1. Management of conflict of interests in the public sector
Aivars Rapša
Representative of
The Corruption Prevention
and Combating Bureau

2. Legal framework of the Corruption Prevention and Combating Bureau
16 years
In accordance with the Law On Corruption Prevention and Combating Bureau The Corruption Prevention and Combating Bureau (KNAB) is the leading specialized anti-corruption authority of Latvia. Its aim is to fight corruption in a coordinated and comprehensive way through prevention, investigation and education.

3. Eternal engine of anti-corruption
Education and awareness rising
Combating corruption
Corruption prevention

4. The law “On Prevention of Conflict of Interests in Activities of Public Officials” (1)
The law “On Prevention of Conflict of Interests in Activities of Public Officials”1 (adopted in 2002).
Purpose of the law is:
to ensure that the actions of public officials are in the public interest,
to prevent the influence of a personal or financial interest of any public official, his/her relatives or business partners upon the actions of the public official;
to promote openness regarding the actions of the public officials and their liability to the society;
to promote confidence of the society regarding the actions of public officials.
1 The Law in is available:

5. prevention of conflict of interest in actions of public officials
The law “On Prevention of Conflict of Interests in Activities of Public Officials” (2)
The law determines:
declarations of assets of public officials and a mechanism for the verification of these declarations
prevention of conflict of interest in actions of public officials
different restrictions and prohibitions in activities of public officials

6. The law “On Prevention of Conflict of Interests in Activities of Public Officials” (3)
Restrictions
To advertise
To accept gifts and donations
To do commercial activities
To combine positions (offices)
To obtain incomes
To act with property of state or local government
To issue administrative acts, perform supervision, control, inquiry or punitive functions and sign contracts
Prohibitions
To influence issue of administrative acts, performance of supervision, control, inquiry and punitive functions
To be a representative
To receive supplementary payments
To use information

7. Asset declarations for public officials
A public official is obliged to specify following information:
relatives;
other positions that the public official holds in addition to the position as a public official;
the immovable property;
commercial companies whose shareholder, stockholder or partner he/she is;
transport registered and owned by the public official;
all kinds of income earned during the reporting period;
cash or non-cash savings if their amount exceeds twenty minimum monthly wages (20 x 430 EUR = 8600 EUR);
transactions performed by the public official if their amount exceeds twenty minimum monthly wages;
the amount of debt of the public official which exceeds twenty minimum monthly wages;
loans granted (total sum) if the total amount of such loans exceeds twenty minimum monthly wages;
if the public official is a beneficial owner of an object or a part of it, capital shares, stocks and other financial instruments owned by another person.

8. Online access to database of assets declarations
of public officials
Detailed information on public officials
Possibility to detect situations of conflict of interests
Possibility to analyze and compare declarations from previous years
Possibility to detect other administrative violations

9. Administrative liability
Verbal warning
Administrative fine ( EUR)
Forfeit of the right to hold office position of the public official

10. Informing society about violations
After the administrative decision regarding a violation has entered into force the following information are posted on the Bureau’s website:
the given name, surname and position held by a public official;
the legal norms of the Law which has been violated;
the essence of the violation and time of commitment thereof;
the decision taken;
the date entering into force of a decision and of execution thereof.
Information are available on the website for one year from the day
when the decision has been executed.

12. New challenges
According the guidelines for the corruption prevention and combating Y2015–Y2020 and Operational Strategy of the Corruption Prevention and Combating Bureau Y2018–Y2019, Bureau has already done and will continue to transfer the prevention of conflict of interest of public officials and control of restrictions and prohibitions imposed on public officials from external control to institutional internal control.

14. Institutional internal control
Regulations of Cabinet of Ministers No.630
Recommendations how to implement regulations No.630

15. What do we expect?

16. Purpose of the corruption risk management
to create a controlling environment, that decreases or prevents violations of norms of the law “On prevention of conflict of interest in the activities of public officials”;
to identify possible risks of corruption, which may result in damage to the institution;
to implement appropriate measures to reduce (or prevent) corruption risks;
revise the identified corruption risks and evaluate the effectiveness and usefulness of the measures to reduce (or eliminate) identified corruption risks;
reduce (or eliminate) possible risks of corruption and promote the proper use of personnel, financial and material resources;
monitor the implementation of a specified measure to reduce (or eliminate) corruption risks.

17. How to start? Confirm the ethical principles
Evaluate professional duties, limits of power, procedures of decision-making, responsibilities
Determine the procedure how to report about irregularities
Determine the procedure how public officials announce their possible conflict of interests
Determine the procedure of requesting permission to combine positions (written permissions)
Identify, analyze and evaluate corruption risks

18. 1. Identify and evaluate functions (tasks), areas or processes which may have major corruption risks:
perform supervisory, control, inquiry or punitive functions
operate with state or local government property
organize public procurements
operate with cash
make or take part in making decisions regarding other persons
perform investigative functions
operate with state or commercial secrets
operate with personal data

19. To identify corruption risks use:
2. Apply existing control mechanisms, identify the risks of corruption, evaluate the probability and impact on occurrence, and resulting consequences:
To identify corruption risks use:
internal normative acts; internal audit reports; detected workplace violations; citizens complaints, surveys; given information by employees; State audit office reports; analysis of disciplinary cases; external information – in the media; etc.
To analyze corruption risks and to evaluate probability of such risks use:
character of duties (regularity, required skills, how many employees are involved); real incidents; complaints (employees, clients); information in the media; internal factors (lack of knowledge, motivation and skills); control mechanisms; other institutions criteria
To evaluate the impact on occurrence and resulting consequences of corruption risks consider:
impact on achieving strategic goals; impact on doing an individual tasks; financial losses; damage to the reputation of the institution; loss of public trust; other institutions criteria

20. 3. Identify positions exposed to corruption risks:
employee works alone and makes decisions alone
employees activities are not restricted by normative acts
employees activities are not documented
there is no regular follow-up control of making decisions
there is no “four-eye” principle
no responsibility for workplace violations
citizens complaints regarding such positions (public officials)
corruption cases against particular public officials

21. 4. Define and implement anti-corruption (corruption risk) measures:
implementation and actualization of internal normative acts
regular follow-up controls
sharing responsibility or functions
trainings on anti-corruption and prevention of conflicts of interests
“Four-eye” principle; registration of irregularities; rotations
physical control (audio, video monitoring)
action plan, secure reporting mechanism
motivation of employees
information for employees about most common irregularities

22. Thank you for your attention!
Corruption Prevention and Combating Bureau
Citadeles Str. 1, Riga, LV-1010, Latvia
Phone: