity policy for entities (maturity scoring) Interal AuditPrevention (control, detection) Manual identification vulnerable functionsIntegrity OfficerPrevention Detection audits (based on fraud risk analysis) Internal AuditDetection (prevention) Forensic auditsInternal AuditReaction Whistleblowers protection actOmbudsmanDetection Personnel charter Flemish government authorities/ employment contracts ManagementReaction HR instruments: personnel questionnaire, bottom up evaluation, competence management ManagementPrevention Relevant rules and regulationsEU legislation, federal & Flemish governments, entities Prevention

Many key-players central and in entities different: responsibilities & competences Central key playersPlayers in entities Integrity OfficerIntegrity contact persons Internal AuditManagers Organisational development experts OmbusmanComplaints managers Social Services Well-being at Work Trusted intermediaries DiversityDiversity contact persons Training and EducationHR experts

706 HR- specialists 240 superiors84 integrity contact persons 89 trusted intermediaries 6 forensic auditors 8 social services experts 1 Ombudsman 1 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 advice Developing integrity tools Measuring and evaluation of policy results Centre of integrity expertise Communications

Main projects & results to date 3rd version code of conduct (communications campaign) ICT code of conduct 2014 Central point of contact to report wrong doings (Spreekbuis ) Uniform registration cases (online application) Internal network integrity contact persons 1st 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 & wishes Challenges 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 Wishes 4th pillar: aftercare Project career long integrity (ethical leadership) Measuring results (parameters)

Contact Tel LinkedIn: be.linkedin.com/in/kristienverbraeken