Within the defence sector, there are several mechanisms with different mandates that are designed to ensure integrity and tackle wrongdoings. The two largest organisations are the Defence Intelligence and Security Agency (DISA) and the Military Police [1, 2].
DISA’s overall mission is intelligence gathering but through its contribution to the process of the security vetting and issuing of clearances for the MoD and armed forces personnel, it helps detect wrongdoings, including serious corruption. DISA reports to the minister of defence [3].
The mission of the Military Police is to maintain order in the Albanian Armed Forces, to detect, prevent and prosecute criminal activity, to engage in the fight against terrorism, participate in peacekeeping and humanitarian operations and protect state property managed and used by the armed forces. The Military Police has judicial police powers and has the competence to use proactive investigative measures, including interceptions of communications [4]. It reports to the chief of the general staff (CHGC) [5].
The General Inspection and Anticorruption Directorate (GIAD) is in charge of conducting proactive and reactive inspections to ensure the legality of the action, controls the implementation of the anti-corruption measures, investigates corruption cases and coordinates the MoD anti-corruption efforts with the broader government efforts [6].
The task of the Internal Audit Directorate (IAD), as defined by the law on internal audits in the public sector, is to conduct audits based on risk assessments, to assess the adequacy of the control systems and to issue recommendations on the effectiveness of these systems [7]. The tasks of the IAD carries include among others: to review, evaluate and provide recommendations on internal control systems; to propose remedies, administrative and disciplinary measures when violations, irregularities and economic damage are confirmed [6].
The IAD reports to the general secretary, but according to the law, the auditors have professional independence and should be certified as auditors while the Ministry of Finance is responsible for ensuring they remain independent [7].
There are no reports available on the human resources capacities and funding of the DISA, the Military Police and GIAD. The IAD of both the MoD and the State Intelligence Service (SHISH) have adequate human resources and expertise [8]. In the SHISH the general inspector is responsible for conducting compliance inspections activities. The general inspector is appointed by and reports to the prime minister [9].

The DISA, the Military Police, and the IAD are established by law and they cannot be removed or shut down by the authorities to which they report. Their mandate and tasks may be amended only by the parliament. The SHISH General Inspector also falls under this category [1].
Being a structure within the MoD established by ministerial order, the GIAD may be removed in certain cases or because of organisational restructuring [2].
In accordance with the international best practices, the civilian executive authorities have the authority to direct, manage and oversee the security forces of a country [3]. Therefore, the fact that these agencies are answerable to the minister is not an anomaly.

It is not possible to estimate the effectiveness of these bodies due to the lack of reports on corruption perceptions by defence and security officials and the lack of reports on their performance by the discussed bodies. Only reports on the IAD have started to be produced by the Ministry of Finances which indicate that the IAD is performing well [1].
However, their performance and effectiveness may be partly gauged by the actions of ministers when there are government rotations.
After the 2013 elections which brought to power a new government, several officials were referred to the prosecution for criminal investigation by the MoD, which showed that political will was the determining factor to prosecution [1, 2].
However, a similar situation has been produced in the later years also under the new government, when the Supreme State Audit Institution (SSAI) revealed several irregularities in the defence sector, such as improper budgeting, procurements, and mismanagement in the implementation of contracts [3]. The identification of such financial violations which led to the prosecution for the criminal investigation of 12 MoD employees in 2015 may be considered as an indicator of the limited effectiveness of the present internal mechanisms within the defence sector [4]. Similarly, The findings of the Supreme State Audit report of 2018 regarding mismanagement of public funds and waste, and the lack of independence of the Internal Auditing Directorate, suggest that the unit is structurally unable to effectively address and assess corruption risks [5].

No information could be found on whether there is a unit within the defence and security sector that is missioned to fight corruption and building integrity. Generally, it is very difficult to find any information on the internal structure of the armed forces given the opaqueness of the military and political institutions, the so called “Pourvoir” (1, 2, and 6). No organigram of the armed forces could be found on the website of the armed forces that could provide further information on this matter (3).

Formally, the National Body for the Prevention and Fight against Corruption (ONPLC) is mandated to implement the national strategy on corruption. However, its legal framework does not provide any evidence that its mandate extends to the defence sector (4). According to Yazbeck, the military “has rejected any civilian effort to oversee internal military affairs, define national security policy, make military officers accountable to No information could be found on whether there is a unit within the defence and security sector that is mandated to fight corruption and build integrity. Generally, it is very difficult to find any information on the internal structure of the armed forces given the opaqueness of the military and political institutions, the so-called “Pourvoir” (1), (2), (6). No organigram of the armed forces could be found on the armed forces website that could provide further information on this matter (3).

Formally, the National Body for the Prevention and Fight against Corruption (ONPLC) is mandated to implement the national strategy on corruption. However, its legal framework does not provide any evidence that its mandate extends to the defence sector (4). According to Yazbeck, the military, “has rejected any civilian effort to oversee internal military affairs, define national security policy, make military officers accountable to civil courts, or diminish the military’s political functions” (2, p. 7), (5). Due to the current legal framework and military pushback, it is unlikely that the civilian ONPLC is allowed to build up integrity or counter corruption in the defence sector.

Since no institution is explicitly mandated to counter corruption in the defence sector, no assessment on independence can be made and the indicator is scored “Not Applicable”.
The ONPLC is supposed to implement the national strategy on corruption but its mandate does not seem to extend to the defence sector (1), (see the answer to question 8A). According to Yazbeck, the military, “has rejected any civilian effort to oversee internal military affairs, define national security policy, make military officers accountable to civil courts, or diminish the military’s political functions” (2, p. 7).

Since no institution is explicitly mandated to counter corruption in the defence sector, no assessment on independence can be made and the indicator is scored “Not Applicable”.
The ONPLC is supposed to implement the national strategy on corruption but its mandate does not seem to extend to the defence sector (1), (see the answer to question 8A). According to Yazbeck, the military, “has rejected any civilian effort to oversee internal military affairs, define national security policy, make military officers accountable to civil courts, or diminish the military’s political functions” (2, p. 7).

There is no institution in place specifically tasked with compliance and ethics throughout the defence sector, and so far, there is no evidence of efforts to establish such a unit (1).

Moreover, the Security Bureau of the Presidency (SBP), established in the 1990s as the Military Bureau of the Presidency, has existed as a powerful parallel military and intelligence structure that is accountable to the president only (2), (3). The new president, João Lourenço has by decree confirmed the same core functions and role of the SBP.

According to an Institute for Security Studies (ISS) (2017) report, “Incoming President Joao Lourenco will need to institute difficult economic reforms and restore the functioning of key state institutions. Reforming the security apparatus will be a challenge if Lourenco wants to streamline command and control and professionalise the sector … the fragility of the security apparatus needs to be addressed. Corruption and opaque arms procurement deals need to be curtailed; defence spending requires oversight.” (1). This indicates a lack of professionalism, continued corruption, and a lack of oversight or order in the sector.

There is no institution in place tasked with compliance and ethics within the defence sector (1), (2), (3). Thus, this indicator has been marked Not Applicable.

According to an Institute for Security Studies (ISS) (2017) report, “Incoming President Joao Lourenco will need to institute difficult economic reforms and restore the functioning of key state institutions. Reforming the security apparatus will be a challenge if Lourenco wants to streamline command and control and professionalise the sector … the fragility of the security apparatus needs to be addressed. Corruption and opaque arms procurement deals need to be curtailed; defence spending requires oversight.” (1). This indicates a lack of professionalism, continued corruption, and a lack of oversight or order in the sector.

There is no institution in place tasked with compliance and ethics within the defence sector (1), (2), (3). Thus, this indicator has been marked Not Applicable.

According to an Institute for Security Studies (ISS) (2017) report, “Incoming President Joao Lourenco will need to institute difficult economic reforms and restore the functioning of key state institutions. Reforming the security apparatus will be a challenge if Lourenco wants to streamline command and control and professionalise the sector … the fragility of the security apparatus needs to be addressed. Corruption and opaque arms procurement deals need to be curtailed; defence spending requires oversight.” (1). This indicates a lack of professionalism, continued corruption, and a lack of oversight or order in the sector.

There are units responsible for promoting transparency in defence institutions, both within the Ministry of Defence and the Directorate General for Integrity, Transparency, and Institutional Strengthening, and the Internal Audit Unit and the General Inspections of each Force; as well as outside, including the SIGEN, the Anti-Corruption Office (dependent on the Executive), and the AGN (dependent on Congress). Personnel and funds are generally consistent with the operation, with no evidence to the contrary. The Directorate General for Integrity, Transparency, and Institutional Strengthening has the primary responsibility for assisting the Legal Undersecretary and Institutional Art in the design, development, and implementation of public policies that strengthen integrity and public ethics, accountability, open government, access to the information, transparency, and the prevention of corruption in the field of jurisdiction, as well as in the administration of a dashboard that provides the centralised information from the Armed Forces and the projects and programmes to be executed in the jurisdiction within each of the Secretariats and Undersecretaries of Jurisdiction. It has a telephone number to make complaints in cases of corruption. Regarding the funds and personnel, these are contemplated within the budget of the MINDEF, which in 2019 corresponded to 0.06% of the Ministry’s own structure, although it is not possible to specify how much is directly distributed to these units, nor the total number of staff. [1] With respect to institutions outside the Ministry, SIGEN and AGN have extensive control and supervision functions over all agencies dependent on the national administration, including therefore defence and security institutions, as per Law 24,156. They have financial autarky and trained personnel. The budget of the SIGEN for the year 2019 represents 0.71% of the budget allocated to the entities dependent on the Presidency of the Nation. AGN represents 9.64% of the budget of the legislative branch. [2] [3] [4]

As part of the ministerial structure, the independence of the General Directorate of Integrity, Transparency, and Institutional Strengthening and the Internal Audit Unit is limited both in terms of resources and personnel (the approval of this is through the Directorate of administration). In addition, the holder of the Internal Audit is appointed as of 2018 by the General Trustee of the Nation. External control by other State agencies, such as AGN and SIGEN, is normatively independent and self-sufficient. The AGN has had constitutional status since 1994, although so far the law regulating its operation has not been approved. [1] An SAIJ report considered that the main weaknesses that affect the effectiveness of the work of the AGN are: “a) Lack of independence from the governing party. Although in the spirit of Article 85 of the CN, the AGN must be led by the opposition, in practice the College is composed of seven members with similar faculties, four of which (the majority) were proposed by the ruling party. This makes the political force occupying the Power Executive is able to form the will of the control body; b) A lack of powers to carry out ex ante or concomitant controls.” In the case of SIGEN, the SAIJ points out that its main problem is the total lack of independence from the Executive Branch, where the General Trustee is appointed and removed at the discretion of the President of the Nation, and the Internal Auditors, although they depend “technically” on the SIGEN, hierarchically they depend on the highest authorities of the organisations and entities which they control. Likewise, the Anti-Corruption Office declares that it depends directly on the Minister of Justice and Human Rights of the Nation, so it lacks independence from the highest authorities of the Executive Power. [2]

The personnel in these control units, both internally and externally, understand the risks of corruption, but across public administration. Personnel trainings exist, but they are not mandatory and there is no evidence that there are specific institutional plans on corruption risks within the control institutions. The trainings are given at the Higher Institute of Public Management Control (ISCGP) which depends on the SIGEN and provides both specialisation careers in auditing and updating programmes related to current regulations and processes. It even has a virtual campus. The Anti-Corruption Office also offers training in topics related to public ethics and integrity for public and private sector organisations. AGN has a Virtual Classroom that provides virtual and face-to-face training in audit matters. [1] While there are no plans, external control agencies have action codes or action plans. In the case of SIGEN, it has an internal code of ethics that regulates personal and professional conduct based on principles of transparency and integrity. [2] The AGN, for its part, has an Institutional Strategic Plan (PEI) for the 2018-2022 period in order to generate efficient performance and better good governance practices. [3]

The Ministry of Defence (MoD) Human Rights and Integrity Centre was established to ensure human rights and strengthening integrity (anti-corruption behaviour inclusive) within the MoD. The Human Rights and Integrity Centre is authorized to initiate, organize, implement, monitor and evaluate programs promoting human rights and integrity both within MoD and through international partnerships. There has been no comprehensive document addressing corruption risks and behaviour within the MoD so far [1]. The Internal Audit Division operates within the MoD [2]. As for external agencies, there is an Armenian Audit Chamber [3].

The Human Rights and Integrity Centre of the Ministry of Defence (MoD) of the Republic of Armenia has been operating since 2015. It is a subdivision adjunct to the minister of defence and is directly accountable to the minister of defence [1]. Its main tool is a hotline; during the first half of 2018, 16116 calls were received, the majority of calls were about information issues [2]. According to the new Statute of the Ministry of Defense, approved by the RA Prime Minister’s Decree N992-L of July 25, 2019, the MoD Human Rights and Integrity Building Centre (HRIBC) is a specialized structural unit of the MoD, and its activities cannot be suspended by the order of the Minister of Defense. The Centre’s objectives are to coordinate the process of strengthening human rights and integrity in different units of the MoD and the Armed Forces of the Republic of Armenia, to establish proper control over the fulfilment of commitments in the field of human rights and good behaviour, to introduce new methods of governance based on human rights and good behaviour value systems; basing on the concepts of military leadership and mission command [1].

The Human Rights and Integrity Centre addresses operational evaluation concerning the human right abuses in the defence sector, it may provide methodological intervention and suggest measure to overcome the situation [1]. The centre has eight employees who are stationed in the military and civilian positions. Three of the employees carry out the functions of the hotline operator of the MoD. All employees of the centre participate in training courses on integrity, fight against corruption and human rights issues. The courses are mainly organized within the framework of international cooperation of the MoD (NATO, CoE, OSCE). The head of the centre is a lawyer by profession, who also has a PhD in Political Science, whose academic interests include the issues of civilian control over the armed forces and the strengthening integrity in the defence system. The staff of the Human Rights and Integrity Centre has no opportunity to neutralize corruption risks independently. It transmits information to the Military Police (MP) on the incident received by hotline, and cases involving elements of apparent corruption offences through the whistleblowing system, as well as reports to the minister of defence. The MP’s conduct a comprehensive investigation of the submitted reports and informs the head of the centre about the results, which is also responsible for the internal and external whistleblowing of the MoD. Those who have been found guilty based on reports submitted through the hotline are subject to liability. The centre, on the instruction of the minister of defence, implements unannounced visits to various subdivisions for operative assessment of the human rights and good behaviour of the defence sector or the specifically targeted issues. The centre also carries out complex studies and presents recommendations based on the results. It provides consultations on anti-corruption actions, human rights and anti-corruption activities, as well as examining normative-legal acts related to the defence sector in terms of human rights and good governance (including prevention and disclosure of corruption) and provides assistance to the development conceptual documents of the defence sector, curricula, and review and reform of normative-legal acts [2].

The Department of Defence has an internal Audit and Fraud Control Division (AFCD), which is constituted of the Audit Branch, which performs internal audits, and the Fraud Control and Investigations Branch, which provides assurance and advice to the senior-most officials of the Department of Defence, writes the Fraud Control Plan, promotes ethical use of government resources, and conducts investigations into serious breaches, including corrupt practices [1]. The mandate of the AFCD includes promoting and overseeing integrity and anti-corruption efforts. The Defence Annual Report says that Defence has a “mature fraud and corruption control plan,” presumably administered by AFCD, and engages in “the promotion of integrity and development of a strong ethical culture” [2]. Other internal and external institutions provide extra capacity to Defence’s ethics and fraud control program. The Defence Annual Report also speaks of an internal Ethics Advisory Service [2], though it is unclear what exactly it involves (the Australian Public Service Commission has a government-wide Ethics Advisory Service which can be used by public servants to “discuss and seek advice on ethical issues that occur in the workplace” [3]). The internal military justice division investigates and prosecutes offences by personnel, with a special focus on fraud offences [4], which often overlap with corruption-related offences. Within the Department of Home Affairs, under which many of the security services fall, the integrity and professional standards framework led by the Integrity and Professional Standards Branch is wide-ranging and well-documenting [5]. The Australian Federal Police host a Fraud and Anti-Corruption Centre, which include Defence participation and aims to “strengthen law enforcement capacity to respond to serious and complex” corruption-related crimes [6]. In early 2019, after considerable public debate, the government has proposed a national anti-corruption agency it calls the “integrity commission,” however, this has not yet come into fruition and the initial proposal has been criticised as weak in power and low in resources [7]. Multiple attempts to reach officials with the AFCD to inquire about their resourcing and level of authority by the Country Assessor were unsuccessful, and there is no comprehensive accounting of this in any public records, making a score of 3 appropriate.

The First Assistant Secretary Audit, at the head of the Defence Audit and Fraud Control Division, reports directly to the Secretary Department of Defence, Defence’s senior-most non-political civilian official [1]. The external Australian Federal Police (AFP)-hosted Fraud and Anti-Corruption Centre is also outside of the Defence chain of command, reporting to senior AFP officials [2].

The Defence Audit and Fraud Control Division (AFCD) are able to carry out audits/investigations and give recommendations, run awareness campaigns, and give training, but their level of resourcing is unclear and they cannot compel other departments to follow advice or recommendations. Oversight of Defence corruption issues is the responsibility of AFCD, and is done through internal audits – which are not publicly released – and fraud investigations, for which basic statistics are available in the Defence Annual Report [1]. These audits and investigations, while focused on fraud, do investigate corruption-related issues. An internal audit was released, heavily redacted, to investigative journalists. This was in response to a Freedom of Information request attempting to confirm a whistleblower’s claim, first reported in the Service newspapers, that several Defence procurement personnel had created positions for themselves at contracting companies, then granted contracts to those companies. These personnel had allegedly quit Defence, and subsequently joined the companies in their tailor-made positions [2]. The accusations were not substantiated, though other shortcomings in Defence procurement were revealed and AFCD made recommendations that these be addressed [3]. However, these recommendations appeared rather soft based on the weight of the accusations and ultimate findings, and it is unclear if they were ultimately followed by units within Defence. The AFCD also apparently failed to stop or detect that the Department of Defence procured materiel from a firm that had been publicly blacklisted for corrupt activities by the US Department of Defence [4]. The AFCD also develops training modules in “ethics and fraud awareness,” [5] described by the Defence Annual Report as “mandatory and focused” [1, p71], though it is unclear to what extent these focus on corruption-related issues, as the Country Assessor was unable to secure comment from AFCD officials.

In general, there are no independent, well resourced, and effective institutions within the defence and security sector that are tasked with building integrity and countering corruption. However, over the last few years, there has been some evidence showing efforts to establish independent institutions within the Defence Ministry, i.e. investigation units (1).

Speaking with regards to the establishment of the new investigation units, MP Zahid Oruj said that their purpose is to limit the subjectivity of military prosecutors (2). According to an official for the Defence Ministry, the establishment of investigative bodies in the Defence Ministry system was a necessary and good step (3).

In addition to this, the Chamber of Accounts has previously conducted and investigation of the Defence Ministry’s units (4), and the Ombudsman also has cooperation with Defence and security institutions (5). The Ministry of Internal Affairs and the State Security Service also have the authority to pursue corruption cases. Internal investigation bodies also operate within the Ministry of Justice, the State Customs Committee, and the State Border Service (6).

There is no information about the activities of these investigative bodies within the Defence Ministry for the last four years. According to the Chief of the Legal Department of the MoD Rauf Kishiyev (2014), work is underway to improve the activities of the investigative bodies, “For example, in May of this year (2014), according to the decision of the Defence Minister, a new decision was made to regulate the conduct of investigative bodies and the conduct of service investigations, which determines the mutual activities the investigation authorities and military units” (1). However, according to some experts (Alakbar Mammadov), the organization of these bodies is formal. “As for the quality issue, it will serve to cover up the lawlessness” (2).

There is no information about the activities of the new investigation units within the Defence Ministry (MoD). External organisations, such as the Chamber of Accounts investigate the MoD’s units (1). Civilian Ombudsman agreed with the Ministry of Defence, the Civil Defence Troops of the Ministry of Emergency Situations and the Interior Troops of the Interior Ministry on the cooperation plan (2). According to experts, all these investigations are not effective and the results of these investigations are not transparent. In many institutions that are part of the defence sector, the staff within the units understand the corruption risks specific to their institutions, but they are failing to prepare an effective action plan with appropriate risk mitigation measures. This was acknowledged in an interview with an MoD representative.

There are no anti-corruption or ethics units within the Ministry of Defence (MoD) [1]. One source said there was an idea of establishing a moral and ethics unit within the army, but it was abandoned, it has nothing to do with corruption [2, 3]. Currently, there is an internal financial auditing unit that is part of the procurement process (mainly delivering) and salaries.

As outlined in 8A, no unit or institution has a mandate to build integrity and countering corruption in the MoD. As such, this indicator has been marked ‘Not Applicable’ [1, 2, 3].

As outlined in 8A, no unit or institution has a mandate to build integrity and countering corruption in the MoD. As such, this indicator has been marked ‘Not Applicable’ [1, 2, 3].

Both the Ministries of Defence [1] and Home Affairs [2] have ethics committees and NIS Focal Points, consisting of regular first-class officials and funded using the revenue budget. Given the absence of publicly available information about the number of designated staff working in these units, it was not possible to ascertain whether sufficient staff are deployed in these units. From the Ministry of Defence’s 2020-21 Annual Work Plan [3], it was found that only Taka 300,000 (USD 3,530) was allocated for the implementation of NIS unit activities. However, there is no public data suggesting that the allocated amount was fully spent, that some portion was returned unspent or that additional money was allocated for the full implementation of the plan.

The Ministry of Defence has its own ethics committee and tasks are performed under the National Integrity Strategy [1]. The ethics committee reports back to the Secretary of the Ministry. The committee’s independence is limited due to the overarching influence of the Chief Executive.

Committee members may be cognisant of specific corruption risks, however, they are unable to address risks adequately [1] or blow the whistle [2].

There are identifiable compliance and ethics units within defence and security. Within Belgian Defence, any claim of corruption can be handled by the General Inspectorate, whose mission it is to ‘serve as the moral compass of Defence, show integrity and respect when handling complaints and when carrying out targeted investigations to malfunctions and issues within Belgian Defence’ [1].

On procurement specifically, the Deontology Office is responsible for ensuring complyence with the Code of Conduct [2]. Laslty, if needed, the Belgian Defence’s legal division (DG Jur) also handles integrity and corruption case [3]. Belgian Defence’s issue of underfunding and understaffing may impact smooth sailing in these units. Defence is currently recruiting intensely to remedy personnel shortages.

The General Inspectorate and Directorate General of Judicial Support (DG Jur) reports directly to the Chief of Defence [1, 2]. Their existence is officialised by the Royal Decree of 2 December 2018 and can thus not be shut down without legislative amendments.

Public servants, including members of Defence, need to abide by the federal Deontological Framework [1]. Moreover, Belgian Defence has a code of conduct in place to counter corruption [2]. Each member of Defence, both civilian and military, is supposed to understand and handle corruption risk. The code of conduct is explained in training, for example during the continuing education for officers or when being assigned to a post directly or indirectly related to procurement [3].

There is a specialized organisational Unit named General Inspectorate in the Ministry of Defence of Bosnia and Herzegovina (MoD) which in accordance with Chapter VII, Article 54, paragraph 2, subparagraph B, of the Law on Defence of Bosnia and Herzegovina is authorised to conduct various educations on ethical behaviour and professionalism and oversee and launch an inquiry on (any) misconduct of military personnel. The law specifically names the misconducts in regards of conflict of interest and non-professionalism (as stated in articles of Chapter VI of the Law) as well as the Code of Conduct and other rules adopted by the minister [1]. The Code of Conduct explicitly forbids any attempts to bribe or extort bribery [2]. The General Inspectorate is suitably staffed following the Rule Book on Internal Organisation and it is financed from the budget allocated to the MoD [3]. In addition to the General Inspectorate of the Ministry of Defence, the inspectors are involved in the commands of units of the operative rank and brigades – two formation positions, in each, are planned within the Operational Command and Support Command and one formation position in each of the five brigades of the armed forces (4th Infantry Brigade, 5th Infantry Brigade, 6th Infantry Brigade, Air Force and Air Defence Brigade and Tactical Support Brigade) [4].

According to Article 54 of the Law on Defence of Bosnia and Herzegovina, the General Inspectorate is an organisational unit within the Ministry of Defence [1]. As it is presented on the organisational chart of the Ministry of Defence, the General Inspectorate is directly under the defence minister [2].

Through information obtained through a telephone conversation with the general inspector, the General Inspectorate of the Ministry of Defence (MoD) is composed of inspectors whose working places are professionalized [1]. The General Inspectorate has actively participated in the process of production of the Plan for Integrity and Fight Against Corruption of the Ministry of Defence of Bosnia and Herzegovina for the period 2015 to 2019 [3]. The General Inspectorate holds training on issues of professionalism, ethic and the fight against Corruption [2]. An example proving the capability of the MoD General Inspectorate to address the corruption risks specific to its institution is the number of investigations conducted in the period 2016-2018 [3]. Namely, in the listed period six reports of irregularities related to public procurement (requests for engagement of an inspector related to the alleged failures of members of the commission, as well as alleged irregularities related to the execution of the contract, etc.) were submitted to the MoD General Inspectorate and all of them were found to be grounded [3]. In all six cases, the General Inspectorate issued recommendations for the remedy of the irregularities [3]. The review of the actions taken because of the recommendations given in these cases was that three recommendations in respect to three cases were taken by the competent authorities while three recommendations concerning three other cases are currently in the process of taking the necessary steps [3]. A leaflet that was prepared by the General Inspectorate and delivered to all members of the Armed Forces of Bosnia-Herzegovina instructing the members of Armed Forces of Bosnia and Herzegovina to report “fraud or corruption” in the MoD and the branches of the military. There was also an alleged case of misuse of military helicopters in 2019, reported to the General Inspectorate by a whistle-blower when he or she purportedly sent photographs of helicopters being misused [3]. The General Inspectorate found that the photos were of military helicopters made in 2011 and that these helicopters are not in use anymore [4].

There is no specific unit within the Defence services sector that is independent and well-resourced. Effective institutions, within defence and security, are tasked with building integrity and countering corruption. However, other relevant authorities in preventing and countering corruption include the Directorate on Corruption and Economic Crime (DCEC), Directorate of Public Service Management (DPSM), Office of the Ombudsman, Office of the President, Auditor General, Public Procurement and Asset Disposal Board (PPADB), Ministry of Finance and Economic Development (MFED), Financial Intelligence Agency (FIA), Bank of Botswana, Botswana Unified Revenue Services (BURS), Non-Banking Financial Regulatory Authority (NBFIRA), Police Service, Administration of Justice, Directorate of Public Prosecutions (DPP), Attorney General’s Chambers and Competition Authority. Generally, these institutions are well resourced [1,2,3,4]. The mandate of these institutions is not exclusive to BDF or the Defence sector, but rather in terms of their work, they extend to the BDF and Defence Sector.

The institutions outlined in 8A are not within the Defence department. However, these are the institutions that are responsible for dealing with issues of corruption and integrity in the Defence department [1]. These institutions are generally independent in terms of their Constitutional mandates [1]. The independence of DCEC and its relationship with Defence and Security remains a thorn in the flesh for Botswana [2]. It has been observed that the Minister of Presidential Affairs and Public Administration, Nonofo Molefhi, said in parliament that “there is no need to move the Directorate of Intelligence and Security (DIS) and the Directorate on Corruption and Economic Crime (DCEC) from the Office of the President (OP).” The reason offered by Nonofo Molefhi in this respect is that “.DIS and DCEC still retain their independence even under the watch of the Office of the President” [2]. He further argued that the process to return them to the Ministry of Defence, Justice and Security where they were originally housed would be labouring [2].

Generally, the institutions are run professionally and they always endeavour to improve their operations [1]. However, their work on Defence is not made public to allow the public to make its own determination [1]. This gap has been acknowledged and remarks as follows: to implement the country’s anti-corruption policies and address the findings of the external assessment, the Directorate on Corruption and Economic Crime (DCEC), as the lead agency in the prevention and fight against corruption, has developed Strategic Plans to guide its work for the periods 2010-2016 and 2016-2021, which stipulate the direction of the anti-corruption discourse [2,3 ]. The DCEC is allocated a combined recurrent and development budget amounting to USD 7,000,000.00 on an annual basis to implement the country’s anti-corruption policies [2]. Staff are generally trained in corruption e.g. the DCEC conduct corruption training and workshops on the BDF Staff. There is no public information about whether staff understand the corruption risks specific to defence.

The Union Court of Auditors (Tribunal de Contas da União) (TCU) is an important institution of external control in Brazil that has powers to audit the accounts of the Ministry of Defence, the Army, the Navy and the Air Force. TCU is well funded and suitably staffed through highly competitive civil service exams. The TCU has a specific committee responsible for national defence (Secretaria de Controle Externo da Defesa Nacional e da Segurança Pública) [1] and has released reports related to the Programa de Desenvolvimento de Submarinos (PROSUB) (the Brazilian Nuclear Submarine Development Program) [2]. The single forces’ internal control agencies have a strong relationship with the external control institutions such as the TCU. This relationship and its nature has been documented by researchers in Brazil [3] and has already been the subject of symposiums [4]. The TCU searches, not only for the integrity of the accounts but in the case of the PROSUB report, it aimed to verify if the project’s transfer of technology was being conducted properly. There is also the Military Public Ministry, which is an independent agency linked to Military Justice, which can investigate any complaint and also prosecute military officials involved in irregular and illegal activities [5]. According to the response to a Freedom of Information Act (FOIA) request, the TCU analysts have the right to have access to and to evaluate the Force’s methodology for analyzing projects. When needed, they can have access to special orientations in specific areas to undertake the assessment, process which includes defence matters [6]. The Federal General Comptroller (CGU) is not responsible for auditing the Ministry of Defence. The Secretariat for Internal Control (CISET) is responsible, according to the Ministry of Defence Integrity Plan [7], confirmed by an FOIA request. This secretariat communicates with CGU when necessary. That is why the previous assessor could not find audit reports on the Ministry of Defence on the CGU’s website.

The TCU is independent of the three branches of government. Its independence is established by the Constitution [1].

According to an interviewee [1], generally, the Military Justice and the Military Public Ministry tend to have a corporatist behaviour towards the armed forces, which probably undermines the investigations of all the complaints and poses challenges to set a list of anti-corruption actions. This interviewee even questioned the will of TCU to investigate some cases – due to the rules for the composition of its ministers, which are primarily political. However, and despite the apparent time irregularity of TCU’s reports on defence, all the available reports seem consistent and consistent with good practices in external control. According to FOIA Request No 321020, the following are reports that can be found by their code in TCU’s website: TC 014.387/2014-0, 025.650/2014-9, 029.775/2016-7, 020.474/2017-2, 030.452/2019-8 and 031.659/2019-5.

There are no existing formal institutions within the defence sector with full corruption countering attributions and mandate. The gendarmerie is supposed to investigate cases of corruption within the security and defence sector; its reports are not made public (1).

However, the High Authority for State Control and Anti-Corruption (ASCE-LA), has recently been given power, with a nationwide mandate to prosecute cases of corruption in any government institution, including the defence sector (2), (3). Even though the ASCE-LA has been provided with financial autonomy, there is no evidence that it has enough resources to perform well its mandate (3). The UNODC report (2018) states, “the budget of ASCE-LC is set under law at 0.1 per cent of the national budget, which should ensure the Authority’s independence and adequate funding (art. 59 of Organic Act No. 082-2015). In practice, however, the narrow interpretation of the budgetary provisions results in inadequate budget allocations” (4).

There are no existing formal institutions within the defence sector with full corruption countering attributions and mandate. The gendarmerie is supposed to investigate cases of corruption within the security and defence sector, but its reports are not made public (1).

The Office of the Inspection General (OIG) (2), as well as a “Contrôle général d’Etat” (The State General Control), the Gendarmerie nationale and the Military Justice have theoretical competencies to investigate possible corruptions cases. However, these institutions have no special mandate on corruption and are not independent institutions mandated to fight against corruption. The UNODC (2018) report states, “the budget of ASCE-LC is set under law at 0.1 per cent of the national budget, which should ensure the Authority’s independence and adequate funding (art. 59 of Organic Act No. 082-2015). In practice, however, the narrow interpretation of the budgetary provisions results in inadequate budget allocations” (3).

There are no existing formal institutions within the defence sector with full corruption countering attributions and mandate. The gendarmerie is supposed to investigate cases of corruption within the security and defence sector, but its reports are not made public (1). However, the High Authority for State Control and Anti-Corruption (ASCE-LA), has recently been given power, with a nationwide mandate to prosecute cases of corruption in any government institution, including the defence sector (1), (2). Even though the ASCE-LA has been provided with financial autonomy, there is no evidence that it has enough resources to perform well its mandate (2). The UNODC report (2018) states, “the budget of ASCE-LC is set under law at 0.1 per cent of the national budget, which should ensure the Authority’s independence and adequate funding (art. 59 of Organic Act No. 082-2015). In practice, however, the narrow interpretation of the budgetary provisions results in inadequate budget allocations” (3).

The Ministry of Defence has an anti-corruption unit which oversees issues of corruption at the level of the ministerial department [1]. The country has several other oversight bodies which equally oversee corruption at the level of the different ministerial departments [2] [3]. The National Anti-Corruption Unit became operational in 2011 with a mandate to fight national corruption. The Superior State Audit Office (also know as the Ministry of Higher State Control)has a mandate to audit state institutions. There also exist the Finance and Budget Disciplinary Council and the Audit Bench of the Supreme Court [1]. However, these oversight bodies do not have the mandate to engage the defence and security sector in issues dealing with corruption [1].

The only structure that engages the Ministry of Defence in corruption-related issues is Military Security (SEMIL) which is in charge of countering corruption and is part of the Ministry of Defence. However, there is no information available on whether this body has the required staff and resources to address corruption within the military [1] [4].

Although there are several mechanisms for countering corruption in the country, the defence and security institutions are not usually subjected to oversight and independent structures [1]. Military Security (SEMIL), which is in charge of countering corruption, is part of the Ministry of Defence [2]. The Ministry of Defence also has an anti-corruption unit [2]. However, there is no evidence that these bodies are independent as they fall under the authority of the Ministry of Defence and are answerable to the Minister of Defence with no other oversight body over the Ministry of Defence [2]. The President of the Republic is the commander-in-chief of the armed forces and he governs the military and security sectors by decrees that are not subject to any independent oversight body [1]. The Minister of Defence and the Delegate General in charge of national security are appointed by the President of the Republic and can be dismissed without cause. Both of them implement the defence and security policies and are solely and directly answerable to the President of the Republic. The National Anticorruption Commission (CONAC) is said to be the country’s principal independent anti-corruption agency; yet it is subservient to the president and so lacks autonomy [3].

According to the United States Department of State and a senior military officer at the Ministry of Defence, there are mechanisms, including SEMIL and ‘Policing the Police’ (where police officers on check points are being checked by other police officers to monitor and investigate corruption and abuse), which have been put in place to address issues related to corruption within the military police [1] [2]. The Secretary of State for Defence and the Minister Delegate at the Presidency are assigned with the task of sanctioning abusers [2]. Cases of aggravated theft, criminal complicity, murder and other serious offences are sent to the criminal court [2]. In 2016, the National Delegation for Security and Gendarmerie carried out investigations and cases were forwarded to court. Lesser offences are handled internally and at different levels based on the category of the offence [2] [3].

The U.S. Department of State (2018) reports that “The national gendarmerie and the army have special offices to investigate abuse and corruption. The government has some mechanisms in place to investigate and punish abuse and corruption. The DGSN and gendarmerie have investigated reports of abuse and forwarded cases to the courts. Lesser sanctions are handled internally. The DGSN, Ministry of Defence, and Ministry of Justice have stated that members of security forces were sanctioned during the year for committing abuses, but few details are known about investigations or any subsequent accountability. The secretary of state for defence and the minister delegate at the presidency are in charge of prosecuting abusers. The minister delegate of defence refers cases involving aggravated theft, criminal complicity, murder, and other major offences to the military courts for trial… Military courts may exercise jurisdiction over civilians for offences including the following: offences committed by civilians in military establishments, terrorism, piracy… The law provides criminal penalties for corruption by officials, but the government did not implement the law effectively and often used it to settle political scores. The penal code identifies different offences as corruption, including influence peddling, involvement in prohibited employment, and non-declaration of conflict of interest. Reporting of corruption is encouraged through exempting whistleblowers from criminal proceedings. Nevertheless, corruption has remained pervasive at all levels of government” [2].

The Chief Review Service (CRS) is one of two major groups within the Department of National Defence (DND) tasked with enforcing ethics and corruption guidelines and laws. [1] The other is the Canadian Forces Military Police Group, whose National Investigative Service carries out investigations into possible offenses within the DND and involving DND property, assets, or people subject to the Code of Service Discipline (which includes civilians). Military Police Institutional Operations were, according to the 2018-2019 DND Departmental Plan, held constant in terms of funding and staffing year on year. However, these numbers are not published, so it is difficult to determine their adequacy. [2] [3] External to the DND, the Royal Canadian Mounted Police has a National Division, which unlike other divisions has no geographic mandate but investigates domestic and international corruption, including that involving government agencies. However, staffing, resourcing, and expertise in the DND units is unclear. [4]

The CRS reports directly to the Deputy Minister of the DND. The Canadian Forces Provost Marshal is a Brigadier General who reports directly to the Chief of Defence Staff. The RCMP and its investigations into corruption or crime within government departments is administratively entirely separate from those departments, including the DND. [1] [2]

The Provost Marshal/Canadian Military Police Group and the RCMP are investigative units not mandated with addressing risk proactively, as compared to investigating reactively. The Chief Review Service is empowered to carry out audits and evaluations proactively, and to make recommendations involving training, oversight, and changes to policy, which a survey of their recent reports and audits reveals they include in the great majority of their evaluations. [1] [2] The RCMP’s webpage on corruption includes the statement ‘prevent corruption by reporting it’ which reiterates the reactionary nature of the issue amongst policing forces. Given recent stories of corruption/collusion in other police forces (on various scales) it is unclear whether policing units are sufficiently aware of the potential for corruption within their organisations. [3] [4]

While some compliance and ethics units have been identified in the defence sector, there are important weaknesses in their mandate and little evidence of adequate expertise. The Ministry of National Defence (MDN) has a Division of Audit [1], which takes care of the preventive financial and functional control in the MDN. It monitors the accomplishment of observations made by the General Comptroller and coordinates internal audits in the bodies and institutions of the Ministry and the defence sector. The division is organised in the Department of Internal Audit and the Department of Internal Control [2]. However, there is almost no information on the degree to which these units accomplish their mandate. On the other hand, the MDN created an External Audit Committee formed by the chief of defence and armed forces (Subsecretarios), the ministerial chief of audits, and a member of the Committee of General Internal Audit [3]. However, beyond the functions of auditing and internal control, these institutions do not have specialised functions in guarantying integrity and transparency in the armed forces and the MDN. Likewise, there is no evidence of adequate expertise in the control of corruption.

The internal units in the MDN and the armed forces lack sufficient independence, for they are integrated by members that are in the chain of command of institutions that they oversee. The chief of the division of audit is a permanent member of the ministerial staff (Gabinete) and advises the ministers in all matters related to financial and functional preventive control in the institution. The chief of the division reports directly to the chief of staff (subsecretario) in the audit and/or control of administrative and financial acts in the defence sector [1]. Likewise, the External Audit Committee does not show enough independence, for it is formed by the chief of defence and armed forces (subsecretarios) of the MDN. These bodies are established by law, and there is no legal provision that would allow them to be shut down [2, 3]. However, due to their lack of independence from the institution they oversee, the law does allow them to be manipulated.

There is no evidence that institutions of internal control and audits within the Ministry of National Defence are thoroughly staff and trained to tackle corruption; although, in recent years, some advances have increased the awareness of corruption risks specific to defence and procurement areas. For one, departments of internal control and audits in the MDN were legally designed to address the preventive financial and functional control of the MDN, but not specifically to control corruption and building integrity [1]. On the other hand, these institutions have had a reactive rather than a proactive role in controlling corruption. This has been observed in recent cases of fraud in the army and the misappropriation of resources of the Restricted Copper Law. The Commissions of Investigation emphasised that, although the irregularities were detected by the Army itself, this was done late [2]. In its account of the case, the Comptroller General of Chile (CGR) underscored the deficiencies of the internal control mechanism in the armed forces, particularly in the Chilean Army. Finally, it is worth highlighting some advances in the development of risk maps in the armed forces, which would have a preventive nature, and the strengthening of the internal control, audit and procurement units [3].

Anticorruption in China has a different rationale and institutional design than in the West. China’s anticorruption is not based on the rule of law and the separation of powers but on the idea of discipline and administrative subordination to the Communist Party. As such, anticorruption institutions are not politically autonomous and organisationally independent from the Party. [1] The CCP has its own organ, the Central Commission for Discipline Inspection [2] that, until recently, was the main anticorruption agency in the country. In 2018, the National Supervision Law introduced a new centralised structure that aimed at subsuming the CCDI and local-level Discipline Inspection Committees, and reducing the influence of horizontal political networks by local politicians. However the logic of anticorruption remains the same: no political or organisational autonomy so that the CCP can direct its work and findings according to its own political priorities. [3] In the People’s Liberation Army the same rationale of anticorruption as a politicised area of work also applies. The CCP controls China’s Armed forces through the Central Military Commission (CMC) that brings together top generals and party cadres under the leadership of the CCP General Secretary. The CMC has its own Discipline Inspection Commission (军委纪委) structure. Although the DIC has a broad mandate to fight corruption, its work is heavily conditioned by the regime’s political priorities.

Discipline Inspection Commissions in the Army are under the political control of the Party. This is not a failure in the system but the product of organisational design. [1] In 2016, as part of a broad restructuring of the CMC, the Discipline Inspection Commission’s status was elevated as it was placed directly under the Party-controlled CMC. [2,3] This means that the CCP is now in a better position to centrally direct anticorruption efforts in the CCP. Previously, the system was such that political influence on anticorruption work came from actors placed in both horizontal and vertical administrative units in the Army. From 2016 the ability of same-level party committees and individual officers to influence the work of Discipline Inspection Committees is reduced, but the political influence of the centre is even stronger than before.

Measuring effectiveness when the political influence on anticorruption efforts is strong and institutionalised is difficult. There is clear evidence of specialisation of Discipline Inspection Commissions, and, since 2012, they have an impressive enforcement record: DICs have captured more than 200 senior army officers, including top generals and former CMC members that were previously deemed untouchable. In addition DICs have been reinforced institutionally and materially. [1,2] According the China’s most recent Defence White Paper: “Since 2012, they have carried out audits over 39,000 units and 13,000 PLA and PAP officers in positions of leadership at and above regiment level”. [3]

There is not enough information to score this indicator. The Colombian legislation clearly stipulates that internal control offices have the independence to carry out their audit work, to do so, their direct participation in the acts of the administration is avoided. The Ministry of Defence has an Internal Control Office that is independent and there is also a General Comptroller’s office. Article 12 of Law 87 of 1993, [1] establishes that ICOs must, among others, engage in oversight of procedures and activities of the organisation. The budgets do not specifically state how much money went into this entity or what is its level of staffing. There is no publicly available information on funding and staffing. Also, although there are no specifically independent institutions responsible for exclusively controlling MMFs, control bodies such as the Attorney’s Office, Comptroller’s Office, and Prosecution are responsible through advisory offices for security and defence issues for the role of such control.

With respect to the independence of officials of internal oversight offices, Article 8 of the Anti-Corruption Statute [1] mentions that appointments are made by the President of the Republic only for entities of the executive branch of the national order. These officials are thus accountable or subordinate to the President of the Republic, but not to the entities they supervise. However, the assessment of officials on their own performance remains with the Executive branch, as is the case in territorial entities, and there is no evidence of merit-based competition to fill these positions. In the case of territorial entities, these appointments are made by mayors and governors for a period of four years. According to Concept 166021 of 2014 [2] of the Administrative Department of the Civil Service, the head of internal control through its audit mechanisms must ensure its due independence and objectivity, avoiding direct participation in the administrative acts of the entities. This characteristic should not be confused with discretion, since this office must attend internal coordination processes in the entities. It should be added that at the national level, entities responsible for exercising control over all other state institutions have independence from the defence sector, and belong to other powers such as the legislative and judicial branches. Although internal oversight offices are not subordinate to the Military Forces it oversees, if internal reporting processes exist within the supervised entity, in many cases this will limit the oversight body’s ability to take action.

The Ministry of Defence, the Armed Forces and the Police understand the specific risks of corruption in their institutions, which is why they have created different actions and measures to address this phenomenon. This is the case of the Directorate of Application of Transparency Standards of the DANTE Army, created by a Working Table conducted by Central Command on 28 April 2016, by Ministerial Resolution No. 3402 Article 27, in Bogotá under the Second Command of the National Army (SECEJ). [1] Its objective is to “sensitize and prevent on issues of institutional transparency and the generation of methods of combating corruption,” [2] and its role lies in the application of standards and pedagogical processes of ethics and transparency. In consulting the progress and balance of the DANTE strategy, interviews conducted suggest that this strategy has managed to position itself at the strategic level of the Army, which allows direct access to all units and battalions to highlight transparency and morality with the Armed Forces; and also has promoted permanent training processes on related issues, and technical, legal, and financial accompaniments to all units that manage public resources, achieving prevention. [3] In the National Police, there is a Comprehensive Policy of Police Transparency (PITP), designed to fight against “conduct that affects morality, defining general guidelines in matters of ethics, discipline, human rights, conflict resolution and attention and service to the citizen.” [4] On the other hand, under Resolution 6302 of 2014, the Ministry of Defence established the Action Group for Institutional Transparency (GATRI) and a review committee of conventions and/or inter-administrative contracts. [5] These will have the function of monitoring and evaluating the procurement processes and management of the security and defence budget, in addition to financial controls. However, no further information is available on the progress made by this Group. While control mechanisms are stipulated and operational, corruption situations persist within the defence sector. Beyond existing regulations and bodies, the difficulty in combating corruption lies with the need to consolidate an anti-corruption policy at the national level, which transcends the transparency procedures of sub entities, and has a widespread and comprehensive “pedagogical program” installed from the centres of basic, secondary, and higher education, so that it is possible to train professionals and officials in the future. [6]

Most of the mandates of the units that target anti-corruption in Côte d’Ivoire extend only nominally to the defence sector. Additionally, the resources allocated by the Secrétariat National à la Gouvernance et au Renforcement des Capacités (SNGRC), tasked with endowing the units with public funds, remain unclear (1).

The broad-based anti-corruption units include:
– Plan National pour la Bonne Gouvernance et la Lutte Contre la Corruption (est. 2013)
– Brigade de Lutte Contre la Corruption, BLC (est. 2012)
– Haute Autorité pour la Bonne Gouvernance, HABG (est. 2014)

The anti-corruption entities that are specific to the defense and security sector include:
– Unité de Lutte Contre le Racket (est. 2012)
– Inspecteur Général des Forces Armées

The Brigade de Lutte Contre la Corruption (BLC) was established in 2012 within the Inspection Générale des Finances (IGF). In theory, it was set up to prevent corrupt behaviour based on reports of an incident. The BLC can carry out investigations with the resources provided by the IGF, which depends on the Ministry of Finance and Economy, and therefore on government funds. The independence of the BLC is compromised to the government’s willingness to fight corruption and promote transparency (1).

The Unité de Lutte contre le Racket was established in 2012 specifically to combat the bribery of police officers at roadblocks. Many roadblocks were set up illegally to extract bribes from drivers. According to a 2015 report by the US State Department, this anti-racketeering unit is underfunded and has not achieved its goal of ending illegal roadblocks because lower-ranking police agents are often complicit with higher-ranking officers. According to a 2015 report by Human Rights Watch, the country’s military courts have also proven ineffective in resolving the cases forwarded by this anti-racketeering unit (1).

Investigating financial crime falls within the mandate of the Audit Court (Cour des Comptes) and the Inspection Générale des Finances (IGF), mentioned above. The first is tasked with auditing all public expenditure (central government, state and regional entities), which in theory also include allocations to the Ministry of Defense and the Ministry of the Interior. However, the IGF depends on the budget of the Ministry of Economy and Finance and is specifically tasked with oversight of public monies to prevent fraud and expenditure irregularities. Both the Cour des Comptes and the IGF are allegedly underfunded, which constrains their independence and effectiveness (1).

The Haute Autorité pour la Bonne Gouvernance (HABG) was established in 2013 but was rolled out in 2014. Its mandate is to prevent corrupt acts and to carry out investigations on corrupt behaviour in all sectors of society identifying those responsible and their accomplices. It is tasked with publishing regular reports and to forward cases of corruption to the public prosecutor (Ministère Public). According to Global Integrity (AII 2016), it is still too early to decide about its level of autonomy and effectiveness. However, Freedom House stated in 2015 that the HABG does not dispose of enough resources (1).

In terms of effectiveness, the direct dependence on government funds and poor resource allocation means that the anti-corruption units and entities in Côte d’Ivoire can be characterized as mostly ineffective.

According to the Freedom House country profile for Côte d’Ivoire (2018), corruption and bribery remain endemic and “particularly affect the judiciary, police, and government contracting operations”. Freedom House adds that the perpetrators seldom face prosecution (1).

However, Freedom House also mentioned the soldier rebellion at their barracks in Bouaké in January 2017, which included raids against the police and Gendarmerie Nationale by unidentified soldiers. In October 2017, a top aide to the President of the National Assembly (Guillaume Soro) was arrested in connection with the soldiers’ mutiny and accused of providing access to arms caches in Bouaké. For Freedom House, this proved that such threats from the soldiers are taken seriously and are prosecuted (1).

In its 2018 country report on Côte d’Ivoire, the Bertelsmann Transformation Index (BTI 2018) states that the government has failed to set up a Special Tribunal for the Fight Against Corruption, which would be tasked with prosecuting the cases forwarded by anti-corruption bodies. The fact that such cases are never forwarded to courts points to ineffectiveness. The BTI 2018 adds that even the high-profile Cour des Comptes and the Inspecteur Général des Finances (IGF) are understaffed and therefore ineffective (2).

“The institutions meant to oversee the utilization of public funds (Inspecteur General des Finances, Cour des Comptes) are understaffed and thus not effective in preventing abuse and corruption.”

The BTI 2018 also labels the Haute Autorité pour la Bonne Gouvernance (HABG) as having questionable effectiveness because it is not a judicial body with the capacity to indict and sanction corrupt officials, including former rebel leaders (COMZONES) who have accumulated wealth and power in the north of the country under President Ouattara (2).

“The effectiveness of Ouattara’s anti-corruption policies and institutions remains to be seen. The HABG is involved in official investigations and publishes annual reports about its activities in the field of prevention, awareness-raising and investigation. It is, however, not a judicial body which could effectively sanction corrupt practices. So far there is still a notable lack of action against former rebel leaders who accumulated wealth during the military occupation of the north.”

As the independent military prosecutor, The Ministry of Defence Military Prosecution Service (Forsvarets Auditørkorps) deals with all violations of the military and civil penal code, i.e. including instances of corruption [1]. The Danish National Audit Office (Rigsrevisionen) and the Defence Internal Audit Office (Forsvarets Interne Revision) audit all activities of the agencies of the Ministry of Defence [2, 3, 4]. However, there have been found no internal institutions or offices tasked specifically with building integrity. This was confirmed by a former civil servant [5]. Of further relevance is the Danish system of ‘the attourneys to the State’ (Kammeradvokaten). Not a public institution, but a private law firm hired by the state, the attorneys to the State provide legal services to the central administration including the Ministry of Defence [6]. The attorneys to the State have conducted several investigations into cases of potential of violations of the Public Administration Act within the Ministry of Defence during recent years [7, 8, 9].

The Ministry of Defence Military Prosecution Service is an independent service and does not form part of the military chain of command. The service reports directly to the Minister of Defence [1]. The Defence Internal Audit Office is an independent department within the Ministry of Defence. The head of the Defence Internal Audit Office refers directly to the permanent secretary (departementschef) in the Ministry of Defence in order to preserve its independence from the rest of the organisation [2, 3]. The Danish National Audit Office is an independent institution under the Danish Parliament [4]. The attorneys to the State (Kammeradvokaten) are from a private legal firm hired to provide legal services including internal investigations of, for instance, potential violations of the Public Administration Act. Criticism has been made about this system in general [5, 6], and specifically in relation to the investigations within the Ministry of Defence [7, 8, 9]. This is because the set-up raises questions about the independence of the investigations and their conclusions. A professor of law has commented that so-called “external legal investigations”, as currently being conducted in relation to the fraud case within the Ministry of Defence Estate Agency, are not impartial because it is the ministry who pays for the investigation [10]. As such, research indicates that the Ministry of Defence relies frequently on investigations conducted by the Kammeradvokat – and not by a truly impartial institution.

There are indications that attention is given to maintaining a highly skilled staff. For instance, The Ministry of Defence Military Prosecution Service has focused on employee development and has, among other things, developed a strategy for employee development in order for the Prosecution Service to become more capable and effective. The strategy was made available upon request. The Prosecution Service is also effecting an analysis of the competencies it needs [1, 2]. Annual reports from the Prosecution Service also indicate the effectiveness of this specific institution: in 2018, 690 criminal cases was set up by the service [3]. However, looking at institutions other than the Military Prosecution Service, the situation appears to be critical: the staff of the Defence Internal Audit Office was cut in numbers since 2016 [4] and has been strengthened in 2020 [11]. In relation to a recent case of corruption within the Danish Ministry of Defence Estate Agency, the effectiveness of the Defence Internal Audit Office must be questioned. A 2018 internal investigation into the risk of financial fraud within the Ministry of Defence concluded that satisfactory control mechanisms were in place and that no obvious risks existed. Further, it concluded that the control systems in place effected that a large case of fraud could not likely take place within the Ministry of Defence [5, 6]. However, within a year later, the Danish National Audit Office reported that it had been very easy for employees within the Ministry of Defence Estate Agency to undertake fraud and that this fraud was found in the very same areas that the internal investigation designated as being secure [7]. This clearly indicates that the internal audit is not effective in all cases. On the other hand, research indicates that the Defence Internal Audit Office for years has identified several systemic pitfalls that makes fraud possible within the Ministry of Defence, while ministerial institutional actions to remedy this have not been taken [8, 9]. Further, media investigations reveal that the Ministry of Defence Accounting Agency – which handles accounting tasks for the MoD and agencies and authorities pertaining to the ministry – was aware that breaches of administrative rules for purchases were made, but covered up the incidences during internal control activities [10]. Thus, there is both evidence of effective units not being met by a responsive environment and evidence that the units themselves are not always effective. Either way, this amounts to less effective units.

There is a specialized unit (general inspector of the army) and another directorate (Morale affairs) that cooperate in most cases (1), (2), (3), (4). They organize field visits to different units to preach about the values and ethics of Islam and unity but have no strong authority over corruption cases. After having reviewed all relevant laws, by-laws and media platforms, no information was found regarding its staff, funding and mandate.

The head of the Inspection Authority is directly appointed by the minister of defence who has financial and political authority over these units (1), and whatever powers it might have are overshadowed by the powers given to the military justice system which has exclusive jurisdiction over investigating and prosecuting military personnel (2), (3), but whose members are also appointed by the minister of defence. It would then naturally come under the influence of top military executives as the minister of defence must be a military officer (3).

The general inspector of the army and the moral affairs unit have no authority over corruption cases. They are aware of corruption cases, but they are not aware of their risk and can not act and have no authority to act (1), (2), (3). Information about the staff of the Inspection Authority and the military courts and their operations is extremely scarce, and therefore it is very difficult to determine how effective they are. However, it is fair to say that how these units are structured makes their effectiveness questionable. For example, they are both considered departments of the MoD and their heads are appointed and removed by the minister of defence. All the justice institutions are subordinate to the MoD, including the Inspection Authority, Military Courts and Military Police and are considered mere “administrative units” of the ministry (4), (5).

The Ministry of Defence does not have a department or a position that specifically deals with corruption and integrity issues. The Ministry’s Audit and Development Department [1] consists of one person, and this could be considered as an understaffed unit. In comparison, the internal audit department at the Ministry of Internal Affairs [2] has seven employees. Part of the internal audit’s task is to make sure everything in the Ministry of Defence is conducted according to the law and existing rules and procedures. [3] This, indirectly, includes preventing corruption. In 2011 the internal audit of the Ministry of Defence published a report that was also covered by the media. It reported about mistakes and faults done in procurement in the defence sector. [4] There have not been significant public reports by the internal audit since then. All reports are available online. There is also a Corruption Prevention Council [5] which aims to analyse anti-corruption activities in Estonia and make proposals to the Minister of Justice on how to prevent corruption. The council met for the first time on 10th January 2017 and therefore is a relatively new entity. The council includes experts in corruption from different fields, however their focus has been on tackling corruption in local governments. Another general institution also exists, the Anti-Corruption Select Committee of the Riigikogu which monitors that the anti-corruption measures provided for in Estonian Acts are implemented.
In the Estonian Defence Forces there is a General Inspectorate Service. [6] All the military personnel has the right to turn to the inspectorate if problems or issues occur that they cannot share with their superior. Another posting within the Defence Forces is the legal interlocutor, who plays the role of an adviser. The military personnel (or anyone else linked to the Estonian Defence Forces) can turn to the interlocutor if they feel they have been discriminated against, or with issues of basic rights and freedoms. [7] There is also an ethical code in the Defence Forces that describes the main values that all the military personnel must possess. [8]
The main unit to scrutinise the Ministry of Defence [9], however, is the National Audit Office of Estonia (Riigikontroll). [11] They conduct regular oversights in governmental institutions such as the Ministry of Defence.
Every ministry in Estonia has at least one coordinator who is responsible for leading the anti-corruption policy, as coordinated by the Ministry of Justice. The Ministry of Defence has two coordinators. [10] They make sure that the goals of the anti-corruption strategy are fulfilled not just in the ministry, but in the whole field under the respective ministry. However, there is no evidence available of how they have exercised their mandate in practice when it comes to the defence institutions.

The internal audit unit at the Ministry of Defence directly reports to the Ministry of Defence, as stipulated by the Statutes of the Ministry of Defence, [1] and is therefore directly in the chain of command of the institution it oversees. In accordance with the National Audit Office Act, [2] the National Audit Office operates as an independent state body exercising economic control. Its activities are audited annually by an auditor appointed by the Riigikogu on the proposal of the Finance Committee. Both the General Inspectorate and the interlocutor report directly to the Commander of the Defence Forces, which may indicate that their capabilities are limited when it comes to issues related to the Commander. [3] Finally, the two representatives of the Ministry of Defence co-ordinating the corruption prevention and ensuring the implementation of the strategy’s activities in defence sector, are also in the chain of command of the Ministry of Defence. [4]

There have been a couple of seminars to build a better understanding of the new corruption law in 2013 for the officials at the Ministry of Defence. 20-30 officials attended. Other than that, there is no evidence of other requests for information or training about corruption at the Ministry of Defence in recent years, while requests do come in from other institutions, as pointed out by an interviewee, a senior official in the Ministry of Justice. [1] The interviewee’s explanation is that the Ministry of Defence is relatively isolated from other sectors. Other interviewees from the civil society sector confirm this perception. [3,5,6]
There are internal rules set within the Estonian Defence Forces. [2] The Internal Regulation stipulates that a serviceman is obliged to refrain from causing corruptive situations and to avoid conflicts of interest. An interviewee, a Member of the Defence Committee, has assessed that the staff within the defence sector recognise and understand corruption, but due to the small population of the country, conflicts of interest may happen, even if not intentionally. [3]
To sum up, based on the interviewees and the sources studied, tackling corruption risks is not a priority topic in the defence sector. Actual measures taken are limited, or there is no evidence available to prove the contrary.

Act on State Budget, chpt 4, section 24 b: All state agencies and institutions must ensure that compliance arrangements are appropriate in its own operations as well as in operations for which it is responsible. [1] Decree on State Budget, chpt 9, section 69: Compliance arrangements shall ensure that the finances and the operations of a state agency or institution are legal and efficient; that the resources and property of the state agency or institution are safe and secured; and that correct and sufficient information on the state agency’s or institution’s finances and operations are available to its management and for external supervision. [2]

Financial compliance is carried out by the accounting units on top of which the Security Unit operating as part of the Administration Policy Department of the Ministry of Defence is tasked with compliance and ethics issues. It collaborates with the National Audit Office as does the entire Security Unit with the Defence Forces, defence industry and other security actors within the Government. One of its main tasks is the internal monitoring of the MoD. [3]

In the Defence Forces, the legal department of the Headquarters is tasked to ensure that the Defence Forces follow the rule of law in its activities and judicial protection takes place. Compliance and ethics oversight is lead by the Defence Forces’ Assessor and carried out by the compliance unit. [4] According to a written response of the Headquarters of the Defence Forces, anti-corruption activities have not been specifically allocated to any unit in the Defence Forces. However, two sectors within the HQ’s legal department advance anti-corruption activities alongside their other activities. [1] The compliance unit within the legal department inspects the legality of the actions of the Defence Forces and hence also carries out anti-corruption activities. [2] The legal department also hosts an investigatory sector, which has specialised in investigating malfeasance and has a central role in anti-corruption activities in the Defence Forces.

In addition, the Defence Forces has a representative in the anti-corruption network coordinated by the Ministry of Justice. The aim of this network is to contribute to the minimisation of corruption in Finland. [4] The National Audit Office inspected the management system of the Defence Forces in 2017 (yet without a specific focus on compliance) [5]. According to the inspection report (2017), the manifoldness of the managerial models and processes complicates the overall picture and makes it difficult to clearly understand the different responsibilities, resources and procedures, even if the different models and processes are carefully depicted in documents. Management processes between the Defence Forces and the Ministry of Defence in general function smoothly, but measurability of efficiency goals and transparency remain challenges. [6] The taks of an internal audit are to clarify the appropriateness and sufficiency of compliance to the leadership and to carry out the auditing tasks assigned to it by the leadership.

An Advisory Board on Compliance and Risk Management operates in connection to the Ministry of Finance [6,7]. Its tasks are e.g. to monitor and evaluate the state of, and arrangements made for, compliance and risk management in the state administration, its methods and the general development, as well as the utilisation of compliance in financial and operational management; to set up initiatives to develop compliance and risk management; to coordinate the compliance arrangements done by different authorities, state agencies and institutions, and to prepare actions supporting this coordination; to monitor and evaluate the stage of internal auditing, including its arrangement, quality and effectiveness of its activities, its utilisation in leadership and management, as well as its methods and general development – and to do initiatives to improve internal audit and its utilisation; to follow and monitor the stage of criminal activities and wrongdoings and to coordinate and develop reporting on criminal activities and wrongdoings as well as to coordinate and develop activities and practices of different authorities, agencies and institutions in these matters; and so forth. [6,7,8]

According to a written response of the Headquarters of the Defence Forces, anti-corruption activities have not been specifically allocated to any unit in the Defence Forces. However, two sectors within the HQ’s legal department advance anti-corruption activities alongside their other activities. [1] The compliance unit within the legal department inspects the legality of the actions of the Defence Forces and hence also carries out anti-corruption activities. [2]

The legal department also hosts an investigatory sector, which has specialised in investigating malfeasance and has a central role in anti-corruption activities in the Defence Forces. In addition, the Defence Forces has a representative in the anti-corruption network coordinated by the Ministry of Justice. The aim of this network is to contribute to the minimisation of corruption in Finland. [1] These units cannot be shut down by the defence instutions for their existence, and operability is required by law. The National Audit Office inspected the management system of the Defence Forces in 2017 (yet without a specific focus on compliance). According to the inspection report, the legion of managerial models and processes complicates the overall picture and makes it difficult to clearly understand the different responsibilities, resources and procedures, even if the different models and processes are carefully depicted in documents.Management processes between the Defence Forces and the Ministry of Defence in general function smoothly, but measurability of efficiency goals and transparency remain challenges. [2]

According to the Act on the State Budget, Chpt 4, Section 24 B: A state agency or institution must ensure that internal auditing is appropriately arranged when it comes to its own activities and activities for which it is responsible. The organisation of internal auditing is lead by the head of the agency or institution, which is also responsible for the appropriateness and sufficiency of auditing. [3]

There is not enough evidence to score this indicator, as no publicly available data that would enable coring was found through research. As such, it is marked ‘Not Enough Information’. Additionally, the response provided by the Headquarters of the Defence Forces was not adequate enough to score this indicator [1].

Several bodies exist to control and audit the defence sector:
– The General control of the armed forces (CGA) [1] is the internal audit entity of the Ministry of Defence. It carries out “Inspection, control, audit, study, advisory and evaluation missions” on all bodies. [2] It is not independent. The CGA is placed under the sole and direct authority of the Ministry of Defence, as explained in the Defence Code. [3] Its mandate does not mention any anti-corruption mission. [4]
– The Commissariat des Armées has recently shown its lack of effectiveness in controlling Opération Barkhane, sub-contracting logistical deals, as pointed out by MP Cornut-Gentile in its Information Mission Report of June 19, 2019, [5] and as the numerous examples listed in an investigation by Le Monde show: “Panh, like Expedition Aviation, never deals directly with the “Barkhane” Commissariat or with the French Ministry of the Armed Forces […] but with “the French logistics subsidiary of the Canadian group SNC-Lavalin” […] Despite its registration in 2013, for ten years, on the black list of the World Bank after the discovery of corruption cases, SNC-Lavalin won the market in early 2016, without detailing either the origin or the operator of the devices.” [6]
– The French Anti-Corruption Agency (AFA), [7] created in December 2016, was formed to bring France up to American and British standards in terms of compliance with anti-fraud and bribery policies, to avoid French companies being prosecuted by foreign justice systems and having to pay important amounts of money in legal fees and fines.
The AFA seems to be showing some concrete steps: though Thales denies being targeted by any investigation by the Agency, the well-informed website Intelligence Online states that it is currently being audited by the AFA on corruption suspicions. [8]
An interview with an anonymous official within the AFA [9] indicated that there is no specific department inside the AFA is dedicated to the Defence sector, nor is there any will or plan to create one, as it is not a priority target of the Agency.
– The new « Ethics Committee » of the Armies (part of the « Sapin 2 » law package on Anti-corruption in 2016): no actions have been taken yet, but an October 2019 report stated its methodology and good will in tackling conflicts of interests within the army. [10]

The AFA is under the authority of both the Ministry of Justice and the Ministry of Economy. When corruption suspicions are confirmed, the AFA can hand all the elements of the case to the National Financial Prosecutor’s Office (Parquet National Financier, PNF). This jurisdiction can then either settle for a financial fine through a Public interest judicial convention (CJIP), or launch a judicial case. [1] The PNF is under the sole authority of the Minister of Justice. High-ranking defence sector officials cannot interfere with such a procedure.
The CGA is under the direct authority of the Defence Minister, who “assists […] in the direction of [his] ministry by ensuring, in all bodies under his authority or guardianship, the observance of the laws, regulations and ministerial instructions as well as the desirability of decisions and the efficiency of results with regard to objectives and the good use of public funds.” [2]
These two institutions are not in the chain of command of the defence and security institutions they oversee.

As explained before, the AFA does not precisely target Defence institutions, nor does it have a department specifically dedicated to fighting corruption in the Defence sector, and the existing unit within the Defence ministry, the CGA, does not address corruption at all.
However, the AFA’s recent creation – operations began in 2018 – is an interesting new development. A real effort seems to have been made in terms of empowering this institution. Its mandate is broader than the former SCLC, and it now includes – on top of auditing and investigating – other missions like training, oversight, and policy recommendations. [1] And though it doesn’t have the ability to impose sanctions itself, it can negotiate and settle for financial fines with companies or administrations guilty of corruption and can hand cases over to the judicial authority (PNF).
According to an interview with an anonymous source within the agency, [2] the AFA staff has been recruited from police or judicial departments or services, specifically for its expertise in anti-corruption, investigation and prosecution.
The head of the AFA, Charles Duchaine, former “investigative judge” (“juge d’investigation”, equivalent to a special judge, free from the authority of the “parquet”, the public prosecution and ministry of Justice), has a reputation for independence and inflexibility when it comes to corruption issues. [3] [4]

There are identifiable compliance and ethics units within defence and security that are mandated to handle integrity and corruption in defence.

The Ministry of Defence has a dedicated anti-corruption department (Unit R III 1 ES) as well as designated anti-corruption experts/points of contact within the specific agencies and in military units from the level of battalion upwards. The anti-corruption department includes a special investigations division of about 30 investigators and former military prosecutors. It works with various law enforcement agencies, drafts guidelines and supervises the latter’s implementation and the relevant training. It is tasked with both building integrity and countering corruption, meaning that corruption prevention is as much a focus area as investigations into corrupt practices and activities.

For instance, during the last two years, the Ministry of Defence has established a Compliance Management System, which aims to increase trust and transparency within the institutions. With regard to legal aspects, the Compliance Management Officer BMVg (CMB) was employed at the sub-department level to ensure compliance within Unit R III 1. Legal Unit III 1 ES performs the basic tasks in the field of corruption prevention at the ministry level and lays down the framework for designing preventive measures, as well as for the uniform implementation of the ‘Federal Government Directive Concerning the Prevention of Corruption in the Federal Administration’. It carries out specialist supervision with regard to corruption prevention measures.

Legal Unit III 1 ES also functions as an organisational unit as defined by the Federal Government’s directive and is equipped with suitable investigative staff to clarify matters relating to economic damage to the Bundeswehr. If there are indications of such damage, these matters are examined by Legal Unit III 1 ES and the Military Defence Reconnaissance Group (investigations in special cases), as part of administrative investigations. This applies in particular to indications of corruption, fraud, infidelity and similar crimes that result in economic damage to the Bundeswehr.

In this respect, in the event of a suspected corruption offence, there is an obligation to inform Unit R III 1 ES immediately so that all investigations can be coordinated centrally and in cooperation with the law enforcement authorities without any loss of evidence through obscuration or obfuscation.
Unit R III 1 ES has the right to speak directly to the State Secretary responsible for suspected cases of corruption in its function as the point of contact for corruption prevention. Its investigative authority extends to the entire defence department and includes the investigation of members of the Bundeswehr (civil and military), as well as the use of all official documents and digital files.

The head of Unit R III 1 ES has been appointed as the point of contact for corruption prevention within the BMVg, with the following tasks:
• acting as the point of contact for all employees and the head of department – including outside official channels – and for all citizens,
• advising the agency management on all issues relating to corruption prevention, particularly in the process of identifying positions that are particularly susceptible to corruption,
• educating and raising awareness among superiors and employees,
• participating in the training, observation and evaluation of signs of corruption.

Legal Unit III 1 ES is also the body responsible for matters of sponsorship (sponsoring officer) and decides on the acceptance of services of private individuals at departments and units of the Bundeswehr that are only possible within narrow limits.

In line with the requirements of the Federal Ministry of the Interior, Building and Community (BMI), members of the Bundeswehr are generally not allowed to accept benefits (rewards and gifts) in connection with the office to avoid any appearance of susceptibility. In cases of meetings of particular importance, the BMVg (Legal Unit III 1 ES) reserves the right to approve the acceptance of benefits.

Unit R III 1 ES is also responsible for investigating incompatibilities in relation to the reported follow-up employment of former civil servants (see Section 105 of the Federal Civil Service Act – BBG [1]) and of former soldiers (see Section 20a of the Act on the Legal Status of Military Personnel – SG [2]) as well as in the context of secondary employment and reservist services. Legal Unit III 1 ES examines any doubts about the reliability of a contractor pursuant to the Act against Restraints of Competition and decides on measures – which may extend to turning an applicant away – in the event of unreliability in connection with corruption- or cartel-related circumstances. In addition, Legal Unit III 1 ES oversees the imposition of a contractual penalty if an applicant or contractor offers or grants an illegal advantage to the client. If private companies are involved in carrying out public-sector tasks, individual employees are required to comply with their obligations under the contract in accordance with the Obligation Act and are thus treated as officials in terms of possible criminal liability [3].

In the medium term, the measures taken should promote a culture of responsibility and integrity that is borne by all employees. Legal requirements, complex regulations and specifications for task fulfilment should be made more transparent and compliance with the rules should be made easier by prevention. For example, a risk analysis was commissioned and carried out in dialogue with all departments and staff in the ministry. It included questions such as ‘Where are conflicts of interest most likely to arise?’, ‘Where might rule violations occur?’ and ‘Where do employees feel insecure?’. The result: a transparent picture of the situation in the form of a so-called risk map. ‘The risk analysis focussed on a total of 17 different risks using a holistic approach,’ said the Brigadier General, ‘Major compliance risks included discrimination, data protection, IT security and corruption’ [4]. However, the implementation of the Compliance Management System is still in its infancy. Not a lot of information is available.

The point of contact for all matters relating to corruption prevention does not work within the chain of command and is accountable to the head of the agency only. Since it is not obliged to follow the official channels, this point of contact can report directly to the head of the agency [1]. Unit R III 1 ES and its point of contact within the ministry have the right to bring all corruption matters directly to the State Secretary’s attention. With regard to the budget, the Federal Audit Office (external financial control) – as an independent body responsible for state financial control – is only subject to the law; no other state body can commission it to carry out an examination. It does not judge political decisions. It examines the federal budgetary and economic management: this includes annual federal income and expenditure exceeding 700 billion euros, the social security institutions and the Federal Government’s actions in the private law companies in which it participates. The Federal Audit Office summarises the results of its audits in audit reports, which it sends to the audited bodies. The Federal Audit Office informs the German Bundestag, the Federal Council and the Federal Government about its most important audit results. In addition to auditing, the Federal Audit Office advises government agencies, particularly the German Bundestag [2].

Regular risk assessments are performed to identify positions with a higher risk of corruption. When it comes to selecting staff for these positions, special attention must be paid to applicants’ profiles. In addition, staff in high-risk positions are subject to specific regular training, which familiarises them with the risk profile of their position, their authority for action and decision-making, controls and measures to be taken in case of irregularities [1,2].

The anti-corruption unit R III 1 ES independently conducts the risk assessment and analysis for the entire institution of the Ministry of Defence (BMVg). The staff of R III 1 ES are fully familiar with the specific corruption risks of every single job position within the institution of the BMVg. The staff of R III 1 ES are well trained and highly experienced in overseeing, training and instructing others within the institution of the BMVg and other agencies. In addition to that, R III 1 ES decides on specific aspects related to corruption prevention (e.g. sponsoring, special cases of gifts/donations, follow-up employment) with regard to all military and civil personnel of the Bundeswehr [3].

There are several institutions mandated with oversight and prevention of corruption in Ghana, although not specifically the defence and security sectors: the Audit Service, the Commission for Human Rights and Administrative Justice (CHRAJ), the Bureau of National Investigation (BNI), the Economic and Organized Crime Office (EOCO), and the Defence Intelligence in the Ghana Armed Forces.

The Department of Defence Intelligence investigates compliance with ethics and code of conduct in the armed forces, but not specifically mandated to fight corruption (1), (2), (3), (4).

The Audit Service, headed by the Auditor-General, audits the accounts of Ghana’s public offices, including the Ministry of Defence, and investigates all use of public funds (5). According to the Parliamentary Budget Committee, despite the recent injection of funds by the government (6), the funds allocated to the Audit Service are not adequately financed (7). For instance, there is a gap of GH¢ 34.67 million. Amongst its operational powers, the Auditor-General can lock and disallow the salaries of non-compliant public offices (8).

The CHRAJ has the explicit mandate of promoting integrity in public service and combat corruption in Ghana. The CHRAJ can investigate cases of corruption and work to “reduce opportunities for corruption in corruption-prone sectors by assisting to implement corruption prevention measures and putting in place robust systems for checking corruption” (9). Powers include demanding information for its investigations, requiring institutions or people to appear before the Commission and to go to court.

The CHRAJ’s Commissioner has recently recommended to the Constitutional Review and Implementation Committee (CRIC) to broaden the legal mandate of the Commission, particularly by allowing it to initiate investigations even in the absence of formal complaints by third parties (10).

The Bureau of National Investigations (BNI) is part of the Ghanaian national security services and it is tasked with fighting issues of corruption with particular reference to the defence and security sectors (11).

The Economic and Organized Crime Office (EOCO), which operates under the authority of the Attorney-General, investigates and prosecutes offences involving financial or economic losses for the state, money laundering, human trafficking, cyber activity, tax fraud and other offences. The mandate of EOCO is broad as it also includes corruption prevention measures. However, according to recent media reports, EOCO’s investigations are perceived by the public for being politically-driven, and the institution is not adequately funded and staffed (12).

Early this year, the government established the Office of the Public Prosecutor, with the mandate of investigating matters of corruption in government institutions (13). Because of its recent establishment, the Office of the Public Prosecutor is not yet fully operational.

These institutions are, at differing levels, under political control, and therefore lack of substantial independence. For instance, both the Auditor-General and the CHRAJ’s Commissioner are appointed by the government rather than the Parliament, something that raises concerns over their independence (1). As an intelligence agency, the BNI answers to the executive (2), while the EOCO reports to the Attorney-General, who is also appointed by the government (3).

It is difficult to assess the degree of effectiveness of these institutions with regards to the defence and security sectors. While the NACAP displays an in-depth understanding of the corruption risks, these do not specifically mention the defence and security sectors.

There are no compliance or ethics units in the strict sense within defence and security currently. An Integrity Advisor’s Office will be established in MOD in line with the new Law 4795/202 which requires establishments of such offices in all ministries. The Integrity Advisor will be responsible for ethics and the development of integrity culture. [1]

This indicator is scored ‘Not Applicable’ as there are no independent institutions within the MOD or other ministries focusing on eradicating corruption.

This indicator is scored ‘Not Applicable’ Greece does not currently have such an institution.

In the Ministry of Defence (MoD) there is a Corruption-prevention Working Group (Korrupció-megelőzési munkacsoport) within the MoD Controlling and Integration Development Department (Hm Kontrolling és Integritás-fejlesztési Főosztály) [1]. There are two separate organisations responsible for countering corruption and organised crime. The primary body is the National Protective Service [2], it is subordinate to the police, it is responsible for countering corruption and organised crime in the law enforcement agencies, civilian security agencies and in the public administration. In the military, the Military National Security Service [3] is tasked with countering various forms of criminality inside the defence forces. According to the Integrity Report 2017 [1] of the MoD, the ministry is working on establishing an integrity control mechanism – it is a work in progress. In addition to this, the military has a separate Military Ethics Codex [4], published in 2014. Recent integrity reports (from 2016-2018) suggest that the department has the necessary financial and human resources, while professional training and improvement are ongoing [5].

Neither the National Protective Service nor the Military National Security Service is independent; both are parts of the chain of command. As far as it can be reconstructed despite the excessive secrecy, both organisations work efficiently [1]. The most relevant actor regarding building integrity is the Corruption-prevention Working Group lead by the MoD Controlling and Integration Development Department. The institutions they scrutinize cannot shut them down, but the minister of defence can. The Corruption-prevention Working Group was established by an instruction that it is a Ministry of Defence level document [2]. Another MoD instruction describes the different organisations and their responsibilities that is also signed by the minister and includes the tasks of the MoD Controlling and Integration Development Department too [3]. Therefore, the working group and this department can be shut down by an instruction signed by the minister. The Military National Security Service, which is countering various forms of criminality inside the defence force, was established by a law agreed on by the parliament [4]. It can be shut down by a similar law or changing the current law by the parliament(the National Protective Service does not have a significant role regarding the defence force).

Anecdotical evidence shows the staff is perfectly aware of the corruption risks and typical corruption schemes. However, although they can create an efficient strategy, implementation and compliance depend not on them, but on the political leadership. The different organisational units are aware of the risks related to them because especially the head of these units go through anti-corruption and integrity training. They can provide guidelines to the employees based on existing documents, but they do not have any concrete tools to address these issues. They do not necessarily have an appropriate overview of what other organisational units are doing in this regard either [1].

There are no defence and security specific institutions within defence tasked with countering corruption and building integrity. There are however, bodies whose remit covers these areas.

The Ministry of Defence (MoD) has a Vigilance Division looking after matters pertaining to the Service HQs/ Inter Service Organisations under Department of Defence, Department of Defence Research & Development and Department of Ex-Servicemen Welfare with respect to corrupt practices, irregularities and vigilance cases [1].

The MoD liaises with the Central Vigilance Commission (CVC) and the Central Bureau of Investigation (CBI). The latter is the primary agency investigating corruption. Since 1987, it has an Anti-Corruption Division. Over the years, the CBI has arrested and chargesheeted individuals carrying out corruptive practices [2][3][4].

As alluded to in Q.1, the MoD’s expenditure is scrutinised by Comptroller and Auditor General (CAG) and Public Accounts Committee (PAC) [5]. In the area of procurement, the Technical Oversight Committee (TOC) certifies if high-value procurement has been undertaken in accordance with prescribed procedures [6]. The MoD has a system of appointing Independent Monitors (IM), whose role is to ensure that there is transparency in business dealings [7].

As alluded to in Q.7, the MoD has approved the establishment of a new Vigilance Investigation Unit in the Army, entrusted with conducting independent investigations into corruption [8].

CVC is conceived to be the apex vigilance institution. It is independent from any executive authority. It is tasked with monitoring all vigilance activity under the Central Government and advising various authorities in Central Government organisations in planning, executing, reviewing and reforming their vigilant work [1]. The CVC does however depend upon pre-inquiry from the MoD itself before investigating further. So though there is independence in functioning, there is a dependency in procedural matters [2].

As mentioned above, CAG and PAC scrutinise MoD expenditure. They are independent bodies [3][4]. IMs are appointed by the MoD and are retired Central Government Officers [5].

On the whole, anti-corruption mechanisms are in place. Units with the MoD do identify corruption risks. There is evidence of the CVC’s efforts to build integrity through the annual Vigilance Awareness Week, hosting workshops for all military and civil personnel from the Ministry [1][2]. The CBI has been proactive in pursuing corruption matters within the MoD [3][4]. There is training, oversight and policy recommendations. The challenges lay with timely coordination of internal units and external bodies to effectively address and mitigate corruption. Diffused accountability is a major hindrance.

According to Minister of Defence Regulation No. 2/2017 concerning the Organisation and Work Procedure of the Ministry of Defence, the task of organising internal supervision within the Ministry of Defence is carried out by the Inspectorate General. Meanwhile, according to Minister of Defence Regulation No. 16/2017 concerning the Performance Accountability System of Government Agencies within the Ministry of Defence and the Indonesian National Defence Forces, the internal oversight function is carried out within the TNI Headquarters by the Inspectorate General of the TNI, within the Forces Headquarters by the Inspectorate General of each Armed Forces service and within the Main Command (Komando Utama/Kotama) or Central Executing Agency (Badan Pelaksana Pusat/Balakpus) by their respective Inspectorates [1]. The Inspectorate General and Inspectorates conduct internal oversight of performance and finance through auditing, reviewing, evaluating, monitoring and other supervisory activities carried out pre-audit, during the audit and post-audit. Minister of Defence Regulation No. 16/2017 concerning the Performance Accountability System of Government Agencies within the Ministry of Defence and the Indonesian National Defence Forces explicitly states that corruption-, collusion- and nepotism-free implementation of government functions within the Ministry of Defence and the TNI is one of the considerations when administering the performance accountability system of government agencies, in this case the Ministry of Defence and the TNI. In order to check the accuracy, reliability and validity of performance information within the Ministry of Defence and the TNI, the internal control unit conducts a review and evaluation of the Performance Report. The Performance Report explains the performance achievements in relation to the work plan, within the framework of implementing the defence budget. The results of the review and evaluation are submitted to the Minister of Defence, the Chief of TNI, the Chiefs of Staff of the Forces and the Commanders of the Kotama/Balakpus. In 2015, based on the findings of the audit by the Audit Board of the Republic of Indonesia (Badan Pemeriksa Keuangan Republik, BPK), the Inspectorate General of the Ministry of Defence conducted an investigation into an alleged corruption offence committed by a high-ranking TNI officer within the Ministry of Defence. After gathering enough evidence, the Inspectorate General reported the alleged abuse of authority to the Army Military Police (POM AD) [2,3]. The suspect was finally sentenced at the end of 2016. In addition, the Inspectorate General of the Ministry of Defence is also collaborating with other independent government institutions to boost anti-corruption efforts in the Ministry of Defence [2]. For example, it recently acted as an extension of the Corruption Eradication Commission (KPK) to control gratification practices within the Ministry of Defence. All Ministry of Defence employees are required to deliver a report to the Inspectorate General regarding the rejection and acceptance of gratuities.

The Inspectorate General also manages the Gratification Register, a gratification reporting system within the Ministry of Defence that is integrated with the system managed by the KPK [4]. Meanwhile, the duties and functions of the Military Police in the TNI are carried out by the Military Police (Polisi Militer/POM). The Military Police Centre is positioned at the level of the TNI Headquarters and Forces Headquarters and comprises the following services: the TNI Military Police (POM TNI), Army Military Police (POM AD), Navy Military Police (POM AL) and Air Force Military Police (POM AU). The Military Police Centre is tasked with organising, coordinating, maintaining and enforcing law, discipline and order within the TNI. The Attachment to Presidential Regulation No. 129/2018 concerning Details of the State Budget Draft for Fiscal Year 2019, for example, specifies that the Ministry of Defence Apparatus Oversight and Accountability Monitoring Programme receives a budget of 56.6 billion rupiah. This figure is relatively small when compared to other defence support programmes that are funded at the Ministry of Defence.

Within the Ministry of Defence, the task of organising internal supervision is carried out by the Inspectorate General. The Inspector General, who leads the Inspectorate General, is under and responsible to the Minister of Defence. This arrangement has caused the independence of the Inspector General to be questioned [1]. Meanwhile, according to Presidential Regulation No. 10/2010 concerning the Organisational Structure of the Indonesian National Defence Forces and its amendments, the Military Police is one element of the Central Executing Agency at the level of the TNI Headquarters and each Forces Headquarters [2,3,4]. The Commander of the TNI POM is positioned below and is responsible to the Chief of the TNI. The Commanders of the POM AD, the POM AL and the POM AU are positioned below and are accountable to their respective Chiefs of Staff. The position of the Military Police within the hierarchy and structure of military command makes it difficult to realise autonomy and independence.

In general, increasing the integrity and effectiveness of anti-corruption measures is still an issue within the Ministry of Defence and the TNI. The Ministry of Defence Inspector General himself claims to have implemented a system for preventing potential corruption in the Ministry of Defence [1]. The Minister of Defence also claims that the Ministry of Defence Inspector General routinely conducts internal audits of the use of the defence budget, including for the procurement of defence equipment [2]. However, when comparing the potential for corruption within the Ministry of Defence and the TNI with the number of criminal cases of defence budget corruption or cases involving members of the TNI, it appears that the effectiveness of corruption management within the Ministry of Defence and the TNI is still low. The need to strengthen the capacity for corruption management within the Ministry of Defence and the TNI also seems to be felt by officials in these agencies. The Ministry of Defence Inspectorate General, for example, has involved the KPK on several occasions, inviting representatives to provide advice and training on corruption prevention [3]. In addition, the need to increase understanding of the legislation and build integrity among military police has also been expressed by the Chief of the TNI [4].

Iran also has the General Organisation of Inspection. Although it has the power to investigate defence and security forces, there is no publicly available evidence that it does so [1]. The Basiji volunteer militia, which is one of the five main units of the Islamic Revolutionary Guard Corps (IRGC), has an ideological-political unit, which offers ethics training, such as the ethics of military management; and political, military and economic ethics. Its mandate is more to counter moral corruption as such its most important responsibilities is to train volunteers to “defend the country and the Islamic Republic regime.” [2]. So its expertise is not really related to compliance.

There is also a counterintelligence organisation within the responsible for identifying foreign spies and corrupt police, but its expertise is also doubtful. For example, its members were used as a tool to confront Tehran’s mayors [3]. Finally, there is the Organisation for the Protection of Intelligence within the military, which serves to identify foreign agents and corrupt police, but the organisation is also used to suppress voices of opposition and dissent [4]. Its expertise and mandate are unclear.

The Basiji Volunteer Militia is one of the five main units of the IRGC is under the political control of the supreme leader [1, 2]. As the example above shows, the counterintelligence organization within the police is misused [3].

Whilst these institutions and units may be aware of the topic of corruption, there is no evidence to imply that staff within the units “understand” the corruption risks specific to their own institutions. Furthermore, evidence indicates that they themselves are highly corrupt [1].

Matters of integrity and corruption matters are handled by a range of national authorities and watchdog groups. The Inspectors General System was set up to undertake monitoring responsibilities, exercise oversight, and root out waste and corruption. The inspectors are placed inside Iraqi ministries, providing independent internal oversight (1). In 2013, it was reported that a total of 36 IGs have maintained regional offices (2), and are appointed directly by the prime minister, and approved by the Council of Representatives. The MoD is assigned an inspector, who reports back to the FBSA. Inspectors should work in tandem with the Federal Board of Supreme Audit (FBSA). The FBSA report suspected corruption in the GI. If the FBSA is not convinced or unable to undertake investigations into alleged corruption, the matter is referred to the Commission of Integrity. A contradiction emerges, however; as the COI does not enforce the law, but rather relies on these agencies tasked with ‘enforcement’ (2) to stamp out corruption. The FBSA’s powers were enhanced after the passing of ‘Law 31’ in 2011 (3) which advanced their mandate to investigate financial fraud. It is responsible for auditing the funds allocated to public and private agencies and whether they ought to be handling/or are eligible to receive such funds. Law 31 was also amended in 2012, after a new law, No 31, granted the GoI the right to request investigations from FBSA into specific cases (2). The PM retains the right to remove an IG based on COI recommendations.

What undermines the integrity of parliamentary decisions and accompanying legislative steps, are actions authorised by the commander-in-chief that bypass the mandates of the above-mentioned agencies. One such breach, as discussed in local press circles, seen by observers as a serious threat to the military establishment, was AAM appointment of Zaid al-Tamimi as the IG for the MoD; a former military commander of special Badr operations in Diyala province (4). The seat is viewed across the ministerial board as the “third most important within the defence establishment after the minister of defence and the chief of staff.

While new strides in the country’s anti-graft drive were made in January 2019 after Iraqi PM AAM revived Iraqi Supreme Anti-Corruption Council. The Council’s ability to root out corruption is unclear at this very early stage (5), (6). There are no successes to discuss concerning its mandate, particularly in light of delays by PM Abel Mahdi to appoint ministers of defence and interior. News searches reveal greater drive in terms of referrals made in the past two months (7). What is important to note as a closer reading of press reports indicate ‘referrals’ to the judiciary which is itself swayed by bribes and political favouritism. These reports also follow a week of unrelenting civilian-led protests calling for the fall of the government (8) which may suggest efforts to tame protests and placate demands.

Experts and politicians cited in the piece published by Al-Monitor (5) believe that the revival of another corruption-fighting body may undermine the existence of the COI and The FBSA which, by constitutional law, are the leading bodies sanctioned by the government to build integrity and combat corruption. The very move, tacitly implies that traditional outfits have fallen short of their mandate, an accusation various leaders have levelled at these anti-graft institutions. Others raise concerns about the absence of sufficient funds needed to unite the efforts of all regulatory bodies and agencies. The answer to the question of what makes this attempt any different from past attempts will become clearer with time. In spite of publicised campaigns and promises to eradicate corruption at the root, a recent report found that important questions and plans for reforming the system “was left unanswered” by the ruling class (9). The response further underscores the lack of independence from political pressures, coupled with underfunding (10) validates the score of one that was initially chosen.

Under CPA Order 57 (2007), inspector generals are charged with a legal mandate to perform and initiate investigations, including financial audits, associated procedures, across institutions of the state (1). The effectiveness of IG’s has been called into question by the Council of Ministers. A recently issued resolution called for their closure due to undermined oversight, which is necessary to achieve desired results and ultimately rests on the body’s independence. The IG is administratively linked to the respective minister, and practically speaking, to the COI and must balance the interests of both. The IG’s connection to the minister has inspired howling controversy particularly in recent years of their ability to act independently. As the previous version of this assessment underlines, the presence of inspectors within key ministries “has not been easily accepted or understood by Iraqi ministries, and they have been seen in some instances as American spies” (2). CPA order 57 remains active and the move to abolish the offices of IG’s has yet to gain parliamentary approval (1). In May 2017, the head of the COI, Yassiri argued that any potential dissolution would violate Iraq’s international obligations, “especially the … UN Convention against Corruption, which stresses the importance of forming a national anti-corruption system composed of Commission of Integrity, Inspectors General and Board of Supreme Auditing” (3).

The overall effectiveness of Iraq’s anti-graft bodies has been called into question. As NATO notes, “even when corruption is acknowledged as a strategic challenge” (1) “this recognition is rarely translated into specific guidelines and tools”. The magnitude of corruption signals a weakness in state function and central power, which results in a select few inconclusive investigations and unkept promises to hold the perpetrators of financial/administrative corruption to account. Iraqi political analyst Yaha al Kubaisi (2) writes the government’s ability to swiftly prosecute state agencies implicated in corruption and to recover stolen funds is undermined by officials taking advantage of loopholes within Iraq’s Amnesty Law, to evade prosecution. In Kubaisi’s assessment, an estimated 90 per cent of embezzled funds have not been recovered due to the provision (Article 5) that pardons officials found guilty of stealing state funds (3). The COI has been unable to effectively challenge the misuse of Iraq’s Amnesty Law. The mere existence of these bodies, Kubaisi argues, is not enough, as is the conventional wisdom among Iraq’s political class (2). As for the Inspectors General System, while it has survived 15 years of administrative misrule, IGs and their relevant ministries lack the trust in each other. In spite of efforts and vocal commitments, legislation and anti-corruption instruments remain weak, which has allowed rent-seeking behaviour to flourish. One source describes the anti-corruption initiatives to date, as ‘tokenistic’ which have “failed to convince Iraqis who are impatient with piecemeal, symbolic reforms” (1).

There are some compliance and ethics units within defence and security and Ministry of Justice that are mandated to handle integrity and corruption in defence (1). There is also the state comptroller who is appointed by the Knesset and some other sub- and joint committees of the Minstry of Defence that monitor the defence and security sector. The State Comptroller carries out external audits on activities undertaken by Ministries, local government and various public organisations, in order to ensure that they comply with the law, good governance and the principles of integrity and efficiency. In accordance with the Basic Law: The State Comptroller, carries out external audits on a range of activities undertaken by Ministries, local government and various public organisations (the audited bodies), in order to ensure that they comply with the law, good governance and the principles of integrity, efficiency and thrift. The State Comptroller is likewise authorised to examine such other matters as he deems necessary. In order for him to perform his functions, the Basic Law grants the State Comptroller broad authority to receive information from the audited bodies, in accordance with section 3 of the Basic Law, which states that “A body which is subject to the State Comptroller’s audit shall without delay provide him with whatever information, documents, explanations or other material he deems necessary for the purposes of the audit.” The status, objectives and methods of the State Audit differ from other manifestations of public scrutiny. It may be defined as a collection of data on the activities of the audited bodies and its evaluation in the light of obligatory norms in various areas. It is a process involving an independent assessment of actions taken by the State, its institutions and corporations. Within the framework of the Audit, the State Comptroller examines the a) Legality and regularity; b) Economy, efficiency and effectiveness; c) Integrity; d) Economy, efficiency and effectiveness.The State Audit applies to all government ministries, state institutions, branches of the defense establishment (the Ministry of Defence, the IDF, the military industries and even the most clandestine units) and local authorities. The audited bodies include all the government companies (of which there are approximately 100) and corporations established by law (statutory corporations), many of which perform important functions in the national economy, such as the exploitation of natural resources and the provision of essential public services. The State Comptroller also serves as Ombudsman under section 4 of the Basic Law: The State Comptroller, in which capacity he receives and investigates complaints from persons who have personally been detrimentally affected by the actions of national and public authorities as defined by law (investigated bodies). The State Comptroller in his capacity as Ombudsman is endowed with a unique combination of powers to investigate individual public complaints. The ambit of the State Audit and the investigation of public complaints are so extensive that virtually all public bodies in the State of Israel come under the scrutiny of the State Comptroller and Ombudsman (2).
In addition to the state comptroller, there are also internal auditors in both the MOD and the IDF. These internal audit units are responsible for examining “whether the actions of the public body in which he is theinternal auditor, as well as those of its officers and rankingemployees, are correct in terms of obedience to Law, orderlymanagement, probity, economy and efficiency, and whether they are useful for the attainment of the objectives set for them” (7).
There is also the National Security Council (NSC) (“HaMo’atzah leBitachon Leumi”) which coordinates, analyzes and monitors all the policies related to security issues (3). Yet, it draws its authority from the executives and acts according to the guidelines of the Prime Minister. Is considered as the “second hand of the Prime Minister” and as very loyal to him (4). See also (5) (6).

Besides the State Comptroller, there are some institutions such as the National Security Council that can monitor and critise issues related to the defence and military sector, but the final decisions are made by the Prime Minster who however doesn’t have to follow their recommendations. However, these institutions are primarly external actors and not within the Ministry of Defence itself. The State Comptroller and its related institutions monitor the work of the defence and security sector from outside, but also has only limited resources and power (1). For instance the relationship between the Knesset and the State Comptroller and Ombudsman is described as independent and ” Section 6 of the Basic Law: The State Comptroller provides that in carrying out his functions the State Comptroller shall only be accountable to the Knesset, and emphasizes his autonomy and independence from the Government. Similarly, section 12(A) of the Basic Law provides that “the State Comptroller shall maintain contact with the Knesset, as determined by law”. The State Comptroller submits reports to the Knesset containing information and recommendations which are used by it as a means of supervising the Executive, and thus he assists the Knesset in a professional and independent way to carry out its duties, which is one of the supporting pillars of the separation of powers in a democratic state: supervision by the legislature of the Executive. The Comptroller’s accountability to the Knesset manifests itself in several ways: First and foremost the State Comptroller is appointed by the Knesset for a seven year term and the Knesset may dismiss him from office with a majority of at least three-quarters of its members. The State Comptroller’s reports and the Ombudsman’s annual report are submitted to the Knesset; the Comptroller is in continual contact with the Knesset State Audit Committee. He submits a report to it on his activities whenever he deems it appropriate or the Committee asks him to do so. The annual budget for the State Audit in Israel is determined by the Knesset Finance Committee in accordance with the Comptroller’s proposal, and at the end of the financial year the Comptroller submits a financial report relating to the affairs of his office for the approval of the State Audit Committee. The State Audit Committee reviews the State Comptroller and Ombudsman’s reports and based, inter alia, on the State Comptroller’s recommendations, determines which issues raised therein it wishes to discuss. The Committee’s meetings take place twice a week, except when the Knesset is in recess, and are always attended by the Comptroller or those of his representatives who are engaged in the matter being discussed, as well as representatives of the audited body and other organisations. During the meeting representatives of the audited body are asked to explain how they intend to correct the shortcomings that were raised by the audit or to redress the grievances set out in the Ombudsman’s report, as well as to submit further information, in particular concerning the timetable for correcting the shortcomings raised by the audit. This is followed by a question and answer session during which members of the Committee are able to put their questions and observations to the audited body’s representatives. Following these discussions the Chairman of the Committee, in coordination with the State Comptroller’s Office, prepares the “Conclusions and Recommendations of the State Audit Committee”, which are then presented to the Knesset plenum for approval. Once approved by the Knesset plenum, the conclusions and recommendations have the status of a Knesset resolution (2).

In addition to the state comptroller, there are also internal auditors in both the MOD and the IDF. According to the 1992 Internal Audit Law, the Auditors report to the Chief of Staff of the IDF and the Director General of the MOD respectively. The Auditors are required to be of adequate qualifications and appropriate experience. They are independent in forming their annual assignment agenda, which requires approval only from the IDF chief of staff or Director General of the MOD, respectively. They have the power to require and receive any document or information in the said bodies, as well as access to any physical asset and any database of those bodies. The Auditors are responsible for reviewing the legality, integrity, propriety and efficiency of the bodies they audit. The administrations of the audited bodies are obliged by law to conduct a discussion of the yearly report and findings of the Auditors (3).

People who work within the units understand the corruption risks that are related to their institutions. They are able to identify and address some of these risks independently. Yet, they are not able to ensure other departments address risks adequately. This is also related to the fact that the Israeli army is considered as a very prestigious institution and has a lot of power (1).

Since 22 July 2019, the Anticorruption Supervisor of the Ministry of Defence is Admiral Inspector Sabino Imperscrutabile [1], who, in the performance of his duties, is assisted by a supporting structure [2]. In his report he identified the procedural and financial shortcuts of the units, as well as the lack of personnel compared to what expected. Nonetheless, according to his report, the shortcuts did not prevent the body to perform its institutional duties [3]. The Anticorruption supervisor works closely with the Independent Performance Review Body (Organismo Indipendente di Valutazione della Performance, OIV) unit established in the Ministry of Defence. [4]

According to article 1(7) of law 190/2012, all public administrations are required to identify a person responsible for the implementation and oversight of the anti-corruption measures enshrined in the three-year Plan of the administration. As stated by law, the person in charge has to be an administrative director of the administration [1]. As indicated in Q.8a, the Anticorruption supervisor works closely with the OIV [2]. According to the legislative decree 150/2009[3], every public administration has to establish a OIV unit with the duty to monitor, with complete autonomy, the good functioning of the evaluation, transparency, and integrity system of internal controls. The OIV is supported in its function by the Permanent Technical Structure (struttura tecnica permanente) [4] and refers directly to the Commission for evaluation, transparency, and integrity of public administrations, which is external to the Ministry of Defence. It operates in a close relationship, entirely independently though, with the Presidency of the Council of Ministers and with the Ministry of Economy and Finances. The Commission role is to coordinate and address the work of the OIV in every public administration, defence included. There are five members of the Commission, nominated by decree of the President of the Republic.

The personnel of the units understand the risks related to the corruption risk. As indicated in the Three-year plan, the knowledge of measures and procedures to follow is to be ensured, also through compulsory training [1], that is performed especially for roles subject to high risk of corruption [2]. The report of the Anticorruption supervisor, that presents all oversight functions performed during the calendar year, states that there is a complete knowledge of the anticorruption system, its responsibilities, and consequences of non-compliance [3]. Moreover, appropriate knowledge of the anticorruption system and related measures is also ensured by to the Code of conduct of the personnel of the Ministry of Defence [4]. To take actions against systematic corruption, the Anti-corruption Supervisor implements the dispositions received by the Ministry of Public Administration on the matter such as the practice of rotating personnel in high-risk positions. Moreover, the Supervisor handles the risks of corruption by adopting the best practices and procedures, which are subsequently summarised in the annual report on transparency and anti-corruption and include training, recommendations, and oversight.

The primary responsibility for dealing with legal compliance within the Ministry of Defence and the SDF lies with the Inspector General’s Office of Legal Compliance (IGO). Its task is to investigate and examine whether the Ministry of Defence is implementing the aims for which the budget was passed in a suitable and efficient manner and is working in compliance with laws and regulations. [1] One of the main means by which the IGO does this is by conducting regular inspections of the defence institutions, as well as special inspections on the directives of the Minister of Defence. The regular inspections focus on the topics of administration of freedom of information requests and the handling of administrative documents, avoiding collusion, and attitudes and institutions promoting compliance with laws and regulations. [2] The IGO has information about an email “hotline” for whistleblowers on its webpage. [3] The SDF Ethics Review Board also has a webpage with information on the principles it works for and a hotline for reporting unethical behavior. [4] The IGO was established in 2007 with a staff of approximately 50 persons. [5] Its staff consists of civilians and Self-Defence Force personnel. Some personnel have been seconded from the Public Prosecutors Office or the Japan Fair Trade Commission, and some are certified public accountants. [6] Some staff have been seconded from other ministries. In 2017, the staff had increased to 70, [7] and the head of the agency was a former Superintendent Public Prosecutor at one of Japan’s eight High Public Prosecutor Offices. [8] For the fiscal years 2015-2018, the actual budget for annual expenditure for IGO has been at about 500 million yen. The amount provided in the initial budget has been well above that in these years, indicating that the budget has not been a constraint for the office. [9] In a search of the mainstream newspapers Asahi Shimbun, [10] Nikkei Shimbun [11] and Yomiuri Shimbun [12] for the timeframe of this research and the Japan Times for the years 2015-2018, [13] no reports of explicit dissatisfaction with the staffing, funding or expertise of the IGO were found. However, a study group under the Ministry of Finance has pointed out that the specifications in many of the requests for tender by the Ministry of Defence are technically complicated and often used only by that ministry. In practice, this can make it difficult and costly for businesses other than large domestic Japanese companies that have produced the products before to bid, leading to a large proportion of tenders with only a single bidder. Finding ways to increase competition for bids is one of the tasks that the IGO is working on, and the study group suggested that it should strengthen its technical expertise to better be able to find ways to promote competition. [14]

The IGO is an independent office in the MOD under the direct supervision of the Minister of Defence. The Inspector General is to submit their reports directly to the Minister of Defence. [1]

The IGO publishes an annual report on its regular inspections. In its report for the fiscal year 2018, it wrote that it was working to implement the implications of a special inspection concluded in 2017, on the disclosure of activity logs of Japanese peacekeeping forces in South Sudan, for the handling of freedom of information requests and of administrative documents. [1] With regard to legal compliance, it mentioned the need to increase efforts to educate personnel about whistleblowing procedures and to make sure that cost-sharing agreements were signed when cooperating with institutions other than defence institutions on public relations events. [1] On the topic of preventing collusion, the IGO wrote that some of the defence institutions that procure equipment made less of an effort than the internal audit units in managing personnel working with procurement, managing contacts with businesses and educating personnel about ways to prevent collusive bidding. [1] Some of the issues mentioned had been mentioned in the 2015 report as well, indicating that preventing collusion was an ongoing effort. Such issues were increasing the number of bidders for tenders with only one bidder, separating the offices that calculate the target price for tenders from those that deal with procurement contracts, making sure that those who wish to submit bids do not communicate with each other, and insufficient cooperation between internal audit units and the institutions calling for bids in analysing the contracts after they had been signed. [2] The IGO is also in charge of organising focus periods in the SDF, lasting from one week to one month, during which emphasis is placed on specific compliance topics. [3] It also conducts courses for SDF personnel on compliance issues. [4]

There are ethics units in the armed forces and its subsequent agencies. These units have the mandate to provide guidance and training. Besides that, there is an internal auditing unit within the financial department. However, it is understaffed and not well-trained on corruption and anti-corruption measures [1,2].

The institutions/ units may be under the command of the defence and security institutions that they oversee. However, they cannot be shut down by these institutions as they are part of the armed forces structure and hierarchy [1,2].

Staff are underprepared for such a job and fail to produce a plan to address corruption risks within their institutions. They lack the experience and the necessary trainings [1,2].

There is no specific independent institution tasked with countering corruption in the defence and security sector. The defence and security sector rely on existing institutions mandated by various statutes to counter corruption. The defence sector draws guidance from The Defence Act of 2012 (No. 25 of 2012) that indicates, in section 124, of part VI that corruption or economic related crimes committed by defence personnel will be dealt with accordance with the provisions of existing laws which are enforced by civilian institutions. [1] Three core interlinked intuitions are particularly relevant. They include, first, the Ethics and Anti-Corruption Commission (EACC) which initially was established as the Kenya Anti-Corruption Commission (KACC) but later it was replaced with an independent EACC with a stronger, constitutionally protected mandate after enactment of the new constitution in 2010. The second core institution is the Office of the Director of Prosecution (ODPP) which is also an independent Commission. The third core institution is the judiciary; in particular, the High Court Division on Anti-corruption and Economic Crimes (ACEC). The ACEC has a Division in Nairobi City and Admiralty Division in Mombasa City. The Divisions deal with disputes relating to corruption and economic crimes matters that may be filed under any Law in the High Court.

Although the EACC still has weaknesses such lack of prosecutory powers, unlike its predecessor, the KACC, EACC as an independent commission has both institutional and financial independence. Institutionally, it means it has independent powers over how it hires and determines how members (director and advisory board members of the Commission are selected, appointed and discharge their duties. [1] Secondly, EACC has financial independence and is able to obtain funds from the consolidated fund rather than from treasury like earlier with KACC. Nevertheless, the EACC perenially faces resource shortages as it rarely receives its full annual budget request owing to government resource constraints and struggles to pursue politically sensitive cases owing to political interference [2].

ODPP’s mandate is to prosecute criminal cases including all corruption and economic crime matters investigated by EACC. The ODPP also gives directions to EACC and Department of Criminal Investigations (DCI) over the investigation of corruption and economic crime cases.

Despite the independence granted to the EACC, ODPP and Judiciary by the constitution, these institutions faces several challenges, particularly with respect to mandate and resources. Most of the funds that EACC for instance receives goes towards meeting salaries and rent expenses, and less is allocated for operations thus unable to effectively carry out its mandate. The same can be argued for the other two. Moreover, EACC was understaffed and internal staff, including the leadership, requires further clarity of role, mandate and accountability.[1]

Some of the major challenges that impact on prosecution of cases within ODPP, that also ends up affecting the effectiveness of the EACC and judiciary in general, include numerous objections such as judicial review applications and constitutional petitions; hostile, uncooperative and unavailable witnesses; shortage of Special Magistrates/anti-corruption courts, frequent transfers of magistrates, high turnover of investigators. [2]

It is not possible to establish from the data available, from EACC on effective investigation and prosecution of corruption cases in defence and security. This is because the data does not categorically specify by sector, where the cases that the EACC has managed to handle come from. Since 2003 to date, the EACC handled 554 cases with 289 of them having been convicted achieving a 52.1 per cent conviction. The rest of the cases (223) were aquittals while (42) were withdrawn. [3]

There are no independent bodies within the Ministry of Defence [1]. However, there are internal bodies who deal with integrity issues of the defence institutions, such as the Kosovo Security Forces (KSF) Inspectorate [2], the KSF Police [3] and the Internal Audit Unit [4].
The KSF Inspectorate is the sole body within the Ministry of Defence that is capable of inspecting, investigating, and supervising of the KSF, while its activities are exercised under direct subordination to the Minister of Defence [5]. The Inspectorate is led by the KSF General Inspector [5]. The Minister of Defence, through delegation to the KSF General Inspector, monitors the KSF and the Ministry of Defence for all activities relating to the KSF [6]. The KSF Inspectorate is tasked with recommending actions to strengthen the efficiency, effectiveness and integrity of the KSF and the Ministry of Defence [7], including recommending actions to prevent the misuse, loss or mismanagement of operations and programmes within the KSF and the Ministry of Defence [8]. Furthermore, the KSF Inspectorate and the Internal Audit Unit are responsible for recording the internal control system, as well as for reporting inconsistencies and violations that create grounds for corruption or fraud [9]. The Inspectorate also controls and investigates actions and assists with programme, policy and operational activities undertaken by the KSF both within and outside of Kosovo [10]. There is no information available regarding the number of personnel engaged in this Inspectorate. However, the Integrity Plan (2019-2022) mentions the Ministry’s inability to increase the number of staff in the KSF Inspectorate due to limitations in the organisation’s structure [11]. According to the government reviewer, the restrictions on increasing the number of staff of the Internal Audit Unit and the Inspectorate have already been exceeded with the approval of the new structure of the MoD by the Government and the start of its functioning in June 2019 [23].
The KSF Police oversee and support the KSF and the Ministry of Defence [12]. The Police Force’s mission is to establish, maintain and enforce law, order and discipline within the KSF and Ministry of Defence [11], as well as to detect and prevent offences and criminal activities [14]. The Policy assists other law enforcement agencies with investigations involving the KSF and Ministry personnel [15]. The duties of the KSF Police are thoroughly described in the Ministry of Defence’s Regulation No. 04/2010 on the KSF Police [16]. No information is available about the Police resources or number of personnel.
The Internal Audit Unit acts as an internal control body within the Ministry of Defence to ensure that all activities, data management and control systems in the Ministry of Defence and the KSF systematically go through internal audit to fully comply with provisions of the Law on Public Internal Financial Control [17], as well as the provisions of the plan approved by the Minister of Defence [18, 19]. More details on the duties of the Audit Unit within the Ministry of Defence can be found in the Government’s Regulation No. 07/2019 on Internal Organisation and Settlement of Job Positions in the Ministry of Defence [19]. This Internal Audit Unit comprises three staff members: the Head of the Unit and two auditors [20].
Alongside the internal bodies of the Ministry of Defence, there are also external bodies, including the Anti-Corruption Agency [21], the General Auditor and the National Audit Office [22], which are tasked with strengthening integrity and preventing or countering corruption in the state institutions, including across the defence sector. The relevant legal frameworks of each institution explains their missions, duties and responsibilities [21, 22].

The Kosovo Security Forces (KSF) Inspectorate, which is led by the General Inspector of the KSF, reports directly to the Minister of Defence [1]. This Inspectorate, which operates within the Ministry of Defence, is directly subordinate to the Minister of Defence [2]. The Minister of Defence therefore monitors the KSF activities [3].
The KSF Police are accountable to the Commander of Land Force Command within the KSF [4]. The KSF Police is granted unconditional independence from political influence or from Ministry of Defence interference with regards to conducting criminal investigations which are reported to Parliament [5]. KSF Police officers, although to a certain extent supervised and guided by leaders of the Police, perform their duties independently from the chain of command within the broader Security Forces [6].
The Head of the Internal Audit Unit within the Ministry of Defence reports to the Minister of Defence [7]. This Audit Unit also reports to the National Audit Office regarding all matters related to the execution of internal audits [8].
External bodies, such as the Anti-Corruption Agency and the National Audit Office as report directly to the Kosovo Assembly [9, 10].

A major challenge evidenced by the Ministry of Defence’s Integrity Plan (2019-2022) to the Kosovo Security Forces Inspectorate and the Internal Audit Unit was the inability to increase the number of staff in both internal bodies due to limitations in the organisational structure [1]. To address this issue, the management and administration of the Ministry of Defence needs to further strengthen the capacities of internal control bodies that cover all activities of the Ministry of Defence and the Kosovo Security Force [2]. With regards to corruption risks, there is a need to revise the Internal Risk Management Guide of the Ministry of Defence in order to adapt to the specific needs of the military mission of the Kosovo Security Force as well as to the specifics of each institution’s management, administrative and functional system, and specific sectorial scope [2]. It is worth mentioning that the activities and reports conducted by the Kosovo Security Force Inspectorate and the Internal Audit Unit are not made public by the Ministry of Defence. While observing the Internal Audit Unit, the National Audit Office stated in its 2018 assessment that the Internal Unit’s reports are qualitative and that it has consistently demonstrated a high quality of work [3]. However, no information is available on the Kosovo Security Force Police and its activities. It is therefore difficult to assess its performance as an internal body of the Ministry of Defence [4].
The Anti-Corruption Agency publishes an annual report [5] although this seems to contain mostly superficial information [4]. Similarly, the National Audit Office publishes an annual audit report on the Ministry of Defence [6]m, but more detailed information is needed for a thorough assessment on the work of the Ministry of Defence and the Security Force [4].

There are no special compliance and ethics units inside the interior and defence ministries but both functions are being carried out by the finance department in both institutions, according to officials (1, 2 and 3). These departments do not lack funding but their staff tend to lack expertise. Most tend to come from a business or a security background. Few studied law or accounting, but their mandate, which is not publicly available, is clear. They are meant to prevent the squandering of public funds and to investigate claims of corruption and any kind of misconduct, auditing officials said. Sometimes, for reasons these ministries do not give, these ministries establish temporary special committees to investigate corruption inside the institution, they added.

Lawmakers are more vocal about the interior ministry than they are about the military because the former is weaker than the latter.

In January 2017, the Parliament’s budgets committee leader, Adnan Abdel-Samad gave a press statement saying that the Interior Ministry’s financial department has been giving the SAB and other auditory agencies “conflicting data” and that it often fails to respond completely to all requests for information (4).

These finance departments are in the chain of command of the defence and security institutions and they can easily be shut down by the minister, according to auditing officials (1, 2 and 3). They are politically controlled by the ministers and other senior executive officials, as well as the Emir, who is the chief commander of the armed forces and the head of the executive branch. As a result, auditing bureaus and agencies in Kuwait tend to not give their reports, which are usually positive, much attention, officials said.

Staff within these finance departments are aware of corruption risks facing the institutions, but they are not encouraged to deliver a strategy to combat this. They are often not interested in doing so either because they are benefiting from the corruption themselves or are frustrated by the limitations imposed on them by the ministers, state auditors said (1, 2, 3 4 and 5). The Interior Minister and the Defence Minister have the legal right to decide how the funds of their institutions would be spent and how they will be monitored, according to article 24 of Law no. 23 of 1968 (6) for the police and article 27 of Law no. 32 of 1967 for the military. The ministers also have the right to decide if and how those who are found guilty of “losing or damaging” ministry funds would be punished. So these in-house units only have whatever power each minister has decided to give to them, and they are seen as the underlings of the ministers, officials say.

State auditors say these auditors tend to be only interested in tackling minor infractions, like reducing the salary of an officer as he was on the pay grade of a Master’s degree graduate, even though he only had an undergraduate degree (1, 2 and 3).

The MOD has established the Audit and Inspection Department (AID), which ensures integrity and is responsible for the implementation of anti-corruption measures. The MOD AID regularly conducts audits in accordance with the Internal Audit Law as well as the approved MOD Internal Audit Strategy and Internal Audit Plan, while the MOD AID General Inspection carries out inspections and investigates violations, including possible corruptive actions as well. Similarly, illegality is investigated by the Military Police of the National Armed Forces. [1] However, they are directly included in the institutional structure, so there is a possibility of micro-lobbying developing. In the best scenario, the department should directly report to the minister, like the system of the Ministry of the Interior, where the Forensic Department is directly under the Interior Minister, and they are believed to have no intermediary supervisor. [2] [3]

Such institutions as KNAB [1] and the State Audit [2] are independent and well-resourced. They report directly to the Defence, Internal Affairs and Corruption Prevention Committee of the Parliament, as well as to the Minister of Defence and the Commander in Chief of the National Armed Forces on their findings and put forward recommendations. [2] [3]

The KNAB is regularly submitted to scrutiny by GRECO, the Council of Europe’s ‘Group of States against Corruption’. The most recent report suggests that whilst the establishment of KNAB is a significant milestone, independence remains a “recurrent source of concern” [4].

Since the main institutions tasked with building integrity and countering corruption (as indicated in Q8A) are KNAB and the State Audit, their performance has been considered largely effective. There are reports on ineffective defence spending and squandering of financial resources. [1] [2]

The State Audit Office, for example, is one of the eight board members of the EUROSAI [3], a sign of its significance not just in Latvia but in Europe.

On June 26, 2019, the Parliament approved the Law on Combating Corruption in the Public sector which includes the creation of the National Anti-Corruption Commission (1). Nevertheless, Lebanon has yet to establish the commission which is responsible for receiving and investigating corruption cases (2). The LAF does not have a specific unit for combating corruption (3). However, as previously indicated, the military police, that operates under LAF Command, is responsible for building integrity and investigating violations committed by military personnel (4). Its personnel undergo specialized courses, continuously (5). According to the LAF’s Directorate of Orientation, the military police ensures integrity and discipline of the soldiers (5).

The Anti-corruption Commission, that has yet to be established, should be independent and have a separate budget that funds its activities (1). The Military Police is within the LAF’s chain of command and reports to the LAF Command or the Military Court (2).

The LAF is aware of corruption risks, though it might not be at the unit level (1). It has conducted workshops for officers on combating corruption (2), including one with the LTA (1). However, it has not addressed risks independently and trained its forces on risk reduction other than the few workshops that take place regularly (3).

In 2017 the Ministry of Defence approved the National Security System for 2017-2021 with an anti-corruption program and an extensive program-implementation plan. The main goals of this program (among others) were to ensure corruption prevention, eliminate conditions which allow the emergence of corruption, and to promote intolerance for corruption. The anti-corruption program and program implementation plan are publicly available online. According to the program, the General Inspector’s institution (the internal institution of the Ministry of Defence) is responsible for implementation, coordination and control of the program [1,2]. In addition, at a national level, there are other institutions fighting corruption such as the Financial Crime Investigation Service, the Special Investigation Service, and the Chief Official Ethics Commission. Other institutions – such as the Public Procurement Office and National Audit Office – analyse and evaluate public procurement processes, corruption-related risks within the National Security System, and provide recommendations on how to improve procurement and anti-corruption processes. However, the internal audit unit is not well staffed or resourced and is more reactive than proactive.

The General Inspector (GI), who is directly responsible for implementing the anti-corruption program within Ministry of Defence, is part of the chain of command within defence and security institutions [1]. The GI is appointed and can be dismissed from office only by the Minister of Defence [2[. The National Audit Office of Lithuania is a supreme public audit institution in Lithuania, accountable to the Lithuanian parliament [3]. The Special Investigation Service of the Republic of Lithuania (Specialųjų tyrimų tarnyba, STT) is a statutory law enforcement institution accountable to the President and the Parliament of the Republic of Lithuania [4]. The Chief Official Ethics Commission is a collegial authority set up by the Seimas (unicameral Parliament) of the Republic of Lithuania, and is accountable to this parliament [5]. The Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania is a state law enforcement agency accountable to the Ministry of the Interior of the Republic of Lithuania [6].
All the external oversight agencies (including the Special Investigation Service, the Public Procurement Office, the Supreme Audit Office) are independent from the Ministry of Defence and their assessments are generally perceived as independent. Only the General Inspector is accountable to the Minister of Defence, who is politically responsible for making the changes in the system of defence.

Staff of the Ministry of Defence understand the corruption risks specific to their institutions, however there is no information suggesting that all the departments address risks adequately and the interviewees could not provide any evidence that any such evaluations are conducted within the Ministry [1,2].

There is an Internal Audit and Investigation Division (BADSA) which is tasked with carrying out internal audits and conducting general investigations to ensure compliance in management. BADSA comprises several teams, each tasked with overseeing specific sections or activities in the ministry. BADSA offices are also established in several select states. Each team is suitably staffed with a Head Auditor and several assistant auditors as well as several administrative officers [1]. In addition, as part of a wider effort to increase integrity and reduce corruption, there is an Integrity Unit established in each government agency, including in the Defence Ministry (MINDEF) [2,3]. The Integrity Unit is tasked with identifying and responding to corruption cases, and with ensuring integrity and compliance. The Integrity Unit is much smaller compared to BADSA but is believed to be adequately staffed to run integrity building programmes and receive tips and complaints of misconduct which are forwarded to MACC for investigation. The unit is headed by an officer from MACC itself, the national anti-corruption task force. There are also numerous external integrity and anti-corruption institutions. The Institute of Integrity Malaysia is the operational body of the GIACC tasked with overseeing the implementation of the National Anti-Corruption Plan (NACP) [4]. The focal point of the government’s anti-corruption efforts is the Malaysian Anti-Corruption Commission (MACC) which is tasked with identifying and investigating all levels of corruption in all government agencies, including defence [5]. There is no information on the budget allocation for these units, nevertheless, judging from the amount and breadth of audits and programmes and activities organised, it is believed that the units are adequately funded.

Both BADSA and the Integrity Unit are placed under the direct command of and report to the Chief Minister of Defence. [1]

BADSA actively oversees activities within MINDEF. [1] [2] [3] In 2018, eleven audits were carried out by BADSA within the Ministry of Defence. [4] The ministry’s annual report incorporates both BADSA’s (page 28) and the Integrity Unit’s anti-corruption and integrity-building activities and assessments (page 53). [5] Defence ministry officials (political appointees and career civil servants) have generally viewed BADSA with suspicion. This is partly because BADSA has been seen as a unit which takes its internal audits seriously. [6] The Integrity Unit is headed by an officer from the MACC. In an interview with officials from the Integrity Unit, the unit demonstrated a clear understanding of corruption risks in MINDEF and seem to be well prepared to mitigate such risks through numerous regular anti-corruption training and activities as well as prompt action in case of any surat layang (poison pen letters) or complaints received of alleged misconduct or corrupt acts. [7]

A senior security governance professional told the assessor that the Inspector General of the armed forces has a constitutional mandate to conduct audits of irregularities within defence sector.⁴ However, the Inspector General does not publish any reports, making it very difficult to tell how effective the system of oversight is. The source told the assessor that the Inspector General reports to the Minister of Defence through the Secretary General, who himself was formerly Inspector General.⁴
A defence attaché working at a foreign embassy in Bamako confirmed that there is a military judicial system, in which the Inspector General plays a central role.⁷ The source said he had seen soldiers arrested and tried for offences such as theft, robbery and murder, but had not come across any cases of corruption being tried.⁷ In any case, he noted that results of such investigations are rarely made public, raising questions about whether offenders have been sanctioned or not.⁷
A security expert said that the Inspector General is there to ensure compliance with the code of conduct, but does not have a specific mandate to root out corruption or build integrity.⁸ Article 9 of the Code stipulates that military personnel should avoid any conduct that could dishonour the force, but there is no explicit mention of corruption.⁹
Indeed, several articles note that there is a need to adopt a code of ethic and compliance within the armed forces if the government is to have any hope of eradicating abuses.¹ ² “To do this, there will need to be an ethics charter and a code of military deontology to be devised by collaboration between the Defence Minister, the Chief of Staff, the various unit leaders and the soldiers”.¹ ²

This indicator has not been assigned a score due to insufficient information or evidence.

The current Inspector General, Ibrahim Dahirou Dembélé, was appointed in February 2018. The appointment was made by the Council of Ministers, having accepted the nomination of the Minister of Defence.⁵ ⁶ Having been a key figure in Captain Amadou Sanogo’s military junta in 2012, the appointment was highly controversial. Moreover, Dembélé was appointed a mere 15 days after a court in Bamako had lifted his probation status.⁵ ⁶ Dembélé currently stands accused of ‘passive complicity’ in the assassination in 2012 of 21 members of the red berets, a rival unit to that of Sanogo’s green berets. The trial of Sanogo and several co-defendants opened in November 2016 and is ongoing.
Making such a controversial appointment can be better understood when one considers that the president faces re-election in July/August 2018. With IBK being in a fairly weak position, the appointment of Dembélé was designed to secure the president votes from supporters of Sanogo and Dembélé.⁴ The overt political calculations in this appointment and the very sudden lifting of Dembélé’s probation status indicate how deeply politicised and non-independent the Inspector General is.

As highlighted in 8A, the Inspector General does not have an explicit mandate to tackle corruption, meaning that the position is largely ineffective in this domain.
A defence attaché working at a foreign embassy in Bamako confirmed that there is a military judicial system.⁷ The source said he had seen soldiers arrested and tried for offences such as theft, robbery and murder, but had not come across any cases of corruption being tried.⁷ Combined with the very controversial appointment of Dembélé as head of the Inspector General, the integrity and effectiveness of the body are severely compromised.

SEDENA and SEMAR have an Internal Control Body (OIC) whose mandate is to prevent, detect, punish, and eradicate corrupt practices. [1] In this regard, there is no information in the press or analysis that indicates that they lack human and monetary resources.

Likewise, they have Ethics and Conflict of Interest Prevention Committees which must help fight corruption through orientation, training, and dissemination actions that help fight corruption. [2] In this regard, there is no information in the press or analysis that indicates that they lack human and monetary resources. However, the SFP has indicated that based on the evaluations of these units, their performance is satisfactory. [3] [4] [5]

Both the Internal Control Bodies and the CEPCI are attached to SEDENA and SEMAR, and are made up of public servants from said agencies. [1] [2] However, neither SEDENA nor SEMAR can close these units since SFP is in charge of coordination and evaluation, based on the National Anticorruption System. [3] [4]

There is not enough information to score this indicator. The ASF carries out evaluations of both the OIC and the CEPCI. In the CEPCI cases, both institutions obtained approving and satisfactory results regarding their performance in the 2018 evaluation. [1]

On the other hand, the reports on the performance of the OICs present some observations, however, they do not detail the content. [2] In this regard, the SFP has also pointed out that in many cases the Comptrollers have dealt with “irrelevant acts aimed simply at updating manuals, conducting surveys or training events but that were not relevant” and the information they have presented is deficient. [3] [4] It is worth noting that most public documents relating to SEDENA and SEMAR do not refer to anticorruption policies or to any method for information or evalutaion of its employees on the subject.

The most relevant piece of information found was a conference held in 2017 with the purpose of informing employees of these institutions on Anticorruption. [4] As far as the research conducted reveals, this was a one time event and was never repeated again.

The Ministry of Defence has recently established an Integrity Department that has five employees. [1][2] The Department is present in the Ministry’s organisational structure, [3] but publicly available rules on internal organisations are outdated and the mandate of the institution is not clear. [4] In a country with limited capacities to fight against corruption, especially in defence sector, staff in a newly established institution may lack the required expertise and capacities. [5] According to the Ministry of Defence, staff in this department regularly participates in trainings and educations which gives them sufficient expertise and capacities to share experiences and help improving the system. [6]

The Integrity Department reports to the Director General of the Defence Policy and Planning Directorate, who is under the Minister of Defence. [1][2] An ethical committee was not established, therefore there is no proper monitoring of the implementation of the Army’s Code of Ethics. [3] There is no assessment related to defence, but, overall, institutions in Montenegro are under strong political control and/or are misused. [4][5][6][7]

According to the head of the recently established Integrity Department, the main corruption risks are presented in strategic documents adopted by the Ministry [1][2][3] However, these documents only superficially mention corruption [4][5] or fail to recognise important risks, especially those related to procurement. [6]

With regards to an effective anti-corruption policy for the defence sector, there was no evidence of compliance; there were no ethical units and not was there any effort to establish them. (1)(2)(3)(4)

Moreover, within the general context of anti-corruption, there seems to be no effective anti-corruption policy in any sector that could also apply to the defence sector.

In 2015, a law was passed to replace the Central Body for the Prevention of Corruption or ICPC (Instance centrale de prévention de la corruption) with the National Body for Probity, Prevention and Right against Corruption or INPPLC (Instance nationale de probité et de lutte contre la corruption) (INPPLC) (5). This law was followed by a series of announcements such as the adoption of a national project to fight against corruption; the signing of a framework agreement of ten programmes regarding 239 cross-sector projects; and the creation of relevant institutions such as the National Commission for anti-corruption (Commission Nationale Anti-Corruption). However, none of the above mentions neither explicitly nor implicitly the armed forces nor the defence sector. (6)(7)(8).

Also, despite the law from 2015, it appears that the National Body for Probity, Prevention and Right against Corruption has not yet been established. (9)

Additionally, the government announced that the National Anti-Corruption Commission was to become an institution in its own right. However, no action has been taken so far in this regard. (10)(11)

This sub-indicator has been marked Not Applicable because so far, the evidence gathered shows that there are no independent, well-resourced, or effective institutions within the defence and security sectors that could help build integrity and counter corruption. Moreover, the institutions that are tackling corruption in general are not performing efficiently so far.

This sub-indicator has been marked Not Applicable because so far, the evidence gathered shows that there are no independent, well-resourced, or effective institutions within the defence and security sectors that could help build integrity and counter corruption. Moreover, the institutions that are tackling corruption in general are not performing efficiently so far.

The military has its own audit body under the Ministry of Defence called the Account Department (KaKaNgwe) [1]. According to the Constitution, the military can adjudicate cases of corruption through its own courts-martial. The decision of the C-in-C is final [2]. Courts-martial are never conducted publicly. Their mandates are also not available to the public.

According to the Constitution, the Minister of Defence is nominated by the C-in-C of the Defence Services (see Chapter 5, Article 232{b}(2)) [1]. The Ministry of Defence is different from other ministries in Myanmar. The governance structure, including the Minister, Deputy Ministers, Permanent Secretary, Director General and Directors, is comprised of military personnel [2]. The Account Department is under the Ministry of Defence because the C-in-C is the Supreme Commander of all armed forces (see Chapter 1, Article 20(c)) [1]. So, the Ministry of Defence is under the control of the C-in-C of the Defence Services. The decision of the C-in-C is final. These institutions cannot be regarded as independent.

The Corruption Prevention Unit of the Myanmar Anti-Corruption Commission has conducted training for 14 ministries but 2 ministries were not included in this training: the Ministry of Border Affairs and the Ministry of Defence, which are under the control of the military [1]. The Military Misconduct Law contains provisions about the misuse of power and misuse of authority. But the law is not publicly available [2]. The Defence Services Act (1959) includes provisions about corruption offences such as insider trading and extortion [3]. So, the law practised in the military does not extensively address corruption. There are officers who conduct theses about corruption at the National Defence College and there are also lectures delivered on corruption by scholars there [4]. So, there are very few personnel with an awareness of corruption and most of the personnel in the Office of the Auditor General and the Directorate of Procurement do not have enough knowledge about corruption risks.

The main institution responsible for integrity within defence and security is the Central Defence Integrity Organisation (COID). The role of the COID is to provide expertise on integrity, support supervisors and employees within the defence sector in implementing integrity policy (including the Code of Conduct), provide risk analyses, conduct studies and manage reports from the Defence Integrity Reporting Centre [1]. The COID releases an annual report, which details the progress made in policy, the activities of the organisation and data on the type and number of reports lodged [2]. There is no evidence to suggest that the COID is understaffed or underfunded. The 2019 Annual Report stated that there were around 650 confidential advisors appointed [2]. Reported delays in investigations in 2020 were linked to COVID-19 measures impeding the COID from conducting personal conversations [3].

The Central Defence Integrity Organisation (COID) is part of the Ministry of Defence and is therefore not explicitly independent. Following a series of recommendations made in 2018 by the Giebels Committee, there has been further investigation on how to ensure further independence and policy has shifted. For example, in April 2019, the COID was designated a ‘Special Organisational Unit’ under the Secretary General of the Ministry of Defence in order to separate the COID from other defence components [1]. Additionally, the Defence Integrity Reporting Centre was disconnected from the COID and repositioned to be directly under the Secretary General of the Ministry of Defence [1]. Studies requested by the Minister of the Interior and Kingdom Relations show that confidential advisors experience sufficient space in their organisation to function independently and also feel that they are seen as independent within the organisation [2]. However, there is a perception among some employees the confidential advisors within their organisation do not act independently [2]. In a letter to Parliament, the Minister of the Interior and Kingdom Relations stated that, as a consequence of advice from experts and the variation in the needs of employees, the organisations within central government, including the Ministry of Defence, will offer a mix of internal and external confidential advisors [3]. An earlier parliamentary letter recognised the vulnerable position of the COID’s confidential counsellors, stating that ‘the advice or involvement of the confidential counsellor will not always be received with open arms and that this can become a threat to one’s own position’ [2]. The COID does have the autonomy to initiate an investigation of suspected integrity violations if they perceive signs of (possible) misconduct [1].

The staff within the COID attend training courses that cover theory, examples and risks of corruption within defence [1]. Confidential advisors must continuously keep up to date with regulations, developments within defence and the agreements made between defence units and their personnel [1]. Staff are able to act independently to address and investigate if they perceive signs of (possible) integrity violations [2]. This occurred in 2020 when the COID began investigating the Submarine Service following four official reports of undesirable behaviour from colleagues [3]. The investigation is still underway. Activities undertaken by the COID to mitigate risks of integrity breaches include research, theatre performances, training sessions, presentations and symposiums [1]. Broadly speaking, however, a pattern of ‘individual incidents’ within the Dutch MoD points to systemic issues in military culture that are treated as ‘individual bad apples’ [4]. Therefore, while some incidents will usually indeed be followed by an extensive report, recent research indicates that the approach of ‘individual incidents’ taken in such reports ensures that defence units can hide behind the idea that individual cases are being adequately solved, while simultaneously actively denying that there are structural issues in this department. This severely limits the real-life, long-term effectiveness of integrity units such as the COID [4].

Intel/Security – The Inspector-General of Intelligence and Security conducts independent oversight of the New Zealand intelligence agencies [1]. The appointment, functions, duties, and powers of the Inspector-General of Intelligence and Security is mandated by the Intelligence and Security Act 2017, Part 6 [2]. There were eight permanent staff members with an expenditure of $1.470 million in 2018/19. The previous Acting Inspector-General has stated that, under current conditions, funding is appropriate, but hinted that provision for growth would need to be included in future budgets [3]. Conversely, the Inspector-General was not aware of any specific training which may or may not occur within the intelligence agencies on corruption risks, however all departments are cognisant of the risks of corruption. This is reflected in both the GCSB and NZSIS having internal compliance and legal teams to ensure adherence to New Zealand law, and internal policies [4].

The NZSIS and GCSB must report to the IGIS on “compliance” breaches within their organisations. This, however, is usually understood to cover compliance with the law or internal policy on how they undertake “operational” activities [5]. While the IGIS’s oversight does not usually cover more corporate matters, such as the agencies’ approach to fiscal or HR risks or corruption, the IGIS is familiar with how their general training systems work. Agency staff must complete various training modules, which include the recording of details of who has undertaken certain mandatory training modules and the issue of certificates to confirm successful completion. This adds a further level of security and contributes to an awareness against corruption. Parallel to these efforts, both agencies have risk and audit committees and legal compliance functions which complement the training initiatives [5]. Typical of the relative lack of corruption in New Zealand Defence and Intelligence sectors, the IGIS has not received a report of corruption from within the agencies [5]. To reinforce this, the IGIS can reveal that no use of protected disclosure legislation has ever occurred for matters of corruption [5]. In the case that corruption could be a sign of foreign malfeasance (which could blur the line between the agencies’ counter-intelligence responsibilities, and integrity oversight of the legality/propriety of their internal activities by IGIS) the respective Director-General would inform the IGIS as a matter of course. However, in the first instance the responsibility for investigation would fall under the purview of the agencies [5]. If signs of corruption within the office of the IGIS were detected by the intelligence agencies, especially the misuse of classified information, this would result in IGIS being notified by the agency [5]. To mitigate against this, all staff within the IGIS and within the agencies undergo a “reasonably comprehensive induction process” [5]. IGIS access to classified information is capable of being reviewed by a specialist team within the intelligence agencies, and all IGIS staff have the highest level of clearance. Despite the relatively small size of the IGIS office, nine personnel, its resources have been sufficient to date and have improved slightly over the last few years [6].

Defence – The Secretary of Defence is empowered by Defence Act 1990, Section 24(2)(e), to arrange for the regular assessment of the Defence Force [7]. Till July 2020, the Ministry’s Independent Review unit conducted assessments and audits of the NZDF, as well as procurements by the MoD [8]. This unit could also commission independent reports into the NZDF, such as the Independent Review on the New Zealand Defence Force’s Progress on the Action Plan for Operation Respect [9]. At least five major reviews were conducted from 2015 to 2020, suggesting that the institution has sufficient resources to fulfil its mandate [10]. A decision was made in July 2020 to move to a model whereby reviews were conducted by external specialists and subject-matter experts, supported by staff in the Ministry’s Governance, People and Executive Services Division [13]. Despite this, there is no Inspector-General of the Defence Force, although this is likely to be created in the near future, based on the recommendations of the Burnham Inquiry [11] .Corruption is a crime under the Armed Forces Discipline Act 1971, a large part of which is monitored by the Military Police, though it is estimated that anti-corruption activities comprise an extremely small part of their duties [12].

Intel/Sec – The Office of the Inspector-General of intelligence and Security is an independent statutory officer appointed by the Governor-General on a recommendation from the House of Representatives (Part 6 of the ISA) [1, 2, 3]. This provides the Office with a high-level of independence.

Defence – till 2020 The MoD’s Independent Review unit submited its report, audit, or assessment directly to the Secretary of Defence for submission to the Minister. Since 2020 audit and assessment function have been conducted by Expert review group consisting of independent external specialists [6].

On giving the report, audit, or assessment to the Secretary the person in charge of the report, audit, or assessment shall give a copy to the Chief of Defence Forc [4]. This system provides for sufficient independence as the Secretary is mandated to provide the report to the Minister. However, the Government inquiry has recommended that a fully independent Inspector-General of Defence be established [5].

There is not enough information to score this indicator.

Intel/Sec – The Office of Inspector General of intelligence and Security regularly publishes annual reports on inquires and reviews, and matters of cooperation such as with the Christchurch Royal Commission [1]. However, the Inspector-General has no efficiency or effectiveness mandate “when overseeing the activities of the intelligence and security agencies and has no intelligence research, collection or analysis capability that might support such a mandate” [2]. Ordinarily, the IGIS does not conduct oversight over the corporate activities of the agencies, as the IGIS tends to focus on operational legislative compliance, however the office could do this if the need arose and if the corporate activity involved issues of legality or propriety that the IGIS was well suited to inquire into [3]. The Office does not review the effectiveness of agencies generally and does not review the efficiency of agency functions [3]. As such the Office cannot direct other departments or units to handle risks in a certain way if that is part of their own respective operating mechanisms and has not caused or could be a cause of improper conduct relating to an inquiry or investigation.

Defence – The findings of the Operation Burnham Inquiry indicate that an increased system of effectiveness is required for developing integrity within the NZDF. Operational integrity is still of a very high order; however, the bureaucratic workings have revealed shortcomings in accurate reporting of information [4]. Owing to a lack of evidence on corruption activities within the NZDF to assess this indicator, it is not scored.

Defence and security services in Niger include different various institutions: the Niger Armed Forces (FAN), under the Ministry of Defence, are responsible for external security and, in some parts of the country, for internal security. Gendarmerie Nationale (GN), also under the Ministry of Defence, has primary responsibility for rural security. The National Guard of Niger (GNN), under the Ministry of the Interior’s Public Security, Decentralisation, and Customary and Religious Affairs (Ministry of Interior) is responsible for domestic security and the protection of high-level officials and the government buildings. The National Police also fall under the command of the Ministry of Interior and are responsible for urban law enforcement (2). 
The Defence Ministry’s internal oversight body is called the Office of the Inspector General of the Armed Forces (IGA/Inspection Générale des Armées) (1). It is responsible for ensuring that all relevant administrative, financial and budgetary rules and standards are applied and respected and that public resources are managed in a transparent, efficient and cost-effective manner. Inspectors work under the supervision of the presidency (3). The IGA has 8 sub-divisions assisted by technical specialists (3).
Similarly, the Ministry of Interior has a General Inspection of Security Services (IGSS) whose mission is to control security services: the National Police, National Guard and the Civil Protection through “skills enhancement and respect for ethics” (4). In addition, two external control mechanisms exist for the police: the direct hierarchy (responsibility of police commanders and field commanders to supervise and train their police officers) and the General Inspectorate of Security Services (IGSS), which is also the internal control mechanism for the Civil Protection and the GN (National Guard). The IGSS, which reports directly to the Ministry of the Interior, conducts fact-finding visits in the field. However, its capacity and the available resources are limited (5).
In 2014, the DCAF initiated a partnership with the IGSS which allowed the institution to reinforce its technical capacity. In 2017, DCAF conducted an institutional audit of the IGSS that highlighted the need for training for IGSS staff to address deficiencies in professional skills necessary for internal control activities. The DCAF started with training on internal control and auditing techniques, as well as risk management and budget (financial) oversight (6).
Finally, it should also be underlined that as the IGA, the IGSS is not provided with unit offices in the field and the approval of fact-finding missions is subject to a specific funding request (3, 7). Therefore, even though compliance and ethics units exist, there are weaknesses connected to staffing and funding that might potentially undermine the efficiency of these institutions.

The IGA depends directly on the Presidency of the Republic (1). Therefore, it is not in the chain of command of the Ministry of Defence that it oversees; however, under the Constitution, the president is also the supreme head of the armed forces. As to the IGSS, it depends directly on the Ministry of Interior (2). Both institutions (IGA and IGSS) depend on funding from their hierarchy to conduct evaluations and audit missions in the field. No information regarding the hypothesis of being shut down by the presidency of the Ministry of Interior was found.
However, as commander-in-chief of the Nigerien armed forces, theoretically, President of the Republic can shut down both units. As noted in 8A, neither the IGA nor the IGSS can be qualified as independent agencies. Furthermore, given funding problems (especially for the IGSS), sufficient independence does not seem to be possible.

According to an interviewee, the IGA could lead two forms of audit: planned and non-planned. The planned one conducts fact-finding visits to the field throughout the year. However, at the time of data collection in May 2018, the planned audit has not yet been implemented due to a lack of resources, such as fuel (1). The last audit conducted by the IGA in the field took place in 2017 (1). In general, the audit conducted by the IGA includes inspection of the number of personnel, armament, ammunition, cars, fuels, food and health services. According to the interviewee, control of munitions is very important as they may explode if too old (1). The audit control also verifies the training of the personnel, its capacity to use armament and to repair it if necessary (1).
However, it has been reported to the assessor, that a joint IGSS-IGA non-programmed audit is taking place in June 2018 to check corruption risks among the gendarmerie (1). Similar joint missions had already taken place through 2015-2017 (1,2). As a result of one of these joint missions conducted in Agadez in 2016, some security officers were revoked (2). Besides, IGSS and GIZ are also regularly conducting joint missions to raise awareness among the population about corruption risks, which are not audit missions (2).

The Office of the Director (Office of the Permanent Secretary) Special Duties was created to oversee the Anti-Corruption and Transparency Unit (ACTU). It has a Civilian Component which incorporates within it a Procurement Department. The corruption units efficacy is questionable as there are not organically integrated into the ministries as they are normally supervised or under the umbrella of the Independent Corrupt Practices Commission (ICPC). This raises questions about their funding and staffing levels as well as their operational effectiveness (1). There is also the Economic and Financial Crimes Commission with powers to investigate any person about financial crimes such as money laundering. The chairman of the Commission is appointed by the president but confirmed by the Senate (2). The EFCC is currently the lead agency in the prosecution of the military chiefs indicted for the abuse of the military procurement process between 2007 – 2015.

The Anti-Corruption and Transparency Unit (ACTU) is under the Ministry of Defence but is also under civilian control. The Unit is quasi-autonomous to the Ministry of Defence as it is a part of the Independent and Corrupt Practices Commission (1). The Office of the Director is located within the Office of the Permanent Secretary which is a civilian role; they report to the Permanent Secretary (2).

The NACS aims to “Strengthen the powers of anti-corruption institutions and other relevant bodies to prevent and proactively mainstream transparency and accountability measures in public and private institutions [Existing prevention platforms include ICPC Ethics and compliance checklist/scorecard, SERVICOM and Code of Conduct Asset Declaration measures]” (3 p.27).

The information available does not suggest that action plans have been prepared since the publication of the National Anti-Corruption Strategy document was published by the Ministry of Justice. There is a problem of coordination between all the Anti-Corruption and Transparency Units of the various MDAs (1), (2). Concerns remain about the efficacy of such units as media reports indicate that ACTU staff in other MDAs do not have the capacity or necessary training in ethics to successfully discharge their role.

Core units responsible for building integrity and countering corruption within the Ministry of Defence are the Internal Audit Department (IAD) and the Inspectorate of the Ministry of Defence [1]. In addition, the Ministry of Defence Department for Legal and Personnel Affairs and the Military Service for Security and Intelligence have a supporting role in this process. The former provides a sound legal and administrative framework for integrity and anti-corruption processes [2] whilst the the latter for vets personnel for the Ministry of Defence [3]. Also, the Department for International Cooperation works closely with the NATO BI Programme, and implements a Partnership Goal on Integrity Development (G0204). The Minister of Defence works in a targeted manner with the IAD to improve existing policies and processes to combat corruption and identify risks. The Inspectorate has the responsibility to detect, investigate and document corrupt activities within the Ministry of Defence and the Armed Forces and cooperates with IAD in this framework [1]. In this context, the IAD has unlimited access to all activities undertaken in the Ministry of Defence, documents, assets and employees, to oversee the integrity of the processes and systems and to confirm that the established controls provide adequate protection against all types of errors, frauds and losses [4]. The Inspectorate, on the other hand, supervises the implementation of the Law on Defence (article 163) and other regulations in the area of defence [5]. Part of that supervision includes detecting any corrupt processes, and if they are found, in cooperation with the other sectors in the Ministry, measures are taken to address and sanction this corruption [6]. The Defence Inspectorate is well-organised, skilled and effective in enforcing laws and fighting corruption. The IAD, on the other hand, according to 2015 Building Integrity Self-Assessment, was authorised to employ 18 members of staff, out of which only 4 were trained auditors [3]. In 2018, the IAD was staffed at 39% capacity (according to the current organisational set-up), and internal auditors accounted for half of this staff [5]. This indicates that the IAD works at only 50% or less of its predicted strength.

All units report directly to a senior member of the Ministry of Defence, Formally, the Internal Audit Department (IAD) is directly subordinated to the Minister of Defence while the Inspectorate of the Ministry of Defence reports to the State Secretary of defence. The Ministry of Defence’s Legal Department also reports to the State Secretary. The Military Service for Security and Intelligence is subordinated to the Minister of Defence [1]. Yet, their autonomy should also be considered in the country’s political context [2]. Prior to 2016, some media reports noted high levels of partisan politics even within the Ministry of Defence. It was claimed, for instance, that in 2006, the then new Government, fired more than 30 Ministry of Defence high-officials and replaced them with party loyalists [3]. Following the political change in 2016, no evidence of political control or manipulation in the Ministry of Defence or the Army has been demonstrated. Nonetheless, pure independence across public sectors remains a contested issue.

The 2016 Integrity Plan of the Ministry of Defence addressed the levels of awareness concerning corruption risks among the Ministry of Defence and Army staff. Regular detection of risks, analyses and various forms of training have been part of the implementation of the plan [1]. Staff within the Internal Audit Department (IAD) and the Defence Inspectorate, given their pivotal role in the fight against corruption, have been the focus of this training. Public information about the trainings, their frequency and subjects covered is not available. There are only a few media reviews reporting mainly on general integrity trainings for high officials in the Ministry of Defence and the Army, such as the training in January 2017 [2]. MoD claims that trainings on anti-corruption and integrity have been performed on regular basis. In 2018 MoD started the Train the Trainer Programme with strong support of the NATO BI Programme. [5] The number and subjects of Internal Audits are reported to the Ministry of Finance as a part of the Annual Financial Report. For example in 2018 3 regular and 3 ad-hoc audits were performed. [5] The number and subject of Inspectorate investigations are available on the MoD website. [6]
The 2015 Building Integrity Self-Assessment peer Review Report [3] and the Difi report [4] also lack information in this domain, despite their comprehensiveness in other fields.

The Centre for Integrity in the Defence Sector (CIDS) was established in 2012 on the initiative of the Norwegian Ministry of Defence. The CIDS’s mandate is to promote and enhance professional integrity and good governance in the defence sector, with a clear focus on anti-corruption. The centre is co-located within the Ministry of Defence [1]. The CIDS has 3 permanent employees and cooperates with a number of associate experts [2]. It also collaborates with other entities within the Norwegian defence sector; for example, together with the Internal Audit Unit (IA) of the Norwegian Ministry of Defence, the CIDS published a guide on “Managing the Risks of Real Estate Corruption and Fraud in the Defence Sector” in 2017 [3]. The Internal Audit department also plays a role in preventing corruption. In addition, the Ministry of Defence has appointed the Council on Ethics for the Defence Sector, an independent council with a mandate to strengthen the ethical awareness and reflection of all employees in the defence sector. The council’s works focuses mostly on military ethics. The council reports to the Ministry of Defence and the ministry approves its budget [4]. The Parliamentary Ombudsman for the Armed Forces can also investigate complaints registered by soldiers and defence employees, which could conceivably address some corruption-related issues. The Ombudsman and the Ombudsman’s committee of 6 members comprise a public body under the Norwegian Parliament. The Ombudsman and committee members are appointed by and report to Parliament [5].

The CIDS was established in 2012 as an independent unit under the administrative authority of the Ministry of Defence. In 2019 the centre was integrated into the MoD’s new section. The CIDS is now a part of the executive and remains in the chain of command of the Ministry of Defence. It reports directly to the Director General of the Norwegian MoD’s Department of Management and Financial Governance [1]. Within the area of good governance the CIFS remains an independent unit, but the Ministry of Defence has the power to shut down the CIDS [2].

The Advisory Board for Integrity in the Defence Sector has been established to provide a forum for professional discussions in the field of integrity building and give advice concerning the ambitions of the CIDS [1]. The Advisory Board meets twice a year to discuss the activities and priorities of the CIDS. Members of the Advisory Board are representatives from all of the MoD’s departments, the director of the Institute for Defence Studies, the Dean of the Defence University College, and the SSR coordinator of the Defence Staff, as well as representatives from the Ministry of Foreign Affairs, the Agency for Public Management and Government, the National Security Authority, the Norwegian Defence Research Establishment, the Norwegian Defence Estates Agency, the Defence Logistics Organisation and the National Joint Headquarters. Collaboration across the entire Norwegian defence sector enables the competence and experience of all relevant defence institutions to be drawn upon. In addition to publishing several guidelines and reports on corruption risk in the defence sector, the CIDS has developed e-learning courses for the Norwegian defence sector and an ethical dilemma bank of workplace dilemmas and scenarios that military and civil employees typically find themselves in [2]. It provides instructors to a course at the Norwegian Joint Staff College [3]. The CIDS aims at conducting a biannual corruption risk assessment of the intersection of the national defence sector and the defence and security industries which it considers to be one of its main tasks. The centre has already developed a method and is ready to apply a maturity model to assess selected suppliers and the Norwegian Defence Materiel Agency. The CIDS plans to present its findings next year [3]. Every other year the CIDS conducts a quality assessment of a chosen area of the defence sector (for example HRM, openness, procurement, impartiality, financial management). The last published assessment from 2017 deals with post-employment restrictions in the defence sector [4]. Recently, the focus has been on its reorganisation. In addition, the CIDS contributes to a number of international integrity building initiatives and serves as Department Head for NATO’s Building Integrity (BI) programme. It should be noted that the CIDS is a rather small united and integrated part of the Ministry of Defence and has a lot of responsibility for effectively building integrity and countering corruption. Moreover, apparently due to more focus on reorganisation, the CIDS is now behind schedule with publishing its biannual quality assessment.

There are no dedicated institutions in the defence or security sectors dedicated to countering corruption or building integrity within either sector. Within the armed forces, there is the moral guidance unit which provides training that does not include corruption per se, but it could mention it as part of the Islamic morals training (1), (2). Sources (3), (4) demonstrate security forces are used to combat corruption in other sectors such as police’s dedication to combatting crime and upholding the law in the private sector (3). The BTI report of 2018 describes the policy as follows, “Corruption falls under the aegis of a number of security services such as the Royal Oman Police, the Internal Security Services and the Ministry of Palace Office” (4). No reference is made to mandates within either the Ministry of Defence or the Royal Oman Police force (5), (6). There is no reference to any ”independent, well-resourced and effective institutions” that exist within defence and security institutions in the country. Neither is there any institution mandated and/or tasked with scrutinizing defence or security across Omani state apparatus.

This indicator has been marked Not Applicable because there are no compliance or ethics units in place in defence and security institutions.

No independent and well-resourced institute fights corruption within the army (1), (2), (3). Even the moral guidance unit is not independent and has no mandate for fighting corruption (4), (5). This sub-indicator has been marked as Not Applicable as Oman does not have institutions or units tasked with building integrity and countering corruption within the defence and security sectors.

Corruption is not a major issue within the armed forces, and therefore, such units do not look at corruption as a risk or try to focus on it, even if it exists (1), (2), (3), (4). This sub-indicator has been marked as Not Applicable as Oman does not have institutions or units tasked with building integrity and countering corruption within the defence and security sectors.

There is no designated commission or unit within the armed forces or the security forces that focus on corruption issues. However, as the PA admits that corruption exists within PA, they have a commission that deals with corruption issues within PA (1). The Anti Corruption Commission works as an anti-corruption institute for all PA agencies. Besides that, within the ministry of interior, there is a designated unit, “The General Directorate for Financial Auditing with the Military Service.” This department works on auditing the armed forces and national security agencies commercial work (2), (3).

There is a special control unit in all the constituent organs of the security forces to handle complaints, following a system approved by the Council of Ministers. However, it is not specifically oriented to corruption or ethics (4).

The Anticorruption Commission is not independent and has no authority. The minister of finance heads it, and as the national forces commanded by the president, their role is weak in countering or investigating corruption cases within the PNF. According to the law, the executive appoints, fires personnel, and ratify the laws of the commission. The president is the head of the state (PA) who selects the head of the Anti-Corruption Commission, as well as the head of all security and semi-military forces. Therefore, this commission is not independent of the executive (1), (2), (3).

Neither the department nor the Anti-Corruption Commission has an active plan. Appointments are made through nepotism and not a meritocracy. The commission failed to act against corruption cases within the PA. Their inability to address the issues sufficiently can be traced back to the fact that their actions need to be approved by the ruling political bodies, so the absence of effectiveness is very much linked to the absence of independence (1), (2).

Units are in place, including the Office of Ethical Standards and Public Accountability (OESPA), Office of the Judge Advocate General (OTJAG), and the Inspector General’s Office. With at least 190 active military lawyers, the OTJAG is responsible for resolving legal issues concerning real estate, personnel, retirement, appointment, separation, demotion, promotion and procurement [1]. The OESPA is tasked with monitoring and overseeing the compliance of AFP personnnel such as in the filing of the SALN (Statement of Assets, Liabilities and Networth) used to assess wealth accumulation [2]. However political influence and resourcing make them prone to weaknesses [3, 4, 5].

The Office of the Inspector General and the Office of Ethical Standards and Public Accountability are under the chain of command of the Armed Forces of the Philippines (AFP) and report to its chief of staff, who is appointed by the executive [1,2,3,4,5]. Budget for personnel and equipment of these offices are generated within the existing resources of the AFP [6]. As such it is not independent and can be either merged with other offices or shut down by the bodies they oversee [7].

Staff within the units, especially in the OESPA that evaluates the Statement of Assets, Liabilities and Networth (SALN) of military personnel understand the corruption risks specific to their institutions, but they are not able to address risks adequately [1, 2, 3]. On SALN submissions, low compliance can be attributed to the general lack of mechanisms to monitor its implementation, and a comprehensive review on these SALNs cannot be conducted due to a lack of resources [1, 4].

The MoND’s Bureau of Anti-Corruption Procedures had been operating during 2006-2016, and it reported directly to the minister. The Bureau of Anti-Corruption Procedures was responsible for preventive monitoring of public procurement at all stages, submitting opinions on classified tenders and evaluating legislative acts of the Ministry of National Defence from an anti-corruption perspective. Currently, the preventing corruption task is carried out by the Unit for Anticorruption Procedures at the Bureau of the Minister of National Defence.
The staff resources were significantly increased from 5 posts (with the director) of the Bureau for Anti-Corruption Procedures, to 7 posts (+ 1 for the director of the Office supervising his work). In addition, up to date all employees deal with substantive issues, because the administrative support has been taken over by other civil servants in the Bureau of the MoD, which also has an impact on efficiency.
In the Ministry, additional ethical advisers (4 people) were also appointed who are not part of the Bureau, therefore, in the field of ongoing ethics consultancy, significant support for the anti-corruption unit has been created.
Moreover from 2018 all employees received significant salary increases. The budget for the international cooperation in the field of anti-corruption has also been increased.
Its mandate has been weakened, as it is no longer a separate body directly subordinate to the minister. The chair has no direct access to the minister, and his/her opinions and proposals are subject of assessment by the cabinet’s director and consequently may be filtered. Further institutions include the Military Police and the Military Counter-Intelligence Service, both of which are tasked with preventing and investigating crimes, including corruption in the armed forces. [1, 2, 3].

The unit is in the chain of command of the defence and security institutions that it oversees. Its role is limited – the Bureau of Anti-Corruption Procedures was incorporated into Bureau of the Minister. The chair has no direct access to the minister, and his/her opinions and proposals are subject of assessment by the cabinet’s director and consequently may be filtered. On the other hand, the director of the Bureau of the Minister is a civil service corps member and he is directly subordinated to the minister. Moreover the unit is not subordinated to Secretary of State responsible for modernisation of the Armoured Force nor to military units, and they have no power to shut down the unit.
Further institutions include the Military Police and the Military Counter-Intelligence Service, which are more independent, as they are regulated by separate acts rather than by internal orders of the minister [1, 2, 3].

Staff within the units understand the corruption risks specific to their institutions. However, the mandate of the anti-corruption unit has been weakened, as it is no longer a separate body directly subordinate to the minister.
The unit gives opinions to new draft of procedures, provide trainings, prepare new procedures, monitor the procurement, some actions of the defence institutions require its acceptance too. Unfortunately, there are examples where its opinions are not taken into account.
[1, 2, 3].

The Inspectorate-General of National Defence (IGDN) is mandated to handle compliance and audit the national defence sector [1]. Its mandate does not specify ethics or anti-corruption activities [2]. The IGDN is not well-staffed if one compares the year 2005 (60 staff members) to 2019 (34 staff members) [3]. Its funding has fluctuated between 2015-2019, and the agency points to budgetary restrictions dating to 2010 [4], which may be related to the low coverage rate of auditing activity reported as of April 19th 2019 [5]. Staff expertise ranges from individuals with college degrees to low-skilled public workers, pending towards the former. Substantive staff expertise is not publicly available, although defence expertise can be surmised from the military ranks of nominated staff.
The Portuguese Navy [6], the Portuguese Army [7] and the Portuguese Air Force [8] operate units charged with internal compliance and oversight.

The IGDN reports directly to the minister of defence [1]. The branch units report to single service chiefs.

There is evidence that the IGND has implemented a defence-specific risk matrix [1] and built a corruption prevention plan which includes practical recommendations [2]. This indicates high understanding of corruption risks specific to the defence perimeter. but there is no evidence that the IGND can monitor implementation nor that it can address risks independently. Reports on the ongoing Tancos case suggest limits to proactive auditing and limited effectiveness [3]. This is reinforced by recent Supreme Audit Institution (SAI) audits that suggest limits to the ability of IGND to affect change from within [4, 5].

It has become apparent through research, that the even though Qatar has an Audit Bureau, the mandate of the Audit Bureau explicitly excludes the Ministry of Interior, Ministry of Defence and the Armed Forces [1]. Qatar does not have any independent well-resourced, and effective institutions within defence and security tasked with building integrity and countering corruption. According to our resources, there is a unit within the armed forces named, the “Ethical Guidance” unit. However, this unit is not independent, it is under-staffed, and it needs more resources [2,3].

This sub-indicator has been marked as Not Applicable, because the country does not have any institutions or units within the defence sector specialised in building integrity and countering corruption [1,2].

This sub-indicator has been marked as Not Applicable, because the country does not have any institutions or units within the defence sector specialised in building integrity and countering corruption [1,2].

The anti-corruption department in the MoD Main Personnel Directorate is a permanent unit tasked with developing internal anti-corruption regulations, maintaining anti-corruption training in the army and ensuring that all MoD personnel declare their revenue regularly and fully [1].

There is also the Anti-Corruption Council under the Minister of Defence (ACC) [2] and the Commission on Compliance with the Requirements for Official Conduct and Settlement of Conflicts of Interest (Commission) [3], formed by the MoD to handle corruption and integrity in the defence sector. The ACC is an advisory body and meets twice a year. Its members include deputy ministers, the heads of the Main Personnel Directorate and the Inspectorate for Financial Control, etc., as detailed in section II of the provisions of the ACC [2]. There is no publicly available information about the members of the Commission, who are appointed by order of the Minister. The Commission fulfills the role of a disciplinary body and meets ad hoc to revise cases related directly to conflicts of interest of MoD employees (whenever a potential/current employee has other jobs/businesses, fails to submit full information about revenues, etc.) [3].

Combined with the Chief Military Prosecutor’s Office under the Ministry of Internal Affairs, the three MoD units have a full mandate to handle integrity and corruption in defence. The suitability of the staff could be brought into question as there is no detailed information available about the members. Similarly unclear is the suitability of the funds they receive because most of the MoD budget is not publicly available.

The ACC, the MoD Commission on Complainace and the anti-corruption department in the MoD Main Personnel Directorate report directly to the Minister of Defence and are therefore in the chain of command of the overseen institutions [1,2,3]. Their work can be influenced by Minister’s order. For example, clause 8 of the ACC regulation stipulates that the council’s meeting are held under the chairmanship of the Minister, while clause 4 prescribes that all the Council’s decisions shall be presented to the Minister for the approval. [1] The similar situation occurs with the Commission, whose members shall be confirmed by the Minister’s signature. [2] There was never a case of such unit or institution being shut down. It looks like in case of disagreement between the unit and the top Ministry’s management, the senior officers of the unit would be dismissed and replaced with more loyal people rather than the whole unit would be disbanded.

The ACC and the Commission organise regular reports about their internal anti-corruption work. All personnel report their revenue and the results are published on the MoD website [1]. These units also provide an analysis of incoming reports about possible corruption offences in the MoD [2]. The ACC publishes reports on the successful implementation of anti-corruption decisions and events [3]. The anti-corruption department in the MoD Main Personnel Directorate publishes information about corruption crimes within the MoD [4].

Although the units are quite active in their anti-corruption activities and they understand corruption risks within the Ministry, there are doubts as to whether they can effectively investigate the corruption offences or compel other departments to do so. The units fail to prevent or investigate major corruption in the army, reporting only minor bribes or offences. For example, the range of bribery sums reported by the anti-corruption department in the MoD Main Personnel Directorate is 500 to 20,000 rubles and they are all committed by junior personnel. The media, meanwhile, uncovers cases where MoD officials have embezzled millions of rubles [5]. Besides, its work is criticised even within the MoD. 44.19% of personnel said the department’s work in 2018 was of ‘low’ quality [6].

More effective results are delivered, it seems, by the anti-corruption investigation units outside of MoD authority – the Chief Military Prosecutor’s Office and Main Military Investigate Office, which withdrew from MoD jurisdiction in 2017 [7,8]. They have uncovered and investigated several grand corruption cases within the last few years [9,10].

Saudi Arabia does not have any institutions or compliance and ethics units solely dedicated to monitoring corruption in the security and defense sectors. There is a unit that provides Islamic teachings and ethics but does not cover corruption(3,4).
However, the GAMI (see above), established in August 2017, appears to act partly as an industry regulatory body. For example, one of its eleven stated targets is:

Establishing monitoring mechanisms for the military industry sector and its complementary industries and following up their application (1, 2).

The extent of GAMI’s oversight and compliance powers for the Saudi defense industry is as of yet unclear, and its charter has not been made publicly available. However, it does not appear to comprise a unit or agency solely focused on compliance and ethics oversight body in the defense and security industry.

Saudi Arabia does not have an institution or unit tasked with countering corruption in the defence and security industry, and therefore this sub-indicator is not applicable (1), (2).

Saudi Arabia does not have an institution or unit tasked with countering corruption in the defence and security industry, and therefore this sub-indicator is not applicable (1), (2).

There are several bodies tasked with tackling corruption within the MoD and SAF. The Military Security Agency (MSA) has the competence to detect, investigate and collect evidence on criminal acts of money laundering, corruption and organised crime [1]. The military police also has an important part in tackling criminal aspects of corruption [2]. The Law on Defence indirectly gives the mandate to the Defence Inspectorate to address corruption, through performing inspection activities [3]. When it comes to security services, the inspector general has the mandate to determine facts on illegal or irregular actions in the activities of the MSA and the MIA and their employees. Also, there is internal control within the MSA and the MIA, tasked with overseeing the legality of their work and the implementation of powers and authorities of their personnel [1]. All documents concerning human resource management in the defence system have been declared confidential in 2016, hence the information on staffing and resources of these institutions cannot be provided.

The independence of these bodies is disputable since they are directly accountable to the executive, i.e. to agencies’ chiefs when it comes to internal control [1, 2, 3]. MSA and MIA directors are directly accountable the Defence Minister. They can be dismissed by the President of the Republic or the Government (depending on whether the person is a military member or civil servant) on the proposal of the minister. Inspector General of the Services can be dismissed on the proposal of the Defence Minister as well [1]. Criteria for the appointment and dismissal of the Director of the Defence Inspectorate are not clearly defined [3].

There is not enough information to score this indicator. The effectiveness of these bodies is difficult to evaluate since the MoD itself does not have the central register of either criminal complaints about corruption against MoD employees and SAF members nor the data on who filed the complaints. In its response to the BCSP questionnaire, MoD has failed to provide that information [1]. There is no evidence of specific training for members of the Defence Inspectorate for instance, in identifying and tackling corruption risks. Individual cases of tackling corruption can be found in media reports [2, 3]; however, it is hard to gain comprehensive image on activity and effectiveness of bodies tasked with addressing corruption within the MoD and the SAF. Moreover, information on the number of employees within the Defence Inspectorate is classified, hence its capacity to perform inspection activities cannot be assessed [1].

MINDEF set up the MINDEF Anti-Corruption Committee (MACC) in 1997 to oversee anti-corruption policy, framework and measures in MINDEF/SAF. Its secretariat is tasked to review the anti-corruption policy and measures periodically to ensure that it is efficient and relevant. [4]
The Internal Audit Department (IAD) evaluates and improves the adequacy and effectiveness of risk management, control and governance processes. The IAD perform audits and reviews on behalf of the MINDEF Audit & Risk Committee (MARC). Its mandate includes the audit of the business and operating processes, financial statements, reviews of MINDEF-affiliated organisations, talks and training on professional ethics and corruption-related topics for service personnel, as well as special investigations [1]. However, details of the staffing and funding are not disclosed publicly [2]. While the IAD audits and provides guidance on governance, matters on integrity and corruption appear to be referred to external organisations such as the Corrupt Practices Investigation Bureau (CPIB) [3]. CPIB it is the only agency in Singapore that has the mandate to investigate any act of corruption in the public or private sector, including the defence sector. [4]

An audit committee, which convenes every two months, examines reports and remedial actions [1]. The IAD reports to civilian leadership in MINDEF and is not within the SAF’s chain of command. Meanwhile, the CPIB is an independent and fully separate organisation that reports directly to the prime minister [2].

MINDEF departments and SAF units are expected to serve as the forefront against corruption; they are responsible for maintaining effective internal controls on a day-to-day basis. Departments and units perform self-assessments based on a checklist developed by the IAD, and the results of internal checks are reported at the appropriate forums for attention and remedial action, if necessary [1]. There is general confidence that the IAD’s efforts in overseeing and training MINDEF/SAF units have been effective in fostering a culture that is adverse to corruption [2].

External institutions mandated to counter corruption, and to a less clearly-defined extent, build integrity, that addresses the defence and security sectors include:
– Public Protector;
– Auditor-General;
– The Portfolio Committee on Defence;
– Joint Standing Committee on Defence;
– The Joint Standing Committee on Intelligence;
– The Standing Committee on Public Accounts (SCOPA).

The Department of Public Enterprises is mandated to counter corruption in state-owned enterprises, including the state-owned aerospace and defence firm, Denel. Within the Department of Defence, the Directorate Anti-Corruption and Anti-Fraud (DACAF) is responsible for policing fraud and corruption. The DACAF has powers nested within the DoD Inspector General (IG) and acts in support of the IG’s overall auditing and anti-corruption objectives [1].

In terms of the DACAF, it is unclear to what extent the DoD command structure exerts, or can exert influence over anti-corruption efforts. The Department of Public Enterprises notes in its 2019/20 Performance Plan that oversight activities funded through the state-owned Companies Governance Assurance and Performance, and Business Enhancement, Transformation and Industrialisation programmes that “the combined budget for these programmes is expected to decrease at an average annual rate of 71.4% over the medium term, from R6.4 billion in 2018/19 to R148.7 million in 2021/22” [1]. The implication being a potential reduction in funding for oversight applicable to Denel.

It is unclear whether or to what extent staff within anti-corruption institutions or units are aware of corruption risks within their respective institutions or units. As such, this indicator is marked ‘Not Enough Information’ and is not scored.

There are two main institutions to oversee and detect corrupt activities within the defence and security sector. The Board of Audit and Investigation of Korea (BAI) is established by the constitution and law and acts independently to oversee and inspect officials and government institutions, including the defence sector. The Department of Defence Inspection at the BAI, which consists of approximately 30 members, is committed to inspecting and monitoring the Ministry of National Defence and relevant institutions and those in the sector. [1] In 2014, the Special Department of Defence Procurement Inspection was launched with a two-year term at the BAI in accordance with defence policy, which focused on improving accountability in the defence procurement sector, under the former Park administration. [2] The Defence Acquisition Program Administration (DAPA) is another monitoring institution in the defence procurement sector. It was founded in 2006 to strengthen the transparency and expertise of the acquisition process. [3] There are two monitoring departments within the DAPA: the Inspector General and the Special Inspector General for Defence Acquisition. Both are responsible for monitoring potential corruption risks in the defence procurement process. [4] The Special Inspector General for Defence Acquisition, which was launched in 2015, has legal experts, including senior prosecutors and accountants. [5] The number of personnel in charge of internal audit is 303, which is 19% of the total employees at the DAPA. [6]

The BAI and DAPA are not within the chain of command of the defence institutions. Although the BAI and DAPA are responsible for inspecting officials and defence institutions, they are not empowered to prosecute officials or shut down these institutions. When wrongdoings of officials or potential corruption are identified, all cases are forwarded to prosecution institutions. [1] [2]

While staff in the defence institutions understand the risk of corruption through anti-corruption training, the effectiveness of monitoring systems and staff’s expertise is highly questionable. [1] A number of high-ranked military personnel and those in the arms industry were wrongly accused of bribery charges by the BAI and audit bodies during the Park administration. Some research and media investigations indicate that the conviction rate for corruption cases related to defence procurement is less than 50%, while the conviction rate for other criminal cases is nearly 90%. [2] [3] In 2015, Choi Yoon-hee, a former chairman of the Joint Chiefs of Staff, the highest rank within the South Korean military, was arrested on the charge of ordering his subordinates to forge documents regarding the operational capabilities of the AgustaWestland AW159 Wildcat, a military helicopter that the South Korean Navy imported. However, he was acquitted in the Supreme Court in October 2018. [4] Another such case is that of a senior researcher working for a domestic arms manufacturer who committed suicide after being accused of manipulating a test for military equipment in 2015. After 2 years, all defendants related to this case were found not guilty of the alleged crime. [5]

Within the Ministry, various departments that are supposed to offer oversight on corruption issues exist. These are the internal audit unit, procurement, accounts, budget, and the department of finance at the Sudan People’s Liberation Army (SPLA) HQs. [1] However, there is no evidence to suggest that the Ministry of Defence (MOD) has set up compliance or ethics units. Government officials are often quick to tout such moves in the media to show the public and the international community that they are serious about fighting corruption. There is no media reporting on the setting up of compliance or ethics units within the MOD. There is a general expectation that civil servants should abide by the ethics language in the Civil Service Act, which says “a high standard of professional ethics shall be promoted and maintained.” [2] But this is inadequate because the Act itself does not oblige government ministries to set up compliance or ethics units.

The MOD has an internal audit unit whose duty is to offer oversight on audits and ensure that the Ministry is audit compliant. [1] Given that the internal audit unit is located within the Ministry of Defense, its work is likely to be under political control and/or undue influence. There has been no audit of government accounts that has been released publicly since 2012. [2]

There is no publicly available information to score this indicator, therefore, it has been marked ‘Not Enough Information’. Sources contacted for information have not been forthcoming. It is important to contextualise the fact that MOD issues regarding purchases of material, contracting, transparency, accountability or any other business dealings are shrouded mostly in secrecy in South Sudan.

There are no specific anti-corruption bodies in the defence and security sector [1]. Cases of crimes against the treasury or heritage in the military sphere are addressed in the laws of the Military Criminal Code: Organic Law 14/2015 [2] and Organic Law 13/1985 [3], nevertheless the existence of the Spanish Army’s small Department of Internal Affairs is an indicator of efforts in this direction [1]. In addition, there exists the legal entity of the General Comptroller of the State Administration who carries out its functions and powers through the General Comptroller of Defence and the General Accounting Subdirectorate of the Ministry of Defence [4]. Moreover, there is a special prosecutor on corruption and organised crime [5] that tackles issues of corruption in defence [6].

There is not enough information to score this indicator. There is insufficent evidence to confirm that the investigation units in the army (internal affairs or the intelligence regiment) are independent, due to their dependence on the military hierarchy; they are in the chain of command of the defence and security institutions [1]. Military jurisdiction is exercised by professional military personnel belonging to a militarily organised corps dependent on the Ministry of Defence [2]. It is also not possible to confirm that the military justice system, which is responsible for upholding the Military Penal Code, also operates as an independent body [2, 3].

The Spanish Army’s Department of Internal Affairs have the required knowledge about corruption risks specific to their institutions, but it does not seem to have the necessary resources to carry out its function, because it was formed in 2012 by three people from the Civil Guard, a paramilitary police force [1]. Despite this, the crime against the patrimony or the military property is found every year among the most common among defence personnel [2, 3]. The effectiveness of this branch came into question when in a question asked submitted to the Transparency Portal in 2018 about the number of senior officers (colonels and generals) convicted of corruption since 2000; the answer was only three. While there are dozens of cases tried through military justice system every year [2, 3], no one has been expelled from the Spanish Army [4, 5].

There are no compliance and ethics units whose mandate extends to defence institutions. Sudan’s previous regime established an anti-corruption commission and an ‘Anti-Corruption Investigation Unit’ that belonged to the National Intelligence and Security Service (NISS) [1]. The government also operated an Auditor General office. Complaints of unethical behaviour by public sector personnel could be submitted to an Ombudsman, but no such independent watchdog had the authority to investigate complaints in the security sector. The International Budget Partnership’s (IBP) 2019 Open Budget Survey for Sudan rated the legislature’s and supreme audit institution’s oversight of the national budget as ‘weak’, scoring it 33/100 [2]; considering that their involvement in defence and security oversight is even more limited than in other sectors, it is fair to conclude that there were no compliance or ethics units in place or sincere and effective efforts to establish them during Bashir’s regime. The IBP formally recommended that the government ‘ensure the supreme audit institution has adequate funding to perform its duties’, implying that it did not have adequate funding at the time [2].

The 2019 transitional Constitutional Charter stipulates a requirement to set up an anti-corruption and public funds recovery commission [3]. The transitional government established the ‘Empowerment Elimination, Anti-Corruption and Funds Recovery Committee’ to ‘disempower’ beneficiaries of corruption during former President Bashir’s tenure [4], but these largely politically motivated efforts have so far almost entirely avoided targeting military officials and military elements that are still active in the new government. An expert on Sudan’s defence sector said that ‘Committee members are politicians, not people with legal or technical backgrounds… [Furthermore,] an attack on anyone in the military by someone else who is part of the [transitional government] agreement is seen on an attack on the [transitional military and civilian government] partnership itself’ [5]. As of October 2020, an independent anti-corruption commission had not yet been formed [4].

This indicator is marked Not Applicable, given that there are no compliance ompliance and ethics units whose mandate extends to defence institutions. The few publicised occasions on which the anti-corruption commission took action against corruption prior to President Bashir’s ouster have been interpreted by analysts as being politically motivated [1]. Since Bashir’s ouster, most activity against corruption has targeted former regime officials from whom property and other assets can be and have been reposessed by the state because they were allegedly obtained via corrupt means under the regime’s rule [2]. A Dabanga article from June 2020 states that Mohamed El Faki, member of the Sovereign Council and acting Chairman of the Empowerment Elimination, Anti-Corruption and Funds Recovery Committee, explained on his Facebook page ‘that during the rule of the deposed regime, the Auditor General had no access to the financial statements of companies and institutions affiliated with the military and security apparatus’ and that ‘the former regime maintained its corrupt activities by controlling the legal system. Therefore, reports of the Auditor General concerning the abuse of public funds and embezzlements were never investigated or dealt with’. He went on to reveal that in January 2020, ‘the Auditor General handed the transitional government 180 reports about abuse public funds and embezzlement, but he did not specify the period in which these violations occurred’, and pointedly noted that, so far, 2019 is the only year for which the Auditor General still has not yet issued a report [3].

In a phone interview, a leading expert on Sudan’s defence sector said ‘The anti-corruption commission has started a sequence of investigations, but it is more of a political operation, having little to do with due justice’ [4]. In other words, there is no readiness within the transitional government to pursue corruption investigations against parties of the fragile coalition government because doing so might risk undermining the stability of the transitional process. Implicit in this analysis is the assumption that military elements who are party to the agreement will not tolerate the extension of due process and accountability to themselves. The potential to do so in the future has been pushed down the road in favour of pursuing low-hanging fruit that all parties of the transitional government agree need to be plucked: corrupt former regime officials.

This indicator is marked Not Applicable, given that there are no compliance and ethics units whose mandate extends to defence institutions. With respect to former President Bashir’s creation of a (headless) anti-corruption commission, a 2020 CIPE report reads: ‘[I]t soon became clear that the main motive behind these measures was burnishing Al-Bashir’s image before the international community… Al-Bashir’s commission failed to make any significant changes and did not present a single criminal case for prosecution’ [1]. A Dabanga article published in June 2020 states that Mohamed El Faki, member of the Sovereignty Council and acting Chairman of the Empowerment Elimination, Anti-Corruption and Funds Recovery Committee, explained on his Facebook page ‘that during the rule of the deposed regime, the Auditor General had no access to the financial statements of companies and institutions affiliated with the military and security apparatus’ and that ‘the former regime maintained its corrupt activities by controlling the legal system. Therefore, reports of the Auditor General concerning the abuse of public funds and embezzlements were never investigated or dealt with’. He went on to reveal that in January 2020, ‘the Auditor General handed the transitional government 180 reports about abuse of public funds and embezzlement’ that presumably dated back to before the 2019 political transition, but pointedly noted that, so far, 2019 is the only year for which the Auditor General still has not yet issued financial audit reports for government institutions [2].

There are no agencies specifically addressing the issue of corruption within the defence and security establishments. However, both internal (see also Q16) and external audit (Q17) institutions are effectively scrutinising issues like legal compliance, policies, integrity, spending, and transparency within the defence sector [1] [2]. The external auditing body, NAO, have issued no recommendations or reports suggesting that the auditing functions in public institutions are currently insufficiently staffed or resourced [3].

Auditing institutions like the National Audit Office (NAO) [1] are not in the chain of command of the defence and security institutions which they oversee. They report to the parliament and submit their reviews and assessments directly to MPs, parliamentary committees, and government ministries [2].

The auditing institution NAO works across government sectors and understands the corruption risks tied to each area, including security and defence. However, as they typically only possess the mandate to issue ‘recommendations’ to other security and defence actors [1], and cannot prepare an action plan with effective mitigation measures which address the risks. The government has not yet drafted an effective or comprehensive anti-corruption policy for the defence sector [2] (see Q7).

The Interdepartmental Working Group to Combat Corruption in its latest report and based on an evaluation by the Swiss Federal Audit Office (SFAO) favours the creation of a more independent body with additional resources that would be in the position of working out a strategy for the whole of the federal administration [1, 2]. However, since 30 January 2020, there is a directive for the Federal Department of Defence, Civil Protection and Sport (DDPS) on fighting corruption with detailed provisions and references to the general code of conduct. The directive also defines the tasks of a “Specialist Unit Corruption” (Fachstelle Korruption) on departmental levels and delegates the responsibility of fighting corruption to the different administrative units of the DDPS [3]. Armasuisse appears to address the topic of corruption systematically, and it put in charge the head of international agreements and compliance of the new specialist unit [4, 5]. Thus for armasuisse the specialist unit has been put in place and forms an additonal anti-corruption structure besides the interdepartemental working group on a lower administrative level. At the time of writing the degree of implementation of the directive in other departments could not been verified.

The Interdepartmental Working Group to Combat Corruption in its latest report and based on an evaluation by the SFAO favours the creation of a more independent body with additional resources that would be in the position of working out a strategy for the whole of the federal administration [1, 2]. However, since 30 January 2020, there is a directive for the DDPS on fighting corruption with detailed provisions and references to the general code of conduct. While delegating the implementation of measures in the fight against corruption to the different administrative units, the directive also defines the tasks of a “Specialist Unit Corruption” (Fachstelle Korruption) [3]. It is too early to assess these measures at the time of writing. Armasuisse also addressed the topic of corruption systematically [4, 5] and issued a directive following up on the DDPS directive [6].

A new directive from 30 January 2020 on fighting corruption the DDPS creates a specialist corruption unit. One of the tasks of that unit is to coordinate the anti-corruption training efforts of the, to be created, anti-corruption units in each department. These departmental units are in charge of awareness and other specific training for the employees in the anti-corruption efforts. The directive also clarifies the duties of the employees in relation to the fight against corruption [1]. The Code of Conduct for federal employees also applies to the staff of the different units at the DDPS, it is also referenced in the directive [2]. Additionally, armasuisse lays out the basic principles for its employees on the pages of the website dedicated to the anti-corruption efforts and has put into place a specialist unit [3]. Although there is no indication of the organization of specific training before the new directive anti-corruption training; measures, awareness-raising and discussions on the topic were part of other training modules [4].

Under the architecture of the Board for Integrity and Anti-corruption, the MND has several institutions working on government ethics, integrity, and anti-corruption from the perspectives of policy design and strategy formulation, education and training, and implementation and execution for Taiwan’s armed forces [1].The Ethics Office of the MND is the leading office to educate, advise, monitor, supervise, and integrate the expansion, progression, and implementation of government ethics, integrity, and anti-corruption across the entire Taiwan’s Armed Forces. [2].The Office of the Inspector-General of the MND is the main office which initiates investigations into and corrective measures for Taiwan’s armed forces for matters not only related to military issues but related to issues surrounding military discipline. Breach of official duties and anti-corruption mandates are regarded as severe violations of military disciplines [1]. The Comptroller Bureau holds the functions for budget accounting and statistics of the military. These functions, which aim to improve efficiency and accountability, mandate the Comptroller Bureau with administrative or executive powers to compile, supervise, and audit all budgets within Taiwan’s armed forces [3]. The issues and agendas of integrity and anti-corruption for the military operations of Taiwan’s Armed Forces are under the authority of the Political Warfare Bureau. The Military Discipline and Ethics Division of the Political Warfare Bureau is responsible for establishing policies for supervisory personnel, military discipline, graft and bribery handling and prevention, case investigation, supervision of investigation, and property declaration [4, 5]. These MND’s units and offices concerning integrity-building and corruption-countering are staffed according MND’s Table of Organization & Equipment and funded with MND’s annual budgets. Both the Table of Organization & Equipment and the annual defence budget are well reviewed and approvaled by the LY.

The Ethics Office is not in the chain of command of the defence and security institution. It is a civil servant unit. Under the “Act of the Establishment and Management of the Government Employee Ethics Units and Officers”, ethics officers are assigned by the Agency Against Corruption of the Ministry of Justice. The promotion and performance evaluation of the ethics officers are decided by Agency Against Corruption not Ministry of National Defense. Unlike the other units, the ethics officer is able to conduct daily routines independently without interference from the chain of commend. [3, 4]

Other institutions and units of anti-corruption and integrity are within the hierarchical structure of the MND and the chain-of-command of the armed forces. The Minister of National Defense and the Chief of the General Staff have administrative and commanding authorities over them [1, 2]. These administrative and commanding authorities of the MND do not have the option or power to “shut down” the institutions/ units of anti-corruption, ethics, & integrity.

The Ethics Office regularly assesses the corruption risks of the institution and deals with risks independently. From January 2015 to December 2020, the Ethics Office finished 22 early warning, 8 re-fighting corruption, 8 project auditing cases and 6 risks assessment. The results and suggestion of these cases were reported in the “Reporting Meeting of Ethics”. The Ethics Office also helps other departments or units handle risks in a proper way. [1]

However, the overlapping functions of these institutions and units within the MND present several concerns for the campaign for government ethics, integrity, and anti-corruption [1]. As the “Corrective Measures Against Subordinate Institutions under the Ministry of National Defence” (國防部所屬軍事機關採購缺失頻仍且異常關聯 監察院糾正國防部) of the CY has highlighted, there are issues to be re-examined; namely, the insufficient understanding of the “National Integrity Building Action Plan”, shortages of expertise on anti-corruption, and institutional tribalism [2].

For example, on the June 20, 2019, the CY proposes corrective measures against flaws in several procurement projects of the navy headquarters, air force headquarters, ROC Air Force Academy, and the Material Production and Manufacturing Centre of the Armaments Bureau for misconducts and mis-operations [1]. The MND’s personnel for ethics and integrity and managing corruption risks are selected, trained, and guided according to the “Organisation and Guidelines for the Board for Integrity and Anti-corruption of the Ministry of National Defence” [3].

The Prevention and Combating of Corruption Bureau (PCCB) functions under the Prevention and Combating of Corruption Act No. 11 of 2007. [1] The Act gives a mandate to the Director General of PCCB to execute the functions of the Bureau listed in section 7 (a) – (f). Further more Part I of the Act, section 3 provides an interpretation of ‘Public Official’ as referenced in the Act. The Act interprets a ‘Public Official’ as any person holding a legislative, executive, judicial, administrative, political, military, security, law enforcement and local government authority or any other statutory office and includes (a) any person performing public services; and (b) any other person natural or legal so defined in any other law. Based on this definition, the PCCB has the mandate to handle issues of corruption and integrity in defence and security.

However, a search of media sources and government websites did not reveal information as to whether the PCCB is suitably staffed and funded.

The PCCB is under the direct control of the President of Tanzania, who is also the Commander-in-Chief of the armed forces. [1] The President has the power to appoint and dismiss the head of the PPCB. The President can also instruct the PCCB which cases to investigate and which to shut down. [2]

There is not enough information to score this indicator. A search of media sources and government websites did not provide evidence to determine whether staff in the PCCB are aware corruption risks specific to defence.

The Office of the Inspector General is a special unit under the Office of Internal Audit responsible for monitoring corruption issues with the MoD [1]. The Office of Internal Audit, Ministry of Defence, generally performs duties relating to the analysis of corruption risks and conflicts of interest and also provides annual reports on these matters to the State Audit Office [2]. Every year, the officers in the Office of Internal Audit attend the anti-corruption training organised by the Royal Thai Armed Forces Headquarters [3]. According to the Regulations of Ministry of Defence on Internal Audit 2010, internal audit officers should have knowledge and expertise in the field of corruption monitoring or possess qualifications specified by the Cabinet or Ministry of Finance [4].

The Office of the Inspector General under the Office of Internal Audit, Ministry of Defence, is not in the chain of command of the MoD, which it oversees. The Office reports directly to the Commander-in-Chief of the Ministry of Defence [1]. Moreover, its annual report is further scrutinised by the State Audit Office [2]. However, it should be noted that an army sergeant did expose some cases of military corruption. He filed a petition with the Ombudsman of Thailand, but was later pressured by his superior not to pursue the case. Later, he filed an appeal via the Director of the Army’s Judge Advocate General’s Office and to the National Anti-Corruption Commission of Thailand, but eventually he was investigated and in the end, he was imprisoned [3]. This story clearly shows that there is no real independent/effective institution tasked with building integrity and countering corruption within the defence sector of Thailand. All those institutions of checks and balances against military control/corruption are merely for show.

Since the Office of the Inspector General, a special unit under the Office of Internal Audit, was established specifically for monitoring corruption issues with the MoD, the staff are required to have knowledge and expertise in the field of corruption monitoring or possess qualifications specified by the Cabinet or Ministry of Finance [1]. In addition, the internal audit officers must attend the anti-corruption training organised by the Royal Thai Armed Forces Headquarters on an annual basis [2,3]. Even if the staff are aware of this corruption risk however, it is the top generals who make the final decision as demonstrated in the cases of mistreated whistleblowers in the military which show that the Office of Internal Audit failed to take appropriate actions [4,5,6]. Each year, the Office of Internal Audit produces an analysis report on risk assessment regarding corruption issues and conflicts of interest. The report is submitted directly to the Commander-in-Chief and then to the State Audit Office [4].

According to our sources, there is a unit in every governmental institute which has the responsibility to fight corruption and enhance integrity. These units were created under the “Government Decree No. 2016-1158 of 12 August 2016, establishing the governance units and setting their attributions”, and a unit called “central governance unit” was created within each ministry, including the Ministries of Defence and the Interior (1). However, these units are not well-resourced and lack independent funding(2,3). The anti-corruption authority extends to defence institutions (4). The Anti-corruption Authority signed a convention with the Ministry of Defence intending to strengthen anti-corruption efforts in the Ministry of Defence (5). The Anti-corruption President often declares that his institution is underfunded (6). The Government decree mentioned above states that each public structure must provide the human and material means necessary to accomplish the tasks entrusted to the governance cell but there is no information available about the real funding and staffing of the Ministry of Defence’s central governance unit. (6)

According to our sources, the central governance units are independent and do not belong to the chain of the commander. However, these units are still linked financially to the MoD(5,6). These cells are responsible for many tasks relating to governance and the fight against corruption (prevention, planning, follow-up of corruption cases, coordination, cooperation, etc.) (1,2). These units report directly to the cabinet of the Minister of Defence. Central governance units are attached to the cabinet of the ministries (3). The Anti-corruption Commission (INLUCC) has recently signed an agreement with the Ministry of Defence. The partnership agreement aims to dedicate good governance and the principles of integrity and accountability, develop a bilateral training program in the areas of good governance and strengthen cooperation in raising awareness of the dangers of corruption (4).

This indicator has not been assigned a score due to insufficient information or evidence.

According to our sources, the units are new and in the development phase, and are being resourced with expertise, and therefore, their effectiveness is still limited(1,2). Based on that, staff have been acquired and they are knowledgeable about what the corruption risks are and how to measure them and handle cases.

There are no independent, well-resourced or effective institutions within the defence/security sector tasked with building integrity and countering corruption. There are currently two primary executive oversight bodies within the state apparatus: the National Security Council, an advisory body on defence/security-related issues, which is chaired by Erdogan and dominated by the civilian cabinet; and the State Supervisory Board, which is directly attached to the presidential palace and has full authority to conduct administrative investigations within any state institution. As mentioned above, there is the Financial Audit Department at the Ministry of Defence, which is responsible for all corruption and integrity-related issues around defence procurement carried out by the Ministry of Defence. There is still onging institutional confusion over the role and responsibility of the National Security Council and its Secretary, the institution that has been playing the role of a government body in charge of developing defence policy and, to some extent, monitoring in the field of defence/security.

So far, open-source research has shown that there has been not a single case of oversight by either one of these two bodies, nor any attempts to initiate an investigation or inspection into defence/security-related executive issues, since the beginning of the executive presidency. Interviewees 4 and 6 suggested that the absence of an independent auditing department within the Presidency of Defence Industries (SSB) is directly linked to the heart of the problem [1,2].

This indicator is marked ‘Not Applicable’ as there are no such institutions in place. The Secretary of National Security and the State Supervisory Board can play an effective role in building integrity and countering corruption within the executive bodies of the defence/security sector. However, as explained earlier, in their current position, they are under the full control of the presidential office and the overall sentiment at the presidential palace is geared towards covering up all allegations of corruption to avoid being exposed to criticism either domestically or internationally [1].

Interviewee 6 suggested that the Financial Auditing Department at the Ministry of Defence is under the full executive control of the Minister and that the personnel working in this department do not have immunity or a service guarantee. He said that he witnessed several instances of financial auditors, following their service in the department, being appointed to the military units of the generals whom they had investigated [2]. This shows that the Ministry of Defence does not care much about the independence/autonomy of the financial auditors and does not prioritise their independence when appointing them within the military.

This indicator is marked ‘Not Applicable’ as there are no such institutions in place. According to Interviewee 4, who worked on military finance for almost two decades, existing institutions or units do not have full and clear awareness of corruption risks within the security sector [1]. Interviewee 5 and 6 fully agreed with this assertion [2,3].

Anti-corruption agencies such as the office of the auditor-general and Inspectorate of Government (IG) [1, 2] and the disciplinary units in the defence sector are in place to enforce integrity and they such as the unit Disciplinary Committee, the General Court Martial and Court Martial Appeals Court [3]. The anti-corruption institutions, however, decry understaffing and inadequate funding. For example, the then Inspector General of Government Justice Irene Mulyagonja noted in 2018 that the inspectorate was underfunded, understaffed and unequipped to perform its mandate [4].

Compliance and ethics units in the defence sector are in place such as the unit Disciplinary Committee, the General Court Martial and Court Martial Appeals Court. Isaac Ssemakadde, a lawyer and activist and other organisations including the African Commission on Human and Peoples’ Rights say Uganda’s military disciplinary and justice systems are not independent and impartial because the judge advocates, judges are appointed by the same authority and are serving military personnel. Ssemakadde also says that the courts convict culprits, but some are redeployed, and yet the offence they committed calls for dismissal, among others [1, 2]. In 2015, the United Nations high commissioner for human rights held discussions on the military justice system in Uganda. A summary of the discussion highlighted that the African Commission on Human and Peoples’ Rights in its third report had noted that the Uganada People’s Defence Force (UPDF) Act did not have adequate safeguards to guarantee the independence and impartiality of the military courts, judge advocates, prosecutors and members of the military courts. The summary also noted that the Constitutional Court ruled in the case of Uganda Law Society and Jackson Karugaba vs the Attorney General that “it is not possible for military courts to be independent and impartial given the laws under which they are constituted and the military structure within which they operate”.

According to the Daily Monitor [1], the staff are aware of the corruption risks, but they are unable to address them through their work or by convincing others due to internal fights, intrigue, political witchhunt and fear of losing jobs or reprisals. They have to get guidance and approval from the military’s leadership to determine the way forward, including how to handle accused and convicted persons. According to Isaac Ssemakadde, a lawyer and an activist says Uganda’s military disciplinary and justice systems are not independent and impartial because the judge advocates, judges are appointed by the same authority and are serving military personnel. Ssemakadde also says that the courts convict culprits, but some are redeployed even if the offence they committed calls for dismissal, among other punishments [2].

There are several units responsible for combatting corruption within the MOD. First, the Corruption Prevention and Combating Bureau. The Bureau coordinates and supervises the activities (in regards to corruption) of all units, enterprises and individuals within the MoD [1]. The Bureau is also responsible for the:
• Preparation, provision and control over the measures on corruption prevention implementation;
• Provision of methodological and advisory assistance on compliance with anti-corruption legislation;
• Participation in information and scientific research provision of measures on corruption detection and prevention as well as international cooperation in the mentioned area;
• execution of organizational and explanatory work on corruption detection, prevention and fighting;
• Checking on the timely submission of declarations on property, revenues, expenses and financial liabilities, examination of such declarations for conflict of interests’ existence;
• Monitoring of compliance with the law on settlement of the conflict of interests;
• Monitoring of compliance with anti-corruption laws.
At the regional level tasks, aforementioned, are executed by territorial authorized bodies (based in the garrisons of Vinnitsa, Kyiv, Lviv, Odesa, Kharkiv) [2]. Second, the Internal Audit Department. The department audits financial and material resources of the MoD and prevents their illegal and ineffective use [3]. Third, the Law Enforcement Military Service in the Armed Forces ensures law and military discipline among the servicemen in areas of their deployment as well as prevents and terminates crimes [4]. The MoD does not provide information on the staffing of its departments. However, there is no clear evidence for the Bureau and the Department to be understaffed or underfunded, although the Law Enforcement Military Service in the Armed Forces may experience some personnel gaps [5].
There are also external bodies contributing to compliance within the defence and security, in particular, the Accounting Chamber, State Audit Service, Military Prosecutor`s Office, NABU, SAPO, National Agency for Prevention of Corruption and Security Service of Ukraine.

The Corruption Prevention and Combating Bureau is subordinate to the Ministry of Defence of Ukraine [1]. The Internal Audit Department is also subordinate to the Ministry of Defence of Ukraine [2]. The direct management of the Law Enforcement Military Service in the Armed Forces is carried out by the Main Directorate of the Law Enforcement Service of the Armed Forces of Ukraine [3]. These bodies are under minister’s direct subordination and can be restructured ny minister’s decision.
There are reasons to doubt the independence of the Military Prosecutor`s Office and Security Service of Ukraine. The Military Prosecutor`s Office is part of the Prosecutor`s General Office which is strongly influenced by the President of Ukraine as is also the Security Service of Ukraine [4, 5].

NABU can be seen as one of the effective authorities tasked with combatting corruption; it also one of the first state authorities to investigate high-level corruption cases with active MoD officials involved [1, 2, 3]. There are reasons to doubt SAPO’s effectiveness since its leader was recently suspected of certain illegalities [4]. The same doubts can be attributed to the effectiveness of the Military Prosecutor`s Office, the NAPC and the Security Service of Ukraine since there is evidence of them being politically influenced [5, 6, 7]. There is no reasonable evidence showing a political influence in the Corruption Prevention and Combating Bureau, the Audit Department as well as Law Enforcement Military Service being ineffective, although one of Audit Department`s employees was accused of high-level corruption [8].

On several occasions, the UAE government announced plans to establish an anti-corruption unit, within the Ministry of Defence (1), (2). In 2015, the Abu Dhabi Executive Council issued an instruction to establish an Anti-Corruption Unit with the aim ‘to investigate corruption and financial violations; and to addresses deficiencies within the legislative framework to strengthen the defence mechanism and lead to a reduction in the number of corruption-related crimes’(3). In spite of these announcements, no evidence supports the existence of such units or even intentions to establish them in the defence sector (4). However, there are moral and religious units within the armed forces. These units preach and encourage good conduct in the armed forces (5).

This sub-indicator has been marked as Not Applicable, as there is no evidence of the existence of an anti-corruption unit in place, assessing the independence of a non-existent unit is irrelevant in this context (1), (2).

This sub-indicator has been marked as Not Applicable, as there is no evidence of the existence of an anti-corruption unit in place, assessing the independence of a non-existent unit is irrelevant in this context (1), (2).

The Fraud Defence Act is the MOD’s single point of reference for the reporting and recording of suspicions and incidents of fraud, corruption, bribery theft or other irregularity [1]. Fraud Defence is the central counter-fraud function for all of defence, and has the strategic lead for fraud across the sector. Their remit covers fraud, corruption, bribery, concerns, theft and irregularity [2].

The Royal Military Police [3] and other Service Police elements, investigate criminal and non-criminal offences (service offences are not replicated in civilian law but are unique to HM Forces) [1]. The MoD Police’s concerns, among others, are with ‘the prevention and investigation of fraud, corruption and the theft of key defence equipment and assets’ [4].

There is no indication that any of the above institutions has issues with staffing and funding. Fraud Defence is staffed by a core team of 25 (FTE) Counter Fraud Experts and also delivers the MOD’s counter fraud response through leadership of the Counter Fraud Profession and Function [5].
Finally, the Building Integrity UK (BI UK) programme delivers BI education and training to UK and Overseas officials. The programme is an implementing partner to NATO BI, and contributes regularly to AC/BI curriculum development [6].

As a Head Office Function, reporting to the Director General Finance and Permanent Secretary, Fraud Defence is independent of the chain of command of the institutions it oversees [1]. The Head of Fraud Defence has unfettered direct access to the Chair of the Defence Audit Committee should the Head of Fraud Defence deem this necessary. The Fraud Defence Charter provides it with necessary authority to operate as an independent unit. Members of Fraud Defence are authorised to have full, free and unrestricted access to all functions, premises, assets, personnel, records, operations and other documentation and information that the Head of Fraud Defence considers necessary to enable the team to meet its responsibilities. This includes any documents relevant to MOD held by its contractors.

All staff and management (civilian or military) are obliged to render any and all assistance to Fraud Defence at all times and particularly during enquiries and fraud reviews [2]. This has remained unchanged. The Building Integrity programme is funded by the MOD Core Defence Engagement budget. It is independent from the Defence Academy, and the annual programme is based on a combination of UK AC strategy, UK Defence Engagement and NATO requirements- plus the appetite/pull of the recipient Nation(s) [3].

As part of the government’s Counter Fraud Function, Fraud Defence leads the Fraud Risk Discipline which has been operational since 2013 and regularly conducts risk assessments across the MOD. According to the MOD, the team has undertaken professional training from the Institute of Risk Management and the Cabinet Office, in order to increase their understanding of corruption risk and become members of the Government Counter Fraud Profession [1].

Fraud Risk Discipline has trained and embedded Fraud Risk Assessors in each of the MOD’s six Top-Level Budget (TLB) organisations to undertake fraud risk assessments independently [2]. Upon completion of a risk assessment, it is reported back to the Head of Fraud Risk Discipline for oversight and inclusion into the Department’s risk register. Once this is done, mitigation strategies are drawn up into action plans that include interventions such as training, oversight, policy recommendations and control improvements [1]. Within the past several years, Fraud Defence’s focus has changed considerably from conducting investigations to undertaking a more proactive role in the prevention area through an increase in the number of detailed assessments of the fraud risk. These are carried out with a focus on ensuring controls are in place minimising the risk of fraud [3].

The Department of Defense Office of Inspector General (OIG DoD) is an independent authority within the DoD, with the mandate to ‘provide leadership and coordination and recommend policies for activities designed to promote economy, efficiency, and effectiveness in the administration of, and to prevent and detect fraud and abuse in, such programs and operations’ [1]. The Inspector General is the principal advisor to the Secretary of Defense in matters regarding DoD fraud, waste and abuse [2]. There is no mention of the term ‘corruption’ in the mandate or responsibilities of the OIG DoD, nor does a search for ‘corruption’ on the OIG’s website bring up any related reports. Across the DoD, the term ‘fraud, waste, and abuse’ is frequently deployed and the term ‘corruption’ is rarely referenced. Whilst there is clearly a nuanced distinction between the two terms, and also between the activities and risks catalogued under the umbrella of ‘fraud, waste, and abuse’ and those under ‘corruption’, the focus on ‘fraud, waste, and abuse’ should not be dismissed as an absence of anti-corruption efforts.

The OIG DoD undertakes various auditing, evaluation and reporting functions, including an annual effort to identify the top risks and challenges facing the DoD, known as the ‘Top DoD Management Challenges’ [3]. These focus on management and performance issues, but also touch upon the importance of ‘ethical conduct’ (see page 49 of the 2020 report) [3]. The DoD OIG oversees both the Whistleblower Protection Coordinator and Hotline, as well as ethics training. Also within the DoD OIG is the Defense Criminal Investigative Service (DCIS), which undertakes investigations into public corruption as it relates to DoD programmes and operations [4]. For allegations of bribery and conflicts of interest involving personnel above the GS-15 levels, the FBI has jurisdiction. When the DCIS uncovers evidence of fraud of government property, a Department of Justice prosecutor and the FBI should be notified [5].

With regard to staffing and funding, in the Fiscal Year 2020, the OIG was appropriated $387,753,000 in the DoD budget [6] and it employs over 1,500 members of staff [7].

The DoD OIG submits a semi-annual report to Congress which is publicly available. This report includes a section on ‘Public Corruption’ as part of the review of DCIS investigations, which outlines the details of a selection of recent cases. There is also a similar section on procurement fraud [8,9,10].

The Inspector General of the DoD is mandated to be a civilian appointed by the President with the consent of the Senate [1]. However, as of February 2021, the position of Inspector General has been vacant since 10 October 2016. Glenn Fine occupied the position of Acting Inspector General until April 2020, when he was fired by President Trump in a widely criticised move that was condemned as ‘corrupt’ by Senator Chuck Schumer, amongst others [2]. The removal of Fine followed a pattern that emerged under the Trump administration of attacks on independent watchdogs and inspector generals [3,4]. Following Fine’s removal, Trump nominated Jason Abend to lead the DoD OIG. Jason Abend was widely criticised for being unqualified, including by previous DOD IGs [5]. As such, throughout Trump’s presidency, the DoD IG position has been filled with an ‘Acting Inspector General’. Acting Inspector Generals are not bound by the explicit qualification requirements laid out by the Inspector General Act [6] and can be seen as more political appointments, given that they do not have the confirmation of the Senate.

The DoD Office of the Inspector General is a statutory inspector general position, meaning it is protected under the Inspector General Act. It is, therefore, an independent institution within the DoD and reports only to the Secretary of Defense [7,8].

The DoD Office of Inspector General (DoD OIG) is a well-established and comprehensive organisation. It publishes extensive reports, undertakes multiple audits and investigations and provides recommendations to Congress and the DoD through publications, such as the semi-annual report to Congress and the Compendium of Open Office of Inspector General Recommendations to the Department of Defense [1,2]. Training regarding ethics issues is largely handled by the DoD General Counsel, who is the ‘Designated Agency Ethics Official’ (DAEO). Some oversight is delegated to the respective inspectors general of the various DoD agencies and the armed forces. As part of its work, the DoD OIG issues recommendations to the DoD and it keeps a record of all the recommendations for which the DoD has not taken corrective action, classing them as ‘open recommendations’. Between April 2019 and March 2020, there were 1,602 open recommendations [2]. Following this, the DoD agreed to take action on 1,446 of these open recommendations. Conversely, in 2019, the Government Accountability Office (GAO) has reviewed the DoD OIG and found that the OIG did not meet its goals with regard to handling whistleblower complaints, and made recommendations for the DoD OIG to improve these processes [3].

CONGEFANB is specifically responsible for internal audit of the defence sector. However, among the functions ascribed to this entity, there is no express mandate requiring the promotion of integrity or the combatting of corruption. In addition, among the activities that evidence indicates CONGEFANB carries out, no actions have been taken that demonstrate a commitment to a fight against corruption in the defence sector. Moreover, there are no other external entities that have this auditing function.

The MPPD does not have an anti-corruption office or management [1]. Although fiscal control of the defence sector lies with CONGEFANB, it functions as a comptroller’s office under the National Fiscal Control System and does not have an explicit mandate to oversee ethical compliance and sound anti-corruption practices. Even within this comptroller’s office there is no anti-corruption governance [2].

CONGEFANB is not an independent entity, given that it is controlled only by the FANB and the executive. Although it should come under the supervision of the CGR as part of the fiscal control system, judicial decisions have prevented any external supervision, leading to the politicisation and closed-off nature of the management of defence sector resources [3]. At a national level, the government created the National Anti-Corruption Body (Cuerpo Nacional Contra la Corrupción) in 2014, which had neither oversight of the defence sector nor a mandate to ensure compliance with ethical standards [4]. Moreover, since its creation it has been virtually inactive, since it has no budget, staff or headquarters [5].

This indicator is marked ‘Not Applicable’. There is no unit mandated to perform ethical compliance or anti-corruption oversight for the defence sector. Indeed, in commitments made in previous years regarding anti-corruption measures [1, 2], only the work of CONGEFANB was mentioned – an institution which depends directly on the MPPD and is made up of members of the FANB [3].

This indicator is marked ‘Not Applicable’. There are no compliance or ethics units in place. Although there is no unit in charge of overseeing ethical compliance and fighting corruption within the defence sector, CONGEFANB – which performs certain supervisory functions and functions to prevent corruption malpractices [1] – offers superficial commitments against corruption in its statements [2, 3]. No evidence was found to suggest that this comptroller’s office carries out either analysis of the main anti-corruption risks or proactive activities to mitigate corruption malpractices.

There are units within the military meant to ensure integrity. However, there is no evidence of compliance or effectiveness or adequate staffing [1]. The units are sometimes compromised by inadequate funding, political interference or operational challenges [1]. The Defence Act sets out procedures for investigating members of the military, including internal courts meant for prosecuting offenders; the courts handle both criminal and civil proceedings [2]. The auditor general also has the power to conduct annual checks on all the military books just like other public departments, also following up on internal audits. A review of the auditor general’s reports does not show evidence that anomalies highlighted in the reports are investigated further by authorities [3, 4, 5]. Even the relevant Parliamentary Portfolio Committee on Defence could be a mechanism to build integrity and combat corruption, but it does not use its powers to summon military officials and scrutinise any issues related to integrity and corruption [6].

The law allows the National Defence Commission to investigate acts of corruption under their broad mandate [1]. The commission is not under military command. The same applies to the auditor general and the parliamentary committee, which has the legal mandate to enforce integrity and corruption issues; they are independent of military command, but their efficiency is affected by politics. The Anti-Corruption Commission is also not under the direct control or influence of the military command; however, there have been allegations that the Anti-Corruption Commission has been politically compromised, and at one point all of the commissioners resigned with no explanation [2].

Staff units have administrative officers trained to detect and prevent corrupt practices [1]. However, they do not necessarily have an action plan, with appropriate mitigation measures, that addresses corruption risks, besides generic operational manuals and standard operating procedures [1]. Other oversight institutions such as the auditor general employ competent people, and they are aware of their responsibilities concerning managing corruption risks in public institutions [2]. However, the auditor general hardly provides in-depth oversight over military institutions except for the operations of the Ministry of Defence [3].