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47.

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

47a. Code of conduct

Score

SCORE: 0/100

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47b. Transparency

Score

SCORE: NA/100

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47c. Enforcement

Score

SCORE: NA/100

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47d. Training

Score

SCORE: NA/100

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Relevant comparisons

Benin has a Code of Ethics and Values applicable to the public administration, and therefore to all civilian staff. This code provides a clear definition of conflict of interest and defend it [1]. It does not, however, define bribery, gifts and hospitality or post-separation activities. However, the code clearly states that public officials must “resist any attempt to bribe, accept gifts, hospitality, transfers of economic value or any act that may lead them to favour a person or group of persons, to take or advise on the taking of decisions contrary to the law or likely to offend public decency, human dignity or tarnish the image of the public service. In the interests of transparency, they must inform their line manager, who will tell them what to do if they have been unable to refuse a donation relating to their professional relationship” [2].
The Code also sets out the whistle-blowing process, stating that “All public officials have an obligation to report or denounce all acts and facts contrary to the Code of Ethics and Values of the Public Administration. In this respect, the administrative hierarchy must preserve a culture of open doors and freedom of speech, in which public servants can express their concerns of all kinds, without fear of sanctions” [3]. This whistle-blowing process nevertheless seems unclear, and does not clearly indicate any formal procedures put in place by the administration.

The Code of Ethics and Values of the Public Administration is publicly available. This is distributed to the civilian personnel [1]. And any person can also download it online on the website of the Ministry of Labor [2].

In the event of suspected breaches of the Code of Ethics and Values for Public Administration, investigations are carried out by the relevant internal structures. Depending on the case, proceedings may be brought before an internal disciplinary committee or before the courts. Criminal offences, such as economic crimes, are tried by the Court for the Repression of Economic Offences and Terrorism (CRIET). [1]. [2] Increasingly, even people considered politically close to the government are being prosecuted for breaches of the code of ethics and values.[3]

The Code of Ethics and Values of the Public Administration is taught in the induction training of all civilian staff. It is part of the training program at the Ecole Nationale d’Administration and of the training program followed by all civil servants before taking up their duties. [1][2]

Burundi has no code of conduct for civilian staff.[1] [2].

Burundi has no code of conduct for civilian staff so this indicator is marked Not Applicable. [1] [2]

Burundi has no code of conduct for civilian staff so this indicator is marked Not Applicable. [1] [2]

Burundi has no code of conduct for civilian staff so this indicator is marked Not Applicable. [1] [2]

The official Code of Conduct for Civil Servants and Public Agents in Cameroon is integrated into the Statut Général de la Fonction Publique, established by Decree No. 94/199 of October 7, 1994, and amended by Decree No. 2000/287 of October 12, 2000. This Code sets out ethical standards for public administration, addressing issues like corruption, bribery, conflicts of interest, and the misuse of public office. It clearly prohibits civil servants from accepting bribes, engaging in actions that create conflicts of interest, and using public resources for personal or third-party benefit [1]. The Code mandates transparency in financial and procurement processes and requires civil servants to avoid actions that could compromise public trust [1]. However, it does not provide specific guidance on how to proceed in the face of these events.

While the Code of Conduct is established through Decree No. 94/199 and its amendment in 2000, which addresses corruption, bribery, conflicts of interest, and misuse of public office, there is limited evidence of wide distribution or systematic communication of the Code to all civil servants. The distribution of the Code is uneven, with some civil servants being more aware of its existence than others, depending on their role and level within the administration[1]. This lack of consistent communication affects the overall effectiveness of the Code, as not all public agents may be fully informed of their ethical obligations or how to adhere to them. The Code’s provisions are often not actively reinforced through regular training or awareness campaigns, which limits its potential impact. In some instances, civil servants may be unaware of specific sections, such as post-separation conduct, which exacerbates risks of conflicts of interest [2].

The implementation and enforcement of provisions of the Code of Conduct remain weak. While the Code exists, breaches are rarely investigated or prosecuted due to insufficient independent oversight and a lack of transparent disciplinary processes [1]. Breaches are acknowledged, they are seldom addressed, and disciplinary actions are not consistently applied [1]. Additionally, the absence of independent oversight means there is no body to regularly review and address these breaches, allowing corrupt practices to persist unchecked. The lack of regulation concerning post-separation activities further exacerbates the problem, enabling former civil servants to maintain influence through private sector positions linked to government contracts, creating conflicts of interest [2]. While the Code of Conduct provides a necessary ethical framework, its ineffective enforcement and the lack of accountability undermine its ability to curb corruption.

Training related to the Code of Conduct is insufficient and inconsistent, which complicates efforts to ensure compliance. Training on the Code of Conduct is not consistently incorporated across all levels of government. Although some training sessions are conducted for new recruits, these are not regular or comprehensive enough to ensure continuous adherence to ethical standards. Training efforts are often fragmented, with no systematic approach to ensure that all civil servants, particularly those already in service, fully understand and apply the Code [1] [3]. The Ministry of Public Service occasionally conducts seminars, but their impact is limited due to the lack of continuity and follow-up [1]. Additionally, these training sessions do not consistently cover critical issues such as managing post-separation roles or addressing conflicts of interest after leaving office [2].

The absence of a comprehensive and sustained training program contributes to a lack of understanding of the implications of breaches, and the weak enforcement of the Code means that violations are often not addressed appropriately. Public servants who breach the Code may face limited or no consequences, particularly if they have political ties or hold influential positions after leaving office [2]. This lack of comprehensive training and follow-up weakens the effectiveness of the Code of Conduct in curbing corruption.

There is a code of conduct for civil servants, the Code of Ethics for Public Officials, which mentions corruption, influence peddling, embezzlement of public funds, conflicts of interest and gifts, but it does not mention specific guidelines on how to deal with such events [1, 2].

The code of conduct for civil servants is accessible to the public and staff and can be easily consulted online [1].

There is not enough information available to score this indicator. No information of violations of the civilian code of conduct has been found. [1][2]

There is not enough information available to score this indicator. No information of violations of the civilian code of conduct has been found. [1][2]

Volume 4 of the Armed Forces Regulations (LI 1114) addresses the activities of Civillian personnel. The regulations outline the various codes of conduct for civilians within the armed forces but fail to provide appropriate guidance for specific acts of contravention that amount to corruption, such as bribery, gifts, and conflict of interest, among others. (1)

The civilian employees within the armed forces have a clear code of conduct easily understandable with a clear focus established under LI 1114, named as Volume 4 of the Armed Forces (Civilian Employees) Regulations, 1977 (1). The code is not distributed among civillian personnel. (2) Moreover, this code of conduct is not readily available to the public as it has been advised on the front page of the regulation that “The information given in this document is not to be communicated, either directly or indirectly to the Press or to any person not authorised to receive it”. (1)

There are instances where the code of conduct, as outlined in Volume 4 of the Armed Forces (Civilian Employees) Regulations, 1977, has been breached and investigated. The activities of civilian employees are governed by the Armed Forces Regulations, which makes their activities liable to the dictates of the Regulations. Interviews with members of the force suggest that there is strict adherence to the regulations. Any case of misconduct contrary to the provisions of the regulation attracts appropriate punitive measures. (1) (2) (3) Under cases where there is suspicion of violation, investigations are undertaken and punitive measures assigned under violation.

The service code of conduct is typically included in the training and induction process for civilian employees. The purpose of the service code of conduct is to inform personnel about the various roles they will play alongside uniformed personnel, aiming to achieve balance and synergy while fostering complementarity. Moreover, to ensure strict adherence and compliance to the standard operating procedures of the armed forces, personnel typically undergo a series of training and examinations during the preparatory stages of staff recruitment.(1) (2)

There is a code of conduct, and guides on conflict of interest, gifts, and conflict of interest [1] . Article 76 of the Constitution provides guidance to State Officers on the treatment of gifts and donations. The act states, “a gift or donation to a state officer on a public or official occasion is a gift or donation to the Republic and shall be delivered to the State unless exempted under an Act of Parliament [2].
The Leadership and Integrity Act No. 19 of 2012 in Article 14 provides 18 sections guiding conduct around gifts and hospitality [3]. The Public Officer Ethics Act (2009) 2003 in Article 11 offers additional guidance on the conduct of state officers regarding gifts, while Article 12 addresses the declaration of conflicts of interest and how state officers should conduct themselves [4].

The Code of Conduct is effectively distributed to all civilian personnel but is not readily available to the public [1]. Civilian staff are expected to familiarise themselves with the procedures and rules within their work areas to support the ministry’s mandate. The training covers how they can create synergy between the KDF and civilian staff to achieve the ministry’s core mandate of defending and protecting the sovereignty and territorial integrity of the Republic of Kenya. They are also inducted on the MoD structure and functions, KDF services and units, the ministry’s mandate, vision, mission, code of conduct, core values, and ethics for MoD staff. Additionally, they learn about civilian-military relations, organisation and functions of government, and Human Resource Policies and procedures, among other topics [2].

The investigation of breaches of the code of conduct within the Kenya military is a complex process, often shrouded in confidentiality due to the sensitive nature of military operations. While the oversight mechanism may not be fully transparent to the public, there are procedures in place to address misconduct. Cases are typically pursued when there is substantial evidence of criminal behavior, ensuring that serious infractions are not overlooked [1]. However, the effectiveness of these investigations and the subsequent enforcement actions can vary, depending on factors such as the severity of the breach and the rank of the personnel involved [2].
It is important to note that the military justice system in Kenya, like in many countries, operates somewhat independently from the civilian justice system. This can sometimes lead to perceptions of a lack of accountability, especially when investigations are not made public. Nevertheless, efforts have been made in recent years to improve transparency and accountability within the Kenya Defence Forces, including collaborations with civilian oversight bodies [3].
For instance, In the case of Laban Agak Nyambok v Republic [2020], the soldier sued his employer and the Attorney General in 2021 seeking compensation and withheld pay, arguing that he was fired without facing a disciplinary hearing and that he never received a dismissal letter. He was court martialled for several offences and sentenced to one year imprisonment in 2018. KDF argued that he was found guilty by the Court Martial of four counts of “conduct to prejudice of good order and service discipline” contrary to section 121 of the Kenya Defence Forces Act (KDFA) did not deserve the compensation. KDF was ordered to to pay Sh.7.3 million as his compensation in 2023 [3].

Guidance on ethics and the code of conduct is included in induction training for civilian personnel. Civilians employed by the Ministry of Defence receive a booklet containing the applicable ethical codes during onboarding, which draws from the Public Officer Ethics Act and the Leadership and Integrity Act [2].

Furthermore, in 2023, CS Aden Duale inaugurated a task force to develop a formal Defence-Civilian Policy, which includes provisions for clarifying and standardising the responsibilities and conduct of civilian staff. This signals an institutional commitment to formalising ethical training processes [1].

However, there is limited public documentation on whether such training is uniformly implemented across all civilian staff. No independent evaluation or audit of these induction processes appears publicly available.

The 6 January 2014 Administrative Code of Conduct for Public Officials promulgated applies to civilian personnel. Part IX (“Gifts, Bribes and Conflict of Interest”) sets rules on gifts/benefits and conflicts, requiring disclosure and recusal where a conflict arises, rather than simply prohibiting misconduct [1]
Part X establishes asset-declaration obligations, and the Liberia Anti-Corruption Commission has issued detailed asset-declaration regulations covering administration, monitoring, receipt, and verification, telling officials exactly how to file and comply.[2] However, comprehensive post-separation restrictions are not specified.[3] The 2022 amendment mainly tweaks pre-election resignation timelines, not broad post-employment conduct.

The Code of Conduct was promulgated in 2014. Then, the Governance Commission (GC) made deliberate efforts to publicise it and draw attention to its utility while every MAC of government must adhere to its regulation. Currently, the Code of Conduct is accessible online and in public offices. However, over the years, the champions of the Code of Conduct have transitioned to other roles leaving behind a void that is yet to be filled. Research has shown that issues of the code of conduct only comes up during elections and immediately thereafter. Though the code of conduct exist and accessible online and in public offices, there is little evidence that it is being used and engaged with by the civilian population.[1][2]

While the Code of Conduct was passed in 2014 [1], the Ombudsman established for enforcement was never made operational until under the administration of President Joseph Boakai in 2024. Even still, it is basically set up and has only attempted a few cases. The Code has lain dormant in the absence of the Ombudsman and even levitation-related provisions had to be raised by individuals or parties themselves.[2]
Instead, in the context of increasing democratisation of the civil-military rule, the code of conduct has been instituted as a confidence-building measure, especially given the perennial history of military rule in Africa and place. Scholars have observed that the code of conduct within the military is a useful mechanism for democratisation and confidence building, but a measure that will take time to catch on.[3][4]

The code of conduct and its essential parts are regularly disseminated among the personnel of the armed forces of Liberia.[1] Elements of the code of conduct are also regularly integrated in standard operating procedures. While the military shows more awareness and familiarity with the Code of Conduct, there is limited evidence that civilian staff undergo structured induction training that includes the Code of Conduct as a core component.[2]
A relevant development that suggests a broader push for professionalism and coordinated conduct across the security sector is the signing of Standard Operating Procedures for electoral processes in December 2022 by joint security forces, the Press Union of Liberia (PUL), and the Female Journalists Association of Liberia (FeJAL). This SOP outlines roles and responsibilities during elections, reinforcing codes of conduct for all actors involved, including both military and civilian staff.[2] This initiative is an effort to standardise ethical behaviour across various sectors, but does not specifically confirm inclusion of the Code of Conduct in induction training for all civilian personnel.

There is no specific Code of Conduct for all civilian personnel. Civilians working for the defense sector are subject to the General Status of Civil Servants [1] [2] as well as the Code of Ethics of the Administration and Good Conduct of State Agents [3][4]. The latter mentions conflicts of interests, gifts and hospitality as well as bribes but it does not provide specfic guidance on how to proceed in the face of these events. [3]

The code is easily accessible to the public [1] and its contents are included in the training modules of administrative schools showing that it is effectively distributed to all civilian personnel [2].

In the event of a violation of the Code, legal action is taken [1] but is not always systematic except in the case of a flagrant violation [2].

Civilian personnel simply know the code of conduct but have not yet had specific training on this subject.[1] [2]

The code of ethics and professional conduct for public officials was updated in December 2019. The code refers to corruption and transparency, but there is no clear mention of corruption risks nor does it provide specfic guidance on how to proceed in the face of these events.[1]

The code of ethics and professional conduct for public officials is published on the website of the Mediateur of Mali and accessible to all.[1][2]. The code is of course made available to personnel at the time of recruitment and during the various training sessions.

Beyond the code of ethics and professional conduct adopted in 2019 and following the procedure set out in Section VI of the Public Procurement Code, any official who fails to comply with the rules of professional ethics commits a breach and is therefore liable, without prejudice to the application of criminal law, to the sanctions provided for in Titles III, V, and VII of the General Civil Service Regulations.
Despite our research, we have not encountered any cases of sanctions related to a breach communicated in this regard, with the mention of a violation of the code of ethics and professional conduct. However, cases of arrest for corruption and financial crime are often reported.
Furthermore, in a study on the ethics of public officials in Mali, the Central Office for the Fight against Illicit Enrichment (OCLEI) clearly identified the absence or lack of awareness of the principles of ethics and professional conduct. According to this OCLEI report, “despite the arsenal, the problem of the ethics and professional conduct of public officials remains a real concern. In some cases, the texts are non-existent. In other cases, the texts exist, but the officials concerned with their content have no knowledge of them. The same is true for users who, faced with so much abuse and misunderstanding, rely on God.”[1][2]

There is not enough evidence to score this indicator. No proof has been found on guidance on the code of conduct being provided to civlian personnel to score this indicator. [1][2]

There is a general code of conduct for civil servants and agents of the State, which applies to civil servants of the Ministry of National Defence: the General Statute of State Employees and Agents [1]. It is a simple and easily understandable guide for all civil servants, comprehensively explaining the implications of cases of bribery, corruption and conflicts of interest and post-separation activities [1]. The specific guidelines of the Statute of Civil Servants and Agents of the State are complemented by the Basic Law on the Organisation and Functioning of Public Administration in Mozambique [2].

The General Statute of State Officials and Agents and its respective regulations is distributed by civil and military institutions and it is available on the government website [1, 2]. It is published in the Bulletin of the Republic, the official publication of the Mozambican State [3]. While the legislation is available to the public and can be accessed online, there is no publicly available evidence confirming if the Code is physically or electronically distributed to all civilian personnel. However, the Code is publicly available [3].

There is evidence of investigations, legal proceedings, and criminal accountability for civilian personnel who violate the Code of Conduct, carried out by the Defence Inspectorate, the Central Office for Combating Corruption, and judicial authorities [1]. For example, in 2017, employees were sentenced to 10 and 16 years in prison for making unauthorised payments at the Army Command, diverting funds to the accounts of family members and friends who had been fraudulently added to the payroll [2]. More recently, in 2024, five employees of the Ministry of National Defence were accused of embezzling over 50 million meticais by transferring funds to companies that were supposedly contracted for public works and procurement, without following proper tender procedures or signing contracts, citing military contingency and urgency as justification [3]. Cases of civilian misconduct are handled in accordance with the Statute of State Officials and Agents, overseen by the General Inspectorate of Defence. However, these investigations follow a confidential process, which limits public awareness of their outcomes.

In Mozambique, training and guidance on the Code of Conduct, corruption, bribery and conflicts of interest have been ad hoc. Such training comprises workshops and lectures convened by senior structures of the Ministry of Defence and the Armed Forces, involving civilian and military personnel [1]. These events often occur on commemorative days. For example, in 2023, at the International Day for the Prevention and Combating of Corruption, the Permanent Secretary of the Ministry of National Defence delivered a lecture wherein he articulated that combating corruption presupposes abstinence from Illegal practices [2].

In February 2025, the Minister of Public Service, Mme Aïssatou Abdoulaye Tondi, publicly announced the adoption of a Code of Ethics and Professional Conduct for public service HR managers. [1][2] This initiative was framed as part of a broader effort to reform and improve the governance of Niger’s public administration. The minister noted that training and awareness sessions were held for senior HR officials, and moral integrity checks were conducted for some departmental staff prior to appointments.
The Code appears to cover general ethical standards, including accountability, responsibility, and professional behaviour. However, based on the available statements, the code is limited in scope—primarily targeting HR managers rather than all civilian public personnel—and lacks clear and specific provisions on key corruption-related issues, such as bribery, gifts and hospitality, conflicts of interest, or post-separation employment. There is also no available documentation indicating that the Code includes procedural guidance on how to report, address, or sanction breaches, nor is there evidence of systematic enforcement mechanisms or public disciplinary outcomes following violations.
While the initiative signals a step forward in formalizing ethics within the civil service, its content—as described—remains broad and procedural, rather than targeted and actionable against corruption risks. Therefore, the Code of Conduct exists, but its applicability is narrow, and its anti-corruption guidance is vague, falling short of comprehensive best practices.

The Code of Ethics and Deontology introduced by the Ministry of Public Service in February 2025 was reportedly developed and presented as part of a broader administrative reform process. According to official statements, the code was accompanied by training and awareness sessions targeting HR managers across various administrative units [1][2]. This indicates that some limited distribution to personnel has occurred, particularly within upper levels of the civil service responsible for human resources and deployment decisions.
However, the code is not publicly accessible online, and no official document or PDF version has been made available through the Ministry’s website or public administration portals. There is also no evidence that it was widely disseminated across all levels of civil service, nor that ordinary civil servants or the general public have regular access to its contents. This lack of public availability significantly restricts transparency and undermines public accountability mechanisms that rely on citizen awareness of ethical standards.
Therefore, although the code may have been selectively shared within internal administrative structures, its overall accessibility remains limited, and the distribution appears to be ad hoc rather than systematic or universal

The Code of Ethics and Deontology for Nigerien civil servants was only recently adopted in February 2025, according to official announcements by the Ministry of Public Service [1]. As such, there has not yet been sufficient time or transparency to observe how the code is being enforced in practice. No publicly available data, disciplinary records, or administrative bulletins indicate that breaches of the code have been investigated or sanctioned since its adoption.
Moreover, the broader governance context under the current military regime further reduces the likelihood of transparent or systematic enforcement of the existing legislation regarding corruption [2][3]. The coup of July 2023 has been accompanied by increased opacity in state institutions, a weakening of civilian oversight, and restricted access to administrative data. In this political climate, mechanisms for reporting violations or ensuring ethical accountability—especially within the civilian workforce—are less likely to be robust or publicly documented.
Therefore, while the existence of the code marks a positive step, there is currently no evidence that enforcement mechanisms are in place or operational, and the prevailing political environment significantly hinders the visibility of such efforts.

Following the adoption of the Code of Ethics and Deontology in February 2025, the Ministry of Public Service organized training and awareness sessions targeting key administrative actors, particularly human resource managers. The Minister specifically mentioned efforts to “sensitize and train the main HR administrators” and to promote a culture of ethical conduct in public service management [1][2].
While this reflects a proactive distribution of guidance within certain layers of the civil service, there is no indication that this training has been systematized across all civilian personnel or integrated into a formal induction process for new employees. Likewise, the guidance appears to be limited to managerial staff and does not cover the broader civilian workforce comprehensively.
Moreover, the absence of a publicly accessible version of the Code further limits its utility as a universal reference, and there is no evidence of ongoing, institutionalized training programs linked to the Code’s implementation. Based on this, Niger scores a 2 on this sub-indicator: “Guidance on the Code of Conduct is available to all civilian personnel, but is not part of induction training.”

The General Code of Conduct of the Fifth Schedule of the 1999 Constitution applies to all public officer, including military personnel [1]. It prohibits accepting bribery and benefits of any kind, accepting any gifts or benefits from commercial firms, business enterprises or persons who have contracts with the government, except gifts from family as custom demands. The Code of Conduct Tribunal has the power to try offences under this provision. The tribunal has the power to punish any infringement of the Act and can impose sanctions such as vacation from office, disqualification from holding public office and seizure of illegally acquired property [2]. The SERVICOM Unit in a Ministry, Department or Agency (MDA) also draws attention of civilian personnel to the existence of Code of Conduct for Public Officers (CCPO) [3]. SERVICOM offers procedures for reporting misconduct and guidance is provided to staff on handling ethical challenges. [4].

The Code of Conduct is readily available on the Code of Conduct Bureau’s website [1]. In a bid to ensure that all public officers understand the content of Code of Conduct for Public Officers, an explanatory manual which seeks to provide annotations to the codes for the comprehension of ordinary public officers was produced and officially launched in September, 2021 [2].

Breaches of the code of conduct are only occasionally investigated [1]. It is pertinent to note that a unit in the Nigerian Army is being dedicated to them called Civilian Personnel Unit (CPU). This unit is charged with all welfare matters and training of civilians. They are being trained by Independent Corrupt Practices and Other Related Offences Commission (ICPC), Anti-Corruption and Transparency Unit (ACTU) to impact civilian personnel in the military [2].

Sensitisation workshops are occasionally organised for the civilian personnel by the SERVICOM unit or the ACTU [1]. However, efforts are in place to provide regular anti-corruption training for both military and civilian personnel in Nigeria. The Anti-Corruption Academy of Nigeria (ACAN) is a key institution responsible for this training. ACAN offers a range of training programs, including those specifically designed for military personnel. Similarly, various anti-corruption agencies, such as the Independent Corrupt Practices and Other Related Offences Commission (ICPC) and the Economic and Financial Crimes Commission (EFCC), also conduct anti-corruption training for both public and private sector personnel [2].

There is no code of conduct for civilian personnel. [1] For civilians working for the Ministry of the Armed Forces, the Code of Criminal Procedure applies in cases of bribery, gifts and hospitality, conflicts of interest, and post-separation activities. [2]

There is no code of conduct for civilian personnel si this indicator is marked Not Applicable. [1] For civilians working for the Ministry of the Armed Forces, the Code of Criminal Procedure applies in cases of bribery, gifts and hospitality, conflicts of interest, and post-separation activities. [2]

There is no code of conduct for civilian personnel si this indicator is marked Not Applicable. [1] For civilians working for the Ministry of the Armed Forces, the Code of Criminal Procedure applies in cases of bribery, gifts and hospitality, conflicts of interest, and post-separation activities. [2]

There is no code of conduct for civilian personnel si this indicator is marked Not Applicable. [1] For civilians working for the Ministry of the Armed Forces, the Code of Criminal Procedure applies in cases of bribery, gifts and hospitality, conflicts of interest, and post-separation activities. [2]

The Department of Public Service and Administration has issued a code of conduct applicable to civilian members of the Department of Defence. [1] The code of conduct is issued as a regulation emanating from the Public Service Act and is clear in defining corruption related offences in line with relevant legislation and provides guidance requiring officials to report instances of corruption.

This code explicitly covers:
– Prohibitions on bribery, gifts, and hospitality, requiring officials to disclose or refuse any such offerings.
– Conflict of interest management, mandating recusal or disclosure when personal interests arise.
– Clear requirements for reporting corruption suspicions to relevant authorities.
– Guidance on post-separation activities, restricting ex-officials from benefiting from former. [1]

The code comprehensively addresses all aspects, including bribery, conflicts, hospitality, and post-employment conduct.

The Public Service Code of Conduct is widely available online and the Public Service Commission and individual departments are proactive in training officials on the code of ethics. [1] The Department of Public Service and Administration has likewise published a compulsory online course on ethics for all public service employees. [2]

Individual departments are tasked with discipline management and investigating transgressions of the Public Service Code of Conduct. The Public Service Commission and the Department of Public Service and Administration provide oversight of the discipline management process and findings by the Public Service Commission show that there is inconsistency in the investigating breaches of ethics standards.[1] This includes political and managerial interference in disciplinary processes, the slow processing of disciplinary cases, inconsistency in the application of sanctions and a view that the system is ineffective. [2]

Guidance on the Public Service Code of Conduct is provided through compulsory training for all public service employmees and as part of the induction process. [1] [2]

Currently the defence ministry does not have a code of conduct for civilian personnel working in the ministry. While the Civil Service Act 2011 could provide a basis for the civilian personnel code of conduct, Section of the act exempt employees of 6 (d) the Sudanese People’s Liberation Army (SPLA); and (e) the Police, Prison Service, Fire Service, Civil Defence and Wildlife Services. [1]

Currently the defence ministry does not have a code of conduct for civilian personnel working in the ministry. While the Civil Service Act 2011 could provide a basis for the civilian personnel code of conduct, Section of the act exempt employees of 6 (d) the Sudanese People’s Liberation Army (SPLA); and (e) the Police, Prison Service, Fire Service, Civil Defence and Wildlife Services. [1] Therefore, this indicator is scored Not Applicable.

Currently the defence ministry does not have a code of conduct for civilian personnel working in the ministry. While the Civil Service Act 2011 could provide a basis for the civilian personnel code of conduct, Section of the act exempt employees of 6 (d) the Sudanese People’s Liberation Army (SPLA); and (e) the Police, Prison Service, Fire Service, Civil Defence and Wildlife Services. [1] Therefore, this indicator is scored Not Applicable.

Currently the defence ministry does not have a code of conduct for civilian personnel working in the ministry. While the Civil Service Act 2011 could provide a basis for the civilian personnel code of conduct, Section of the act exempt employees of 6 (d) the Sudanese People’s Liberation Army (SPLA); and (e) the Police, Prison Service, Fire Service, Civil Defence and Wildlife Services. [1] Therefore, this indicator is scored Not Applicable.

​The “Code of Conduct and Ethics for Uganda Public Service,” dated July 2005, serves as a comprehensive guide for public officers in Uganda, outlining standards of behaviour to ensure impartiality, objectivity, transparency, integrity, efficiency, and effectiveness in public service. The Code addresses conflicts of interest, emphasising that public officers must avoid situations where personal interests could conflict with official duties. ​It addresses handling of gifts and bribes. Although the Code prohibits bribery, it lacks detailed procedures on how to handle or report bribery incidents [1].​ The Code addresses the handling of gifts but does not elaborate on hospitality, leaving ambiguity in situations involving official hospitality.​ There is no specific guidance on post-separation activities, which could lead to potential conflicts of interest after public officers leave service. [1][2]

The Code of Conduct and Ethics for Uganda Public Service is intended to be distributed to all civil servants at their first appointment and is officially available at the Ministry of Public Service, public libraries, and online.[1][2] However, in practice, there are no definite or predictable ways through which civilian personnel receive the code. Access is sometimes ad hoc, through online platforms, newspaper publications, or other unofficial channels, which may not guarantee consistent availability to all personnel.[3]

The ghost pilot case within the UPDAF stands as a stark example of alleged systemic corruption involving the creation and prolonged maintenance of a fictitious employee on the payroll of the army. This case centred on the alleged existence of a ghost Russian pilot, named Valerie Ketrisk, who was purportedly placed on the UPDAF payroll around 2005 and remained there for approximately 11 years, until 2016 [1]. During this period, substantial sums of money, amounting to hundreds of thousands of US dollars, were fraudulently disbursed as salaries and gratuities to this non-existent individual. The case came to light following investigations initiated by the Chief of Defence Forces, implicating both military and civilian personnel from the Ministry of Defence, highlighting a potentially widespread issue [2][3].
The subsequent legal proceedings were fraught with complexities, particularly concerning jurisdictional disputes between the General Court Martial and civilian courts, especially regarding the trial of civilian defendants. The investigations further revealed alleged forgeries of signatures, raising questions about the extent of involvement and responsibility for the fraud.
However, recent reports such as the UN High Commissioner for Human Rights criticized a proposed legislative change permitting civilians to be tried in military courts, arguing it undermines impartiality and independence of the judiciary[4]. Recent discussions highlight the Constitutional Court’s decision that civilians cannot be tried in the General Court Martial, prompting legislative attempts to reaffirm that jurisdiction in limited circumstances [5]. There are concerns that military justice is being politically leveraged, and that civilian access to fair judicial processes is impaired. This suggests civilian disciplinary action via military courts may be influenced by politics—not necessarily grounded in objective, impartial enforcement.

The Uganda Public Service Standing Order states that the performance and competency gaps identified during the performance appraisal process shall form the basis for training and development in the Service. Such training shall be guided by the Training Policy and the Induction Manual and shall be conducted by Section J of these Standing Orders.[1] The Ministry of Defence and Veterans Affairs (MoDVA) invites personnel for training and induction on an annual basis, with guidance on the code of conduct included in the induction training for all civilian personnel.[2]

However, there are no definite or predictable ways through which the code of conduct is consistently distributed to civilian personnel. In practice, access to the code may be ad hoc, occurring online or through publications such as newspapers, and it may not always be readily accessible to the public [3].

The civilians in the defence forces are guided by Section 1969(2) of the constitution of Zimbabwe which talks about public officers that they must conduct themselves, in public and private life, to avoid any conflict between their personal interests and their public or official duties, and to abstain from any conduct that demeans their office [1]. The public officers must ensure, a. objectivity and impartiality in decision making; b. honesty in the execution of public duties; c. accountability to the public for decisions and actions; and d. discipline and commitment in the service of the people and statutory provisions guiding the conduct of civil servants [2]. In addition, the Civil Service Commission through the Public Service Act provides a code of conduct for civilians, especially Section 25(1) of the Act which states that any case involving misconduct or suspected misconduct on the part of a member of the Public Service shall be investigated, adjudicated upon and, where appropriate, punished by such person or authority as may be prescribed in service regulations [2]. This covers bribery and other misconducts in the civil service [2]. Although the constitution and public service act provide guidance on the behaviour of civilian personnel, they do not constitute a Code of Conduct. There is no specific Code of Conduct document mentioned that is easily accessible or known to personnel.

Even if there is no specific Code of Conduct document mentioned that is easily accessible or known to personnel [3], each employee, civilian personnel, is inducted into the Civil Service through training [1]. The civilians are made aware of the existing and guiding code of conduct [1]. The Public Service Act and the Constitution of Zimbabwe gives them the right to access information related to their employment [1,2]

Section 25 of the Public Service Act mandates that allegations of misconduct or corruption by civilian public officers must be investigated, adjudicated, and, where proven, sanctioned through service regulations or by the Public Service Commission [1]. If the alleged offence exceeds internal jurisdiction, the case is referred to the police and subsequently the courts [2].
This legal framework is reflected in practice [3], a public utility employee was convicted of bribery under national law and sentenced to 24 months in prison, confirming that corruption-related misconduct is actively prosecuted in civilian service contexts. Such enforcement demonstrates that these sanctions are not theoretical but applied in real cases.

Training of civil of public civil service is done during induction, and during the course of employment by the civil service as required by the Public Service Act [1,2]. This training is being delivered in practice by the Public Service Training Centre, which conducts both induction and in-service competency courses for public servants across ministries [2].
Training modules include ethical leadership, customer service, and corporate governance, which encompass public sector ethics and misconduct prevention [3]. While the frequency and consistency may vary by institution, these are established practice-based training inputs, aligning with the legal mandate.

Country Sort by Country 47a. Code of conduct Sort By Subindicator 47b. Transparency Sort By Subindicator 47c. Enforcement Sort By Subindicator 47d. Training Sort By Subindicator
Benin 75 / 100 100 / 100 100 / 100 100 / 100
Burundi 0 / 100 NA NA NA
Cameroon 50 / 100 50 / 100 25 / 100 50 / 100
Cote d'Ivoire NEI NEI NEI NEI
Ghana 25 / 100 25 / 100 100 / 100 100 / 100
Kenya 75 / 100 75 / 100 50 / 100 50 / 100
Liberia 75 / 100 50 / 100 50 / 100 50 / 100
Madagascar 50 / 100 75 / 100 75 / 100 0 / 100
Mali 25 / 100 100 / 100 25 / 100 NEI
Mozambique 100 / 100 100 / 100 75 / 100 25 / 100
Niger 25 / 100 25 / 100 25 / 100 50 / 100
Nigeria 75 / 100 50 / 100 50 / 100 50 / 100
Senegal 0 / 100 NA NA NA
South Africa 100 / 100 100 / 100 50 / 100 100 / 100
South Sudan 0 / 100 NA NA NA
Uganda 50 / 100 50 / 100 50 / 100 75 / 100
Zimbabwe 50 / 100 75 / 100 100 / 100 100 / 100

With thanks for support from the Dutch Ministry of Foreign Affairs who have contributed to the Government Defence Integrity Index.

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