No specific code of conduct exists for the civilian personnel in the Ministry of Defence (MoD) and the armed forces. However, the conflict of interest and ethics for civilians in the MoD are provided in the legal framework on ethics and conflict of interest in Albania that apply to all public administration and civil servants [1, 2]. The Law on Conflict of Interest clearly defines specific restrictions also for the senior and mid-level officials the public administration and in the armed forces.
The Law on Ethics bans the public officials from requiring or accepting any benefit such as gifts, favours or any other benefit or promise for himself, his family, friends or affiliated organizations. The law requires the official to refuse any benefit, and report the attempts to provide him/her with such benefits [1]. The regulation of external activities and benefits is further detailed by the Council of Ministers [3].
The Law on Conflict of Interest incorporates a broad range of private interests such as among others: property rights and obligations, gifts, promises, favours, preferential treatment, possible negotiations for employment in the future by the official during the exercise of his function or negotiations for any other kind of relationship with a private interest for the official after leaving the office [2]. However, although post-service employment is considered, there are two provisions: it bans the representation of any party against the government for two years, and it bans the use of classified information. Overall, the lack of a Code of Conduct is an important omission the MoD should address [4].

The legislation is available to all civilian personnel and the public. The High Inspectorate of Declaration and Audit of Assets and Conflicts of Interest (HIDAACI) has produced manuals and guidelines that are accessible on its website that assist public officials informing them of the law and how to implement the law [1, 2].

The Law on Ethics provides disciplinary sanctions in accordance with the Law on the Status of the Civil Servant, and it requires the relevant public institutions and the DAP to verify and register all the sanctions to the National Register of the Public Administration [1]. Breaches to the Law on Conflict of Interest are investigated by the HIDAACI, which can issue disciplinary and financial sanctions [2]. The reports of the HIDAACI and the Commissioner for the Oversight of the Civil Service show that cases are investigated and sanctions are applied, but not systematically, although, there is an increasing trend over the years [3, 4]. The EU Commission has called upon Albania to systematically follow up on conflicts of interest [5].

The legislation is available to all civilian personnel and to the public. The HIDAACI has produced manuals and guidelines that are accessible on its website that assists the public officials to get informed and implement the law [1] [2]. There is no evidence to suggest that this is part of the induction training.

No evidence could be found that there is a Code of Conduct specifically for civilian personnel working in the defence sector. No information could be found on the website of the Ministry of Defence (1). The Statute for Military Personnel, which was mentioned in question 48, explicitly does not apply to civilians. According to Art. 1, it applies to professional soldiers, contractors and military personnel performing national service (2). It might be possible that the rules written down in the Anti-Corruption Law of 2006 apply to civilians working in the military (3).

This question has been scored Not Applicable because no evidence could be found that there is a code of conduct specifically for civilian personnel working in the defence sector. No information could be found on the website of the Ministry of Defence (1). The Statute for Military Personnel, which was mentioned under question 48, does explicitly not apply to civilians (2).

This question has been scored Not Applicable because no evidence could be found that there is a code of conduct specifically for civilian personnel working in the defence sector. No information could be found on the website of the Ministry of Defence (1). The Statute for Military Personnel, which was mentioned in question 48, does not explicitly apply to civilians (2).

This question has been scored Not Applicable because no evidence could be found that there is a code of conduct specifically for civilian personnel working in the defence sector. No information could be found on the website of the Ministry of Defence (1). The Statute for Military Personnel, which was mentioned in question 48, does not explicitly apply to civilians (2).

The 2010 Law on Public Probity contains a general code of conduct (Chapter II) for all public servants, but there is a lack of guidance (1).

The 2010 Law on Public Probity is available to the public, but there is no indication that it is distributed to personnel.

The media and civil society organizations have often referred to the 2010 Law on Public Probity since it came into force, though the law has been poorly enforced. Since President Lourenço took office, there have been some public declarations of political will to implement the law on public probity (or at least some of its provisions). For instance, in March, the attorney general announced that public servants who failed to submit their declaration of assets (as required by the 2010 Law on Public Probity), would be held accountable (1), (2), (3).

There is no evidence that any training has been conducted.

The civil staff of the national public administration (at all hierarchical levels) is governed by the Code of Ethics of the Public Function. It defines the principles of action of the public official, the regime of gifts, functional impairments, regime of affidavits, and the applicable sanctions. However, it does not have specific guidelines for action nor does it contemplate all situations of bribery and conflict of interest. In this sense, in 2019 a draft of a new public ethics law that regulates nepotism, conflict of interests, and affidavits was presented. [1] [2] Likewise, civil personnel fall within the National Public Employment Regulation Framework Law which establishes, among other prohibitions, that “accepting handouts, gifts, or other benefits or obtaining advantages of any kind on the occasion or occasion of the performance of its functions” is strictly forbidden (Art. 24 Subsection F). [3] [4] [5]

The Code of Public Ethics is available to the public and according to it, the entry into the public function implies taking knowledge of the Code and assuming the commitment of its due compliance. Beyond this, there is no evidence as to whether the code is distributed to civilian personnel. [1] [2] [3] [4]

The code is a behaviour guide. There is no evidence of regular investigation into cases. It is only possible to know those who are processed before civil and/or criminal justice. The disciplinary regime is also defined in the regulatory framework of public employment, where the rights of employees in the disciplinary procedure, types of sanctions, etc. The summary processes are internal to each jurisdiction and are not easily accessible, as they are not published. In accordance with current regulations, the Chiefs of the Joint and General Major States of the Armed Forces, the Undersecretary of Coordination and the highest authorities of the National Geographic Institute, the National Meteorological Service, the Naval Hydrography Service, and the Financial Aid Institute for Payment Withdrawals and Military Pensions, they must submit a bi-monthly report to the Directorate of Institutional Transparency of the Ministry of Defence, in which they must detail all the criminal complaints that have been promoted or about those that they have knowledge of and/or those that have had administrative actions. This is aimed at defining disciplinary responsibilities for civil and/or military public officials who provide services in such areas. [1] [2] According to Palacios, in the proceedings of administrative summary, there is a risk of impartiality, while “who acts as an investigating judge is the instructor, and who fulfills the role of court or sentencing judge is the administrative authority that can validly impose the sanction. The instructor acts on the orders of the person who must issue the sanctioning act, with which there is a dependency relationship that could affect his actions.” [3]

There is no evidence that there is an initial compulsory training regarding ethics and transparency regulations. Existing training is voluntary through courses from the National Institute of Public Administration (INAP) or the Anti-Corruption Office.

The Code of Conduct of the Civilian Personnel is regulated by the Law on Special Civil Service and other decrees and policies within the Ministry of Defence (MoD). Clause 5 of Article 24 of the law provides that a special civil servant should follow internal disciplinary rules. Clause 10 of the same article provides, that special civil servant should follow the ethics fixed by the head of the institution [1].
In addition to the law, there is Decree N 573-Ն, On Ethics by a Civil Servant by the minister of defence. Among other provisions, it anticipates that a civil servant should be objective, impartial, discreet and exemplary, avoid any type of sponsorship, treat the information available to him/her confidentially, etc. [2]. To avoid bribery and illicit enrichment, Decree N48, regulates the handing in gifts and other valuable treatments to civil servants and high-ranking official to the State Treasury [3].

All the policy documents regulating the CoC for civilians are available to the public and the civilian personnel is very well aware of the provisions on ethics prescribed both by the law and decrees [1]. The principles of public servants behaviour and the rules of conduct and other restrictions imposed on them, including conflict of interest, are defined by the RA Law on Civil Service and the Code of Conduct adopted by the Corruption Prevention Commission. Per the Law on Amendments and Addenda to the Law on Corruption Prevention Commission, the Commission adopts a Code of Conduct for Public Servants [2]. The law also establishes the prohibition on accepting gifts related to the exercise of official duties: public office holders and public servants should not accept a gift or consent to a later adoption if it is reasonably understood that it is related to the exercise of their official duties. The Law on Public Service also clearly defines the concept of “conflict of interest” as well as the provisions prohibiting it. A person holding a position must avoid conflict of interest or refrain from acting in conflict-of-interest situations. Civil servants may submit a written statement on the conflict of interest to the Corruption Prevention Commission, which suggests taking steps to address the situation, including announcing the presence of a conflict of interest in a particular situation. The findings of the Corruption Prevention Commission are published on its official website within three days. Acting or deciding under the conflict of interest entails disciplinary liability. A separate code of conduct for civil servants has not been developed by the MoD [3].

Cases that breach the CoC are investigated through due procedures. If a criminal offence takes place, the case goes through a procedure provided by the Criminal Code [1]. Decree N48 is discussed in the media from time to time in terms of its applicability. The decree has a clause that the gifts exceeding monthly wage of an official five times should be transferred to the State Treasury. Gifts below that are not qualified as items eligible for transfer [2]. “Hraparak” an online newspaper had an article questioning the application of the Clause of the Decree, as there was no evidence that transfer of gifts occurred within the last three years (as requested by the paper) [3, 4].

Since 2019, the Civil Service Office of the Office of the Prime Minister of the Republic of Armenia has been conducting trainings under the integrity program within the framework of trainings on civil servants’ competencies, which also includes the civil servants of the MoD. [1, 2].

The Australian Public Service (APS) Code of Conduct – which also applies to civilian defence personnel – as laid out in the Public Service Act 1999 [1] and elaborated on in guidance documents, comprehensively covers corruption risk areas. The Code of Conduct itself is a concise list of 13 rules that only briefly deals with conflict of interest [1, s. 13(7)] and vaguely states that public servants must uphold integrity and use resources in a proper manner [1, s. 7(1)]. The Australian Public Service Commission, which is the body that provides guidance on the Code of Conduct and evaluates the integrity approaches of other agencies, including defence agencies [2], makes available a comprehensive interpretation of the Code of Conduct in the Values and Code of Conduct in Practice [3]. This document outlines APS policy towards bribery [3, p48], hospitality and gifts [3, p47-48], post-separation employment [3, p50-52], and conflicts of interest [3, p41-52].

Given that the Code of Conduct is a legal instrument under the Public Service Act 1999 [1], transparency and awareness are taken seriously in the Australian Public Service, including in defence agencies. The Code of Conduct and several explanatory web pages [2] and documents are readily available online [3]. The Australian Public Service Commission states: “All employees must inform themselves of their obligations under the [Public Service] Act” [4]. Sources employed with the Australian Public Service, including defence agencies, told the researcher that the understanding the Code of Conduct was an important part of their induction and continuing training.

The Department of Defence has comprehensive procedures for how breaches of the Australian Public Service Code of Conduct should be determined and sanctioned, and it is clear that there are regular investigations and sanctions for defence personnel involved in breaches. The Department of Defence – Procedures for determining breaches of the APS code of conduct and determining sanctions lays out in detail how breaches and sanctions are to be determined [1]. The Defence Annual Report last included detailed statistics on Code of Conduct investigations in the 2008-09 edition, which showed that there were 107 investigations, 45 employees found to have breached the code, and 71 sanctions issued [2]. The Australian Public Service Commission revealed in its 2018-19 Annual Report that there were 22 reviews, including 12 Primary Reviews of Code of Conduct breaches, in the Department of Defence during the budget year [3].

Relaying the key lessons of the Australian Public Service Code of Conduct and related guidelines to civilian defence personnel is an important part of induction train. Sources employed with the Australian Public Service, including at the Department of Defence, told the Country Assessor that the Code of Conduct was an important part of their training, including during induction and as a continuing part of their professional development [1]. The Public Service Act 1999 [2] requires “APS employees and agency heads at all times to behave in a way that upholds the APS Values… All employees must inform themselves of their obligations under the” Act [3].

In 2007 the Law on Ethical Behaviour Rules of Civil Servants was adopted in Azerbaijan. This law also covers civil servants working in the defence and security sector:
Article 12 prohibits the obtaining of tangible and intangible benefits, privileges or discounts. According to the law, it is prohibited for a civil servant to act (inaction) or make decisions aimed at illegally obtaining material and non-material benefits, privileges or concessions. A civil servant shall take measures to exclude the possibility that his actions (inaction) or decisions may lead to the acquisition of material and intangible benefits, privileges or concessions. A civil servant who provides free services (services) to persons in accordance with the legislation may not demand any payment for that service (services). A civil servant who provides services (services) to citizens in exchange for payment established by legislation may not charge more than the amount provided for that service (services);
Article 13 deals with the prevention of corruption. According to the law, in cases where a civil servant is offered illegal material and intangible benefits, privileges or concessions, the civil servant must refuse them. If tangible and intangible benefits, privileges or privileges are granted to a civil servant for reasons beyond his control, he shall inform his supervisor and the material and intangible benefits, privileges or privileges shall be handed over to the public body where the civil servant is serving;
Article 14 deals with restrictions on gifts (according to the law, a civil servant may not demand or accept gifts for himself or others, which may affect the impartial performance of official duties, or which give the impression of such influence, or which are given as a reward for the performance of his duties, or which give the impression of such an award. . This rule does not apply to gifts related to hospitality and the value of which does not exceed the amount specified in the Law “On Combating Corruption”. If a civil servant is unable to decide whether to accept a gift or use hospitality, he should seek the opinion of his immediate superior). (1).
It is not known to the public how civilians follow the rules of ethical conduct. There are no statements or statistics in this regard.
Zohrab Ismayil believes that this law needs improvement (2)

Though the Law on Ethical Behaviour Rules of Civil Servants is available online (1), guidance is not available to the public. Regular training is not conducted, and many do not have any information about the rules reflected in the law. Defence and security organizations do not conduct continuous awareness-raising activities (2).

There is not enough information to score this indicator. The public is not informed about violations of the Law on Ethical Behaviour of Civil Servants. Further, the public is not informed about the issues that arise during the implementation of the law or the ways of solving them (1). There are no reports from the Defence Ministry and other military organizations regarding this issue (2).

There is no code of conduct specific to civilian personnel in the defence sector. Though the Law on Ethical Behaviour Rules of Civil Servants is available online (1), guidance is not available to the public. Regular training is not conducted, and many do not have any information about the rules reflected in the law. Defence and security organizations do not conduct continuous awareness-raising activities (2).

There is a Bahraini Code of Employee Conduct and Ethics of the Public Position for all civilian employees is available online on many ministerial websites. However, the code of conduct is not readily available for all employees at hand in all ministries and positions [1, 2]. Article 5 of the Code of Employee Conduct and Ethics of the Public Position prohibits accepting gifts and payments that can be masked briberies. The code has no information or guidelines on how to proceed in cases of bribery or corruption activity.

The Code of Employee Conduct and Ethics of the Public Position exists, and it is widely available online, but not at departments, it is not distributed between employees [1, 2]. Additionally, the public has no access (except online) to the Code of Employee Conduct and Ethics of the Public Position [2]. The Code of Employee Conduct and Ethics of the Public Position is also available online [3].

The Code of Employee Conduct and Ethics of the Public Position exists has no credibility as it is not supported or enforced. As one source said, it is “ink on paper” [1, 2].

There are no guidelines or similar training on the Code of Employee Conduct and Ethics of the Public Position and its application for civilian employees [1, 2].

The Government Servants (Conduct) Rules of 1979 [1] provide an exhaustive list of conduct rules for personnel involved in the Bangladesh Civil Service. These cover, among other things: gifts, foreign awards, fundraising, lending and borrowing. This document also calls for the annual declaration of assets and disclosure of liquid assets.

The Government Servants (Conduct) Rules of 1979 are available online [1], however, it is not possible to confirm whether these rules are disseminated effectively [2].

According to the Government Servants (Discipline & Appeal) Rules of 1985 and the Civil Service Act of 2018, departments are empowered to take necessary action, in compliance with the respective rules, to investigate any violation of the Code of Conduct. In its annual report for 2019-2020 [1], the Ministry of Public Administration stated that a total of 4,033 reports were submitted involving disciplinary and corruption cases.

The Bangladesh Public Administration Training Centre (BPATC) is the lead institution for organising professional training for civil servants. As part of the Foundation Course for all cadre officials [1], the BPATC also runs courses on the Code of Conduct and Conflicts of Interest. These courses aim to improve participants’ behaviour and character and thereby enable them to perform their roles in the workplace with due sincerity, commitment, fairness and objectivity.

Personnel of the Belgian Defence, including civilian employees, have to abide by a deontological code, which includes references to bribery, gifts, hospitality and conflicts of interest [1]. The Circular on the revolving doors principle stipulates rules and sanctions on post-separation activities [2].

For civilian and military personnel directly or indirectly involved in procurement, an extensive code of conduct is shared and the individual needs to sign a declaration to the effect that he or she has read and understood the code of conduct [3]. The document also includes a contact form template in case the individual is faced with transgressive behaviour. The specificities and pitfalls of this code are explained in detail during a mandatory two hour course [4].

The code of conduct is readily available to all members of personnel, both military and civilian, in the Belgian Defence, explicitely distributed to the candidates and tenderers for procurement, and in summary form to the public [1, 2]. Based on the law of Freedom of Information, citizens may request to see the full Code of Conduct [3].

The deontology office of the Procurement Division of Belgian Defence monitors compliance with the Code of Conduct, both for civilian and military personnel [1]. If procedures need to be initiated (based on information received by the hierarchy, by the office of deontology or through whistleblowing), the cases are pursued by the DJMM specialized unit of the federal police and the public prosecutor, independently of the Belgian Defence [2]. For their investigations, they base themselves, amongst others, on the deontological code, which includes references to bribery, gifts and conflicts of interest, the Circular on the revolving doors principle, which stipulates rules and sanctions on post-separation activities, and the Code of Ethics in Public Procurement [3, 4, 5].

There is Not Enough Information to score this indicator, as the guidance on the code of conduct, which is included in induction training for all civilian personnel could not be ascertained. However, regarding the specific code of conduct on public procurement, the guidance is mainly intended for civilian personnel having directly or indirectly a link to procurement [1]. This training is provided as soon as the person in question takes the post [2].

The Code of Conduct for Civil Servants applies to civilian personnel employed by the state. This code establishes the rules and principles of good conduct, prevention of conflicts of interest, how to proceed with gifts and has other provisions relating to good behaviour. Article 8 states the procedure on gifts, allowing low value gifts in accordance with other regulations, calling to refuse gifts if it is of higher valuer and describing the procedure if the gift is delivered. Also, the article places the decision on the immediate superior if the civil servant is in doubt [1]. The Code of Conduct for Civil Servants doesn’t include bribery, as the Criminal Code already prohibits it.
The Code of Conduct in the Armed Forces of BiH and the Code of Ethics of Military Personnel in the Armed Forces of Bosnia and Herzegovina do not apply to civil personnel [2, 3].

The Code of Conduct is available on the Civil Servant Agency’ official website, but there is no clear confirmation that the Code of Conduct is effectively distributed to the civilian personnel [1]. There is also no evidence pointing whether guidance is provided through training.

Article 17, paragraph 2 of the Code of Conduct states complaints about non-compliance with the code are considered by the Head of the Institution and, if necessary, heshe submit a request for disciplinary action following the Law on Civil Service in the Institutions of Bosnia and Herzegovina, which violates this Code as a violation of official duty [1]. In 2018, inspectors in the Ministry of Defence and Armed Force of Bosnia and Herzegovina were engaged 293 times to establish the facts in various irregularities, including violations of the Ethics Code. In 126 cases the preliminary investigations were conducted, and five investigations were carried out [2].

The Civil Service Agency organizes regular introductory courses for new civil servants, where one of the topics covered is the Code of Conduct. Also, there is a course titled “Ethics in public administration and the Code of Conduct of Civil Servants” as a part of general refresher courses [1].

Botswana does have General Public Service Principles and Standards that are meant to guide the conduct of the civil servants on matters of corruption, bribery, conflict of interest etc [1,2]. In addition, there is the Public Service Code of Conduct, however, in terms of Section 3 of the Public Service Act Chapter 26:01, it does not apply to the Security Services.

The General Public Service Principles and Standards are available but not to the general public [1,2]. As noted in 47A above, the Code that applies to the rest of the civil servants is by operation of law not applicable to the BDF and other related security establishments. This document is handed over to personnel at the time of appointment, thus signifying effective distribution.

Enforcement of the General Public Service Principles and Standards is occasionally carried out [1,2]. For example in 2020, the Voice reported that following the lengthy demands by the defence lawyer, Kgosietsile Ngaakagae, to have Isaac Kgosi charged for the infamous looting of the National Petroleum Fund (NPF), the former head of the Directorate of Intelligence and Security Services (DISS) has finally been roped in to join other suspects. Kgosi is expected at the Village Magistrates court tomorrow, 21 May 2020, at 8.30am for his first appearance. He joins other big names entangled in the NPF saga such as former Minister Sadique Kebonang and his twin brother- Lobatse High Court judge Zein Kebonang, businessman Bakang Seretse and his former business partners at Kgori Capital, Alfonse Ndzinge and Sharifa Noor, suspended Botswana Energy Regulatory Authority director, Kenneth Kerekang and his wife Mpho Kerekang and civil servant, Tshepo Bojelo. Some of these above suspects were civil servants who had breached the General Public Service Principles and Standards.[3,4]

Guidance is given to civil servants on an ad-hoc basis as part of training [1]. There is no widespread training, it depends on the urgency of the job as well the location of the job that is being filled [2].

There is the Federal Government Code of Conduct. According to the Integrity Plan of the Ministry of Defence (MoD) [1], the Ministry’s Ethics Committee was created in 2002, and it is responsible for corrections and stipulates a code of conduct to the MoD and the single forces. However, as stated in the Integrity Plan that they follow federal norms that vaguely tackle the issue of bribery and gifts, and also is not directly applicable to those who are not considered ‘public authorities’ [2], as already stated in the 2015 assessment [3]. The Code of Conduct forbids public officials from receiving gifts that could indicate undue influence; obliges officials to make public any considerably big changes in their patrimony; and establishes the possibility of generating a formal warning to those who do not comply with this norm.

The Federal Government Code of Conduct is available to the public and it is effectively distributted publically and to public officials. [1].

There is not enough information to score this indicator, as no evidence of investigations was found [1].

According to a Brazilian Army interviewee, all military units which have administrative autonomy have to conduct an annual Administration Seminary, the content of which is published in the internal official bulletin. In this Administration Seminary, both the Federal Government Code of Conduct and the Military Ethics Code are discussed. Civilians are included in this training [1].

The code of conduct in effect for military personnel does not apply to the civilians working for the MoD (Article 2 of the Law N° 038). Civilians in the MoD follow the code of conduct that applies to civil servants holding civil service positions (1). For civilian positions, the legal framework of the code of conduct encompasses a variety of binding instruments, of which the Law N° 081 (2015) and the decrees that apply, remains the most important. According to Article 1of Law N° 081 (2015), the provisions of the actual general status apply to civil servants, including civilians serving at the MoD. Article 2 says that the law does not apply to the military and paramilitary, magistrate, university teachers and researchers, etc. The obligations of civil servants or civilians within the MoD are enumerated in the Title III of Law N° 081 (2015), and civilian MoD personnel should comply with these obligations. For example, Article 48 says that “the civil servant including the defence ministry civilians must, at the office or outside, avoid any behaviour that may jeopardize the dignity and honour of [his/her] functions or those of the public service.” Possible sanctions for not complying with this provision of the law are enumerated under Article 49. Article 50, says that in addition to the obligations listed in Title III of the law, civil servants and, of course, defence ministry civilians, should comply with ethics rules and those pertaining to their profession adopted through a decree at the Council of Ministers (1), (2), (3).

The National Transitional Council adopted an anti-corruption law, the Law N° 004 (2015), which all civil servants, including defence ministry civilians, appointed or elected in some positions such president, member of parliament, minister, director and alike, should comply with. The military should also comply with the provisions of Law N° 004 (2015). The major focus of this law is that civil servants, military personnel, or elected or appointed officials in the above-mentioned positions, should declare their assets before taking office, as well as when their mandate or service ends (4). Hence, a code of conduct for civilians working for the MoD is available. However, there is not much guidance or specificity in it, which often leads to breaches.

The code of conduct in effect for civilians working for the MoD is unfortunately not readily available to all civilian personnel. Civilian MoD employees rarely have access to the code, even if requested. Again, this is the immediate effect of the lack of information at government institutions in general, and at the MoD, in particular, which the 2016 and 2018 Business Anti-Corruption Portal Report points out (1), (2). The lack of transparency due to the lack of information in the defence ministry was also pointed out by the Executive Secretary of the REN-LAC (3). However, guidance is often provided through capacity building.

According to Business Anti-Corruption Portal 2018, “weak enforcement of law, coupled with poor access to information, a culture of impunity, weak institutions, have made the fight against corruption all the more difficult” (1), (3). Yet, investigations and prosecutions of government officials rarely occur (3). When they do take place it is likely because of disloyalty of the official in question or the case was in the public consciousness pressurizing the government to “offer up a political scapegoat” (3). Therefore, breaches on the code of conduct are only occasionally investigated.

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

The General Rules and Regulations of the Civil Service (1994) apply to civilian personnel within the defence and security sectors as well as for general public servants. According to Article 1, it applies to state employees who are civil servants [1].

The General Rules and Regulations of the Civil Service do not make mention of corruption [2,3]. Its Article 93 lists the types of conduct for which, if found guilty, public servants will face disciplinary and even penal sanctions. Article 93 contains malpractice, negligence of duties and obligations, and professional misconduct that undermines professional ethics, public morals and reputation [1]. The General Rules and Regulations (1994) is available online and in the ministries and public departments though it may not have been distributed to individual public servants [1].

A Business Anti-Corruption report states, “The Cameroonian Code of Ethics (in French) addresses conflicts of interest and provides regulations for the ethical conduct of civil servants in all public institutions. Civil servants and private-sector employees are not legally protected from recrimination or other negative consequences when they report cases of corruption. Cameroon’s National Anti-Corruption Agency (CONAC) reported that for its 2016 report, eleven ministries and agencies refused to supply them with information (Cameroon Intelligence Report, Dec. 2016), casting doubt on the agency’s ability to fight corruption” [4]. This shows that corruption in general is not sufficiently discouraged within the public service or in general.

The General Rules and Regulations of the Civil Service (1994) applies to civilian personnel within the defence and security sectors as well as it does for general public servants (Article 1) [1]. While is is made available in the ministries or departments, and online, it is not distributed to individual public servants [2] [3]. Furthernore, it is not effectively implemented and even when sanctions take place it is not made known to the public [2] [3]. According to the U.S. Department of State, “Although the government took some steps to identify, investigate, prosecute, or punish officials who committed human rights abuses in the security forces and in the public service, it did not often make public these proceedings, and some offenders, including serial offenders, continued to act with impunity” [4].

The General Rules and Regulations of the Civil Service (1994) applies to civilians working in the Ministry of Defence and security officers (Article 1) [1], but this code covers conflicts of interest and related misconduct without specifically mentioning corruption [1]. However, civilians working in the Ministry of Defence are covered under the category of civil servants and are subject to Article 134 of Law No. 77/23 of 6 December 1977, which criminalizes corruption [2]. Civilians working in the Ministry of Defence and security sectors charged with corruption and embezzlement can be charged in both civilian and military courts, or in a special court created to try corrupt government officials.

A Business Anti-Corruption report states, “The Cameroonian Code of Ethics (in French) addresses conflicts of interest and provides regulations for the ethical conduct of civil servants in all public institutions. Civil servants and private-sector employees are not legally protected from recrimination or other negative consequences when they report cases of corruption. Cameroon’s National Anti-Corruption Agency (CONAC) reported that for its 2016 report, eleven ministries and agencies refused to supply them with information (Cameroon Intelligence Report, Dec. 2016), casting doubt on the agency’s ability to fight corruption” [3]. This shows that corruption in general is not sufficiently discouraged within the public service or in general.

As an example of the prevalence of corruption in Cameroon (all sectors included) and insufficient enforcement mechanisms, the 2017 GAN report stated that “Corruption is endemic in Cameroon…. Bribery, nepotism, and corruption are rife in almost all sectors of the Cameroonian government and economy;… Cameroon’s public services represent an area of high risk of corruption. Bribery, abuse of office and embezzlement are widespread in the public administration. Administrative positions are usually appointed based on personal and business connections as well as political allegiance instead of merit (BTI 2016). The legal and regulatory systems are non-transparent and difficult… In addition, there exists a lack of effective regulations, insufficient law enforcement and significant delays in courts. Cameroon’s Penal Code (in French) criminalizes corruption, bribery, extortion, and bribery of foreign public officials, and corruption is punishable by a prison term of five years to life, a fine of up to USD 4,000 and/or asset seizure. Facilitation payments and gifts are also addressed in Cameroon’s legislation, yet insufficient implementation of anti-corruption legislation coupled with impunity among public officials has exacerbated the levels of corruption in the country” [3].

The General Rules and Regulations of the Civil Service is taught during training and made available in the ministries or departments and online [1], [2].

The “Values and Ethics Code for the Public Sector” applies to all civilian staff of the Department of National Defence (DND). [1] [2] The Code comprehensively explains bribery, gifts and hospitality, conflicts of interest, and post-separation activities. [2] This Code fulfills requirements set out by the Treasury Board of Canada as laid out in the Public Servants Disclosure Protection Act and was developed in conjunction with public servants, public service unions, and public sector organisations. [2] Specific guidance related to ethical decision-making, as well as activities and discussion tools are provided. [3]

The code of conduct is distributed to all public servants (civilian employees of the Department of National Defence) and made available to the public online. [1] [2]

According to the Treasury Board of Canada “Members of the public who have reason to believe that a public servant has not acted in accordance with this Code can bring the matter to an organisational point of contact that has been designated for the handling of such concerns or to the Public Sector Integrity Commissioner to disclose a serious breach of this Code.” [1] Within the department, public servants are encouraged to bring up ethical concerns with their immediate supervisor/manager. [2] Under section 38.1 (1) of the Public Servants Disclosure Act, the Commissioner must report to Parliament founded cases of wrongdoing within 60 days after the conclusion of the investigation. [3] Case Reports and Referrals to the Tribunal are published. [4,5] For sensitive, high risk matters that cause significant threats to Canada’s political, economic and social integrity of its institutions accross Canada and internationally, the RCMP has an mandate relating to domestic corruption and political investigations. [6] Criminal charges, included those for public servants, are provided in news releases. [7] However, the extent to which investigations of breaches of the code of conduct are less clear in instances of post-employment, that is, “Once a public servant has left the public service, there are no simple procedures that a department can use to check whether that public servant is respecting the post-employment compliance measures to which they are subject. The onus for compliance is on the individual in question. Once an individual has left office, they are no longer a public servant; hence, managers no longer have any authority over that individual. Public servants who are no longer employed in the public service cannot be subject to disciplinary measures.” [8]

The code of conduct is distributed to all public servants (civilian employees of the Department of National Defence) and made available to the public online. All employees are trained according to the “Values and Ethics Code for the Public Sector” at the time of their induction into the civil service. [1] [2]

There is no code of conduct for civilian personnel in the military they are, expected to observe general norms for public administration. Many governmental branches and ministries have their own code of conduct; however, there is no evidence that defence institutions have one [1, 2, 3, 4, 5, 6, 7].

This indicator is marked ‘Not Applicable’ because there is no code of conduct for civilian personnel in defence institutions.

Although there is no formal and specific code of conduct for civilian personnel in the defence sector, rules and regulations that apply to public servants and members of the public administration are public. However, there is no evidence that there is special training or easily understandable guidance on these matters. Norms for post-separation activities (cooling-off) seem to have been included in the Ministry of National Defence’s agenda to strengthen the probity and transparency in the institutions of the defence sector, but information of the effectivity and specific content of these norms are not available to the public [1, 2].

This indicator is marked ‘Not Applicable’ because there is no code of conduct for civilian personnel in defence institutions.

There is no formal and specific code of conduct for all civilian personnel in the defence sector. There is mixed evidence on the effective enforcement of codes of conduct and regulations for civilian personnel in the defence sector. Presentations of military and civilian authorities to Special Parliamentary Commissions to investigate irregularities suggests that remedial actions have been taken against both military and civilian personnel involved in misdeeds, including the exclusion of accused providers and contractors from the Special Registries for Acquisitions in the Armed Forces [1, 2, 3]. At the same time, commentators and legislators have been more critical of the implementation of preventive measures, and there is no evidence that detailed and clear codes of behaviour are being applied for civilian personnel in strategic positions.

This indicator is marked ‘Not Applicable’ because there is no code of conduct for civilian personnel in defence institutions.

Although there is no formal and specific code of conduct for all civilian personnel in the defence sector, as outlined in 43A, rules and regulations that apply to public servants and members of the public administration are public. However, there is no evidence that there is special training or easily understandable guidance on these matters.

A separate Code of Conduct for civilian personel in the Armed forces does not appear to exist. Τhe Civil Service oath (Constitutional Oath) makes a clear reference to integrity [1] but does not detail the other elements. In addition, China’s Civil Service Law (articles 12 and 53) [2,3] refers to integrity, professional ethics and clearly prohibits “being corrupt, giving or accepting bribes, making use of the post to seek personal gains for himself or others.” In addition, the Ministry of National Defence has a large percentage of CCP members as civil servants, so in addition to anticorruption regulations in the civil service law, relevant Party regulations also apply.

Τhe relevant documents [1,2] are publicly available and widely distributed to civilian personnel.

Τhere is no specific information regarding the enforcement of the Code of Conduct for civilian personnel. As with Q46C, it can be assumed that it reflects the overall anticorruption enforcement in the PLA, that is characterised by a) an absence of external scrutiny, b) a high degree of politicisation, and c) institutional reliance on CCP organs for implementation. [1,2]

Given that it is impossible to assess the extent of enforcement, this indicator is marked ‘Not Enough Information’.

There is no information in this regard but also no reason to assume that training would be less institutionalised than for military personnel (see Q46D). Given the lack of information on this issue, this indicator is marked ‘Not Enough Information’.

For civilian personnel there is a Code of Conduct from 2017, [1] the “Public Service Values. Code of Integrity,” which details the essential values for the performance of public work: (i) honesty; (ii) respect; (iii) commitment; (iv)diligence; and (v) justice. It lists unacceptable practices by public officials, detailing some examples of possible acts of corruption that should be avoided. However, there is no explicit action plan for responding to acts of corruption, although existing legislation on prosecuting crimes against the public administration exist. On the other hand, the Ministry of Defence has a Code of Ethics, [2] which aims to define the rules of ethical behavior for public servants within the Ministry of Defence, both uniformed and civilian. The document is divided into a) principles related to the administrative and management activity of the entity, such as accountability; (b) values of respect, responsibility, honesty, commitment, among others; and c) ethical policies, including relations with citizens, with the public force, with managers, with public servants, and with the media. It also proposes the consolidation of a single Code of Ethics. Although the Code of Ethics does not have specific procedures for dealing with disciplinary proceedings, there are broad regulations such as the Penal Code and the Single Disciplinary Code, which identify and stipulate disciplinary sanctions resulting from violation of the Public Servant’s Code of Conduct.

All the codes of conduct of the various entities that make up the defence sector are available on the websites of each force and the Ministry of Defence. [1] Likewise, the Public Servant’s Code of Conduct is available on the website of the Administrative Department of the Civil Service. [2] It has not been established whether it is distributed to civilian personnel directly and, therefore, this indicator cannot be properly scored so it is marked Not Enough Information.

The Internal Disciplinary Control Office is responsible for knowing, advancing preliminary inquiry, investigating, and adjudicating in the first instance disciplinary proceedings against public servants, ensuring autonomy and independence and the principle of second instance. [1] The Single Disciplinary Code defines a number of sanctions: (a) general dismissal and disqualification; (b) suspension from the exercise of office and disqualification; c) suspension, d) fines; and (e) a written warning for minor offenses. [2] Sanctions or corrective actions must be reported to the System of Registration of Sanctions and causes of disqualification to SIRI of the Attorney General’s Office. This platform leaves a record of the conduct, possible perpetrators, date and place of commission, as well as the procedures advanced for verification. Once in the system, it is the decision of the Procuratorate to refer these cases to the judicial authorities. [3] It is not possible, however, to demonstrate the application of the law in the case of civil servants or civilian personnel. As such, this indicator cannot be properly scored so it is marked Not Enough Information.

Some Codes have vague references to training. The Ministry of Defence’s Code states, for instance that Directors need to “foster knowledge and participation of every public servant in the Entity’s programmes.” [1] The Code of General Ethics states that personnel needs to “dedicate its whole time to the fulfillment of their duties” except whenever they are undergoing training. There are no specifics on this, meaning that while the codes expect some level of training to occur, they offer no rules on how to do so.

Order No. 2013-660 serves as a broad-based anti-corruption law whose scope of application includes the military and, by extension, civilian personnel employed by the MoD. Though it covers bribery, gifts and conflicts of interest, it does not refer to post-separation activities because it is not specific to military personnel.

Order No. 2013-660 (Relative à la prévention et à la lutte contre la corruption et les infractions assimilées) of 20 September 2013 serves as clear and comprehensive guidance for public officials concerning bribery, gifts and hospitality and conflicts of interest. In Title 1 (Dispositions Générales), Chapter 1 (Définitions), Article 1, the scope of Order No. 2013-660 includes military personnel:

“Art. 1 – For the purposes of this order, the following terms mean: (1)
– public administration, all bodies, institutions and public services created by the laws and regulations in force;
– a public official, any natural person who holds an elected, executive, administrative, military, paramilitary or judicial mandate, whether he has been appointed or elected, permanently or temporarily, whether he is paid or not, and whatever the hierarchical level is.
• any person who performs a public service, including for a state institution or a state enterprise, or provides a public service;
• any person in charge, even occasionally, of a service or public service mission, acting in the exercise or the occasion of its functions;
• any public or ministerial officer;
• any agent, servant, or clerk of any other corporation public law or a public or ministerial officer” (1).

Order No. 2013-660, Sub-Section II, Articles 12 and 13 explicitly state that the Order should be considered a general code of conduct for civil servants (Codes de Conduite des Agents Publics) (1). The order penalizes the active and passive bribery of a public official through payments, gifts or benefits, as well as the acceptance of a bribe by a public official to carry out (or not to carry out) action as a public official. Penalties include 5-10 years of prison and a fine of 5 to 10 million FCFA (1).

The Order covers issues of bribery (offres, promesses, dons, présents ou avantage quelconque) in Articles 28-30. The acceptance of gifts (cadeaux) is covered in Sub-Section 5 (Cadeaux), Article 57. Conflicts of interest (conflits d’intérêt) are covered in Sub-Section Sub-Section 1 (Conflits d’Intérêt), Article 52. As mentioned above, there is no reference to post-separation activities in Order No. 2013-660 (1). According to TI’s Ant-Corruption Helpdesk from March 14, 2016, Order No. 2013-660 encourages public institutions to adopt their codes of conduct for their civil servants to address issues of corruption in the public administration more effectively. This could signal a certain weakness of Order No. 2013-660 to serve as an across-the-board code of conduct for all ministries (2). Order No. 2013-660 is meant as a code of conduct for all civil servants and that military and paramilitary personnel are included within its scope of application. It explains most of the corruption risks except for the post-separation activities that may apply to MoD civilian personnel.

Order No. 2013-660 (Relative à la prévention et à la lutte contre la corruption et les infractions assimilées) has been available to public officials as an anti-corruption code of conduct for five years as of 2018. Order No. 2013-660 is readily available to civilian personnel at the MoD and its scope of application includes officials serving as “military or paramilitary” in the public administration, as shown in 47A. The full-text version of the order, with the sections covering bribery, gifts and conflicts of interest among public servants, can be uploaded online through open sources (1).

In terms of public awareness and general transparency, the provisions in Order No. 2013-660 have been widely distributed and publicized by Ivorian and international media, as well as through workshops and training set up by the High Authority for Good Governance (HABG) throughout Côte d’Ivoire. For example, HABG organized an awareness-raising workshop in Yamoussoukro on June 1, 2016, to discuss how the Order could tackle specific corruption risks more effectively. The workshop was initiated to propose draft legislation that would allow for the application of articles 11, 12, 13, 14, 17, 19 and 22 of the Order No. 2013-660 (2). In terms of effective distribution (criteria for a score of 4) or the anti-corruption guidance during induction training (criteria for a score of 3), there is no evidence of this in open sources. There are shortcomings of Order No. 2013-660 to serve as an explicit and targeted code of conduct for civilian personnel at the MoD.

There is no concrete evidence that breaches of Order No. 2013-660 were investigated among civilian personnel at MoD. However, there is evidence of investigations in other branches of government. For broad-based corruption offenses contained in Order No. 2013-660 (Relative à la prévention et à la lutte contre la corruption et les infractions assimilées), it appears that enforcement is weaker and a lower level of investigation is applied than for disciplinary issues among military officers, as has been shown by the action taken by the Executive to early retire or oust the military officers behind in the 2017 soldier uprisings. For example, on September 14, 2018, the government website (www.gouv.ci) reported that Public Prosecutor Christophe Richard Adou had announced legal proceedings against individuals accused by HABG of corruption as per Order No. 2013-660. According to the report, there were 15 cases involved, three of which were still being investigated by the judges and another twelve cases that were also pending an investigation. The cases involved influence peddling, misappropriation of public and private funds, illicit enrichment and money laundering. However, none of the cases implicated civilian personnel at the MoD (1).

According to TI’s Anti-Corruption Helpdesk from March 14, 2016, Order No. 2013-660 is not necessarily a signal that there is political will in Côte d’Ivoire to tackle corruption in the public administration. The report states that the country has a track record of adopting legislation without subsequently working on enforcement. The TI report stated:

“In September 2013, the government issued Order 2013-660 on preventing and combating corruption (for both public and private employees) with the support of UNDP… According to some observers, it is not yet certain that these measures are really a sign of a strong political will to fight against corruption and that they will attain the expected results. In the past, Côte d’Ivoire has demonstrated its ability to create laws and institutions that have not translated into concrete action” (2).

According to the 2018 Bertelsmann Transformation Index (BTI 2018), anti-corruption has featured prominently in President Ouattara’s agenda. But some of the anti-corruption measures such as Order No. 2013-660 lack teeth and cannot effectively sanction corrupt practices, much less in the politically sensitive defence sector (3).

An article from Libre Afrique by researcher Safiatou Ouattara stated:

“A National Plan on Good Governance and the Fight Against Corruption was launched in 2013 together with a new institution, the High Authority for Good Governance (HABG, operating since 2014). 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” (4).

Order No. 2013-660 has been criticized for its lack of effectiveness concerning its asset disclosure provisions and its lack of independence vis-a-vis the Executive. According to an article published in Libre Afrique by researcher Safiatou Ouattara (December 20, 2017), the HABG would enjoy a greater level of transparency if it were attached to the NA instead of to the Executive (3).

There is no evidence that training on the code of conduct is provided to civilian personnel.

There is no code of conduct specifically for the Defence domain and neither one specifically for military personnel. The Ministry of Defence inform that the combine of the Minstry of Defence follow the general Code of Conduct for the Public Sector (“God adfærd i det offentlige”), published by the Agency for Modernisation (Moderniseringsstyrelsen), the Danish Regions (Danske Regioner) and the Local Government Denmark (Kommunernes Landsforening) [1, 2]. The Code of Conduct communicates and adheres to the basic legslation and principles that apply to the public sector and it is 52 pages long. Following the recent cases of (possible) misconduct within some areas of the Defence, the Ministry of Defence Personnel Agency has published a directive on how employees should manage situations of incapacity [3]. This instruction is only a summary of the already existing legislation on the area, as found in the Public Administration Act and the Penal Code, and is not a code of conduct as such. The Code of Conduct for the Public Sector addresses bribery, gifts and hospitality and to some degree conflicts of interest and post-separation. Guidance on how to proceed in the face of these events is in very general terms and not specific to the organisational structure of the combine of the Ministry of Defence.

The Code of Conduct for the Public Sector is available to the public on the Agency for Public Finance and Management’s website [1]. There is no evidence that the guide is effectively distributed to personnel, and this was confirmed by a source [2, 3].

Recent media investigations suggest that breaches of the code of conduct are not always investigated. As reported in Q16 for example, media investigation in relation to the fraud case within the Ministry of Defence Accounting Agency shows that the leadership in the department of the Ministry of Defence failed to act and launch investigations into warnings they received [1]. Research also identified cases with evidence of criminal behavior being investigated and pursued by the Police [2]. Naturally, it is impossible to determine how many cases occur that are not investigated. Further, as reported in Q8B, there is also some public criticism of the alleged independence of the external legal investigations that are regularly used within the Ministry of Defence (see Q8B).

Guidance is in very general terms and not specific to the organisational structure of the Ministry of Defence. Civilian and military employees working with public administration need to complete basic online courses based on the general Code of Conduct for the Public Sector on the public sectors education site ‘Campus’. There are different basic courses addressing relevant themes in relation to the employees specific function and tasks, e.g. conflicts of interests, gifts etc. [1] There are also equivalent online courses available on the Defence’s Electronic School.

According to our sources, a new Code of Conduct was drafted and recognized by the Council of Ministers in 2014 for all civilian personnel and was made public. However, this Code of Conduct is mostly unavailable and unknown to employees and personnel (1), (2), (3), (4).

According to our sources, the Code of Conduct is not available always to all officers, and it is hard to find a copy of it in any of the ministries in most cases (1), (2), (3), (4).

According to our sources, as the code of conduct is not readily available, there is no enforcement mechanism, and therefore, it is not credible (1), (2), (3), (4).

There is no evidence that training is provided to civilian personnel on the Code of Conduct (1), (2), (3), (4).

The Civil Service Act applies to all officials of national and local government authorities, as well as active servicemen. It stipulates the formation and the functions of the Council of Ethics of Officials. [1] The council is responsible for approving and implementing the Code of Ethics. The purpose of the council is to reinforce the core values and ethics of officials. All officials are obliged to follow the Code of Ethics for Officials, approved by a Council of Ethics of Officials under the Ministry of Finance. [2] The code explains issues addressed in the question in detail. It also provides comprehensive guidelines on how to behave in these situations.

The Code of Ethics is publicly available and it is expected to be integrated into the everyday work of officials. The Code is introduced during ethics training and internal training. It is possible to request explanations and information from the Council of Ethics of Officials. [1] The Council advises officials and authorities regarding the issues of ethics of officials. However, based on a study, a third of officials have not read and/or heard about the Code. [2].

This indicator has been marked Not Applicable. The Council of Ethics of Officials analyses the implementation of the Code of Ethics of Officials. [1] The members of the council have the right to request information, documents and explanations which are necessary for its work from a national or local government authority and involve experts and other persons in the settlement of issues and formation of working groups. There is no evidence, however, that the Council of Ethics of Officials has investigated breaches. Its role is rather to share knowledge about the Code and conduct training for officials rather than act as an overseer. However, when it comes to unlawful activities, like bribery, there is regular scrutiny in place. Corruption cases, including those done by officials, are listed in the annual report about criminal activities in Estonia compiled by the Ministry of Justice. [2]

Although the Code of Ethics is publicly available, and it is expected to be integrated into the everyday work of officials, a study has revealed that a third of officials have not read and/or heard about the Code. [1, 2].

According to a written response provided by the Headquarters of the Defence Forces, the following two norms have been given in the Defence Forces: PVHSMK – PE HENKILÖSTÖ-, MAANPUOLUSTUS- JA EDUSTUSTILAISUUKSISTA AIHEUTUVAT MENOT PUOLUSTUSVOIMISSA (HP418/27.9.2019) and PEOIKOS 109 HYVÄKSYTTÄVIEN ETUJEN VASTAANOTTAMINEN JA KIELLETYT EDUT PUOLUSTUSVOIMIEN TOIMINNASSA (HK1038/9.12.2014).

The former as an obligatory order, the latter as an instruction equalising the operation. [1] The code of conduct is thus the same for both military and civilian personnel. Legislation like the Act on State Civil Servants (750/1994) also regulates on the matter regarding both civilian and military personnel. [2] Given that the two pieces of guidance named by the Defence Forces are not public, it is not possible to assess the level of guidance they provide.

The two aforementioned norms cannot be found online [1]. However, they may be available upon request. Acts, norms, and other guidance is distributed, for example, by uploading them to the document management system. It is not clear if distribution takes place beyond this.

Act on State Civil Servants, Decree on State Civil Servants, and the Criminal Code of Finland regulate on malfeasance and other misbehaviour of state officials. [1, 2, 3] In civilian matters, the normal accountability procedures are followed and possible police investigations are carried out.

There is not enough information to score this indicator.

According to a written response provided by the Headquarters of the Defence Forces, the following two norms have been given in the Defence Forces: PVHSMK – PE HENKILÖSTÖ-, MAANPUOLUSTUS- JA EDUSTUSTILAISUUKSISTA AIHEUTUVAT MENOT PUOLUSTUSVOIMISSA (HP418/27.9.2019) and PEOIKOS 109 HYVÄKSYTTÄVIEN ETUJEN VASTAANOTTAMINEN JA KIELLETYT EDUT PUOLUSTUSVOIMIEN TOIMINNASSA (HK1038/9.12.2014). The former as an obligatory order, the latter as an instruction equalising the operation. [1] The information provided by the Defence Forces HQ does not enable the scoring of this point. However, it is not clear from the information currently accessible that training specifically focuses on the General Service Code or accompanying norms.

In December 2020, The Ministry of the Armed Forces has adopted a standalone Anti-Corruption and Ethics Code of Conduct for all civilian and military personnel working under it or in associated agencies [1]. The Anti-Corruption Code is extensive and broken down into four parts:
– Part 1: details the main types of corruption offences under French law, based on a typology of corruption.
– Part 2: provides rules and recommendations on specific corruption-related issues such as conflicts of interests, gifts, hospitality, with guidelines on how to proceed to avoid exposing oneself to associated corruption risks.
– Part 3: provides a practical guide for personnel working in sensitive positions such as procurement, financial management and human resources, with a list of dos and donts and recommendations on mitigating corruption risks in practice.
– Part 4: provides information on existing procedures already in place to address corruption issues, such as whistleblowing procedures and ethical controls related to the revolving door.
The Ministry’s Anti-Corruption Code has been reviewed favourably by the Anti-Corruption Agency, which commended the Ministry for being the first ministry to implement such a code, which complies with requirements listed in the Sapin II Law of 9 December 2016 [2].

Aside from this, a patchwork of additional legislation and ethics rules provide further guidance on integrity and anti-corruption for civilian personnel. The Law of April 20, 2016 on the ethics, rights and obligations of civil servants states that “the public servant carries out his duties with dignity, impartiality, integrity and probity; is bound by an obligation of neutrality in the performance of his duties”. [3]
This law explicitly addresses conflicts of interests. It reinforces the mandate of the Ethics Committee, [4] with extended powers to prevent conflicts of interests, revolving doors with the private sector, influence peddling, and the holding of multiple posts at the same time. The Ethics Committee investigates the integrity of departures of civil servants to the private sector. [5]

Though all Ministry of the Armed Forces (MOAF) civilian personnel do not have the status of civil servants, articles 14 and 15 of the 2016 law [6] align contractual employees with the obligations of civil servants with regards to ethics rules.
In addition, as citizens, they are compelled to abide by Law Sapin 2 on transparency, anti-corruption and modernisation of public life, which has a wide array of anti-corruption provisions.

The 2016 Sapin 2 law also created the French Anti-corruption Agency (AFA). [7] As of January 2020, the AFA is investigating every Ministry to establish a diagnostic of their current state of compliance and that of their operators and sub-contractors. [8]

The MOAF anticipated this investigation, [9] and undertook in 2020 a “corruption-risk mapping” (with a broader definition of corruption than found in the Penal Code, encompassing embezzlement and misappropriation of funds), in the form of two separate questionnaires: one sent to over 60 departments at risk of corruption-exposure (procurement, subcontracting, exports, subsidies, HR, etc.) see [10] [10bis] within the Ministry, and a second one, anonymous, sent to operators working with the Ministry. The “contrôleur général des armées” and “ethics chief” of the MOAF, Jean Tenneroni, indicated that this risk mapping would feed into the development and subsequent publication of the new Code of Conduct published in December 2020. [9]

Finally, a decree on the management of financial instruments held by certain personnel (audit agents for instance) of December 3, 2019, finalised the implementation of prevention and ethical control tools for the Ministry covering the most exposed positions of responsibility. While “declarations of interest” aim to prevent any conflict of interest for the agent and “declarations of assets” prevent the risk of undue enrichment during the term of a mandate or function, this decree supplements the existing one for certain civilians (Secretary General for the Administration, General Delegate for Armaments) and certain soldiers (Chief of the Defence staff and government commissioners in armaments companies). It is a question of avoiding any “insider trading” by entrusting the public agent’s portfolio to a manager so that he cannot interfere in the purchases or sales of his securities. [9] [11] This decree is currently awaiting the Minister’s signature. [11] A charter of procurement already exists within the ministry. [12]

The Anti-Corruption Code of Conduct is readily available online in an easily accessible and legibile format on the website of the Ministry of the Armed Forces, along with other ethics-related documents [1].
The Law of April 20, 2016 [2] and the Law “Sapin 2”, [3] are also available online although they do not constitute codes of conduct as such.
Interviewees, civilian personnel of the Ministry of Defence, [4] said that they were told about general ethics principles upon induction, with a focus on risks of involvement in dishonourable behaviour being used against them for blackmail, rather than proper training on corruption risks (bribery, gifts and hospitality, conflicts of interest, and post-separation activities).

There is not enough information to score this indicator. The anti-Corruption Code of Conduct was only approved in January 2021 and it is still too early to assess its enforcement [1].
However, the anti-corruption law of 2016 [2] clearly states the corrupt behaviors it wishes to combat among civil servants and contract-based employees of public institutions. These breaches of the law are investigated, namely by the National Financial Prosecutor (PNF), as was recently shown with the ICS case (3) in which both military and civilian personnel are currently under investigation for influence peddling over procurement of overcharged subcontracting deals with the Ministry for aerial transportation, as well as in the cases of Airbus contracts for the Barkhane operation in Sahel, [3] and Airbus corruption practices in Egypt [4] and Mali, [5] for instance.

The Ethics Committee for civil servants mandate was extended by the 2016 Law on ethics. [6] It now has the power to investigate conflicts of interests, revolving doors with private sector, influence peddling, the holding of multiple posts at the same time and the integrity of departures of civil servants to the private sector. [7]

As the Anti-Corruption Code is very recent, it is difficult to assess whether it has been integrated into training programmes. The Code itself is intended as guidance, and therefore does not provide details of how it is to disseminated throughout the defence apparatus, nor does it specifiy training requirements on its contents. Instead it simply “calls on commanders to disseminate the code amongst personnel to ensure its provisions are respected” [1]. There is evidence that this Code was disseminated widely to all heads of departments, regiments and basis throughout France (both digital and hard copies) [2]. In addition, there is evidence that ethics “referents” have provided training to civilian and military personnel [3] [4], though it is not clear whether this forms part of the induction process.
An interviewee, a civilian member of staff of the MOAF, [5] said they were told about general ethics principles upon induction, with a focus on risks of involvement in dishonourable behaviour being used against them for blackmail, rather than proper training on corruption risks (bribery, gifts and hospitality, conflicts of interest, and post-separation activities).

The ‘Federal Government Directive Concerning the Prevention of Corruption in the Federal Administration’ [1] includes a ‘Code of Conduct Against Corruption’ as an annex, which outlines standards of conduct with regard to gifts, bribes and hospitality [2]. Civilian personnel are subject to these provisions, which apply across the Federal Administration. Moreover, the ‘Rules on Integrity’ (‘Regelungen zur Integrität’) provide guidelines for staff regarding good conduct and corruption prevention [3].

The Code covers conflicts of interest but not post-separation activities. It also provides detailed guidance on how to proceed in specific situations.

The Code of Conduct and the Rules on Integrity are available to staff and the general public via official websites [1,2]. The ‘Federal Government Directive Concerning the Prevention of Corruption in the Federal Administration’ specifies that awareness-raising training should be conducted with staff upon entering office and in preparation for high-risk positions [3].

The annual report on corruption prevention issued by the Ministry of the Interior provides details of corruption cases and investigations for each federal ministry [1], suggesting that investigations and sanctions take place. Furthermore, internal investigations are carried out by a specialised unit (Unit R II 1), which then lead to internal disciplinary measures or criminal investigation [2].

Regarding the ‘enforcement’ of the Code itself, it should be noted that the Code provides guidance for action/corruption prevention/awareness-raising. Corruption cases are investigated/prosecuted under criminal law. However, it should be noted that the Code’s legal status is enhanced by the fact that it features as part of an administrative directive.

The ‘Federal Government Directive Concerning the Prevention of Corruption in the Federal Administration’ specifies that awareness-raising training should be conducted with staff upon entering office and in preparation for high-risk positions [1]. Section 7.1 specifies that employees are to be made aware of the dangers of corruption when they swear an oath of service or undertake a commitment and are to be instructed about the consequences of corrupt behaviour. This instruction must be documented.

Article 284 of Chapter 24 regulates conflict of interest for public officers (“A public officer shall not put himself in a position where his personal interest conflicts or is likely to conflict with the performance of the functions of his office.”) (1). Additionally, the Public Officers (Disqualification and Assets Declaration) Act, 1998 (Act 550) requires certain categories of public officers to declare their assets and liabilities (2). However, the provisions are not very comprehensive (no mention of bribery, gifts and hospitality, and post-separation activities).

To enhance its anti-corruption education among public officers, the CHRAJ launched the Code of Conduct and Conflict of Interest Guidelines (3) and adopted an internal Code of Conduct in 2010. Following CHRAJ’s example, other public institutions have adopted internal code of conducts, such as the Public Services Commission in 2014 (4).

However, Ghana failed so far to adopt the Conduct of Public Officers’ Bill, in parliament since 2014, which would provide a more comprehensive legal framework (5).

The code of conduct for public officers is publically available, but it is not clear how effectively it is distributed to all civilian personnel (1).

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

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

The code of conduct for public officers is publically available, but there is no evidence that training is provided to civilian personnel (1).

There is a code of conduct, however its content are not comprehensive. Article 107 of the code states that “the acquisition of financial benefit or consideration for his own benefit or a third party in the performance of his duties is a disciplinary misconduct” [1]. Breaches of the code are investigated by the Department of Internal Affairs [2]. Corruption in the form of bribery and gifts is punished by a wide range of sanctions, including dismissal. Decisions against civilian personnel are made by the disciplinary committee [3].

The code of conduct is distributed to civilian personnel but only on an ad hoc basis [1]. The code of conduct is available to the public [2].

Breaches of the code of conduct are regularly investigated, even if the oversight mechanism is confidential [1, 2]. However, cases may not always be pursued where there is evidence of criminal behaviour. According to the Department of Internal Affairs, there were 1113 complaints against public servants in 2019 but only 0.63% were against civilian personnel in the defence sector [2]. All complaints were investigated by the department [3].

Guidance on the code of conduct is available to all civilian personnel but is not part of induction training [1, 2]. Civilian personnel can seek advice from the legal department if they want clarification on the legislation regarding breaches of the code of conduct.

There has been serious development since 2015 when it comes to legislation and code of conduct. The National Anti-Corruption Program was approved in 2015 for the period 2015-2018 [1]. The program served as a strategy and tasked ministries to manage internal development of integrity and anti-corruption schemes. The Code of Conduct for Government Officials [2] includes a detailed description of bribery, gifts and hospitality, conflicts of interest, and post-separation activities. It provides specific guidance on how to proceed in the face of these events [3]. The strategy supported the effective implementation of the Code of Conduct. It needs to be clarified that in the case of Hungary ‘civil servants’ is a better translation than ‘government officials’. Although the second one is closer to the literal translation, we are talking about civil servants in general, and they have a clear, easily available code of conduct [3]. Other civilians are not civil servants, and they have to follow the Code of Conduct of the Military [2]. So, overall, every civilian is covered by simple, readily understandable codes of conduct.

The Code of Conduct is available online together with detailed information on the efforts and updates oof the government programs [1].

Some cases are investigated, the Integrity Report of the Defence Ministry suggests that so far methods to tackle the issue of corruption are not all-encompassing [1]. The reports suggest, that internal documents, training materials and strategies are still under development. This is also suggested by internal measures [2] and answers provided in the integrity report of the ministry [3].

Special training was launched for the integrity advisers that are present at every ministry, while civil servants have to participate in ethics, integrity and integrity management training. The topic of corruption become an integral part of the raining of government officials at the National Public Administration University [1].

There is no unified Code of Conduct but civil servants in India are bound by codes of conduct as prescribed in the All India Services (Conduct) Rules,1968 and the Central Civil Service (Conduct) Rules, 1964. Civilian defence personnel are bound by the aforementioned and the Armed Forces Headquarters Civil Service Rules, 2001 [1][2][3]. Codes and guidance include but are not limited to gifts, hospitality and conflicts of interest. There is a zero tolerance policy on corruption and bribery would fall under this. Guidance on post-separation activities is not found.

All public servants can be penalised under the Indian Penal Code, 1860, the Prevention of Corruption (Amendment) Act, 2018, the Prevention of Money Laundering Act, 2002 and the Benami Transactions (Prohibition) Amendment Act, 2016 [4][5][6][7]. The Vigilance Division in the Minitry of Defence carries out oversight across all defence departments [8].

Codes of conduct are given to civilian personnel and are publicly available [1][2][3][4].

There is evidence of breaches of conduct by civilian personnel being investigated. During 2016-2017, 16 disciplinary cases of Group ‘A’ officers in the Department of Defence were finalised. In the same year, 21 cases of investigation were concluded in the Department of Defence Production, out of which 10 cases were for administrative action and 9 cases were referred for disciplinary action [1]. During the period 2017-2018, sanctions for prosecution were conveyed against 26 officials and 27 disciplinary cases were finalised [2]. During the period 2018-2019 penalties were imposed on 14 officers and 15 officers have been chargesheeted [3].

Guidance on the codes of conduct is included in induction training and strict adherence is expected throughout employment [1][2][3][4][5].

Based on the master rules regarding gratification, stipulated in Law No. 20/2001 concerning Eradication of Corruption, state administrators who are required to report gratuities include members of the TNI and the police, as well as civil servants within the TNI and the police [1]. The gratification rules were then ratified by each state organisation, including the Ministry of Defence and the TNI. In the regulation [2] concerning bribery, gifts and hospitality, conflicts of interest and post-separation activities within the Ministry of Defence, it is stated that the object of gratification control is ‘Ministry of Defence employees’, which are defined as ‘members of the TNI and the State Civil Apparatus work in the Ministry of Defence’. This means that civil servants who work in the TNI environment are subject to the the same regulation that is applied to their military colleagues. However, even though its formulation has been mentioned [3], the regulation cannot be accessed by the public.

The basic principles of the Ministry of Defence’s civil service Code of Ethics, which also covers those working within the TNI, are the Panca Prasetya KORPRI (Five Vows of Indonesian Civil Servants), the Code of Conduct for Appointment Oaths and the Position Oath Code of Ethics. The latter covers the obligation not to offer, give, receive or solicit any item of value to influence the actions of an official or other person with a public or legal duty [4].

The basic principles of the Ministry of Defence’s civil service Code of Ethics, which also covers those working within the TNI, are the Panca Prasetya KORPRI (Five Vows of Indonesian Civil Servants), the Code of Conduct for Appointment Oaths and the Position Oath Code of Ethics. It is available on Ministry of Defence website [1] thus can be accessed publicly.

There is insufficient evidence to score this indicator; as such, it has been marked ‘Not Enough Information. Reports of rejection and acceptance of gratuities are submitted once a month to the Gratuity Control Unit (UPG), which is overseen by the Inspectorate. Within the Ministry of Defence, a summary of gratuity reports from the IG submitted regularly to the Commission of Corruption Eradication (KPK) every three months [1]. The Chief of TNI regulations regarding bribery, gifts and hospitality, conflicts of interest and post-separation activities within the TNI are not accessible to the public. There are no publicly known cases of Code of Ethics violation by civilian personnel in the Ministry of Defence and Armed Forces so it is difficult to assess whether they are properly investigated.

Code of Ethics training, which addresses bribery, gifts and hospitality, conflicts of interest and post-separation activities, is carried out routinely, usually as part of the annual leadership, procurement management and character building training [1] held by the education and training agencies (Badiklat). Examples of this training include the three-month basic course on defence management for captains/majors and equivalent-level civil servants and the one-month basic training course for Level II civil servants. In other courses, anti-corruption is only discussed as an additional topic covered by an invited speaker.

There is no code of conduct for civilian personnel working in the defence sector. There is a civil code, and the contents are known, but it has no provisions related to how to proceed in the face of corruption [1].

This indicator has been marked Not Applicable, as there is no code of conduct for civilian personnel wrorking in the defence sector. There is a civil code, and the contents are known, but it has no provisions related to how to proceed in the face of corruption [1].

This indicator has been marked Not Applicable, as there is no code of conduct for civilian personnel wrorking in the defence sector. There is a civil code, and the contents are known, but it has no provisions related to how to proceed in the face of corruption [1].

This indicator has been marked Not Applicable, as there is no code of conduct for civilian personnel wrorking in the defence sector. There is a civil code, and the contents are known, but it has no provisions related to how to proceed in the face of corruption [1].

Online evidence reveals the existence of a Code of Conduct (2005) it was amended in 2006 (1). It sets out a series of instructions and standards to guide public and mixed sector workers. As the law state’s, employees to whom the code applies “shall sign the code of conduct”. Provision 9 forbids employees (civil servants and otherwise) from “accepting gifts or seeking benefits”, while provision ‘9’, issues warnings “not to dispose of [state] funds and assets without explicit authorization”. It is unclear whether the code applies to defence sector employees as there is no mention of this in the code.

The Code of Conduct is available online (1).

Citing “the absence of any implementing structure”, and the “malfeasance in office” and “central agency responsible for punishing breaches of the code” (1), the code, according to the legal source (2), has proven impossible to enforce. The most up-to-date statistics concerning bribery, gifts and hospitality, published by the UNDP (3) reveals that 60% of the 31,000 civil servants interviewed were offered bribes. Few structural reforms have resulted in any mass overhaul of the prevalent practice of bribery.

There is no evidence that training is provided to civilian personnel on the code of conduct.

The Public Service Commissioner has set a civilian Code of Ethics for public servants (i.e. government employees). This code contains explicit references to issues of integrity, mortality etc., such as prohibitions regarding conflicts of interest and use of position and status to benefit oneself or others, as well as instructions regarding restrictions of receiving of gifts, relationships and contacts which may affect the employees discretion etc. For example, Article 41 of the code stipulates that “a public servant will refrain from taking advantage of his/her status or position in order to further his/her or an acquaintance’s personal interest, and or any other goal which is not related to the fulfillment of his/her job”; Article 46 stipulates that “a public servant, especially one filling a sensitive or senior position, should apply discretion and cautiousness regarding holding meetings and maintaining personal contacts that due to their nature or circumstances may affect his/her discretion or in way that will interfere with his/her duty to maintain equality and avoid conflicts of interest or damage the image or reputation of the public service. If such contacts have been maintained by a public servant – he/she must report them to their superior’ (1).
The MoD also has its own code of conduct for all civilian personnel which provides guidance on how act based on integrity, but not related to specific forms of corruption (2). Instead, specific guidance with respect to bribery, gifts, hospitality and conflicts of interest is provided by an internal MOD policy that acts to complement the more general code of ethics. The policy provides clear guidance with respect to these situations and outlines the penalties for personnel found to contravene its provisions (3).

The code of conduct is available to the public and distributed to civilian personnel. Guidance on the code of conduct is included in induction training (1). Equally, the overall Civil Service code of ethics is publicly available on the Public Service Commissioner’s website (2).

Breaches of the code of conduct are regularly investigated, even if the oversight mechanism is confidential. Cases are pursued where there is evidence of criminal behavior (1). There are examples for corruption cases and stories about how the police is investigating cases (2) (3).

Guidance on the code of conduct is included in induction training (1).

In 2018, the Ministry of Defence updated its Code of Conduct for the personnel of the ministry, that applies to both civil and military personnel and that takes into consideration provisions included in the Three-year Anticorruption Plan [1]. The Code of Conduct regulates the personnel attitude with regards to gifts, compensations and other utilities (art.3), participation to organisations or associations (art.4), conflict of interests (art.5), corruption prevention (art.7), transparency and traceability (art.8), abuse of power (art.9), cases of abstention from contracting (art.14). The Code also includes specific rules for high ranking personnel (art. 13), as well as for personnel employed in areas of high-risk of corruption (artt. 18, 19, 20). Art. 15 and Section IV of the Code of Conduct presents guidance on how to proceed in case of breach of the Code. Further, each of the aforementioned articles specify what the employer should do in case these events occur. The Code does not cover issues related to post-separation activities. Nonetheless, the Code (art.2) is meant to provide a link with the Three-year anticorruption plan, where pantouflage (revolving doors) is regulated (section III.6.7) [2].

The Code of Conduct and the illustrative report on the Code of Conduct are both published on the website of the Ministry of Defence. On the same webpage, it is also possible to access the previous version of the Code of Conduct [1]. Art.1(2) of the Code of Conduct specifies that a copy of the document has to be distributed to all civil servants – even temporary personnel, consultants or suppliers – of the ministry at the moment of their post assignment [2].

Enforcement of the Code of Conduct is implemented with the support of the Office for Disciplinary Proceedings (Art. 15(2)). In its work, the Office follows rules included in the Three-year anticorruption plan [1] and annually reports any cases [2]. For civil personnel, the Office for Disciplinary Proceedings is regulated by the national collective labour agreement [3]. According to art. 23 of the Code of Conduct, incidents are investigated “without delay” (senza indugio) as soon as they are reported. Given that national legislation applies, it can also result in criminal procedures [4]. An evidence of the reported cases can be found in the annual report of the anticorruption supervisor, where there is an indication of the number and type of violations incurred and enforced during the year [5].

Art. 15 (3) of the Code of Conduct provides for a training on transparency and integrity to be given to the entire personnel of the Ministry. Training should include comprehensive annual updating sessions in order to guarantee a proper knowledge of provisions included both in the Code of Conduct and in the Three-year Anticorruption Plan [1].

The great majority of the employees of the Ministry of Defence (MOD) are designated Special service national public employees in the National Civil Service Law. [1] Therefore, the provisions of this law, which apply to most national civil servants, do not apply to most civil servants in the MOD. [2] Instead, these civil servants are employed by the Self-Defence Force (SDF), and their employment is regulated by the Self-Defence Forces Law. [3] Regular SDF personnel under the MOD thus include SDF officials (the largest group, see Q46) and four categories of civilian employees. As of March 31, 2020 these four categories were made up of 20,165 administrative officials, 708 secretaries, a smaller number of Defence Councilors and one Administrative Vice-Minister. In addition, there were non-regular SDF personnel, of which the most numerous category was made up of 47,900 reserve SDF officials. [4] It is however stated in some articles of the National Civil Service Law that they apply to civilian SDF personnel as well. [5] The SDF Ethics Law, [6] and the SDF Code of Conduct, which is based on this law, both apply to these groups of regular civilian employees of the MOD. [7] The Inspector General’s Office has made a Compliance Guidance in two versions that refer to the Code of Conduct (see Q46A). Both the version for supervisors [8] and the one for personnel in general [9] state that examples are equally relevant for administrative officials and SDF officials. Guidelines for how to deal with the issues of bribery, gifts and hospitality are described on pages 31-32 in the book for personnel in general. How to deal with conflicts of interest that arise over procurement is described on pages 27-30, and with conflicts that arise with contract parties in general, on pages 31-32. Compliance issues in post-separation employment are dealt with on pages 33-34. A list of who to contact in the various situations, with contact details, is found on pages 56-58.

All documents listed are found on easily accessible homepages (see Q47A). According to the foreword of the supervisor version of the book on compliance, it is distributed to all units of the SDF in booklet form. [1] A Ministry of Defence official stated that through various categories of training, not the least training for newly employed, in which instructive cases are discussed, staff are educated on the Code of Conduct. [2]

The National Personnel Authority handles disciplinary measures against most national civil servants, [1] but not against civil servants employed by the SDF, who belong to the category special service national public employees. [2] The SDF Law regulates disciplinary reactions against SDF personnel, however. [3] The MOD publishes lists of SDF personnel, in the categories SDF officials and administrative officials, who have received disciplinary punishment. In 2018, five administrative officials in the MOD received disciplinary punishment. [4] One report of an SDF staff member who was prosecuted for corruption was found in the mainstream media between 2015 and 2019. The Yomiuri Newspaper reported in October 2019 that the public prosecutor had indicted an Marine SDF (MSDF) Petty Officer Second Class, who was stationed at an MSDF depot and in charge of purchasing food supplies, for accepting bribes. [5] Although this is only one case, it shows that the public prosecutor has taken the step of indicting an SDF official in recent times.

Circulars from ATLA confirm that the Compliance Guidance is used in the education of administrative officials. [1] [2] It is distributed to all units of the SDF, which includes civil servants in the MOD employed by the SDF, in booklet form. [3] A Ministry of Defence official stated that through various categories of training, including training for the newly employed, in which instructive cases are discussed, staff are educated in the Code of Conduct. [4]

There is a Code of Conduct for civilian personnel within the defence sector, but it does not include all items such as bribery, giving and recieving in detail. Rather it addresses ethical conduct in general [1]. It is the same for all other employees in the Government. It is published in every unit and available online in every ministerial website. The civilian employees in the armed forces are employed within the Minsitry of Defence, and therefore, the general Code of Conduct is applicable to them [2,3].

The Code of Conduct is widely available for all personnel, yet there is a lack of guidance within the minisiterial divisions and units. Personnel do not receive the code of conduct in the induction phase, but they are asked to sign on it the as part of the contract [1,2]. The code of conduct is also available on the ministries’ website.

The Code of Conduct is not a law per se, but violating it, just like engaging in bribery, stealing and abuse of power, can be investigated and potentially be punished. It is not throughly followed and enforced, but in case of grievous breaches or violations, investigations would be ineviatable. Howeer, prosecution is not guaranteed even if warranted by law [1,2].

There is no evidence that training is provided on the code of conduct [1,2].

Civilian personnel in the armed forces are covered by the Public Officer Ethics Act, 2009 upon their employment. [1] The Code of Ethics covers issues of gifts and conflict of interest, but does not explicitly address issues of post-separation activites and bribery. For the issues covered in the Code of Conduct, there is specific guidance on how to proceed in the face of those events.

The Code of Ethics governing civilian personnel is provided to the personnel upon their employment.The public has access to the Code of Ethics through the Public Service Commission website, but there are no channels to ensure that all members of the public have access to the Code of Ethics. [1]

The Code of Ethics provides for investigation into breaches of the code and possible prosecution through civil and criminal proceedings. [1] Section 35 covers enforcement of the Code of Ethics. This section stipulates that once a public officer is found to have been in contravention of the code, the responsible Commission should conduct investigations. If the investigations reveal contravention of the Code of Ethics, appropriate disciplinary action should be taken within 30 days of completion of the investigations. There is evidence of cases where breaches of code of conduct have been investigated and prosecuted, however this does not appear to take place on a regular basis. [2]

Thre is not enough information to score this indictor, as no details are available on what the induction training civilian personnel involves. However, it is the responsibility of Commanding Officers to provide training and ensure discipline to personnel under their command (see Public Officer and Ethics Act, p.79). [1]

Senior officials of the Kosovo Security Forces and the Ministry of Defence have stated that the there exists a Code of Conduct for all civilian personnel [1]. However, this document is not published by the Ministry of Defence [1] or other relevant institutions.

According to the government reviewer, there is Regulation NO. 04/2015 on the Code of Conduct in the Civil Service of the Republic of Kosovo, which is published in the Official Gazette of the Republic of Kosovo.

Senior officials of the Kosovo Security Forces and the Ministry of Defence have stated that the there exists a Code of Conduct for all civilian personnel [1]. However, this document is not published by the Ministry of Defence [1] or other relevant institutions.

There is not enough information to score this indicator. The Code of Conduct is not published and it is also difficult to establish whether potential breaches of the Code are investigated [1]. All the same, senior officials of the Ministry of Defence and the Kosovo Security Forces have stated that violations of the Code of Ethics are regularly investigated [2].

There is not enough information to score this indicator. The Code of Conduct is not published and it is also difficult to establish whether any training/ guidnace is provide to civilian personnel.

There is a Code of Conduct for all civilian personnel in the security agencies, but it is also unavailable to the public, state auditors said (1, 2 and 3). That being said, the aforementioned article 14 of the military trials law applies to the civilian staffers, and so does the conflict of interest act (4 and 5). Both these laws address bribery and other conflicts of interest issues and, as laws, they outrank the Code.

The code is not available to the public, but the aforementioned laws are available to the public online, but it remains unclear whether they are distributed to all civilian personnel and whether guidance is provided, officials said (1, 2 and 3). All Government bodies, however, do hold one or two-day training workshops about integrity, which covers corruption.

The code is generally not used since most corrupt practices are alive and well and those behind them are never punished, officials and activists said (1, 2, 3, 4, 5 and 6). It is important to note, however, that the code and the laws are disrepected not because the legislation is weak but because there is a lack of political will to enforce them.

There is no evidance that training is provided to civilian personnel on the code of conduct.

On November 21, 2018, the Cabinet of Ministers adopted Recommendation No1 – Values of State Administration and Fundamental Principles of Ethics, explaining – bribery, gifts and hospitality, conflicts of interest, and post-separation activities. According to the document all state institutions have to integrate these recommendations into their Codes of Ethics. [1] The MOD constantly works on improving the Code, which applies to civilian as well as military personnel. [2] However, it does not provide specific guidance on how to proceed in the face of these events.

The Code of Ethics of the MOD is publicly availbale online. [1] The observation of the Code of Ethics is overseen by the Commission of Ethics of the Ministry of Defence of Latvia. There is no special guidance and training on the Ethics Code. [2] The present Code was adopted in 2009 and is now under revision.

There is not enough information on cases of breaches to score this indicator. Officials are obliged to submit an annual income tax declaration. The Corruption combatting and Prevention Bureau is responsible for overseeing this process, and is entitled to issue fines. [1] There is no publicly available information on the quantity of fines issued to employees of the MOD and NBS. [2]

The guidance on the code of ethics is included in the training for younger personnel who are starting their work at the MOD or service in NBS. [1] For senior personnel, military courses on corruption and corruption-related issues are available at the School Public Administration. [2] Training is optional for senior staff.

There is no Code of Conduct for all civilian personnel working at the Ministry of National Defence or its departments, including the LAF (1). As mentioned in Q46, the LAF launched in, January 2019, the Code of Conduct for Law Enforcement that targets LAF military personnel (2).

This sub-indicator has been marked Not Applicable, as a Code of Conduct for civilians is not available (1).

This sub-indicator has been marked Not Applicable, as a Code of Conduct for civilians is not available (1).

This sub-indicator has been marked Not Applicable, as a Code of Conduct for civilians is not available (1).

There is a Code of Conduct for all civilian personnel, who work in public sector institutions (some institutions, such as the State Tax Inspectorate have their own internal Code of Conduct). Rules cover policies such as respect for all individuals, justice, altruism etc. The Code also stipulates that civilian personnel cannot accept gifts, hospitality, money, services or other valuable things from other individuals or companies. Moreover, they should avoid situations which can cause conflict of interest. According to the government reviewer, anyone who recognizes any possible breaches of the civilian code may inform about this the head of the institution who decides if an internal investigation is needed. However, rules do not provide specific guidance on how to proceed in the face of such events [1, 2].

The Code of conduct is publicly available and accessible by each civilian personnel at any given time. The Code of Conduct is not distributed individually, but published in the Register of Legal Acts [1]. There is no publicly available evidence of guidance being provided through trainings.

According to the code of ethics, anyone who recognizes any possible breaches of the Code of Conduct (not civil code!) may inform the head of the institution about this who decides if an internal investigation is needed. The official website has a column “Misconduct in Office” and refers only to two investigations conducted in 2016, concerning a gross disciplinary violation, for which sanctions were applied (a fine and a reprimand).(1) It should be noted that as per measure 5.2. of the Action Plan of the Anti-Corruption Programme, such information should be made regularly available (2). The news column of the Ministry of Defence also refers to the 2019 Report issued by the General Inspectorate of the Ministry of Defence, one of the functions thereof is to examine complaints concerning violations by servicemen and in relation to their service. As stated in the Report, during 2019, the General Inspectorate conducted 9 investigations regarding alleged disciplinary violations by servicemen, and that servicement made 35 complaints and requests regarding the disciplinary sanctions applied to them, refusal to grant them a military rank, assessment of their service, etc.(2)

The Code of conduct is publicly available and accessible by each civilian personnel at any given time. The Code of Conduct is not distributed individually, but published in the Register of Legal Acts [1]. There is no publicly available evidence of guidance being provided through trainings, as such we are not able to score this indicator and have marked it ‘Not Enough Information’.

All public officials are bound to the Public Officers (Conduct and Discipline) Regulation 1993 [1] which outlines bribery, gifts and hospitality, and conflicts of interests. Furthermore, all public officials are also bound by signed commitment to any additional General Orders and Circulars. Malaysia also adopted the MACC Act which prohibits officers of public bodies from accepting gratification or bribery. [2] The Public Officers (Conduct and Discipline) Regulation 1993 restricts hospitality in the form of gifts, travel and entertainment and also provides specific actions to be taken when given gifts that are difficult to turn down. There are, however, no guidelines or restrictions on post-separation activities.

The Public Officers (Conduct and Discipline) Regulation 1993 [1] and the MACC Act [2] are available for public access on official government websites. Civilian personnel are introduced to the Code of conduct during their induction training and anti-corruption seminars. [3]

The MACC has proactively investigated reports of corruption in numerous cases. [1] [2] [3] The Integrity Unit also monitors cases relating to misconduct and receives reports of concluded cases relating to misconduct and disciplinary action taken. According to the 2018 annual MINDEF report, there were no cases of misconduct reported in 2017 and one case reported in 2018. [4]

All personnel are sworn to respect the Public Officers (Conduct and Discipline) Regulation by signature. All civil servants, including civilian personnel, are mandated to undergo a minimum of 7 days of conduct and discipline training per year. [1] Matters pertaining to conduct and discipline for civilian MINDEF staff fall under the purview of the Human Resource (HR) Division and the Integrity Unit. Civilian officers who handle conduct and discipline are trained internally by the training unit of the HR Division through the process of mentoring, coaching and shadowning. The Public Service Department also conducts regular training sessions on matters pertaining to the Code and Discipline. [2]

There is a Code of Conduct, however, its guidance is inadequate or lacks clarity and specificity.
Each public service has its own Code of Conduct. For instance, the code for tax officials dates from 2002,¹ while the one for prison and school inspectors was adopted in June 2016.² The former specifies that tax officials must “avoid situations that entail a conflict of interests”. These may relate to “money, presents and holding privileged information over a taxpayer”.¹ By contrast, the code of conduct for prison and school inspectors makes no reference to not accepting bribes, gifts or avoiding conflicts of interest. The government is currently seeking to harmonise the respective codes of conduct for public servants, but there is no evidence that is has completed this task and adopted a new comprehensive law.³ ⁴ ⁵ ⁶ In addition, the Penal Code does outlaw bribery and acts designed to gain undue influence in the civil service (see Q46A).

The respective Codes of Conduct are issued to civil servants during their induction training, which outlines the key tenets of the codes. However, the codes are not necessarily readily available to the public. There is also a standard welcome booklet that is issued to state employees, which outlines that their annual performance evaluations are based upon their conduct as a public official.[1]

Corruption is widespread within the state administration and breaches of the Code of Conduct are only occasionally investigated and enforced. Citizens are accustomed to paying a small bribe to public officials to obtain a service that everyone has the right to obtain free of charge.¹ ³ ⁴ Indeed, rent-seeking opportunities are so lucrative that many people pay to become public officials.² In 2016, it was reported that a number of people had paid between 3,000,000 and 5,000,000 CFA to obtain posts within state agencies, such as customs.²
However, the BVG has uncovered cases of large-scale corruption. In a 2012 report, the Auditor General announced that USD 20 million in public funds had been embezzled, and in a 2013 report the number increased to USD 100 million.⁵ Following the 2013 BVG report, the government submitted approximately 100 cases to the Ministry of Justice, all of which still await judicial action (as of March 2016). “In 2011, the anti-corruption prosecutor announced that around USD 15 million of embezzled public funds were recovered, but no prosecutions were made.⁵ Similarly, inspectors from the Global Fund for AIDS, Tuberculosis and Malaria uncovered cases of embezzlement of public and donor funds at the Ministry of Health, leading to the prosecution of several high-ranking health ministry officials.⁵

The respective Codes of Conduct are issued to civil servants during their induction training, which outlines the key tenets of the codes

There is a Code of Conduct for civil servants from SEDENA [1] and SEMAR. [2] The same applies as for military personnel. In this regard, neither document explains the bribes, gifts, conflicts of interest, and post-separation activities of the service, and therefore does not provide guidelines on how to proceed in the face of these events.

There is a new Code of Conduct for public servants of SEDENA [1] which is published online and is easily accessible. It states that all personnel must receive a copy and sign a voluntary committment that they are familiar with and understand the terms of the code of conduct, as established under section 4 of that document.

It is not possible to find official information that would allow us to know if violations of the Code of Conduct are investigated. As such, this indicator cannot be scored and is marked ‘Not Enough Information.’ For example, the annual activity reports of SEDENA’s Ethics and Conflict of Interest Prevention Committees (CEPCI) do not indicate cases in this regard. [1] [2] In the case of SEMAR, 3 cases of complaints were reported but not related to corruption issues. [3]

In this regard, it is important to mention that it is difficult for infractions not to be committed, so it follows that sanctions are not applied or not investigated. For example, corruption was recently detected in SEDENA contracts in the construction of a fence at the New Mexico City Airport, and, although the institution has been identified as such, the people who participated have not been investigated. They may have been violating the Code of Conduct and may even be military. [4] [5]

While the Code of Conduct 2019 specifies that members of the military shall have access to training on its terms, there is no mention of this being offered to civilan personnel. Having said that, they are required to be informed on the Code. [1]

There is a Code of conduct for civilian personnel, [1] but it does not explain bribery, gifts and hospitality, conflicts of interest, or post-separation activities, nor does it provide specific guidance on how to proceed in the face of these events.

According to the MoD reviewer, ethical standards and rules of conduct for civil servants and state employees in the Ministry are defined by the Code of Ethics for Civil Servants and State Employees. When it comes to civilians in the Armed Forces, they are subject to the provisions of the Law on the Armed Forces of Montenegro.

The Code of Conduct is publicly available [1] and included in initial training. [2]

There is not enough evidence to score this indicator. Information about breaches of the Code of conduct are not available in the reports of the Ministry, [1][2][3][4] or on its website, [5] and was not provided upon request. [6]

Throughout the public administration, the results of the implementation of the Code of conduct are lacking. [7]

According to the MoD reviewer, breaches of the code of conduct are regularly investigated, even if the oversight mechanism is confidential.

There is not enough evidence to score this indicator on training/ guidance relating to the code of conduct for all civilian personnel.

The general conduct of military personnel is detailed in two documents: the Regulations on General Discipline of the Royal Armed Forces and the Military Justice Code (1)(2).

However, neither of them covers conduct with respect to corruption, even though they provide a detailed account of the behaviour military personnel should observe before, during and after operations (1).

In the absence of elements referring to the conduct of military personnel with respect to corruption in these documents, the assessor looked for similar elements in other documents and sources, such as the government’s website, NGO reports and the anti-corruption government platform (3)(4)(5).

However none of them mentioned conduct with respect to corruption.

This lack of evidence of a clear, proper and published code of conduct with respect to corruption indicates a lack of transparency.

Since Morocco has no code of conduct, this sub-indicator is marked Not Applicable.

Since Morocco has no code of conduct, this sub-indicator is marked Not Applicable.

Since Morocco has no code of conduct, this sub-indicator is marked Not Applicable.

There is no separate Code of Conduct for civilian personnel. However, there is general legislation in the form of the Anti-Corruption Law, which was enacted in 2013 and amended in 2014, 2016 and 2017. This law covers a wide range of types of corruption offences (bribery, extortion, speed money and abuse of public property) as well as corruption prevention. The law covers both the public and private sectors [1]. All civilian personnel must obey the law, but the military enjoys immunity from it because of the Constitution [2]. However, this is not specifically a Code of Conduct.

This indicator is marked ‘Not Applicable’, as there is no separate Code of Conduct for civilian personnel.

This indicator is marked ‘Not Applicable’, as there is no separate Code of Conduct for civilian personnel.

This indicator is marked ‘Not Applicable’, as there is no separate Code of Conduct for civilian personnel.

For civilian personnel in the defence sector, Chapter 7a (‘Integrity’) of the Civilian Defence Personnel Code (Dutch: Burgerlijk ambtenarenreglement defensie) includes provisions on bribery, gifts and (financial) conflicts of interest [1]. Additionally, the Secretary General directive SG A/984 ‘Implementation of Defence Integrity Policy’, which also pertains to civilian personnel, elaborates on the Code of Conduct by addressing and explaining bribery, gifts and hospitality, conflicts of interest and post-separation activities in further detail [2]. Chapter 6 of ‘Implementation of Defence Integrity Policy’ is dedicated to guiding personnel on what they should do in the event of an integrity violation, including methods of reporting and contact persons or organisations that personnel can report to [2]. In 2017, SG-Designation A/984 ‘Implementation of Defence Integrity Policy’ was enhanced in a number of areas, such as the hiring of former defence personnel (post-separation activities), and entered into force on December 20, 2017 [3].

The codes mentioned in Q47A (the Civilian Defence Personnel Code and ‘Implementation of Defence Integrity Policy’) are publicly available [1]. The most recent iteration of ‘Implementation of Defence Integrity Policy’ is available to the public, accessible through the defence staff intranet and unclassified [2,3].

In terms of enforcement, breaches of the Code of Conduct by civilian personnel are regularly investigated and cases are pursued where there is evidence of criminal behaviour. Since 2012, breaches of the Code of Conduct have been reported annually in the Defence Annual Report. The Annual Report of 2018 notes that there were 454 integrity reports made about (suspected) breaches of integrity that year [1]. These reports are then further broken down into categories of misconduct (for example, 46 reports were made in 2018 pertaining to financial violations). Of all reports made, a total of 134 integrity investigations were conducted, with 65 of these found to be integrity violations (please note that the original report mistakenly reported that a total of 143 integrity investigations were conducted – this was later corrected to 134). The report also details the internal measures taken against those who violated the Code of Conduct. The Military Police (KMAR) advises and supports executives and employees in implementing integrity policy and, if necessary, investigates and reports on violations of integrity and criminal offences [2]. The KMAR registers these reports in the police systems.

The induction training for civilian personnel includes guidance on the Code of Conduct for Defence [1]. However, it is noted that, in some cases, induction training can be slow to commence and, in some instances, personnel may be employed for a few months before the training (and thus the guidance on the Code of Conduct) is delivered [1].

All employees of the Ministry of Defence are required to comply with the Ministry Code of Conduct and the Code of Conduct issued by the Public Service Commissioner. This sets out the need to ensure actions are not affected by personal interests or relationships; that positions are not used for personal gain; and that gifts or benefits that place staff under any obligation or perceived influence are declined. Ministry staff are also required to comply with ministry policies and procedures which cover these matters. These include the sensitive expenditure policy; gifts and hospitality policy; interests and conflicts of interest policy; and procurement policy. Induction training for new ministry staff includes sessions on the ministry’s internal control framework and the State Service Commissioner’s Standards of Integrity and Conduct. Breaches of the code are considered very seriously and may be grounds for dismissal [1, 2, 3, 4].

For the Defence Force, members of the Civil Staff are required to act in accordance with the NZDF Civil Code of Conduct which is compliant with the Public Services Commissioner direction and covers the standards of behaviours and performance. It includes expected behaviours and instructions in relation to bribery, gifts and hospitality, conflicts of interest and post-separation activities. In addition, the Code of Conduct requires members of the civil staff to comply with NZDF policies. Breaches of the Code are addressed on a case-by-case basis and, depending on the nature and severity of the matter, disciplinary action may or will be taken in accordance with defined disciplinary processes. Guidance on the expected work practices and behaviours is promulgated in the induction welcome booklets and training is provided during the induction processes [5]. DFO 9/2003 is the NZDF Code of Ethics applicable to both military and civilian members of the NZDF [6]. DFO 16 is the Defence Force Orders for Civil Staff Human Resource Policy and Administration, and contains relevant information on best practices [7]. DFO 52 – Procurement refers to MBIE Guides for Standards and Ethics, and Office of the Auditor General’s guidance for Public Sector purchases, grants and gifts [8].

The Ministry of Defence Code of Conduct is not available publically but can be requested (it does not require an OIA request). Given that its code is aligned to the Public Services Commission’s own standards and best practices, this is not necessarily required to award a high score, though there seems no reason why the ministry could not publish its code online.
Public Services Commission’s Code of Conduct applies to all MoD staff regardless of internal policies and is publically available on the Public Services Commission website.
Induction training for new ministry staff includes sessions on the ministry’s internal control framework and the Public Service Commissioner’s Standards of Integrity and Conduct. The NZDF Civil Code of Conduct is distributed to all NZDF employees. Guidance on the expected work practices and behaviours is promulgated in the induction Welcome Booklets and training is provided during the induction processes. The NZDF Code of Ethics is also distributed to all NZDF personnel [1, 2, 3, 4].

According to the ministry, it takes breaches of the code very seriously and are grounds for dismissal [1]. Cases are investigated and, depending on their severity, would be referred to the Serious Fraud Office (SFO).
The SFO have a high threshold when it comes to accepting cases under Part 2 of the Serious Fraud Office Act 1990. During the period under review, only one case referred by the Vice Chief of Defence Force met the threshold required by the SFO, and was investigated under Part 2 of the Act. As a result, a woman was charged for allegedly stealing non-public funds administered by the NZDF while she was employed by the organisation.[2].

In 2016, the MoD commissioned an external review into financial irregularities as it prepared to wind up the Maritime Helicopter Capability project, set up to acquire and upgrade 10 Seasprite helicopters and based in the United States. An internal investigation found approximately NZ$147,530 unaccounted from the Connecticut-based project team office’s administration budget. After American authorities investigated, a US team member was convicted of felony larceny and given a five-year prison sentence, suspended for five years. The Ministry received a one-off payment of US$50,000 from the convicted US team member, with the court ordering further payments of $40,000 over five years. [2].

Induction training for new ministry staff includes sessions on the ministry’s internal control framework and the Public Service Commissioner’s Standards of Integrity and Conduct. All staff must sign the Ministry Code of Conduct and disclose any conflicts of interest as part of their employment contract [1].

As a result of cooperation with the Geneva Centre for Democratic Control of Armed Forces (DCAF), based on a 2011 Decree (1), in 2015 the National Police adopted an Ethics and Deontology Guide which determines the norms of conduct for Nigerien police (2). However, there is no explicit mention of corruption issues (2). It does not apply to all civilian personnel. Besides the code, there are also “regulations on [the] general discipline of the staff of the national police” (3). However, corruption does not appear in the Disciplinary Regulations as a specific fault to be sanctioned.
In addition to the Code of Ethics for the National Police (4), Articles 130–133 of the Public Penal Code of 2003 should be mentioned because they apply to all civilian personnel and can be generally interpreted to be serving as a guidance tool for dealing with bribery, gifts, hospitality. In Section VII of the Public Penal Code (On Corruption and Influence Peddling), Articles 130–133 apply to civil servants, which theoretically include members of Niger’s police forces (5). They describe penalties for corruption and influence peddling, with penalties for those who solicit or accept bribes, offer gifts or misuse public office. In sum, based on the examples above, there are regulations similar to what a Code of Conduct would include, but existing ones regarding corruption lack clarity and specificity.

There is no single 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. Therefore, this indicator has been marked Not Applicable.

There is no single 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. Therefore, this indicator has been marked Not Applicable.

There is no single 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. Therefore, this indicator has been marked Not Applicable.

The General Code of Conduct of the Fifth Schedule of the 1999 Constitution applies to all personnel. It guides how to escalate issues. 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. Conflicts of interests are not mentioned (1). 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. Other criminal sanctions may still apply (2).

The Code of Conduct is readily available on the Code of Conduct Bureau’s website (1).

Enforcement of the code does not apply to all cases (1).

There is no evidence to show that personnel are trained (1)

The Code of Ethics for the employees of the Ministry of Defence and the Army, introduced in November 2017 [1] also applies to civilian staff. Articles 4-7 address issues of gender equality, professionalism, impartiality and conflicts of interest etc. Article 8 highlights the integrity of the Ministry of Defence and the Army while Article 10 addresses the issue of corruption. Accepting or asking for gifts and any other benefits of material nature are prohibited and criminalised, in accordance with the relevant national laws (Article 1) [1].

The Code of Ethics is publicly available and published on the Ministry of Defence website [1]. Together with other measures for building integrity, including integrity training, the Code is proactively distributed to military personnel [2].

According to an interview, breaches of the code are only occassionally investigated [1]. The Code is not so much designed to punish as to encourage a stronger sense of moral values and integrity amongst Ministry of Defence and Army employees [2]. More severe breaches of ethical behaviour are dealt with according to the Law on Service in the Army [3] and the Criminal code [4].

Guidance on the code of conduct is available to all military personnel, but is not part of induction training. The training is more linked to building integrity mainly for managing positions. It is done in the MOD Training Centre in Skopje.

The “Ethical Guidelines for the Public Service” include fundamental guidelines for all Norwegian state personnel [1]. The document covers bribery, gifts, hospitality, conflicts of interests and post-separations rules. Guidelines for the defence sector may be found in the “Ethical Guidelines for Contact with Business and Industry in the Defence Sector”. They apply to all military and civilian personnel within the defence sector [2]. This document covers bribery, gifts, hospitality and conflicts of interest in contact with business and industry, which is considered to be area at the greatest corruption risk. Both documents provide specific guidelines on how to handle incidents of corruption. Confidentiality during the transition to other organisations is mentioned on the list of the fundamental ethical rules for the defence sector available on the MoD’s website [3]. A separate document, “Core Values of Norway’s Defence Sector”, broadly outlines ethical values, including openness, broadmindedness, respect, responsibility and courage [4]. The document does not explicitly refer to anti-corruption guidelines, but provides an overarching structure intended to raise awareness across the entire sector. Moreover, the Armed Forces and the Norwegian Defence Materiel Agency have published their own statements on ethical conduct [5, 6].

All the documents mentioned in the previous indicator are published on the websites of the Ministry of Defence or its respective agencies [1]. Given how widely published all these documents are and the numerous public statements from the Armed Forces and the Norwegian Defence Materiel Agency on ethical conduct, it can reasonably be assumed these are effectively distributed to personnel [2,3].

The oversight mechanism includes administrative and legal steps. The application of the guidelines can be handled in an administrative manner – both the “Ethical Guidelines for the Public Service” and “Ethical guidelines for Contact with Business and Industry in the Defence Sector” detail career-related consequences of breaches [1, 2]. The code of conduct is regularly enforced [3]. If the relevant and applicable law applies to a breach, it is pursued as a criminal offence. However, in 2018 the Judge Advocate General for the Armed Forces found it necessary to issue a letter to the Military Policy emphasising a need to distinguish between criminal and administrative investigations [4]. The Judge Advocate General pointed out certain legal principles on how the Military Policy should intervene in order to avoid situations when administrative investigation conducted by the respective Internal Auditor Units (of the Ministry of Defence and of the Chief of Defence) would hinder, disturb or spoil criminal investigation of the same incident. Moreover, a leakage of an internal audit report in 2016 revealed that the Norwegian Armed Forces and the Ministry of Defence operated with slightly different definitions of misconduct. While the Ministry of Defence used a broad definition which also encompassed breaches of ethical guidelines and rules (in accordance with the Office of the Auditor General’s recommendation), the Armed Forces operated with a narrow legal definition derived from the Penal Code [5]. Note that there is one system for military and civilian personnel. The Norwegian Armed Forces and the Ministry of Defence employ both military and civilian personnel.

During the induction proces all civilian personnel have to take an e-course module called “Attitude, Ethics and Leadership”. Issues related to corruption and corruption risk are included in this training [1, 2].

The Civil Service Law (RD 120/2004), applies to civilian personnel according to the eGovernment portal (1), (2). Article 103 and 104: prohibits accepting gifts, conflict of interests, exploiting position while employed, and it requires an employee to declare all assets if requested (1), (3). The term bribery is not used or defined in the piece of legislation (4). Chapter 13 of the Civil Service Law sets out the procedure for administrating investigations; including suspension, impact on salary, questioning, and penalties (3). The procedures set out for administrative investigations are serious and detailed, spanning between Article 105 and 137 (3). There is a fairly comprehensive code of conduct including guidance on how to proceed in cases of misconduct; however, no explicit reference is made to bribery or post-separation activities, which makes it incomplete.

The Civil Service Law is accessible through the eGovernment website (1), (2). However, there are no details of how it is presented to civilian personnel on either the eGovernment website, within the legislation, or the Royal Armed Forces website (1), (3), (4). According to a senior officer within the Omani army, the code of conduct is usually presented on boards in the units for all personnel, but nobody pays attention to it (2).

The code of conduct is seen as a bureaucratic tool, rather than as a serious document. It lacks credibility and is not taken seriously by many personnel in the armed forces (both civilians and soldiers) (1), (2). No reports or media articles were found demonstrating the enforcement of the Civil Service Law against civilian personnel (3), (4), (5). There is no evidence on institutional websites that breaches of the law are addressed (6), (7).

No information was found regarding professional training concerning the code of conduct (1), (2).

There is a Code of Conduct for all civilian personnel, which covers the majority of aspects related to corruption and bribery, “activities that undermine reputation or the agency or in a form of conflicts of interest”. However, it does provide specific guidance on how to proceed in cases if they face corruption incidents (1).

The Code of Conduct is available online on almost all agencies and ministries websites. Some agencies print it out and distribute it to their employees (2). However, it may not be readily available to all civilian personnel, but the code of conduct is given to personal when they sign an employment contract (1).

There are many breaches by employees (1). Violations of the Code of Conduct are rarely investigated. Violating the Code of Conduct happens often because there is little oversight or repercussions to the violations. Most breaches of the Code of Conduct are minor violations (2), (3).

There is no evidence that training is provided to civilian personnel on the code of conduct.

There is a Code of Conduct (RA 6713) for all civilian personnel that addresses corruption issues [1]. However, in recent years, the definition of some of these issues (e.g. bribe and gifts) have been described as vague. While the Civil Service Commission authorised to carry out the provisions of RA 6713 said that law clearly prohibits government workers from accepting gifts [1], some officials (including the President and a member of the Presidential Anti-Corruption Commission) have said that it is acceptable to ignore the anti-graft law and, in the case of police officers, to accept gifts given out of gratitude or generosity [2, 3, 4].

Both the Code of Conduct (RA 6713) and its Implementing Rules are publicly available and published on most government websites [1, 2]. According to Section 4, Rule IV of the Rules Implementing RA 6713, “every head of department, office and agency shall establish information systems and networks that will affect the widest possible dissemination of the provisions of the code” [3].

There have been many breaches of the code of conduct by civilian personnel: between 2015 and May 2020 there were 1,381 cases of malversation and 1,725 cases of graft filed against public officials before the Sandiganbayan (SB) [1]. These cases make up more than half of the 5,153 corruption cases received by the special court during the same period. Not all of these civilian personnal are with the defence and security sector. Based in a 2018 data, statistics from the Sandiganbayan showed that the Philippine Coast Guard and Philippine National Police are two of the top government agencies with the most number of cases field [2]. According to data from the SB, there were 3,535 cases pending the court’s decision data as of 31 May 2020 [1]. The media has been vigilant in monitoring high-profile corruption cases [3]. While cases are investigated, the process is slow, and complaints remain pending for years before charges could be lodged [4].

In its implementing rules and guidelines, the Civil Service Commission requires every department to ensure that guidance on the code of conduct is available to all civilian personnel [1]. All new entrants to government service undergo the “Alay sa Bayan” (For the Country) Induction Programme, a three-day workshop focusing on ethics and the conduct of conduct [2, 3].

There are two relevant codes:
1. Decision No. 145 / MON of the Minister of National Defence of July 13, 2017, on the rules of conduct in relation with contractors, with amendment [1, 2] described in 46A.
2. Order on Compliance Guideline with Civil Service Principles and Ethics Principles of Civil Service, issued by the prime minister applies to civil service personnel, namely civilian personnel in the ministry, although not civilians in the armed forces [2].
The second code provides guidance on the 15 principles of civil service, including conflict of interest, gifts and hospitality.
The codes do not cover post-separation activities nor provide guidance on how to proceed in the face of bribery.

Both codes are available to the personnel and the public through websites. The personnel of units dealing with procurements and contractors are aware of the MoD code. Civil service personnel have to formally sign that they read the Order on Compliance Guidelines; however, in practice, many civil servants are not familiar with it. Guidance is provided with some training [1].
Since June 2019 also the code based on 145/MON decision has been implemented to the induction materials. Every new employee is given some materials on corruption, including information on decision 145/MON. [2].

Breaches of the MoD code of conduct are investigated; however, there is no information on the results or sanctions [1]. Due to its low-level legal status, breaches of the Civil Service Code may not directly lead to disciplinary action, as only breaches of the civil service principles listed in the Act on Civil Service may be addressed by disciplinary means (Article 113).

Personnel from units dealing with procurements and contractors are aware of the MoD code. Civil service personnel have to formally sign that they read the Order on Compliance Guidelines; however, in practice, many civil servants are not familiar with it. Guidance is provided along with some training [1].
Since June 2019 decision 145/MON has been implemented to the induction materials. Every new employee is given some materials on corruption, including information on decision 145/MON. [2]. However there are no evidences of induction training of it.

The Government has published a Code of Conduct that applies to all top-level management officers in public administration [1]. An Ethics Charter for Public Administration exists but does not mention bribery, gifts, hospitality or conflicts of interest [2]. In the Ministry of Defence (MoD), the Directorate-General of Defence Resources (DGDR) [3] and the Inspectorate-General of National Defence (IGND) [4] have unit-specific codes of conduct. The DGDR code mentions gifts, conflicts of interest and integrity in procurement, but no explicit mention of bribery or post-separation activities. The IGND code mentions bribery, gifts and conflicts of interest.

While there is evidence of unit-specific codes of conduct, namely the DGDR [1] and the IGND [2] within the MoD, there is no code of conduct that binds all civilian personnel. Therefore, this indicator is marked ‘Not Applicable’.

While there is evidence of unit-specific codes of conduct, namely the DGDR [1] and the IGND [2] within the MoD, there is no code of conduct that binds all civilian personnel. Therefore, this indicator is marked ‘Not Applicable’.

While there is evidence of unit-specific codes of conduct, namely the DGDR [1] and the IGND [2] within the MoD, there is no code of conduct that binds all civilian personnel. Therefore, this indicator is marked ‘Not Applicable’.

There is a code of conduct for civilian personnel in Qatar. [1] However, this code of conduct does not cover all aspects such as bribery, gifts and hospitality, conflicts of interest, and post-separation activities. The code of conduct is easily accessible online and covers a wide range of topics such as bribery and clash of interests and gifts but does not regulate post-separation activity. The document also cites the penal code and the civil Human Resources Law, specifically in relation to bribery and clash of interests. It is important to note here that, despite the availability of a code of conduct, the document is lacking in clarity and detail. [2,3]

There is a code of conduct for civilian personnel that is available and accessible to the public. [1] The code of conduct is available online and is easy to access. [3] Data also suggests that some Government agencies are working towards enforcing the code of conduct. The Audit Bureau has created a code of ethics pertaining to civilian personnel and is adopted by technical and administrative staff. [2] It is important to note that some Government institutions have their own code of conduct, such as the Ministry of Education and Qatar Petroleum.

Although there is a code of conduct, adherence to the code is not monitored by any external agency. [1,2] There is, therefore, no evidence to suggest that there have been violations of the code of conduct, and thus assessing its enforcement is not possible due to this lack of evidence. [3]

There is very limited training by local experts on issues related to the code of coduct . Corruption is mentioned within such trainings, but not treated as a primary topic. Guidance is available periodically, especially for senior civilian officers [1].

MoD Decree No. 555 defines the Code of Conduct for civilian personnel of the MoD [1]. The number of corruption-related provisions is close to zero. Article 11 states that civil personnel that are vested with organisational powers shall take measures to prevent and resolve conflicts of interest and fight corruption [1]. Article 12 obliges civil personnel that are vested with organisational powers to ensure that their employees avoid and prevent rent-seeking behaviour [1]. A special commission handles cases of conflicts of interest among MoD civil personnel [2].

The code of conduct is not easy to find on the MoD website. It is listed among dozens of MoD decrees [1]. No information is available about whether or not the Code of Conduct is distributed to civil personnel.

Section IV of the Code stipulates that any breach of the Code will be followed up with ‘moral condemnation and investigation at the Special Commission’s hearing’ [1]. The latter mostly focuses on conflicts of interest or failure to declare one’s family’s income in detail [2]. Comment: some cases are investigated [3,4], while some, including those involving high-profile senior personnel, are not investigated regardless of journalist reports [5].

There is no evidence of any relevant training and the special commission that is responsible for controlling the implementation of the Code of Conduct has not published any reports or specific plans about providing training [1]. Its annual reports only mention cases of potential conflicts of interest [2].

The website of the Saudi Ministry of Civil Service features the Code of Conduct for civilian personnel, which was approved by the Council of Ministers in August 2016 (1), (2). The Code of Conduct has a section outlining guidance for gifts, bribery and hospitality. It prohibits public sector employees from accepting: gifts or services offered to the employee directly or indirectly or any advantage that has a direct or indirect impact on his or her integrity; decoration or gift or award from any foreign government without obtaining official approval; or any special facilities or discounts on private purchases from suppliers who have formal transactions relating to his or her work. It also prohibits the use of any information obtained by virtue of the employee’s work to obtain a service or special treatment from any party (3).

The Code of Conduct does not, however, outline the sanctions that would be incurred by the employee should he or she violate the stipulations of it.

The aforementioned Code of Conduct is published on the website of the Ministry of Civil Service. However, in August 2018, Saudi Arabia’s primary anti-corruption body, Nazaha, published a survey stating that 69% of the country’s public sector employees did not have access to the Code of Conduct for public service within their government agencies. This survey was based on a random sample of approximately 4,700 employees across the country, with 63% of those surveyed stating that the government agency at which they were employed did not publish the relevant Code of Conduct on its website. In that month, the anti-corruption body also urged government agencies to train employees on the content of the Code of Conduct (1), (2). According to our sources, there is no training provided on anti-corruption measures and the use of code of conduct (3), (4).

Breaches of the Code of Conduct and related investigations are occasionally reported in the Saudi and regional press. According to our sources, a breach of the code of conduct can lead to stringent consequences if it catches public attention, but in most cases, it is ignored or superficially investigated (1), (2). A notable example in 2017 was the dismissal of Minister of State for Civil Service Khaled al-Arraj from his post in April 2017, on charges that he abused his position by appointing his son to the country’s Ministry of Municipal and Rural Affairs, despite his son lacking the relevant qualifications. In that same month, al-Araj reportedly faced 10 years in prison (3). However, no further information was released in the public domain relating to the current status or outcome, if any, of the investigation. This case represents, at least publicly, a rare example of civil servants in the country being investigated and apprehended over breaches of the Code of Conduct.

There is no training provided on anti-corruption measures and use of the code of conduct (1), (2).

The Code of Honor of the Serbian Armed Forces also covers civilians within the armed forces and the MoD. The part of the code that applies to civilians, vaguely mentions that position within the defence system, as well as official information obtained through service in the MoD or the SAF, should not be misused [1].

The Code of Honor is published in the Official Military Gazette, where all the MoD and SAF legal acts and bylaws are published. It can also be found on the SAF website [1].

There is not enough information to score this indicator. The Code of Honor does not have sanctions for its breaches, other than ethical responsibility for committed acts. In this regard, civilian personnel are subject to the Law on Civil Servants with regards to bribery, gifts, conflict of interest etc [1].

There is no evidence available on whether guidance on the code of conduct is included in induction training for all civilian personnel [1].

All public servants are expected to adhere to an established code of conduct (CoC) that expressly prohibits any conflict of interest between the officers’ public duties and their activities outside these official duties. Additionally, Ministry of Defence (MINDEF), Singapore Armed Forces (SAF) and Defence Science and Technology Agency (DSTA) personnel are also subject to internal regulations that specifically prohibit all types of misconduct outlined in the rubric [1]. For example, public officers must not receive any donation, gift or other benefits, from the public and suppliers, or must immediately declare it to a superior when required to accept one [2]. Personnel are not allowed to exploit official information or an official position to further their own private interest or that of others. Procurement officials vested with the power to be an approving authority must declare any potential conflict of interest and not participate in a procurement process if there is one [3, 4, 5].

The civilian CoC is available to both serving personnel and the public, along with the associated consequences [1, 2. Guidance and instruction on appropriate conduct are embedded within civilian-run training courses and processes [3].

There have been no specific examples of investigation and persecution of civilian defence personnel in the public domain, but a robust framework that is already in place [1] suggests that such cases (if any) will be appropriately handled, with prominent examples widely reported [2].

The civilian CoC forms an important aspect of the day-to-day operations of non-uniformed personnel [1, 2]. Guidance on the code of conduct for civilian personnel is included in induction training [3].

There is a Code of Conduct for all civilian personnel in the Department of Defence:

“The DFSC Code of Conduct stipulates, with respect to bribery, gifts etc: 4.5 (…) does not engage in any transaction or action that is in conflict with or infringes on the execution of his or her official duties; 4.6 (…) will rescues himself or herself from any official action or decision-making process which may result in improper personal gain, and this should be properly declared by the employee; 4.8 (…) is honest and accountable in dealing with public funds and uses the Public Service’s property and other resources effectively, efficiently , and only for authorized official purposes; 4.9 (…) promotes sound, efficient, effective, transparent and accountable administration; 4.10 (…) in the course of his or her official duties, shall report to the appropriate authorities, fraud, corruption, nepotism, maladministration and any other act which constitutes an offence, or which is prejudicial to the public interest; 5.3 (…) Does not use his or her official position to obtain private gifts or benefits for himself or herself during the performance of his or her official duties nor does he or she accept any gifts or benefits when offered as these may be construed as bribes; 5.4 (…) Does not use or disclose any official information for personal gain or the gain of others; and 5.5 (…) Does not, without approval, undertake remunerative work outside his or her official duties or use office equipment for such work” [1].

The Department of Defence states that it is committed to a code of conduct, but only lists a set of vague values under the ‘Code of Conduct’ section of the 2017/18 Annual Report:

“• Accountability
• Consultation rooted in effective and efficient partnership and collaboration
• Discipline
• Ethics
• Excellence
• Openness and transparency
• People
• Service standards
• Teamwork” [2].

The Defence Force Service Commission (DFSC) Code of Conduct is published in the DFSC annual report. It is not known to what extent specific guidance is provided to personnel through training. Beyond the DFSC Code, no additional or expanded Department of Defence code of conduct applicable to civilian personnel is available.

This indicator is scored ‘Not Enough Information’, because it is unclear to what extent the code(s) of conduct are enforced. Breaches of the code of conduct, to the extent of legal infractions, are dealt with through relevant legal structures. The results of investigations or hearings in the enforcement of pure ‘codes of conduct’ for civilian personnel are seemingly not published or made readily available.

The DFSC Code of Conduct is included in induction training for all personnel, civilian and defence alike.

Civilian personnel are also subject to the Code of Conduct for personnel at the Ministry of National Defence (MND), according to Article 1 of the Code (see Q46). The Code prohibits civilian personnel from receiving bribes, as well as accepting free meals which exceed 30,000 Korean won. Any gift worth over 50,000 Korean won is not acceptable. Improper solicitation of other officers for a personal gain or illicit advantage is highly illegal. Sharing family events, such as weddings or funerals, with people related to work is prohibited. This Code also includes post-separation activities which restrict retired personnel from accessing military and defence institutions for the purpose of improper solicitations for defence bidding. Those who violate the Code are punished according to the MND’s punishment guideline, which includes dismissal as the maximum possible sanction for bribery. [1]

Guidance on the cCde of Conduct is included in induction training for all civilian personnel. [1]

Breaches of the Code of Conduct are regularly investigated based on the Code of Conduct for Personnel at the Ministry of National Defence. [1] However, cases are not always pursued when wrongdoing of officers is detected. A media report reveals that civilian personnel involved in public opinion manipulation around the 2012 South Korean presidential election were promoted rather than dismissed. The article points out that an officer who played a significant role in the election scandal was working for the military as a high-ranking officer as of 2018. [2] On the other hand, in the election scandal case, there were many civilian personnel who acted against their intentions by oppression and direction of their superiors. Consequently, only core offenders faced criminal punishment or discipline. Recently, there was conviction against the former Minister of Defense. [3]

The MD and relevant institutions are expected to implement a training session, which addresses the Code in detail, at least once a year for two hours; the training can be conducted online or in person. New civilian personnel should take the training session within three months of the job start date. [1]

There is no code of conduct for civil servants at this moment, [1] although there is language in the Civil Service Act 2011, that called for its establishment almost ten years ago. [2]

This indicator is marked ‘Not Applicable’, as there is no code of conduct for civil servants at this moment, although there is language in the Civil Service Act 2011, that called for its establishment almost ten years ago. [1] There is also reference to a yet-to-be written code in the Procurement Act, which was passed in April 2019. As stated in the Act, the Procuring Authority (also yet to be established) will author a code of conduct for all government departments regarding contracts, acquisition and disposal of assets. [2]

This indicator is marked ‘Not Applicable’, as there is no code of conduct for civil servants at this moment, [1] although there is language in the Civil Service Act 2011, that called for its establishment almost ten years ago. [2]

This indicator is marked ‘Not Applicable’, as there is no code of conduct for civil servants at this moment, [1] although there is language in the Civil Service Act 2011, that called for its establishment almost ten years ago. [2]

Article 6 of the Royal Decree 5/2015 (on the Law of the Basic Statute of the Public Official) states that “any gift, favor or service in advantageous conditions that goes beyond the usual, social and courtesy uses will be rejected, without prejudice to the provisions of the Penal Code”. Art 53.7 of the same Royal Decree states that public employees “will not accept any treatment of favor or situation that implies privilege or unjustified advantage, by individuals or private entities”.

Instruction 23/2020 of the Secretary of Defence, on the Ethical Code and Code of Conduct of Personnel Related to Purchasing, which affects both military and civilian staff in the purchasing areas of the Ministry of Defence (and only on purchasing), states in Section 2.1.f that personnel “will abstain from accepting gifts and will reject any benefit in personal interest”. This instruction does comprehensively cover aspects related to bribery, gifts and any benefit also to conflicts of interest, and provides specific guidance on how to proceed in the communication of events “that are not constitutive of fault and crime” [2].

The Law of the Basic Statute of the Public Official (Royal Decree 5/2015) is widely known and distributed, and penal consequences derive [1]. Royal Decree 5/2015 is public and widely distributed. Instruction 23/2020 (which approves the code of conduct regarding purchasing) is publicly available and clearly indicates the obligation of its dissemination within the Ministry of Defence (e.g. Section 5.1.a and 5.3.a) [2].

The Law of the Basic Statute of the Public Official (Royal Decree 5/2015) is widely known and distributed. Instruction 23/2020 provides specific guidance on how to proceed in case of an event, but only those “that are not constitutive of fault and crime” [1]. This instruction only affects purchasing. The Code of Conduct was approved in June 2020; there is still no evidence of impact. There is evidence of judicial cases of bribery (“cohecho”); they can be found online [2, 3].

Instruction 23/2020 states in Section 5.3.a that guidance on conduct and documents will be elaborated on and widely distributed [1]. The Code of Conduct was approved in June 2020. So far, there is no evidence of training and/or dissemination of materials. This instruction only affects purchasing.

No evidence could be found of a Code of Conduct that civilian personnel must agree to follow. However, the Sudanese Criminal Act of 1991 [1] and Penal Code of 2003 [2] provide evidence that active and passive bribery, extortion, the taking of gifts in certain contexts, embezzlement and other corruption offences have been criminalised.

No evidence could be found of a Code of Conduct that civilian personnel must agree to follow. This indicator is therefore marked Not Applicable [1,2].

No evidence could be found of a Code of Conduct that civilian personnel must agree to follow. This indicator is therefore marked Not Applicable [1,2].

No evidence could be found of a Code of Conduct that civilian personnel must agree to follow. This indicator is therefore marked Not Applicable [1,2].

The Swedish Defence Materiel Administration Agency (FMV) has published a brief code of conduct in the form of a statement on ‘ethics and social responsibility’ which indicates that their ‘internal guidlines’ address the risks of ‘conflict of interests, sideline activities, bribes, and corruption’ [1] as well as ‘shareholding, travel, and representation’ [2]. It does not define these issues further, however, nor provide specfic guidance on how to proceed in the face of such corruption-related events. FMV, and the Swedish defence sector at large, has also received major criticism from NGO’s, the media, and the Swedish Anti-Corruption Institute for entirely overlooking the issue of post-separation activities. No rules such as a formal ‘period of restraint’ for public officials are in place, and several cases have been noted of high-level civilian personnel moving to the private sector and major arms companies (see Q37A) [3] [4]. Civilian personnel within the SAF, however, receive the same comprehensive anti-corruption training as military staff (see Q46A-D).

The FMV code of conduct is effectively distributed to all civilian personnel during their training, but a full-length version of the ‘internal regulations’ where the code is explained in more detail is not made readily available to the public. It should, however, be possible to request it according to the Public Access Law [1]. The Swedish Armed Forcesn (SAF) code of conduct is made available to the public on the SAF website [2]. Along with other internal anti-corruption and anti-bribery policies, it is also distributed to all military and civil personnel during introductory training and promotions, and included in staff training courses and performance talks [3].

The State Disciplinary Board (SA) handles instances of bribery or corruption involving civil servants in senior positions such as directors, judges, prosecutors, and professors, and the SA annual reports state clearly how many cases have been investigated in practice during the year [1]. Only other government agencies can report to SA, while individuals have to report potential instances of bribery or corruption to the Chancellor of Justice (JK) who publish both ongoing and previous investigations online [2]. Where employees have committed criminal acts that fall under the Swedish Penal Code [3], the crime must be reported to the Police.

Guidance on the code of conduct as well as related internal policies for anti-corruption and anti-bribery is included in induction training for all civilian personnel [1].

The Code of Conduct Federal Administration (COC), that also applies to the military, summarizes the rules for government employees. It discusses gifts and invitations as well as illegal behaviour or transgression of rules. It refers to and summarizes the Bundespersonalgesetz – Federal Personnel Act (BPG) and the Bundespersonalverordnung (BPV) with regards to bribery, gifts and conflict of interests. The documents provide guidance on what are acceptable invitations and gifts. The COC reminds employees of their obligation to report transgressions of those rules, and it also highlights options for whistleblowing [1]. A 2018 booklet on compliance for employees of the Federal Department of Defence, Civil Protection and Sport (DDPS) uses this COC for federal personnel as the basis for their rules. The document refers to other guidances by the Federal Personnel Office, for example on corruption and whistleblowing. It reaffirms rules on avoiding conflict of interests, bribery, nepotism and corruption [2].

The COC, as well as the guidance on compliance, are available online [1, 2]. The COC is distributed to all federal employees [3]. The guidance on compliance is also considered to be binding [4].

There are a few public known breaches that were investigated at the highest level. For example, there were reports on a case that occurred in 2019. Newspapers uncovered that a high ranking officer who was a pilot was allegedly hired by Saab to lobby for the Gripen fighter jet that Switzerland was considering buying. The officer was released of his duties as spokesperson of the “Patrouille Suisse” but remained at the DDPS in his role as Head of Special Staff Communication (Chef Fachstab Kommunikation) [1]. Other recent examples are an expenses scandal, where the suspects were cleared, but the rules subsequently changed [2] or on the sudden cancellation of a major armament project in its evaluation phase [3]. There are no known instances where cases are not pursued despite evidence of criminal behaviour.

Although this research did not find direct confirmation of inclusion of the general COC into the induction training specifically, it seems very likely that it is included as it represents a legally binding document for all federal personnel and is issued by the Federal Council [1]. It is easily available and referenced on government plenty of government websites including, for example, Armasuisse’s [2]. A series of binding documents for employees like the Group “Defence” brochure on compliance [3], the directive on corruption prevention for employees of the DDPS [4] and the same directive for Armasuisse [5] are all explicitly based on the code of conduct. The Group “Defence” has a directive specifically on compliance and offers information on their intranet [3] as well as on the internet. [6]. The anti-corruption directives of the DDPS [7] and Armasuisse [8] both mention continued training and obligation for awareness-raising on the issue. Armasuisse also states, on its site dedicated to the fight against corruption, that its employees are “regularly informed on their obligations in terms of their conduct” [9].

The Code of Conduct for Taiwan’s public servants concerning issues of ethics and integrityis well illustrated and regulated in the Directive of Ethics and Integrity Guidelines for Public Servants which explains bribery, gifts and hospitality, conflicts of interest, and post-separation activities. It provides specific guidance on how to proceed in the face of these events [1].

The Directive of Ethics and Integrity Guidelines for Public Servants is made available in the public domain and thus can be accessed by the public, all public servants, and Taiwan’s armed forces [1].

Breaches of the Code of Conduct are regularly investigated and cases are pursued where there is evidence of criminal behavior. Monthly statistics released by the Agency Against Corruption of the Ministry of Justice disclose breaches of the Code of Conduct, which are under executive investigation internally by the Ministry of National Defence, and criminal behaviours, which are under independent juridical allegation by the Ministry of Justice, of both military and civilian personnel of the MND [1]. Monthly statistics released by the Agency Against Corruption of the Ministry of Justice disclose breaches of the code of conduct only up to the first quarter of 2019.

Guidance on the Code of Conduct is included in induction training for MND’s civilian personnel. Regulations, codes of conduct, and training programmes derived from both the “Directive of Ethics and Integrity Guidelines for Military Personnel” and the “Directions of Ethics and Integrity Guidelines for Military Personnel” are also applicable to civilian personnel working in the Ministry of National Defence [1, 2, 3].

The Code of Ethics for public servants does not address post separation activities. For conflicts of interest, the code advises that superiors are to be informed, who will decide on the correct course of action. While it prohibits receiving bribes, there is no evidence of guidance on what to do if facing this situation. [1]

The Code of ethics and conduct of Public Servants is available publicly and well distributed to civillians. It is also accessible to the general public through the media. [1] [2]

Breaches of the codes of conducts are regularly investigated and many public servants (defence personnel are also civil servants in Tanzania) have been taken to court for allegations of breaches of the ethics and codes of conducts of public service. Recently, the government has been very strictly on the issues of intergrity of public servants and the emphasis on adhering to the codes of conducts is always put to the Public Servants including millitary personnel. This has made Public servants responsible and accountable for their day to day activities and responsibilities. [1] [2] [3]

All public service employees (including those in the defence sector) are subject to an induction course in which they are given guidance on the codes of conduct. [1] There are guidelines, but they are not implemented in many circumstances except for the sensitive positions such as medical care and security. However, there is an Integrity Pledge form for Civil Servants which must be filled out by the Public Servants soon after being confirmed in a certain position or soon after acquiring new position. [3] In these forms, the codes of conducts concerning adhering to the ethics and intergrity pledges are included as part of an oath, and the forms are supposed to be signed by the Public servants. But because these codes are available in various media, the public servants are able to freely read them on their own. However, it is not clear if this is included in training.

The Civil Servants Act 2008, Section 85, defines and prohibits bribery, gifts and hospitality and conflicts of interest [1]. In addition, the Civil Service Code of Ethics, implemented by the Office of the Civil Service Commission, was issued in 2009 as a code of conduct for all civilian personnel and a framework for the anti-corruption policy of each ministry. The Code of Conduct defines gifts and conflicts of interest, explains how to avoid them and outlines possible penalties for offering or receiving them. However, there is no clear guidance on how to proceed in the face of these events [2]. The most recent quantitative follow-up on the effectiveness of the Code of Conduct was in 2017; the report of the follow-up results is available online [3]. Nonetheless, post-separation activities are not mentioned in the Code of Conduct.

Fundamentally, laws and national strategies regarding anti-corruption policy are communicated to all civilian personnel in accordance with the short-term and long-term masterplans and strategies of each governmental agency in order to reduce misunderstanding and increase awareness of the Code of Conduct [1]. The Code of Conduct is available to the public and distributed to all civilian personnel [2,3].

Even though many laws and national strategies concerning corruption issues have been implemented for a long time, breaches of the Code of Conduct are not regularly investigated due to widespread corruption at a local level, a lack of law enforcement and difficulties in evidence-seeking and prosecution against civilian personnel [1]. According to the research conducted by Srisombat Chokprajakchat and Nittaya Sumretphol, knowledge of the 2009 Code of Professional Ethics for Civil Servants B.E. 2552 is disseminated among civil servants, staff and employees. Civil servants are encouraged to comply with the code. However, breaches of the code still occur among governmental agencies since many agencies are not investigated for their implementation of the code, meaning that their officials ignore their commitment to the Code of Conduct [2]. As such, it can be concluded that breaches of the code of conduct by civilian personnel are not regularly investigated in practice.

According to the Civil Servants Act 2008, Section 79, supervising officials are only required to order a civil servant to undertake the Code of Conduct training when the civil servant fails to comply with the ethics of officials [1]. Therefore, the research conducted by Srisombat Chokprajakchat and Nittaya Sumretphol in 2017 recommends that training on the Code of Conduct should be compulsory and held at least once or twice every year [2]. Apparently, the Bureau of Disciplinary Standard, under the Office of the Civil Service Commission, is responsible for providing consultation, support, follow-up and evaluation of discipline building and promotion of merit, ethics and the Code of Conduct to officials through training [3].

The Code of Conduct for Public Officials was approved by the decree dated 3 October 2014, which is a code setting the behavior of all Public Officials in all Ministries. The code includes, but is not limited to, bribery, gifts and hospitality, conflicts of interest, parallel and political activities (1). However this code covers all areas of public services and therefore lacks clarity and specificty for the defence sector.

According to our sources, the Code of Conduct is usually readily available for all employees within their offices and can be accessed online. In many ministries, the Code of Conduct is distributed annually as practice(1,2).

According to our sources, breaches of the Code of Conduct are usually investigated but superficially, unless the violations are serious and attract the attention of the public (1,2). No evidence of enforcement of the Code of Conduct for public officials could be foud (3).

According to our sources, periodic ad hoc guidance may be provided to military personnel by commanding officers. (1)

Interviewees 3 and 4 both suggested that there is no Code of Conduct issued for civilian personnel working in the defence sector [1]. However, he noted that all military and civilian personnel within in the sector are obliged to adhere to the Public Employees and Civil Servants Code of Conduct, which was issued as a regulation in 2005 [1,3]. The code of conduct provides specific guidance on how to proceed in the face of ethics issues. The Civil Servants Code of Conduct calls for the formation of an Ethics Commission, consisting of three members and responsible for answering all complaints of ethical abuse, bribery and corruption [3]. However, Interviewee 6 suggested that he did not see the existence of an Ethics Comission in any military unit or defence/security-related government body during his service [4].

As emphasised above, there is no Code of Conduct issued specifially for civilian personnel working in the defence/security sector. All civilian personnel are obliged to adhere to the Civil Servants Code of Conduct (2005) [1]. Interviewee 6 suggested that, during the six-month orientation phase just after entry, there are some courses on anti-bribery, anti-corruption and integrity-related issues offered to the newly appointed civilian personnel as part of the training in the Military Code of Conduct, but this is not a well-established or routine regulation [2].

Given the lack of available evidence on the enforcement of the code, this indicator is marked ‘Not Enough Information’. There is no evidence of an Ethics Commission being established to handle allegations of ethical abuse, bribery and corruption or to enforce civil service code of conduct stipulations, so it is unlikely this data is collected.

As there is no comprehensive Code of Conduct that specifically applies to all military personnel and civil servants working in the defence/security sector, there is no all-encompassing and comprehensive training on this issue. Yet, Interviewee 6 suggested that the personnel in charge are provided ad hoc guidance by either their superiors or predecessors. [1]

All civil servants are governed by the Code of Conduct and Ethics for the Uganda Public Service. The Public Service as the implementing arm of Government policies and programmes is charged with the responsibility of providing timely, high quality and cost effective services to the nation. To achieve this, it must have public officers who are loyal, committed, results-oriented, customer-centred and observe a high standard of conduct in both official and private life. The existence of a Code of Conduct and Ethics for public officers to enhance performance and reflect a good image of the Public Service and promote good governance is of paramount importance[1]. In addition to the above, Section 109 (a)of the UPDF Act (2005) [2] states that a civilian employee shall perform the duties of his or her appointment with all reasoanble skill, care and diligence in in accordance with any recognised standards applicable to his or her profession and appointment and the duties of that profession and appointment. Furthermore subsection (f) requires employees to” not engage in any business or activity likely to interfere or conflict with the performance of his or her duties”.

The Code of Conduct and Ethics for Uganda Public Service[1] is distributed to all the civil servants upon their first appointment and is available to the public at the ministry of public service and public libraries. It is also available online.

There is not enough information to score this indicator due to lack of access relating to evidence on enforcement relating to civilian employees at the Ministry of Defence and Veterans Affairs. It is worth pointing out that section 6.0 of the Code of Conduct [1] provides the different sanctions and penalties should a public servant breach the code of conduct. It further states that unethical conduct by public officers shall not be accepted in the Public Service. Sanctions for any breach of this Code shall be those prescribed by the Service Commissions Regulations, the Uganda Government Standing Orders and Administrative Instructions issued from time to time. Depending on the gravity of the offence or misconduct, the following penalties shall apply: i) Warning or reprimand; ii) Suspension of increment; iii) Withholding or deferment of increment; iv) Stoppage of increment; v) Surcharge or refund.
vi) Making good of the loss or damage of public property/assets; vii) Interdiction from duty with half pay; viii) Reduction in rank; ix) Removal from the Public Service in public interest; and x) Dismissal

There is not enough information to score this indicator, as it could not be established if guidance on the code of conduct is included in induction training for all civilian personnel. It is worth noting that 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, the Induction Manual and shall be in accordance with Section J of these Standing Orders[1].

Although the Law On Corruption Prevention provides rules of ethical behaviour Stepan Poltorak, the Minister of Defence, approved the Code of Conduct for AFU and MoD military and civil personnel in 2017 [1]. The content of the code is clear, and it addresses issues of bribery, gifts, conflict of interest, etc. [2, 3]. The code provides guidelines on how to act [2]. Additionally, there is also a comprehensive briefing note drafted by the NAPC on conflicts of interest which applies to the MoD as well. It is published on the website of the MoD [4]. Lastly, there is also a Code of Dignity and Honor of the Officer of the Armed Forces of Ukraine, which plays a supportive role to the Code of Conduct [5].

The Code of Conduct is available to the public on the MoD’s website [1]. The minister of defence instructed the heads of the structural divisions of the MoD and the AFU to arrange training on the provisions of the code for officers and sergeants of the AFU, civil servants and other individuals [2]. The MoD report on anti-corruption measures for 2017 provides evidence that the MoD started the implementation of the code in regards to the activities for structural units of the MoD, the General Staff of the AFU, and other MoD entities [3]. Additionally, there is a methodological manual “Commentary on the Code of Integrity and Professional Ethics in the MoD” as well as a briefing note for personnel “Rules for the Integrity and Prevention of Corruption” [4] which were presented to the forces and made available to the public [3]. Currently, the MoD makes efforts to apply the provisions of the code in the activities of the MoD and AFU units, institutions, state-owned enterprises, etc. [3]. However, an active AFU serviceman who participated in ATO could not confirm in April 2018 any training on the code or the distribution of Code of Conduct leaflets [5]. All new MoD orders are always distributed, by default, among the MoD and General Staff departments as well as the order approving the Code of Conduct, but one of the General Staff’s active serviceman could not confirm any training on its provisions [6].

Although the MoD Code of Conduct was developed in cooperation with NGOs, it is mainly based on the provisions of the existing Ukrainian legislation, particularly, the Law on Corruption Prevention. As a result, any breach of the Code of Conduct leads to a breach of the Criminal Code of Ukraine and the Code of Ukraine on Administrative Offences. This is also stipulated in the code itself [1]. There is evidence of corruption among MoD and AFU personnel [2, 3] and corrupt individuals being sentenced [4, 5, 6]. However, there is little evidence [8] for high-level corruption or undue behaviour cases being investigated and sanctioned; one example is the practice of illegal trade with the occupied territories of Eastern Ukraine [7].

The Code of Conduct is available to the public on the MoD’s website [1]. The minister of defence instructed the heads of the structural divisions of the MoD and the AFU to arrange training on the provisions of the code for officers and sergeants of the AFU, civil servants and other individuals [2]. The MoD report on anti-corruption measures for 2017 provides evidence that the MoD started the implementation of the code in regards to the activities for structural units of the MoD, the General Staff of the AFU, and other MoD entities [3]. Additionally, there is a methodological manual “Commentary on the Code of Integrity and Professional Ethics in the MoD” as well as a briefing note for personnel “Rules for the Integrity and Prevention of Corruption” [4] which were presented to the forces and made available to the public [3]. Currently, the MoD makes efforts to apply the provisions of the code in the activities of the MoD and AFU units, institutions, state-owned enterprises, etc. [3]. However, an active AFU serviceman who participated in ATO could not confirm in April 2018 any training on the code or the distribution of Code of Conduct leaflets [5]. All new MoD orders are always distributed, by default, among the MoD and General Staff departments as well as the order approving the Code of Conduct, but one of the General Staff’s active serviceman could not confirm any training on its provisions [6].

There is a clear and well-defined code of ethics and professional conduct available for all public and private personnel working under the Federal Authority of Human Resources in the UAE. The code of conduct includes explains bribery, gifts and hospitality, conflicts of interest, and post-separation activities. However, it lacks the procedual guidance on application or enforcement (1).

The code of ethics and professional conduct is available for all public and private personnel online, and also employees are provided with a signed copy when they first get a job (1).

There are rare cases when investigations occur as a result of a breach of the Code of Conduct. This usually happens with foreign employees who commit financial crimes and other crimes within the country (1).

There is no guidance provided during ad-hoc training or in the induction period. There is only a paper referencing the code of conduct that employees have to sign at the beginning of the employment period, as part of the employment contract. (1).

Civilian Personnel are subject to the Civil Service Code [1], which has statutory underpinning by virtue of the Constitutional Reform and Governance Act 2010 [2]. The code covers seven principles, two of which are relevant to corruption: honesty and integrity. The Civil Service Management Code [3] makes clear that the Departments and agencies should incorporate in the conditions of service of their staff the Civil Service Code. The MoD does this through Vol 7 of the Personnel Manual [4] which comprehensively explains bribery, gifts and hospitality, conflicts of interest, and post-separation activities. It provides specific guidance on how to proceed in the face of these events. In addition, JSP 462 provides guidance on bribery [5]. The MoD Corporate Standards policy explains bribery, gifts and hospitality, conflicts of interest, and post-separation activities. It provides specific guidance on how to proceed in the face of these events [6].

The Civil Service Code, the Civil Service Management Code as well as the Personnel Manual are publicly available [1][2][3]. These codes are also available on DefNet, Defence’s intranet which is available to all civilian personnel. MoD induction processes require all new entrants to work through an induction pack, which covers all codes of conduct and conflict of interest policies [4].

There is little publicly available information on the enforcement of the Civil Service Code of conduct within defence institutions. The Civil Service Commission hears complaints under the dode from civil servants, and works with departments to help them with their promotion of the code.

The Commission keeps records of Civil Service Code complaints, although these records are not extensive as they only cover cases where the commission has been asked to intervene. There were 10 complaints in 2019-20 from MoD staff about possible code breaches, 10 in 2018-19, and 11 in 2017-18 [1, 2, 3]. However, the vast majority of these cases were outside the remit of the code and were simply referred back to the department without investigation, despite some touching on issues surrounding disciplinary procedures, conflicts of interest, whistleblowing and fraud.

Guidance on the Civil Service Code is publicly available on various government websites [1, 2]. In addition, the MoD’s Fraud, Bribery and Corruption training is mandated as an annual training requirement for all civilian personnel and military that line manage civilians. The training draws attention to the code and is housed on Defence Learning Environemt, an internal training platform where managers can track whether personnel have completed courses, fulfilled requirements and achieved the necessary pass marks to pass [3].

The Office of Government Ethics oversees the ethics programme for the executive branch, with a specific focus on financial conflicts of interest [1]. All employees of the executive branch, with the exception of enlisted members of the uniformed services (i.e. military personnel), are subject to the ‘Standards of Ethical Conduct for Employees of the Executive Branch’ [2]. The Standards provide guidance on ‘gifts from outside sources’; ‘gifts between employees’; ‘conflicts of financial interests’; ‘impartiality in performing official duties’; ‘seeking other employment’; ‘misuse of position’; ‘outside activities’. For each issue, the general prohibitions are outlined, definitions and examples are provided and guidance on how to proceed is outlined. The guidance is fairly detailed, with the Standards being a 97-page document.

Bribery is only covered briefly under the solicitation or acceptance of gifts (see § 2635.202), and personnel are directed to the related federal statute (18 U.S.C. 201(b)) under which bribery is prohibited. Hospitality is included in the definition of ‘gift’, which extends to any gratuity, favour, forebearance, discount, entertainment or item that has monetary value (see § 2635.203, part b). Post-separation activities are only covered briefly in the ‘seeking other employment’ subpart, and personnel are directed to the relevant statute (18 U.S.C. 207) [2].

For DoD employees, the Joint Ethics Regulation provides one single source of standards of ethical conduct and ethics guidance for DoD personnel, which includes both military and civilian personnel [3]. It includes the abovementioned ‘Standards of Ethical Conduct for Employees of the Executive Branch’, as well as the ‘Supplemental Standards of Ethical Conduct for Employees of the Department of Defense’ and further guidance. The supplemental provides additional limitations on gifts between DoD employees, additional restrictions on outside employment and business activity, amongst other guidance [4]. Bribery is covered extensively in this regulation, with reference to 18 U.S.C. 201(b).

The Standards of Ethical Conduct is publicly available [1]. Each new employee must receive, in addition to their training as outlined in 47D, the summary of the Standards of Conduct, relevant supplemental agency regulations, instructions for contacting the agency’s ethics office and other relevant materials [2,3].

There is not enough information to score this indicator. If the Director of OGE becomes concerned about violations of noncriminal government ethics law or regulations, they may notify the employee’s agency for investigation by the agency or relevant Inspector General. With regard to criminal violations, the Director of OGE should notify the Inspector General or Department of Justice [1]. With regard to data on enforcement, the DoD’s Encyclopedia of Ethical Failure outlines a selection of ethical violations and the sanctions applied. As a snapshot, it illustrates the variety of cases of violations and the various sanctions applied. It does not, however, provide an insight into the number of ethical violations recorded annually or specific details on the enforcement of sanctions [2]. The researcher has submitted an FOIA request to access further information on breaches of the Standards of Conduct, however, no information has been provided as of March 2021.

Each new employee of the executive branch who is subject to the Standards of Conduct must complete initial ethics training within 3 months of appointment. The training must cover financial conflicts of interest; impartiality; misuse of position; and gifts [1]. Each agency must appoint a ‘Designated Agency Ethics Official’ (DAEO), who is responsible for the agency’s ethics programme and for coordinating the training. Every agency must also carry out a government ethics programme. Any personnel who is required to file an annual public financial disclosure or confidential financial disclosure report is required to complete additional annual ethics training. The DoD publishes an additional guide to the Standards of Conduct for their personnel [2].

An Ethics Code for public servants sets out the principles govering the actions of civillian personnel and establishing duties and prohibitions, including the duty to refuse bribes and prohibitions that seek to avoid conflicts of interest. However, this code applies generally to all state civil servants and does not include specific guidelines for civilian personnel working in the defence sector.

According to legislation set out by the Directorate of Civilian Personnel of the Ministry of the People’s Power for Defence (MPPD), it is the Ethics Code for public servants that currently regulates the conduct of these personnel [1]. This code includes the prohibition of receiving or soliciting payments, perks, or benefits in exchange for services to be provided, as well as a prohibition against advising, intervening in, or sponsoring processes in which there is evidence that persons involved are related to or share interests with the public servant [2]. Although it sets forth punishable behaviours, the Code does not elaborate on any procedures or sanctions to follow in the event that a servant commits these actions. It also does not include measures to be upheld after separation from service.

According to the Organic Law of Citizen Power, the Republican Moral Council is responsible for punishing officials who engage in the conduct described above, following the penalties imposed by the Penal Code [3]. In cases of bribery of public officials, the Penal Code establishes prison penalties, but in cases of conflicts of interest the regulations are unclear [4]. Current laws do not explicitly include conflicts of interest as punishable conduct, despite addressing conduct that seeks to prevent officials from participating in processes where they may have a vested interest [5].

There is no information regarding whether the Ethics Code is effectively distributed to civilian personnel. It is, however, extremely easy to find on government websites. It therefore complies with two of the three conditions of this indicator: the code exists, and is available to the public [1,2].

Despite existing evidence, reports from different civil society organisations and the press, and even recognition on the part of some government entities of the involvement of civil servants in corruption, very few are investigated and punished [1, 2].

In the defence sector, the few cases of corruption that have been sanctioned or recognised by the government show evidence of the participation of civil servants as facilitators in procedures or in actions, together with military officials, where public goods have been used for individual benefit [3]. However, the Office of the Comptroller General of the Republic (CGR) and the justice system in general is ineffective in punishing these officials. Even officials who have been charged with participating in acts of corruption are not sanctioned or investigated by the Venezuelan state, but have been sanctioned by other countries for their involvement in transnational illicit activities [4].

The MPPD lists a series of documents with guidelines for the training process for civilian personnel; although the Ethics Code is included among these documents, no evidence was found of specific training on this code [1].

The conduct of civilian personnel is guided by the general constitutional and statutory provisions guiding the conduct of civil servants. This would be Section 196 of the Constitution, which outlines the principles of public administration and leadership and Section 200, which outlines the conduct of members of Civil Service [1]. Civilian personnel’s conduct is also guided by the Public Service Act, and any other code of conduct put in place by the Civil Service Commission. [2] The Code of Conduct is comprehensive; it covers acts of bribery and corruption and spells out the sanctions [2].

The Code of Conduct developed by the Civil Service Commission is distributed to civilian personnel in the Ministry of Defence at the time of employment or during training by the Civil Service Commission, but it is not readily available to the public [1, 2].

Breaches of the Code of Conduct are investigated regularly, and both the investigation and disciplinary proceedings are confidential [1]. If there is evidence of criminal behaviour, the cases are reported to the police, and in some cases to the Anti-Corruption Commission [2]. Cases are also reported to the Civil Service Commission, and it can carry out an investigation or institute further disciplinary processes [3].

Guidance on the Code of Conduct is included in induction and refresher training for all civilian personnel in the Ministry of Defence that is conducted by the Civil Service Commission [1, 2].