Personnel Risk:

High

Score:

44/100

Leadership Behaviour

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Q34 17/100

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

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Chiefs/Ministers: Internal communications Score: 25 / 100
The Ministry adopted the Integrity Plan and reports on its implementation, [1][2] in line with legal obligations. [3] However, the Defence Minister, Chief of…
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Chiefs/Ministers: Public commitment Score: 25 / 100
Almost no public commitment by the Defence Minister, Chief of Defence, or Single Service Chiefs or the Ministry as an institution to fight against…
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Unit commanders and leaders Score: 0 / 100
Aside from the Integrity Plan and the reports on its implementation, [1][2] which the Ministry of Defence adopted like all other public institutions in…
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Q35 63/100

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

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Sanctions Score: 100 / 100
The Criminal Code of Montenegro criminalises offering, giving, receiving, or soliciting any item of value to influence the actions of an official or other…
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Enforcement Score: 25 / 100
Concrete results are still lacking in the fight against corruption. [1] Sanctions are inconsistently applied in the event of bribery, and most frequently administrative…
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Q36 33/100

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

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Legal provisions Score: 75 / 100
Legislation on whistleblowing and reporting corruption exists. The Law on Prevention of Corruption regulates the rights of the whistleblowers and the process of reporting…
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Prioritisation Score: 25 / 100
Whistleblowing is only formally encouraged, therefore procedures exist, but concrete results are lacking, as well as training sessions and campaigns. [1] The Agency for…
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Effectiveness Score: 0 / 100
Cases of whistleblowing are extremely rare and whistle-blowers are not adequately protected. The President of the Army Trade Union publicly and repeatedly reported possible…
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Q37 25/100

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

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Coverage of sensitive (higher-risk) positions Score: 50 / 100
The government claims that all persons employed in the Ministry are scrutinised by the National Intelligence Agency, and special attention is given to those…
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Selection process Score: 25 / 100
Not all sensitive positions are openly declared; instead, many personnel are initially employed through short-term contracts. [1] There is no information about the implementation…
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Oversight Score: 0 / 100
The Minister decides on the appointment and promotion of all personnel including those in special positions, upon proposals of the Head of the Army…
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Payroll, Promotions, Appointments, Rewards

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Q38 67/100

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

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Accuracy Score: 50 / 100
The number of civilian and military personnel is published in the annual reports of the Ministry of Defence. [1] However, statistical information about number…
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Transparency Score: 50 / 100
Information on the number of civilian and military personnel in defence is publicly available in the annual reports of the Ministry of Defence. [1]…
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Ghost soldiers Score: 100 / 100
Some sources believe that ghost solders used to be an issue in the past, but now it is rather the case with civilian personnel,…
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Q39 25/100

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

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Pay rates Score: 25 / 100
The calculation of salaries for employees is made in accordance with the Law on salaries in the public sector and for military personnel on…
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Allowances Score: 25 / 100
No information on allowances is publicly available, [1] and the Ministry claims that releasing such information would violate the right to privacy. [2] The…
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Q40 58/100

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

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Timeliness Score: 100 / 100
Payment of salaries is usually done on time. [1][2][3][4]
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Accuracy Score: 25 / 100
In just the year 2018, more than 500 employees initiated court cases against the Ministry in relation to labour issues, and many of those…
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Transparency Score: 50 / 100
Pay brackets for all ranks, disaggregated by seniority, are established by regulations, as well as a list of some permitted allowances and expenses, but…
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Q41 42/100

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

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Formal process Score: 50 / 100
According to the MoD, the Law on the Armed Forces stipulates the criteria for military personnel appointment. Therefore, officers and NCOs are assigned on…
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Scrutiny Score: 25 / 100
Council for Defence and Security, composed of the President of Montenegro, the Prime Minister and the Speaker of the Parliament, appoints the head of…
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Transparency Score: 50 / 100
Limited information is publicly released about the appointment process. The Government claims that information is available in its Newsletter, [1] but it does not…
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Q42 25/100

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

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Formal process Score: 25 / 100
A request was made to the MoD for further insight into this issue, but no information was provided. The available evidence suggests personnel are…
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Exceptions Score: 0 / 100
Research undertaken did not identify any regulations that underpinned such exceptions in practice [1][2]. At the assessor’s request, the Ministry also provided regulations. Further,…
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Comprehensiveness Score: 50 / 100
Little to no information is released about postings and the promotion cycle. [1][2] According to the MoD reviewer, when it comes to the special…
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Frequency Score: 25 / 100
Little to no information is released about postings and the promotion cycle [1][2]. According to the MoD reviewer, official promotion ceremonies are held at…
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Conscription and Recruitment

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Q43 NA/100

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

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Policy Score: NA / 100
Mandatory conscription was abolished in Montenegro in 2006, hence this indicator is not applicable.
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Sanctions Score: NA / 100
Mandatory conscription was abolished in Montenegro in 2006, hence this indicator is not applicable.
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Enforcement Score: NA / 100
Mandatory conscription was abolished in Montenegro in 2006, hence this indicator is not applicable.
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Q44 75/100

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

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Policy Score: 100 / 100
The Criminal Code criminalises bribery for the obtainment of any benefit including in employment and promotion, while bribery offences cover offering, giving, receiving, or…
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Sanctions Score: 100 / 100
Possible sanctions include criminal prosecution and up to 12 years of imprisonment. [1] An employee in the defence sector who is found guilty and…
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Enforcement Score: 25 / 100
Concrete results are still lacking in the fight against corruption. [1] Cases of corruption in the army are very rarely reported and processed, while…
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Salary Chain

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Q45 100/100

Are chains of command separate from chains of payment?

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Score: 100 / 100
Chains of command are strictly separated from chains of payment. The armed forces provide information about their needs and the Ministry deals with procurement…
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Values and Standards

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Q46 56/100

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

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Code of conduct Score: 25 / 100
There is a very brief Code of conduct for all military personnel. [1] According to the MoD reviewer, the Code of Military Ethics presents…
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Transparency Score: 100 / 100
The Code of conduct is available to the public. [1] The Code is distributed to all military personnel and presented at initial training. [2][3]
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Enforcement Score: 25 / 100
Ethics in the army have been eroded through the years and remain one of the main problems, as breaches of conduct are rarely investigated.…
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Training Score: 75 / 100
For each person upon joining Armed Forces there is an obligation to get acquainted with Code of Military Ethics. Regular training for persons in…
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Q47 NEI/100

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

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Code of conduct Score: 25 / 100
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…
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Transparency Score: 100 / 100
The Code of Conduct is publicly available [1] and included in initial training. [2]
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Enforcement Score: NEI / 100
There is not enough evidence to score this indicator. Information about breaches of the Code of conduct are not available in the reports of…
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Training Score: NEI / 100
There is not enough evidence to score this indicator on training/ guidance relating to the code of conduct for all civilian personnel.
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Q48 50/100

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

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Comprehensiveness Score: 25 / 100
According to interviewees, no anti-corruption training takes place, [1][2] but when personnel is sent on foreign missions, they are trained by partner countries also…
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Regularity Score: 50 / 100
According to the MoD reviewer, anti-corruption training is delivered once a year, and upon entry into high risk positions and environments. [1] More recently,…
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Coverage of personnel Score: 75 / 100
According to the MoD reviewer, anti-corruption training is delivered to higher rank brackets of military personnel and the equivalent for civilian personnel. [1] This…
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Q49 25/100

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

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Policy Score: 50 / 100
There is no formal policy of the Ministry or the army to make the outcomes of the prosecution publicly available. [1][2] According to the…
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Transparency Score: 0 / 100
No information is available on prosecutions of personnel in defence in official publications of the Ministry available on its website, [1] or on the…
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Effectiveness Score: 25 / 100
Corruption in defence is rarely reported due to the fear of reprisal. [1] Even when it is reported, the prosecution does not investigate such…
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Q50 0/100

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

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Legal framework Score: 0 / 100
Facilitation payments are not criminalised: the Criminal Code criminalises a bribe only if it is given to an official with the aim of them…
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Enforcement Score: NA / 100
Facilitation payments are not criminalised, hence this indicator is not applicable.
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Prevalence Score: NEI / 100
According to available public opinion surveys, more than 45% of businesses admit that they have given a bribe in order to speed up procedures…
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