Personnel Risk:

Moderate

Score:

61/100

Leadership Behaviour

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Q34 42/100

Do the Defence Ministry, Defence Minister, Chiefs of Defence, and Single Service Chiefs publicly commit, through, for example, speeches, media interviews, or political mandates, to anti-corruption and integrity measures?

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Chiefs/Ministers: Internal communications Score: 25 / 100
Research indicates that top-down internal communication and commitment to integrity and anti-corruption is rare. A review of the (by late 2019 discontinued) newspaper “Forsvarsavisen”…
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Chiefs/Ministers: Public commitment Score: 75 / 100
Research has identified several instances where the Chief of Defence, the Minister of Defence or the permanent secretary of the Ministry of Defence have…
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Unit commanders and leaders Score: 25 / 100
Research found no evidence that unit commanders and leaders focus on communicating commitment to an anti-corruption message. As reported in Q34A, the internal defence…
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Q35 100/100

Are there effective measures in place for personnel found to have taken part in forms of bribery and corruption, and is there evidence that these measures are being carried out?

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Sanctions Score: 100 / 100
The Danish Penal Code also applies to employees (military and civilian) in the Danish defence sector. The penal code criminalises bribery and contains a…
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Enforcement Score: 100 / 100
Instances of bribery or corruption are investigated and disciplined through formal processes and according to provisions in the civil and military penal code. Evidence…
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Q36 17/100

Is whistleblowing encouraged by the government, and are whistle-blowers in military and defence ministries afforded adequate protection from reprisal for reporting evidence of corruption, in both law and practice?

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Legal provisions Score: 0 / 100
There is no Danish legislation on whistleblowing – neither generally nor specifically concerning the defence [1]. A EU directive on whistle-blower protection of persons…
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Prioritisation Score: 25 / 100
Research indicates that efforts are being made to enhance whistle-blower mechanisms in the defence. The so-called Employee Hotline (“Medarbejderlinjen”) was strenghtened with an extra…
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Effectiveness Score: 25 / 100
It is stated on the MoD website that the Defence Internal Audit Office will attempt to conceal the identity of the whistle-blowers (if he/she…
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Q37 0/100

Is special attention paid to the selection, time in post, and oversight of personnel in sensitive positions, including officials and personnel in defence procurement, contracting, financial management, and commercial management?

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Coverage of sensitive (higher-risk) positions Score: 0 / 100
The Ministry of Defence does not operate with a category of higher-risk or sensitive positions and there is thus no special internal oversight mechanism…
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Selection process Score: NA / 100
This indicator has been marked Not Applicable, as there is no recognition that certain positions may be more open to corruption than others i.e.…
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Oversight Score: NA / 100
This indicator has been marked Not Applicable, as there is no recognition that certain positions may be more open to corruption than others i.e.…
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Payroll, Promotions, Appointments, Rewards

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Q38 83/100

Is the number of civilian and military personnel accurately known and publicly available?

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Accuracy Score: 50 / 100
Research indicates that the number of civilian and military personnel is updated at least annually. This is evident from the public reports as assessed…
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Transparency Score: 100 / 100
The number of civilian and military personel is available to the public in two sources. The Ministry of Defence Personnel Agency maintains a website…
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Ghost soldiers Score: 100 / 100
Ghost soliders has not been an issue for Danish Defence. This was confirmed by a senior officer [1]. The issue is de facto prevented…
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Q39 38/100

Are pay rates and allowances for civilian and military personnel openly published?

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Pay rates Score: 50 / 100
Personnel are employed according to stipulations in collective agreements, why pay rates are available to the general public. Pay rates for military and civilian…
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Allowances Score: 25 / 100
Some information on allowances could be found on the (publicly accessible) Defence website for employee information (1). However, the information appears to be very…
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Q40 67/100

Do personnel receive the correct pay on time, and is the system of payment well-established, routine, and published?

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Timeliness Score: 75 / 100
Research only found one instance of issues specifically related to timeliness. As the Danish Defence transitioned to a new IT system for time management…
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Accuracy Score: 75 / 100
Research only found one instance specifically related to accuracy, but the Danish National Audit Office issued general critique of the Defence salary management in…
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Transparency Score: 50 / 100
As reported in Q39, there are considerable shortcomings in the transparency of the payment system. This is simply due to poor accessibility and exposition…
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Q41 42/100

Is there an established, independent, transparent, and objective appointment system for the selection of military personnel at middle and top management level?

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Formal process Score: 50 / 100
Research only found brief description of the selection process of military personnel at middle and top management level. The HR strategy states that all…
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Scrutiny Score: 25 / 100
As stated in the HR strategy, for positions at the middle and top management level (from salary cap 37), the Ministry of Defence Personnel…
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Transparency Score: 50 / 100
As mentioned in Q41A, research only found brief description of the selection process of military personnel at middle and top management level. This is…
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Q42 42/100

Are personnel promoted through an objective, meritocratic process? Such a process would include promotion boards outside of the command chain, strong formal appraisal processes, and independent oversight.

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Formal process Score: 75 / 100
Guidelines and rules for personnel promotions are described in summary form on the Defence employee website [1, 2] and in the HR strategy [3]…
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Exceptions Score: 50 / 100
Guidelines for acting ranks and/or battlefield promotions are published on the Defence employee website [1]. They are short and somewhat vague: here, it is…
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Comprehensiveness Score: 0 / 100
Research did not find any regulations on the public declaration of all officers above OF-4, nor did it find indications that the Defence follows…
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Frequency Score: NA / 100
This indicator has been marked Not Applicable, as no information is released about postings and promotion cycle.
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Conscription and Recruitment

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Q43 NA/100

Where compulsory conscription occurs, is there a policy of not accepting bribes for avoiding conscription? Are there appropriate procedures in place to deal with such bribery, and are they applied?

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Policy Score: NA / 100
Denmark has compulsory conscription for males at the age of 18 [1]. There is no legislation specifically concerning bribery offences in relation to compulsory…
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Sanctions Score: NA / 100
This indicator has been marked Not Applicable, as recruitment is actually solely based on volunteer conscripts. Bribery in the public sector is prohibited by…
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Enforcement Score: NA / 100
Research found no instances of bribery in relation to conscription [1]. Nor is bribery likely to occur in this area because Danish legislation allows…
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Q44 100/100

is there a policy of refusing bribes to gain preferred postings? Are there appropriate procedures in place to deal with such bribery, and are they applied?

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Policy Score: 100 / 100
The Danish Penal Code also applies to employees (military and civilian) in the Danish defence sector. The penal code criminalises bribery and contains a…
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Sanctions Score: 100 / 100
Sanctions for bribery exist in law: In the Penal Code, offering and receiving bribery are sanctioned by fine or jail of up to six…
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Enforcement Score: NA / 100
This indicator has been marked Not Applicable, as there are no cases of bribery for soliciting preferred postings.
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Salary Chain

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Q45 100/100

Are chains of command separate from chains of payment?

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Score: 100 / 100
Chains of command are separated from chains of payment. All matters related to HR are managed by the Ministry of Defence Personnel Agency [1].…
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Values and Standards

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Q46 56/100

Is there a Code of Conduct for all military personnel that includes, but is not limited to, guidance with respect to bribery, gifts and hospitality, conflicts of interest, and post-separation activities? Is there evidence that breaches of the Code of Conduct are effectively addressed?

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Code of conduct Score: 75 / 100
There is no code of conduct specifically for the Defence domain, nor is there one specifically for military personnel. The Ministry of Defence inform…
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Transparency Score: 50 / 100
The Code of Conduct for the Public Sector is available to the public on the Agency for Public Finance and Management’s website [1]. There…
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Enforcement Score: 50 / 100
Recent media investigations suggest that breaches of the code of conduct are not always investigated. For instance, as for the the recent conviction of…
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Training Score: 50 / 100
Guidance is in very general terms and not specific to the organisational structure of the Ministry of Defence. Civilian and military employees working with…
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Q47 56/100

Is there a Code of Conduct for all civilian personnel that includes, but is not limited to, guidance with respect to bribery, gifts and hospitality, conflicts of interest, and post-separation activities? Is there evidence that breaches of the Code of Conduct are effectively addressed?

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Code of conduct Score: 75 / 100
There is no code of conduct specifically for the Defence domain and neither one specifically for military personnel. The Ministry of Defence inform that…
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Transparency Score: 50 / 100
The Code of Conduct for the Public Sector is available to the public on the Agency for Public Finance and Management’s website [1]. There…
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Enforcement Score: 50 / 100
Recent media investigations suggest that breaches of the code of conduct are not always investigated. As reported in Q16 for example, media investigation in…
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Training Score: 50 / 100
Guidance is in very general terms and not specific to the organisational structure of the Ministry of Defence. Civilian and military employees working with…
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Q48 42/100

Does regular anti-corruption training take place for military and civilian personnel?

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Comprehensiveness Score: 25 / 100
There is no evidence that personnel – both civilian and military – receive any anti-corruption training [1, 2]. This was confirmed by a source…
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Regularity Score: 25 / 100
Currently, it can be argued that training is undertaken on an ad hoc basis [1].
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Coverage of personnel Score: 75 / 100
Civilian and military employees working with public administration need to complete basic online courses based on the general Code of Conduct for the Public…
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Q49 92/100

Is there a policy to make public outcomes of the prosecution of defence services personnel for corrupt activities, and is there evidence of effective prosecutions in recent years?

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Policy Score: 75 / 100
The annual reports of the Ministy of Defence Military Prosecution Service contain information on case-work and statistics pertaining to military criminal proceedings [1, 2].…
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Transparency Score: 100 / 100
The annual reports of the Ministry of Defence Military Prosecution Service contain complete information on the number of cases etc., but not all cases…
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Effectiveness Score: 100 / 100
Cases are prosecuted according to the regulations set forth in the civil and military Administration of Justice Acts [1, 2]. The military justice system…
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Q50 100/100

Are there effective measures in place to discourage facilitation payments (which are illegal in almost all countries)?

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Legal framework Score: 100 / 100
Offering and receiving facilitation payments are illegal according to the Danish Penal Code §122 and §144 [1].
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Enforcement Score: 100 / 100
Cases are investigated and prosecuted through formal processes. The Ministry of Defence Military Prosecution Service investigates and prosecutes military criminal cases, including violations of…
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Prevalence Score: 100 / 100
There has been documented instances of “normal” bribery within the Defence, but not of facilitation payments; it is very rare. Research identified two instances.…
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