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Does the country have an openly stated and effectively implemented anti-corruption policy for the defence sector?

7a. Anti-corruption policy


SCORE: 0/100

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7b. Effective implementation



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There is no specifically defined and actively implemented strategy on anticorruption in the defence sector in Albania. A clear anticorruption deference strategy is supposed to be comprehensive and cover all potential risks of the defence sector, which is not the case.
There is an Inter-Sectoral Strategy against Corruption (ISSC) for the period 2015-2020 which includes 18 specific objectives subdivided in prevention, repressive and awareness-raising. The defence sector is specifically referred in one of the 18 objectives, namely Objective 2 – Increasing transparency in planning, elaboration, management and control of budget funds. Under this objective, the MoD is required to publish key financial information on defence, concessions, procurements and income of state capital companies [1].
The Action Plan of the Inter-Sectoral Strategy against Corruption 2015-2017 included the improvement of the legal framework for procurements that are not subject to the general rules of public procurement and the completion of the registering all the immovable properties of the Armed Forces to the cadastral offices [2]. The MoD has complied with two of the tasks and is in the process of completing the registration of properties [3].
However, these actions and measures represent only a small part of corruption risks in the defence sector and do not amount to a fully-fledged anticorruption policy in defence. The cases of corruption involving high ranking officials of the Ministry of Defence are an indicator of the vulnerabilities posed by omissions [4].

Under the ISSC, the MoD has adopted an Action Plan for the period 2014-2017, which includes 31 measures subdivided in prevention, repressive and awareness-raising, under 10 headings [1]:
– Increasing transparency and minimizing the opportunities for corruption in the Armed Forces.
– Increase access to MoD personnel and the public to information.
– Increase transparency in planning, detailing, managing and controlling funds.
– Strengthen the electronic infrastructure of the Armed Forces.
– Improve the system mechanisms and for making and handling complaints.
– Adopting and implementing risk analyses.
– Maintain the integrity of the MoD employees.
– Improvement of statistics by law enforcement institutions and commands.
– Improve cooperation on criminal disclosure and punishment of corruption.
– Public awareness and participation in the fight against corruption and monitoring the progress in implementing the measures taken by the Ministry of Defence.
The Action Plan includes the unit responsible for each measure, the deadline for its implementation, the required financial resources and their origin, and the indicators on the implementation. All measures are reported as completed in section “indicators on the implementation” of the Action Plan [2, 3].
However, the Action Plan addresses only some of the corruption risks in the defence sector and doesn’t derive from a clearly defined corruption risk assessment and anti-corruption policy. The Action Plan for the period 2018–2020 has been adopted and was recently published by the MoD [4].

Algeria has an official anti-corruption policy, but it is unclear whether it applies to the defence sector. There is also no evidence that the government is in the process of developing an anti-corruption policy that explicitly applies to the defence sector. There was no significant change to the situation in 2015.

Algeria’s anti-corruption policy was based on the National Anti-Corruption Law (Law No. 06-01 of February 20, 2006, relative à la prevention et à la lute contre la corruption) (1), which was finalized by Presidential Decree (No. 06-413) in November 2006 (2), and then amended and supplemented by another Presidential Decree (No. 12-64) in February 2012 (3). The anti-corruption policy enumerated in the law is broad and makes no reference to corruption in the defence sector. Instead, the code of conduct applies to, “the state, elected assemblies, local authorities, institutions and bodies governed by public law, as well as public companies engaged in economic activities” (Art. 7 of Law No. 06-01/2006). The law refers to public procurement and the private sector.

Algeria has several agencies that are mandated to fight corruption or review suspicious transactions but their missions do not explicitly include the defence sector.

Law No. 06-01/2006 mandates the National Body for the Prevention and Fight against Corruption (ONPLC) with the implementation of the national strategy on corruption (1). There is also the Central Office for the Repression of Corruption (Office central de répression de la corruption, OCRC), which is governed by the presidential decree of December 8, 2011, and is part of the Ministry of Finance. The central mission of OCRC is to: collect, centralize and exploit all information within its jurisdiction (Art. 5). The office includes officers of the Judicial Police under the Ministry of National Defence (Art. 6, 4). Finally, there is the Financial Intelligence Processing Unit (Cellule de Traitement du Renseignement Financier, CTRF), which processes financial information collected through suspicious transaction reports from financial institutions; as well as, non-financial professions including notaries and lawyers. The CTRF was created by Decree no. 02-127, on April 7, 2002 (5).

It is unclear whether Algeria’s anti-corruption policy applies to the defence sector, and no action plan could be found on the Ministry of Defence website (1).

Scholars have emphasized that corruption is an essential part of the Algerian system of governance. Political corruption can pay for the loyalty of high-ranking regime members, and can be used against competitors (2). Therefore, political corruption can be considered as a tool to monitor and regulate conflicts in the Algerian government (3). Since any real anti-corruption efforts would destabilize the system, their implementation is very difficult (2). Against this background, the Algerian leadership, including the military, aims to maintain the status quo, and it is doubtful that any anti-corruption initiative will be implemented effectively. The BTI notes that the anti-corruption legislation has not been implemented (4).

Currently, no specific defence-sector anti-corruption policy exists. The 1994 Law on Military Crimes establishes that corruption-related offences are punishable under civilian law. The Angolan authorities have been working on a draft bill of a new Military Criminal Code in cooperation with the Brazilian Military Justice authorities, which reportedly will include corruption-related offences (2).

The 2018 IMF notes on Governance and Economic Performance in Angola, states “Since the end of civil conflict in 2002, Angola has implemented a legal framework for supporting good governance and combating corruption, Despite these efforts, Angola did not catch up with peers in sub-Saharan Africa (SSA) and continues to underperform in many areas of governance. This reflects several factors, including remaining deficiencies in legal and regulatory frameworks, patchy law enforcement, and the lack of independent and well-resourced anti-corruption institutions” (3). This shows that though the legal framework addresses national corruption, it reflects the weak environment of anti-corruption measures in the defence and security sectors.

There is no action plan to implement a defence-specific anti-corruption policy since no such explicit policy exists. Thus, this indicator has been marked Not Applicable.

Military members are subject to civil law for corruption-related offences. Since João Lourenço took office, the pace of prosecution of public servants and senior officials on corruption charges appears to have sped up, though it’s too early to judge whether these are temporary and selective measures or part of a sustained policy that would also include the defence sector (1).

After publicly announcing in April that Chief of Staff of the Angolan Armed Forces, General Sachipengo Nunda, was named a formal suspect of criminal association in a $50 million scam led by a Thai businessman, the attorney general later apologized claiming his announcement was a “mistake”, and the Supreme Court later dropped the charges. Angolan media have interpreted the announced prosecution of General Nunda as politically motivated (for being a former UNITA general), rather than the result of a sustained anti-corruption policy (2).

There is an open policy to fight corruption that cross-cuts all State agencies. The newly launched 2019-2023 Anti-Corruption Plan, established by Presidential Decree No. 258/2019, acts as a general framework for the development of sectoral policies. [1] Points 22, 119, and 152 (all with deadline of 2019) set as objectives for the jurisdiction the “update of the Regulations concerning the Classification of Reserved Information of the Ministry of Defence” by preparing a document that contains a diagnosis and recommendations to adapt the regulations, policies, and procedures for the classification of information with security levels in the jurisdiction of the Ministry of Defence to meet Law No. 27,275 of the Right of Access to Public Information and to international standards, the development of a risk map, and the creation of a complaints system in the Ministry. This plan also incorporates a point regarding the state companies of the Ministry of Defence for the creation of a work table that must define, between 2019 and 2023, a joint action plan and guidelines, guides and orientations will be implemented regarding integrity and transparency for its application in the companies of the jurisdiction. [2] As reported by the Ministry of Defence, the General Directorate of Integrity, Transparency and Institutional Strengthening is currently conducting a survey of standards, guidelines, and good practices in order to generate the Corruption Risk Map by the end of 2019. [3] The Open Government policy in Argentina is part of the 8 objectives and 100 priorities set by the National State in 2016. In the analysed period, the 2nd National Open Government Action Plan (2015-2017) has been completed and is underway the 3rd Plan (2017-2019). The latter has 44 commitments; 33 at the national level and 11 for sub-national governments, arranged in five axes: Transparency, Accountability, Participation, Innovation, and Sub-nationals. In its preparation, 28 organisations from the three branches of the State and 54 civil society organisations participated. [4] However, none of the 44 commitments directly involve the defence and security area. [5]

The National Anti-Corruption Plan 2019-2023 cross-cuts all Ministries, but it is not possible to evaluate the effectiveness of its application. However, the Ministry of Defence, through internal resolutions in order to generate greater transparency, dictated the update of the regulations of the Defence Archives System and the declassification of archived documents preserved in the Historic Service of the Argentine Army. [1] It is worth mentioning that according to the latest management report of the Anti-Corruption Office, that body has submitted complaints to the judiciary regarding the area of defence and security, realising that the problem of transparency exists in the sector. [2] [3]

After the revolution, in 2019 the Government adopted a new Anticorruption Strategy and Its Implementation Plan for 2019-2022. [1] Tհese documents do not contain sector-specific measures, but rather outline and detail the approaches, methods, laws and institutions to be in charge of corruption. One of the measures of the Implementation Plan document mandates all the sectoral institutions to conduct corruption risk assessment and another – to develop integrity plans for their specific sectors. In this respect the Ministry of Defence will be in charge of implementing these activities, or, given its engagement with NATO’s Integrity Program may use the self-assessment and action plan to comply with the respective requirement.

The Ministry of Defence (MoD) Human Rights and Integrity Center has been established to build integrity and address corruptions issues within the ministry.[1] Through participating in a range of international programs and through building partnerships the Human Rights and Integrity Center contributes to the raising awareness of the corruptions risks and provides expertise on the spot. One of the major activities of the Human Rights and Integrity Center was the establishment of the hotline that aims at raising trust towards whistleblowing and engaging the public in identifying potential corrupt behaviour [2]. The MoD joined the NATO Building Integrity Program’s self-assessment process in 2013, which aims to assist the MoD in evaluating the corruption risks in the defence sector and ensuring effective management of corruption-related issues. Within the framework of the program, the MoD has twice filled the NATO self-assessment questionnaire, which is a unique diagnostic tool and provides an overview of the existing structures and procedures in terms of corruption risks. The review of the questionnaire was done by all the units of the MoD and armed forces, which allowed to reveal the main corruption risks and outline the main directions of the fight against corruption in the defence sphere. The self-assessment questionnaire will be followed by a visit by the NATO Building Integrity Program’s expert group, which will develop and publish a report on the self-assessment of the MoD [3].
The MoD also carried out a “Test of Honesty”, which is a self-assessment tool to identify corruption risks in each military unit. The aim of this measure was not only to identify corruption risks but also to assess the perception of possible corruption risks by different units. Based on the findings of the corruption risk assessment and the report of the NATO Building Integrity Program’s expert group, the MoD will develop an anti-corruption strategy and an action plan [3]. The MoD’s Internal Audit Department periodically conducts a current analysis of corruption risks and submits the results to the minister of defence.

In the 2015 edition of the Government Defence Anti-Corruption Index (GI), the then-Country Assessor could publicly access the Defence Fraud Control Plan and interviewed a Department of Defence official, who indicated that the Department was in the process of developing an Anti-Corruption component to the Fraud Control Plan [1]. However, after an exhaustive public records search, the Defence Fraud Control Plan can no longer be found – including previous versions of the Plans, which were hyperlinked to in the 2015 GI – and repeated attempts to retrieve substantive information on the Fraud Control Plan from the Department of Defence went unanswered. Therefore, it cannot be determined if defence has developed an anti-corruption component to their Fraud Control Plan. Other government departments, such as the Department of Foreign Affairs and Trade (DFAT), had their Fraud Control and Anti-Corruption Plans as publicly available in August 2019 [2]. However, the document has seemingly been pulled from the public domain since then, with the formerly working link throwing up a 404 error in April 2020. The DFAT website now refers to the Fraud Control Plan as an “internal” document [3, pC6]. The Australian government does have an whole-of-government fraud control policy, the Commonwealth Fraud Control Framework [4]. However, while in practice the acts that consitute fraud and corruption may overlap, these are not the same and the Framework cannot replace a anti-corruption policy, as the Framework acknowledges: “The guide is not intended to cover all types of entity risk. For instance, where corruption or other entity risks are concerned, this guide acts as a starting point to be used in conjunction with other appropriate guidance materials” [4]. In recent years, the government has been criticised, including by Transparency International [5], for abandoning efforts to develop a unified national anti-corruption policy and create a national institution to police corruption. Most recently, the Australian government agreed to “Strengthen the national anti-corruption framework” as one of the commitments in Australia’s Second Open Government National Action Plan for the Open Government Partnership. However, progress on all three of the implementation steps, the first of which was meant to be delivered in mid- to late-2018, have been reported as “delayed” as of September 2019 [6].

This indicator has been scored ‘Not Applicable’ because Australia does not have a (publicly stated) anti-corruption policy for its defence sector (see Q7A).

There is not any openly stated and effectively implemented anti-corruption plan for defence sector in Azerbaijan. But Parliament has adopted the Law of the Republic of Azerbaijan on Combating Corruption in 2004 (1) and there is National Strategy on Increasing Transparency and Combating Corruption which was adopted in 2007 (2). After the change in the leadership of the Defense Ministry in 2013, the new Minister Zakir Hasanov announced that he would fight corruption in the army (3). After that, the military prosecutor Khanlar Veliyev stated about fighting against corruption in the defense and security sector. According to him, the fight against corruption in the army is carried out on the following documents (4):
– The law “On Combating Corruption”
– “National Action Plan on Combating Corruption in 2012-2015” approved by President Ilham Aliyev’s Order dated September 5, 2012,
– Tasks set forth at the meeting of the Cabinet of Ministers, chaired by the head of state on 10 January 2015.
Though the government states that they fight against corruption, the measures in the defence sector to tackle corruption are either not taken or superficial. Several times, After the Defence Minister was changed in 2013, Military prosecutor’s office informed the media about the corruption facts in the military and the criminal cases against those responsible, but the public was not further informed clearly about the results of the criminal cases and the measures didn’t enclose high ranking officials.
According to Military prosecutor Khanlar Valiyev 24.7% of all crimes committed in the military sector are corruption-related crimes. But the questions still remain open: whether the figures affect the reality? Who are these persons, what were the results of the criminal cases instituted against them? Whether they were punished or not? He just shared general figures which don’t enable us to come to such a conclusion that the measures indeed are taken in practise (7).
Besides, in order to get a bit more information about those cases, we took a look at the E-Court portal where the trials are recorded. However, in the portal I couldn’t find a single case related to corruption crimes. It seems the corruption relation crimes (if any) are not added to the E-Court portal (8).
According to experts, the lack of transparency in the institutions of defense and security will further increase the likelihood of corruption in them (5). Official Baku still does not join the NATO’s program – Building Integrity, which intended to strengthen tools against corruption and does not disclose its reasons (6).

There are some special action plans at the ministry level in Azerbaijan, but they are secret. The National Strategy on Increasing Transparency and Combating Corruption (1) and The law “On Combating Corruption” (2) are superficial and they do not address the institutional weaknesses in the system. According to the Ministry of Defence, some of the tasks in the National Action Plan on Combating Corruption are under the authority of the Defense Ministry. For this reason, executive and supervisory bodies, persons, as well as execution deadlines have been defined for their implementation (3). According to Arzu Rahimov, Head of the State Service for Mobilization and Conscription, the Action Plan against Corruption was prepared and approved by the Service in connection with the implementation of the “National Action Plan for 2012-2015 on Combating Corruption.” Implementation of the proposed measures was ensured (4).

According to our search and sources, there is not any anti-corruption policy dedicated only for the defence sector; however, there is an anti-corruption strategy in Bahrain [1]. The strategy, which was adopted in 2013 and ended in 2018, apparently does not apply to the defence sector. The institute that handles corruption in Bahrain is part of the ministry of the interior [2, 3, 4]. The General Directorate of Anti-Corruption and Economic and Electronic Security (GDAC) has no guidelines and no plan. Based on a search (online and offline), no information about the strategy of the GDAC was found. The work of the GDAC is not clear, and it has no mandate. Based on extensive research online and offline, there is no data that defines the work of the GDAC.

As there is no anti-corruption strategy for the defence sector in Bahrain, this indicator has been marked ‘Not Applicable’ [1, 2, 3].

Bangladesh does not have an openly stated anti-corruption policy that also applies to the defence sector. No clear evidence could be found on this subject.

This indicator is marked ‘Not Applicable’, as Bangladesh does not have an openly stated anti-corruption policy that also applies to the defence sector.

The anti-corruption policy of Belgium is overarching and codified into laws, deontological codes and procurement processes. However, the country does not have an overarching national anti-corruption policy or strategy that applies to the defence sector [1]. This is partly due to corruption being a non-issue in Belgium and thanks to trust in the process.

Belgian Defence does have a Code of Conduct in place to avoid corruption [2]. This document is communicated to third parties when necessary, for example in the framework of public procurement [3]. The parties involved need to sign an acknowledgement document stating that they read the code. Additionally, a 2007 law endorses the 2003 UN Convention against Corruption to Belgium [4].

There is no public information available on an action plan against corruption at the ministry level [1]. The current government agreement mentions action points which will strengthen anti-corruption measures in Belgian Defence: parliamentary oversight on the military procurement will be extended, and the Court of Audit will receive more control competence during defence procurement processes [2]. Overall, there is no detailed action plan on corruption in Defence [3].

The National Anticorruption Strategy is not structured to specify or address the obligations separately for every institution in Bosnia and Herzegovina (BiH), including the defence sector, but each institution in BiH, including the defence sector, is required to implement the strategic objectives established under the Strategy and incorporate them in their plans to fight corruption as well as in their objectives and concrete measures [1]. There is an openly stated anti-corruption policy regulating the integrity plan and fight against corruption for the Ministry of Defence of Bosnia and Herzegovina (MoD) [1]. This anti-corruption document adopted by the Ministry of Defence titled Integrity and Anti-corruption Plan of the Ministry of Defence of Bosnia and Herzegovina for the period 2015-2019 relies on the state anti-corruption strategy and action plan for the implementation of the strategy and other relevant adopted laws and defence policies such as the Law on Defence of Bosnia and Herzegovina, the 2013 Ministry of Defence Policy for Building Integrity, Reducing Risks and Fighting Corruption, the Law on the Service in the Armed Forces of Bosnia and Herzegovina, Self-Assessment of the Integrity Building – Report on Collegial Assessment of Bosnia and Herzegovina (NATO HQ Brussels) [2]. The Plan of Integrity and Combating Corruption of the Ministry of Defence of BiH for 2015-2019 includes all the strategic goals defined in the State Strategy and specific strategic programs and concrete activities have been developed to achieve these strategic goals [1]. For example, the first strategic goal of the strategy reads: Establishing and strengthening institutional capacity and improving the normative framework for combating corruption, 13 concrete programs have been developed in the Integrity and Anti-Corruption Plan of the BiH Ministry of Defence 2015-2019 [1]. One of these programs is (11th program) Implementation of the recommendations of relevant international institutions and anti-corruption organizations and one of the 5 concrete activities of this program is to: Participate in the NATO Self-Assessment Initiative of Building Integrity in the Respected Sector (Activity 1.11.3) [2]. This activity was planned and executed in the MoD [2].

Per obligations from the strategy, the MoD created the “BiH MoD Integrity Plan and Fight against Corruption for the period 2015-2019”, containing 182 measures. Additionally, the MoD integrated 106 measures from the strategy into the Action Plan. The plan was submitted to the BiH Agency for the Prevention of Corruption and the Co-ordination of the Fight against Corruption (Agency) and it was approved by the Agency [1]. The realization of the plan is performed following the schedule stipulated by the Action Plan. The MoD regularly reports to the Agency on the realization of measures stipulated by the plan. Reporting is carried out once a year and it includes activities realized during the reporting period [1]. The information that was submitted by the MoD in the last report to the Agency, presents statistical indicators with precisely listed activities, description of realization degree and character of activities [2]. The statistical indicators (status of the realization of the planned activities) on the status of implemented measures from the Action Plan are presented below. Continuous activities: (Number of activities):19 activities, (Realized Activities):9 activities or 47%, (Ongoing): 8 activities or 42%, (Partly realized): 2 activities or 10.5%, (Unrealized activities):0.
Activities with realization deadline in the third year after the adoption of the plan: (Number of activities):14 activities, (Realized Activities): 10 activities or 71%, (Ongoing): 2 activities or 14%, (Partly realized): 2 activities or 14%, (Unrealized activities):0 [2].

Botswana does not have a National Anti-Corruption Policy [1]. The government has admitted this by stating that President Mokgweetsi Masisi has called on governments to ensure the existence of sound policies for fighting corruption [1]. Officiating at the Southern Africa Regional Conference on Corruption in Gaborone on June 18 2018, he said that sound policies relating to accounting governance; internal controls and auditing systems within the public sector; adherence to the rule of law; and the prosecution of perpetrators of corruption should be put in place. However, the general legislation on corruption, such as the Corruption and Economic Crime Act, No 13 of 1994 applies to Defence corruption [1]. DCEC, in terms of its enabling legislation, has the mandate to develop the Defence Anti-Corruption Policy. However, that Defence Anti-Corruption Policy is not yet in place. There are no public statements by DCEC that it will produce the Defence Anti-Corruption Policy anytime soon.

This indicator has been scored Not Applicable, as there is not an openely stated anti-corruption policy.

An Integrity Plan was launched in 2018, it was created due to the Federal General Comptroller’s (CGU) request to follow international standards of anti-corruption [1]. There are other anti-corruption policies in Brazil that apply to the defence sector as any other ministry or public institution [2]. The latest anti-corruption law was enacted in 2013 and created more rigid the penalties related to the corrupt behaviour of private (national or international) companies. Companies can be penalized in cases of corruption, even when guilt is not fully proven [2]. This could apply to companies that sell products or services to the armed forces and the Ministry of Defence. Despite the absence of evidence that this is happening, the legal device exists. Other anti-corruption measures are being discussed by the current government, such as the “Anti-corruption Package” [3]. This set of draft bills has a more juridical form, establishing different types of punishment for the practices of slush funds, crimes against the public administration, penalties for members of organized crime, among others. Some of the laws proposed in this package are being discussed, but none of them have been enacted, yet [4].

The Ministry of Defence (MoD) has an Integrity Plan that mandated by CGU, has to encompass an evaluation of weaknesses of the institution. The Ministry of Defence Integrity Plan; however, only focuses on the MoD itself – the different service branches have individual plans, all of them assessing risky areas. The Integrity Plans were launched in 2018, by December 2019, there was no follow up on the planned actions [1].

There is no anti-corruption policy specifically targeting the defence sector. However, several state institutions and CSOs have issued anti-corruption policies and strategies that also apply to the defence sector (1), (2), (3). These include the ASCE-LC, which has a nationwide mandate (1), the Ministry of Civil Service, Employment and Social Welfare (MCSESW) (2), and the BNAF. The National Anti-Corruption Network (REN-LAC), subscribed to the Partnership for an Open Government (POG): 2017-2019 National Action Plan of the MCSESW. These anti-corruption policies usually apply to the defence sector, through an information session, workshops and training (1).

Effectiveness in the implementation of anti-corruption policies within the defence sector is limited, as the government does not engage fully with anti-corruption institutions, as well as CSOs committed to effectively eradicating the phenomenon (1). Severe criticism against the government has often taken place in the media and other public forums for not disclosing its information to enable effective implementation of anti-corruption policies (2), (3). For example, the Open Government (POG): 2017-2019 National Action Plan of the Ministry of Civil Service, Employment, and Social Work applies to the defence sector, like any other ministry. However, its implementation is more likely to face a lack of collaboration and information sharing (2), (4).

In 2010, the Government of Cameroon elaborated a National Strategy to Fight Corruption that had been established by Decree No. 2006/088 (in French) on 11 March 2006 by the President of Cameroon [1]. This organ has units in some ministerial departments but not all [2]. The Cameroon’s Anti-Corruption Status Report officially presented to the public on 27 June 2016 reported that the Ministry of Defence and the General Delegation for National Security were among the ministries that regrettably did not implement any of the Rapid Results Initiative elaborated in the National Strategy to Fight Corruption [2].

In the same assessment report of 2014-2016 the Commission stated clearly that “The National Anti-Corruption Strategy validated by the Government and its Technical and Financial Partners in February 2011 is the National Policy document for the fight against corruption in Cameroon; consequently, its application is obligatory to all administrations and citizens, without exception” [2]. The Strategy is an anti-corruption policy to fight general corruption, including that in the defence and security sectors [2]. However, there is no evidence of the anti-corruption strategy being addressed in the defence and security sectors [3].

The National Anti-Corruption Commission stated in its assessment report of 2014-2016 that the defence and security sectors are included in its National Strategy to Fight Corruption although these two ministerial departments “regrettably” did not implement any of the Commission’s Rapid Results Initiative elaborated in the National Strategy to Fight Corruption [1].

Although the National Strategy to Fight Corruption has a general anti-corruption strategy, informants from the Ministry of Defence say that the Ministry of Defence has an anti-corruption unit which oversees issues of corruption at the level of the ministerial department [2] [3]. However, there is no evidence to state how effective this unit is because defence institutions are not subjected to external scrutiny [2] [3] [4].

There are broad anti-corruption laws in Canada, such as the Corruption of Foreign Public Official Act, and an assortment of tools and indicators used by the RCMP to detect, deter, and prosecute corruption. [1] [2] There is no defence-specific anti-corruption policy in Canada. However, policies through Public Works apply to all government activity, including defence, and regulate hiring and the use of public funds throughout the public sector, including defence. [3] Bribery is forbidden under the Criminal Code. GAN International, which evaluates corruption from the perspective of businesses operating internationally, rates corruption in Canadian law enforcement, government operations, public services, procurement, and the judiciary as very low. [4]

The broad anti-corruption laws in Canada (see 7A) in addition to the DND’s “Code of Values and Ethics” (which clarifies expectations of individuals, supervisors, and units with respect to corruption) apply to both the Civilian and Military Defence staff, as the Code of Service Discipline defers to the Criminal Code of Canada for issues not explicitly mentioned therein. [1] [4] [5] While outlining expectation, regulations, and laws, the Code of Values and Ethics does not specify mechanisms for regular or proactive assessment, but rather reactive investigation and how to report breaches. [3] The Chief Review Service within the DND, reporting directly to the Deputy Minister, is the organisation that implements anti-corruption and ethics measures, and while the service is active, it does not communicate a specific plan, nor its priorities. [2]

The anti-corruption policy in the defence sector derives from different legal bodies in government and the Agenda on Probity and Transparency in the defence sector [1]. Concerning legal sources, different regulations concerning the transparency and probity in the exercise of government and public agencies. Among the main sources are the Political Constitution [2] and the Organic Law of the General Constitutional Basis for the Administration of the State, which define the principle of administrative probity [3]; the law on administrative probity for the agencies of public administration [4]; the Penal Code, which defines the concepts of active and passive bribery [5]; the Law on Access to Public Information [6]; the Law that Regulates Lobby [7]; the Law on Probity and Conflicts of Interest in the Public Sector [8]; and the Framework for Probity and Public Ethics for Public Servants [9]. In 2016, the Ministry of National Defence (MDN) developed a plan for the strengthening of probity, transparency, and internal control based on five actions [10]: the implementation of a model for the prevention of administrative wrongdoings, the implementation of a model for the management of internal risks, a review of regulations for special providers in the defence sector, a review of the procurement process, and the strengthening of the law that regulates lobby. This plan was updated and broadened through a new internal regulation in 2018 [11]. The plan was later materialised and set in a Website that documents the accomplishment of different measures in the following main areas: internal control and management of providers, public integrity, travels abroad, the relationship between Armed Forces and healthcare facilities, channel to denounce irregularities, control over disposables, patrimony and conflict of interests, control and use of public resources, fight against discrimination and harassment, and legislation and norm changing.

The MDN established an action plan with five pillars [1]. Each pillar has been addressed through specific actions and policies regulated through Exempt Resolutions and plans. Concrete measures have involved the strengthening of the MDN Institutional Control System, the execution of an external audit to the military process, the design and implementation of a new Institutional Control System, the review and structuring of the Institutional Functioning Doctrine, the improvement of the institutional risk assessment, the implementation of a model for the prevention of the administrative wrongdoing, the strengthening of the procurement process, and the reform of the information system of finance in the army. However, there is no evidence of an associated timeline for the development of this plan [2]. In terms of implementation, there are noticeable advances in areas that present risks of corruption, such as the development of a unique registry of suppliers [3]. However, advances have been minor in issues related to acquisitions through the Restricted Law of Copper and restrictions in the access to information regarded as important to national security.

After Xi Jinping’s rise to power in 2012, the CCP launched an extensive anti-corruption crackdown in the government and the military. In the last 7 years, Chinese civilian and military leaders have repeatedly reiterated their commitment to battling corruption in the People’s Liberation Army. [1,3,4] The latest Defence White Paper published in 2019 outlines the PLA’s anticorruption policy. [2] These efforts seek to enforce the Party’s anticorruption regulations (Regulations, 2011). Still, it needs to be noted that the intensity of the anticorruption campaign in the PLA has not been replicated in the defence sector, with very few defence industry executives and armament personnel having been arrested on corruption charges. [5]

There is no public information on how the policy is translated into a concrete action plan by the MoD, although internal guidelines most definitely exist. We can only reach a conclusion based on enforcement. The 2019 White Paper provides evidence of the implementation of the anticorruption policy in the PLA, noting that between 2012 and 2019, “over 39,000 units and 13,000 PLA and PAP officers in positions of leadership at and above regiment level” have been audited. [1] In addition, more than 200 senior military officers have been implicated in corruption cases. [2] Anticorruption in the CCP and the PLA serves political purposes, creating opportunities for corrupt officers with factional ties to the Party leadership to escape punishment.

Colombia has a consolidated regulatory framework around the fight against corruption: a) Law 1474 of 12 July 2011, “Anti-Corruption Statute”, which dictates rules aimed at strengthening mechanisms for the prevention, investigation, and sanctioning of acts of corruption and the effectiveness of the control of public management. [1] The Law creates various administrative and criminal measures to combat public and private corruption. Article 73 states that national, departmental, and municipal entities should develop their strategy to combat corruption and citizen service annually, submit it by 31 January each year, and publish it publicly. This strategy also includes the corruption risk map and measures to mitigate corruption, in addition to mechanisms to improve customer service. Both the Ministry of Defence and its entities, the Armed Forces and Police, have complied; (b) Decree 4637 of 9 December 2011, establishing the Presidential Anti-Corruption Programme and the “Secretariat of Transparency” with the mission of advising and directly supporting the President in the design of comprehensive policies of transparency and anti-corruption, in addition to coordinating its implementation; [2] c) Law 1712 of 6 March 2014, [3] establishing the Law on Transparency and the Right of Access to National Public Information. In addition, it should be noted the authorisation of the Economic Transparency Portal, [4] administered by the Ministry of Finance and Public Credit and the Colombia Buys Efficiently (Colombia Compra Eficiente) portal, in which the expenses, revenues, and contracts of the entities at the national and subnational level can be tracked, including those belonging to the defence sector. This tool is up-to-date and available for consultation by the general public. In the particular case of the defence sector, the DANTE (Directorate of Transparency Standards Enforcement for the Army) strategy was created in 2016 to counter corruption within the Military. [5] This strategy has 3 components: (i) prevention via re-education of ethical principles; (ii) General Inspection of the Army, verifying proper compliance with the rules governing the institution; and (iii) internal disciplinary control. [6] There is thus an openly and explicit anti-corruption policy within the defence sector.

Law 1474 of 2011, [1] on the fight against corruption, stipulates that all public entities must build a strategy to combat corruption and address citizen services. This includes a risk map, reflecting the levels of risk within the processes of the institutions, in addition to proposed actions to mitigate them, and goals, products, and evaluation indicators. [2, 3] However, after reviewing in depth the components and activities that make up some of the Defence Sector Anti-Corruption Plans for 2018, [4] it is not possible to identify the impacts of these measures on strengthening transparency and the priority strategies that make up the document. In addition, the conclusions and evaluation of the implementation focus on formal elements, setting aside the priority themes of the plan and addressing institutional weaknesses. In terms of the overall effectiveness of anti-corruption policy, while mechanisms exist to promote greater transparency and monitor the actions implemented by the SECOP, situations of corruption and excessive use of force by members of the military persist. There also remain limits on access to information by the current administration. [5] Thus, there are obstacles and delays in implementation. At the same time, acts of corruption have been identified within the military forces, involving high-ranking individuals and private companies that have acted in collusion. Even though there is an action plan, inside the Military Forces there are incidents of corruption that the Plan fails to account for.

There is a general anti-corruption policy, but also a lack of an explicit anti-corruption framework for the defence sector. The existing anti-corruption mechanisms apply only nominally to the defence and security establishment.

The National Plan for Good Governance and Anti-Corruption (Plan national pour la bonne gouvernance et la lutte contre la corruption) was established by the Ouattara administration in 2013 as a broad-based anti-corruption plan. In turn, it led to the setting up of the Haute Autorité pour la Bonne Gouvernance (HABG) in 2014. The HABG oversees one of Côte d’Ivoire’s main anti-corruption initiatives: an asset declaration scheme that affects 4,600 senior politicians and managers at state-owned enterprises.

The Anti-Corruption Brigade (Brigade de lutte contre la corruption, BLC), launched in 2012, and the Anti-Racketeering Unit (Unité de Lutte contre le Racket), implemented since 2012, are additional examples of anti-corruption policy that extend to the security sector. The Anti-Racketeering Unit seeks to end bribes extorted by police agents and their higher-ranking officers at roadblocks in isolated areas. Additionally, the government has established reporting mechanisms for citizens to denounce corrupt acts among the police. However, the effectiveness of such mechanisms appears to be questionable (1).

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 mechanisms such as HABG lack teeth and cannot effectively sanction corrupt practices, much less in the highly sensitive defence sector where certain former rebel leaders, known as the COMZONES, have accumulated wealth and power in their local bastions (2). Here is an extract from BTI 2018:

“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 government had also planned to create a Special Tribunal for the Fight Against Corruption, a plan not implemented yet. The institutions meant to oversee the utilization of public funds (Inspecteur General des Finances, Cour des Comptes) are understaffed and thus not effective in preventing abuse and corruption.”

TThe anti-corruption policies and their associated measures have not been effectively implemented. The reasons include institutional weakness, but also the fact that despite a prominent anti-corruption agenda, the defence establishment remains a threat to national reconciliation. Corruption allegations could, therefore, be perceived as politically destabilizing elements.

As part of Côte d’Ivoire’s 2016-2018 first action plan to improve governance and as a result of its participation in the Open Government Partnership (OGP), the government published a partial self-evaluation report in September 2017 to gauge the effective implementation of transparency agreements, including anti-corruption mechanisms (1).

The report revealed that most ministries had been involved in the self-evaluation (Ministry of the Interior, Ministry of Justice, Minister of Economy & Finance, Budget Ministry, Ministry of Industry) except for the Ministry of Defense. The report also highlighted the number of transparency initiatives that had been adopted:

-Order No. 2013-660 of September 20, 2013 (Prévention et Lutte Contre la Corruption et les Infractions Assimilées)
-Order No. 2013-661 of September 20, 2013 (Fixant les attributions, la composition, l’organisation et le fonctionnement de la Haute Autorité pour la Bonne Gouvernance)
-Law No. 2013-867 of December 23, 2013 (Accès à l’information d’intérêt public)
-Decree No. 2014-462 of August 6, 2014 (Portant attributions, organisation et fonctionnement de la Commission d’Accès à l’Information d’intérêt Public et aux Documents Publics, CAIDP)
-Decree No. 2014-787 of December 11, 2014 (Portant nomination des membres du Conseil de la Commission d’Accès à l’Information d’intérêt Public et aux Documents Publics, CAIDP)

However, the performance report did not mention Côte d’Ivoire’s implementation action plans to make the anti-corruption and transparency measures in the defence sector effective. The measures had an implementation timetable that concluded on June 30, 2018 (1).

Furthermore, the military court, general security section of police services, the ministry of security and defence and the Military Civil Committee regularly meet to discuss security issues (2).

Furthermore, the anti-racket unit together with gendarmes conducts field operations to detect and prevent corruption. Security forces caught in the act of corruption are tried by the military court, the anti- racket unit is intensifying the fight through social media platforms. Security forces caught in acts of corruption were given a 3 months suspension (3).

The Danish Penal Code also applies to employees (miliatry and civilian) in the Danish defence sector. The penal code criminalizes bribery and contains a chapter on crimes within public service [1]. The Public Administration Act (Forvaltningsloven), which outlaws corruption in the form of incapacity, also apply to the defence [2]. The national code of conduct in the public sector (“God adfærd i det offentlige”) applies to the defence domain as well [3]. However, while research identified a code of guidance on incapacity (no different from provisions in the Public Administration Act), there is no evidence that there exists a comprehensive anti-corruption policy specifically for or within the defence sector [4, 5]. This was confirmed by a former civil servant [6]. Both the Ministry of Foreign Affairs and Ministry of Justice have an openly stated anti-corruption policy, and these are available online [7, 8]. These are not different from existing general legislation and code of conduct, but are intended to increase the knowledge about and awareness of corruption. There are specific administrative directives that concern the Defence domain directly – these stipulate directions for the acceptance and presentations of gifts and donations, for private (“menige”) performance of personal services, and for the acceptance and presentations of gifts, financial loans or other benefits between superiors and subordinates [9, 10, 11].

Research did not identify a specific action plan to foster effective implementation of the national anti-corruption legislation. However, in light of recent cases, the Minister of Defence is currently attempting to tackle the issue, and has for instance acted by ordering all 500 senior leaders (civil and military) in Danish Defence take a basic public administration course [1]. A professor highlighted that the Minister of Defence has not made new rules, but intends to emphasise existing legislation [2]. In conclusion, implementation of anti-corruption legislation has been lacking, but on the grounds of recent cases, a high-level focus on implementation has occured. This is work in progress that had not ended at the time when research was finalised. We may expect to see more focus on implementation and enforcement of anti-corruption legislation and policies within the Defence domain.

According to our sources, there are no anti-corruption policies that apply to the defence sector. There are no institutions that have the authority to oversee or issue laws and policies that target the defence sector or the armed forces (1), (2). The Central Auditing Organization, formerly under the control of the Parliament, was effectively taken over by Sisi in July 2015, when he decreed the appointment of its new director, giving him the capacity to fire, appoint and imprison the executives of auditing and monitoring institutions (3), (4), (5).

This indicator has been marked Not Applicable because Egypt has no anti-corruption strategy that tackles the defence sector (1) (2) (3).

Estonia passed a general anti-corruption law. [1] In addition, there is a Civil Service Act that, in addition to the officials of state and local government authorities, also applies to active public servants. For example, it states that an official must refuse to execute an order if “the order would lead to the breach of a procedural restriction for the purposes of the Anti-Corruption Act.” [2]
Estonia, however, does not have a clearly distinguishable, openly stated anti-corruption policy for the defence sector in particular. The National Security Concept [3] only briefly touches upon the issue. It states that in fighting corruption, Estonia prevents and pre-empts the proliferation of organised crime, the black market and money laundering. There seems to be no urgent need for an anti-corruption policy for defence, as it does not seem to be an urgent issue in the defence sector. For example, according to a report of Transparency International, the share of respondents who consider that defence sector is corrupt in Estonia was only 8%, which was by far the lowest level among various other areas (political parties, parliament, legislation, business, judiciary, medicine, public officials).

This indicator has been marked Not Applicable. The National Security Concept [1] only emphasises that it is important to tackle corruption for Estonia’s good reputation. There is no timeline or list of weaknesses, and no anti-corruption policy [2] specifically for the defence sector. This has also been confirmed by interviewees, a member of the National Defence Committee and an expert from the Ministry of Justice. [3,4]
The implementation of the overall Action Plan on anti-corruption (not particularly for the defence sector) is monitored regularly in Estonia. The implementation progresses according to the estimated timeline. Regular reports in Estonian are available online. [5]

There is a draft of anticorruption strategy produced by an anticorruption cooperation network operating under the mandate of the Ministry of Justice. The strategy was handed to the Ministry (after a commentary round) in February 2017, but it has not yet been confirmed by the Government. [1] The draft strategy is available on the Ministry’s website. [2] The strategy does not state whether or not it applies to the defence sector, but in general strategies like this are cross-sectoral and apply across the branches of government and admistration.

The existence of corruption in Finland is acknowledged and, for example, the Ministry of Justice’s website describes it as: “Studies show that instead of street-level corruption, Finland is characterised by larger-scale structural corruption that is more difficult to detect. Such corruption often occurs in the interface between the public and the private sectors. High-risk areas for corruption are the construction sector, public procurement and competitive tendering, urban planning, political decision-making, and party and campaign funding. Corruption typically takes the form of giving and accepting undue advantages, conflicts of interest and favouritism.”

The Ministry of Justice coordinates anti-corruption efforts in Finland and participates in international cooperation in combatting and preventing corruption. Other key actors in the field are named as the Ministry of the Interior, the Ministry of Finance and the Ministry for Foreign Affairs as well as the Office of the Prosecutor General and the court system. [3]

This indicator is marked ‘Not Applicable’. As noted in 7A, there is a draft of anti-corruption strategy produced by an anti-corruption cooperation network operating under the mandate of the Ministry of Justice, but it has not yet been confirmed by the Government [1,2]. The Ministry of Justice is coordinating anti-corruption work, which also applies to the defence sector, [3] but neither the Ministry of Defence nor the Defence Forces has any anti-corruption document publicly available. [4,5]

Since November 2016, there has been an anti-corruption policy through the Law “Sapin 2” on transparency, anti-corruption and the modernisation of the economy. [1] This law applies to all sectors of the government and of the economy, the Defence sector among them, unless “secret-défense” classification impedes its application, which can happen in specific cases. There is also evidence that the ministerial code on anti-corruption (“Code de prévention des atteintes à la probit”) is applied to the armed forces through an annual reporting system. [2] [3] No specific anti-corruption legislation exists for the defence sector.

The Law “Sapin 2” on transparency, anti-corruption and the modernisation of the economy of December 2016 created the French Anti-Corruption Agency (AFA), replacing the SCLC. [1] Since its creation (it took over a year for the agency to be staffed and ready to operate), the AFA hasn’t worked on corruption or compliance cases in the defence sector, according to an anonymous source within the agency. [2]
In compliance with the Law Sapin 2, the Ministry of Defence empowered the Military Ethics Committee with the appointment of an “Ethics manager” and a General rapporteur. In an interview, [3] this “deontologist of the armies” confirmed that, so far, no anti-corruption actions have been taken, though awareness programs and trainings have been undertaken. There is evidence in the Military Ethics Committee’s annual report that it follows up on case referrals of suspected conflicts of interest in relation to post-military appointments in the private sector. [4] A corruption risk mapping, based on the ministerial anti-corruption code (“Code de prévention des atteintes à la probit”) was also undertaken in 2020; though it is not clear whether full details are publicly available. [5]

There is an openly stated anti-corruption policy that applies to the defence sector. The Federal Government Directive Concerning the Prevention of Corruption in the Federal Administration applies to all federal agencies and the armed forces [1]. Generally speaking, German anti-corruption legislation is largely divided between the German Criminal Code and the Administrative Offences Act. The German Criminal Code applies to individuals and makes it illegal to offer, pay or accept a bribe. The Law on Fighting Corruption has expanded the scope of individuals covered by the act, now including German public officials in domestic and foreign transactions, MPs, delegates and EU officials. This Law has also expanded the capabilities of German authorities to prosecute foreign bribery (GLI 2018). The level of enforcement with regard to foreign bribery cases has steadily increased in the past few years (GLI 2018). Active and passive bribery of employees or agents of a company is criminal even if it does not involve a distortion of competition (GLI 2018). Companies can be held civilly liable for corruption offences committed by their representatives under the Act on Regulatory Offences, or if individuals in management roles intentionally or negligently omit necessary supervisory measures designed to prevent criminal activities. Fines can be up to EUR 10 million for each intentional criminal offence and up to EUR 5 million for each negligent criminal offence.

Facilitation payments are prohibited, while gifts and hospitality may be considered illegal depending on their intent, benefit and value (CMS 2016). Other relevant legislation includes the Money Laundering Act, which criminalises offences such as fraud, forgery and embezzlement, and imposes due diligence and reporting requirements on financial institutions and the majority of the wholesale and retail sector. In March 2021, the Act to Improve Criminal Law Combating Money Laundering passed into law. This Act implements the requirements of Directive (EU) 2018/1673 of 23 October 2018 on combating money laundering through criminal law [2]. It introduces an ‘all crimes’ approach by abandoning the catalogue of predicate offences for money laundering (see Section 261, German Criminal Code [3]). Previously, only objects that were derived from crimes (criminal offences with a minimum term of imprisonment of one year or more) or from certain other criminal offences listed in the law, and which usually had to be committed on a commercial basis or by a member of a gang, could constitute objects of money laundering. The inclusion of all offences as possible predicate offences is connected with a considerable extension of the scope of the money laundering offence. On the one hand, the offence is much broader than before; on the other hand, it will be easier for investigating authorities and courts to prove the predicate offence, since in the future it will only be necessary to convince the court that the objects to be laundered in the process of the crime, the product of the crime or another (asset) object of any crime that has taken its place [4].

Whistleblowers have some legal guarantees against arbitrary dismissal in the public and private sector, but there is no strong separate law regulating whistleblowing (WLG 2016). Public officials must maintain secrecy about official matters that become known to them during or on the occasion of their official activity. As an exception, they are allowed to report reasonable suspicion of corruption to the highest service authority or law enforcement agency under the Act on Federal Civil Servants [5].

According to page 6 of the Rules on Integrity published by the Federal Ministry of the Interior, Building and Community, which include the Directive of the Federal Government Concerning the Prevention of Corruption in the Federal Administration, ‘the Directive applies to the measures taken by all federal agencies for the prevention of corruption; the supreme federal authorities, the authorities of the direct and indirect Federal Administration, the federal courts and federal special funds are all considered to be federal agencies. The Directive also applies to the armed forces; the Federal Ministry of Defence is responsible for settling the details’ [6]. For example, page 104 of the Rules on Integrity describes the obligations under Section 14 of the Act on the Legal Status of Military Personnel (‘Secrecy’) [6]. All regulations are described in detail in a 208-page document [7]. Still, the Rules on Integrity are binding directives which provide concrete guidance on how to counter corruption. They therefore support the implementation of the ‘Directive of the Federal Government Concerning the Prevention of Corruption in the Federal Administration’.

The action plan at the ministry level reflects the institutional weaknesses in the system, as described on page 20 of the Rules on Integrity: ‘Examples of weaknesses that may lead to corruption include: 1) inadequate administrative and task-related supervision; 2) blind trust in senior staff or those with specialized functions; 3) character weaknesses of staff in sensitive areas; 4) negative example set by supervisors who accept gifts; 5) lack of consequences after manipulation has been revealed, therefore no deterrent effect’ [1]. However, these examples do not explictly refer to the defence and security sector. There is no information on whether implementation progresses according to estimated timelines.

The Federal Ministry of Defence has a provision on implementation called the ‘Federal Government Directive Concerning the Prevention of Corruption in the Federal Administration’, created in 2004. This provision details the expected standards of employee actions and behaviour in order to avoid any misconduct in this area. It also defines processes and responsibilities, such as the role of points of contact in larger agencies [2].

Additionally, further legislation such as the ‘Gesetz über die Rechtsstellung der Soldaten’ (Act Governing the Legal Status of Soldiers) [3], or the more general ‘Strafgesetzbuch’ (German Criminal Code) [4], includes articles concerning bribery and malpractice. Overall, there is evidence that the Bundeswehr implements the anti-corruption policies of the Federal Government.

Ghana ratified the ECOWAS Protocol on the Fight Against Corruption (ECOWAS Protocol) in 2003 (1), the United Nations Convention Against Corruption (UNCAC) (2), the African Union Convention Against Corruption in 2005 (3) and subsequently adopted in July 2014 its own National Anti-Corruption Action Plan (NACAP) for 2015-2024 (4), (5). However, although there is an openly stated anti-corruption policy, this does not include the defence sector (6), (7), (8), (9), (10). The Armed Forces Act of 1962 bans bribery but does not elaborate on more complex corruption rules (11).

The NACAP identifies institutional weaknesses as one of the prominent causes of corruption in Ghana, together with “poor ethical standards including limited commitment to the values of integrity and self-discipline, skewed incentives structure, and insufficient enforcement of laws within a patrimonial social and political context” (1), (2), (3), (4).

The government has shown a formal commitment to the implementation of the NACAP. For instance, government representatives participated in the Anti-corruption week and National Anti-Corruption conference organized in Accra on December 2017 (5). The NACAP is implemented by the Office of the President while the CHRAJ is the coordinating and monitoring agency (6).

The implementation of the NACAP started in 2015 and thus far two progress reports have been published, at the end of 2015 and 2016. However, they are not publicly available. According to the policy outcome indicators and targets identified in the CHRAJ Medium Term Economic Framework (MTEF) Estimate for 2017, 20 per cent of the NACAP has been implemented in 2017 (70 per cent target for 2021) (7). For the 2016 Independent Reporting Mechanism (IRM) of the Open Government Partnership (OGP), the implementation has been coded as “substantial” (according to OGP’s criteria, the completion of a commitment can be coded as “not started”, “limited”, “substantial”, “completed”) (8).

Greece adopted a National Anti-corruption Action Plan (2018-2021), which applies to the defence sector [1].

There is an anti-corruption action plan covering, among other sectors, the defence sector [1]. However, there is no evidence the government has taken action to implement it. The last implementation report was produced in 2018 [2]. However a relevant plan to fight corruption was developed by the OECD with the cooperation of Ministry of Defence officials titled “Draft Integrity Action Plan for the Ministry of Defence: Assuring high integrity and low corruption risk in defence contracting” [3]. It not clear if the plan was prioritised by the political leadership of the Ministry. It should be noted that it is primarily a plan and needs to be further elaborated on, and developed by, officials from the Ministry of Defence.

There was an anti-corruption strategy covering all branches of government adopted in 2015, but it expired at the end of 2018 [1]. The expired strategy required Hungarian soldiers to submit asset declaration (1). There has been no news on a new anti-corruption strategy (policy) of the government. There have been references addressing the anti-corruption commitments on behalf of the Ministry of Defence (MoD) in the current decade. A white paper was published in 2011 for 2010-2014 [2], but it primarily addresses the malpractices of the previous government and the lessons learned from that period, rather than guidance for the future.
The government has set an anti-corruption framework, the Integrity Leading System. The system includes the Anti-corruption Program and the Integrity Project as the practical steps of the anti-corruption policy framework. They outlined new regulations and actions to be taken in the public service [3, 4]. The MoD is part of this system and in line with it, it released a report in 2017. According to the report, an action plan was planned for 2018. This anti-corruption project is in line with NATO standards according to the Hungarian government’s sources [5, 6, 7].
The fact that MoD implements international anti-corruption methods in line with commitments of the North Atlantic Treaty Organization (NATO) membership of the country was acknowledged by the Deputy Director-General of NATO according to the coverage of the official news portal of the MoD in 2017 [3].

The white paper [1] addressed some institutional weaknesses but was unable to be translated into an action plan. The Integrity Report of the Integrity Leading System, shows that it is in line with the legal requirements, some anti-corruption measures were implemented in the ministry. There has been no update since 2017, but an action plan for 2018 was planned according to a report released by the MoD. Although the MoD meets the legal requirements monitored by the OECD, the action plan is not public [2, 3, 4]. However, the Integrity Leading System is only a formal tool that in a captured state [5] such as Hungary might not counter effectively corruption, especially the legalised parts of it.

The current government’s election success of 2014 was centred on bringing greater transparency in governance and combating corruption in all sectors including defence. Prime Minister Modi has sought to fight corruption and since taking office, has implemented a number of anti-corruption measures. In July 2018, the government passed the Prevention of Corruption (Amendment) Act, 2018, which amended and brought significant changes to the Prevention of Corruption Act, 1988 to bring the legal framework in conformity with current international practices of the United Nations Convention Against Corruption (UNCAC). India widened the definition of criminal misconduct to include the briber giver [1][2]. This Act is applicable to the defence sector.

India has an institutional and legislative framework for fighting corruption including an independent Central Vigilance Commission, Central Information Commission, Comptroller and Auditor General, the Judges (Inquiry) Act ,1968 and a number of legislations including the Whistle Blowers Protection Act , 2014; the Lokpal Act, 2013; the Prevention of Money Laundering Act; the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 and the Benami Transactions (Prohibition) Amendment Act, 2016 [3][4]. All of the aforementioned are applicable to the defence sector.

The Ministry of Defence (MoD)’s Vigilance Division is entrusted with the task of dealing with complaints regarding corrupt practices, misconduct and irregularities in respect of employees of the MoD and the various units under it. As part of new defence reforms, the MoD recently approved the establishment of a Vigilance Investigation Unit in the Army under the new ADG Vigilance. The unit will call upon Corps of Military Police (CMP) personnel to conduct independent investigations into corruption [5]. Each of the branches of the Armed Forces have an Act which governs them. These Acts such as the Army Act, 1950 cover corruption and mention penalties. The Indian Army Act, 1950, Chapter IV Section 53 states:

“53. Extortion and Corruption. – Any person subject to this Act who commits any of the following offences, that is to say : (a) commits extortion ; or (b) without proper authority exacts from any person money, provisions or service; shall, on conviction by court-martial, be liable to suffer imprisonment for a term which may extend to ten years or such less punishment as is in this Act mentioned.” [6]

The MoD has an Integrity Pact provision in procurement. Bidders and the MoD need to sign an Integrity Pact committing to not offering or accepting bribes and ensuring integrity in public procurement. Submission of Integrity Pact Bank Guarantee (IPBG) is needed. The Seller must confirm and declare to the Buyer that it is the original manufacturer of the stores contracted and that no third party has been engaged who can influence or manipulate award of the contract, or indulge in corrupt and unethical practices [7][8][9].

India has attempted to address country-wide systemic corruption with the Lokpal Act which came in to force in 2014, encouraging anti-corruption efforts from the Center. Its efficacy has yet to be measured given the delays in appointing a Lokpal. India does have a strong institutional framework to ensure the accountability of its defence institutions (10). These include the Comptroller and Auditor- General (CAG) and the Parliamentary Public Accounts Committee (PAC). State governments such as Maharashtra have an Anti-Corruption Bureau. The Central Bureau of Investigation (CBI) provides oversight and has an Anti-Corruption division [11][12][13][14].

One can conclude from above, that the government is robustly addressing corruption at the Centre, encompassing defence. From the significant changes to the Prevention of Corruption Act, 1988 to the new Vigilance Investigation Unit in the Army, the government is taking an holistic approach. Evidence of CBI cases filed against defence personnel shows that there is legal apparatus at work and implementation of the anti-corruption measures [1][2][3][4][5].

The area of defence that has courted the most controversy historically in India is procurement. It seems that this is acknowledged and the Defence Procurement Procedure (DPP) mechanisms are being tightened to allow less room for corruption, greater transparency and probity. There is evidence that sanctions have been recently applied such as suspension and banning. As of 2018, six firms were debarred from further business dealings with Ministry of Defence for a period of ten years [6][7]. This also applied to allied and subsidiary firms of each of the debarred firms. Business dealings with fourteen firms were suspended. Orders were issued restricting procurement from two other firms. In the past, Lockheed Martin, Textron, and Boeing have all been fined for failing to meet offset obligations [8].

Indonesia’s anti-corruption policy was issued through the Anti-Corruption Law of 2002 (which was amended in 2015 and 2019) [1]. Accordingly, President Widodo issued Presidential Instruction No. 7/2015 concerning Action to Prevent and Eradicate Corruption in 2015 [2]. Previously, the KPK issued Regulation No. 2/2014 concerning Guidelines for the Reporting and Determination of Gratification Status [3]. These three policies were adopted by the Ministry of Defence in Minister of Defence Regulation (Permenhan) No. 16/2015 concerning the Gratification Control System in the Ministry of Defence [4]. This Permenhan only regulates the control of acceptance of gratuities among Ministry of Defence employees. For this purpose, a Gratification Control Unit (UPG) was formed in the Inspectorate General. The UPG selects gratification reports that should be processed by the KPK and follows up on the KPK’s recommendations regarding the determination of the corruption case. The report is submitted by the UPG to the KPK no later than 30 days after the gratuity is received. This Permenhan also regulates administrative sanctions for Ministry of Defence employees who do not report gratuities to the UPG. As for the TNI, at least five regulations have been issued [5], including TNI Commander Regulation No. 15/2014 on Guidelines for Handling Gratification in the TNI Environment, TNI Commander Regulation No. 17/2014 on the Whistleblowing System and TNI Commander Regulation No. 19/2014 on the General Guidelines for Developing the Integrity Zone into a Corruption-Free Area and a Bureaucratic Area Serving Within the TNI. None of these regulations are available to the public. A quick check of the Ministry of Defence strategic plan 2014-2019 reveals that there is no dedicated programme related to anti-corruption, although the word ‘corruption’ is mentioned twice, once in reference to threats to the nation state and once as part of the President’s vision and mission, dubbed ‘Nawacita’. Interviewees have stated that, although there is no specific policy, there have been steps to push the anti-corruption agenda in the defence sector, for example, training for law enforcement officers in defence and security institutions [6], the application of the ISO 37001 anti-bribery standard in state-owned industry and a dedicated network between the Inspectorate in the Ministry of Defence and the KPK [7]. This special network enables information to be shared between the two institutions. A quick check of one of the state-owned defence companies confirms that, although the ISO has not been implemented, the industry has moved to adopt anti-gratification measures from the KPK [8].

This indicator is marked ‘Not Applicable’, due to the fact that there is no anti-corruption policy that applies to the defence sector. Despite the absence of an anti-corruption action plan for the defence sector, there are many forms of activities that uphold anti-corruption values. Some of the anti-corruption measures implemented at the ministry level include organising legal advice events on corruption for Echelon III and IV officials in the Ministry of Defence with speakers from the KPK [1], installing anti-corruption banners in various locations in the Ministry of Defence [2] and inviting the KPK leaders to the leadership meeting [3]. In early 2019, the KPK reported that, among all government institutions, the Ministry of Defence has the lowest level of compliance with the mandatory Submission of State Assets Report (LHKPN) [4]. In the defence industrial sector, a quick check of one of the state-owned defence companies confirms that, although the ISO 37001 anti-bribery standard has not been implemented, the industry has started to adopt anti-gratification measures from the KPK [5]. Unfortunately, anti-corruption efforts are still hampered by secrecy clauses in the defence sector. This was criticised by the Chair of the KPK, who recommended a more selective application of the clause [6]. Confidentiality should only apply to domestically developed weapons and force deployment and not to the defence budget. Another issue that was raised is the use of export credit for the procurement of weapons in Indonesia, something that had been banned by the OECD rules but allegedly maintained by weapons brokers.

There is currently an anti-corruption drive within Iran – and an explicitly stated anti-corruption policy [1]. Although, it is unclear whether this applies to the defence sector. It reportedly applies to the judicial system. Iranian Judiciary Chief Ayatollah Sadeq Amoli Larijani says he will not “tolerate” any form of corruption in the judicial system, pledging to publicly name all employees that are involved in such practices one way or the other. He said, “[m]alpractice is possible across the vast judicial system, just like it is in any other system” [2].

The supreme leader, the president, as well as many other senior officials, have spoken against corruption. But, the president also expressed hope that while he is in office, the cabinet could introduce a bill defining political and security crimes to help avert irregularities in this relation [1].
Depending on how these crimes are defined, such a move could either be positive or negative for anti-corruption within the defence and security sector.

This indicator is marked as Not Applicable, as the country has an explicitly stated anti-corruption policy [1]; however, it is unclear if this applies to the defence sector [2].

While no anti-corruption policy tailored towards the defence sector exists, Iraq’s National Anti-Corruption Strategy (2010-2014) provides a guide (1), and tangentially addresses defence corruption. It is unclear whether the UNDP-developed plan has been renewed. It was initially proposed as part of Iraq’s commitment toward the United Nations Convention against Corruption (UNCAC). There is no information on whether this has been since updated.

The policies and operational activities within the defence sector are not formulated with the aim of fighting/reducing corruption risks. The government’s top priority is geared towards the eradication of the remaining Islamic State terrorist cells (1).

As established in 7A, there is no anti-corruption policy that clearly appliess to the defence sector.

In the past 15 years corruption became a major issue in Israel. Therefore the fight against corruption in the public sector led to many plans by political parties and NGOs in order to tackle the phenomenon – particularly provided by the Ministry of Justice (1). Today there is no official policy against corruption in Israel that is clear to the public but there is a policy of how to fight against corruption, money laundering and organised crime. In 2006, the government decided to “determine the fight against severe and organized crime and their outcomes as a long-term goal” (2). As part of the government decision, two coordination and control bodies were established – A policy-setting board to outline policies to combat severe crime and organized crime and their outcome, and a lower level inter-agency Implementation Committee headed by the Head of the Investigations and Intelligence Division of the Israel Police. In recent years, the policy-setting board has taken on a more orderly manner of determining the priority of issues of interest to be addressed in a comprehensive strategy and policy of combating serious crime and organized crime and their products. In this context, the board determined that the fight against corruption is one of the issues that should be prioritized by all relevant bodies parties to the Implementation Committee. The Committee is charged with establishign tailored work plans that implement the priority in all relevant government bodies’ and ministries’ overall work plans, including the Ministry of Justice (3) and Ministry of Public Security (4) for instance. With regards to the MOD , the Directorate of Defence Trade Control (DECA) includes exmaples of the MOD’s anti-corruption policy, such as instructions for defence exporters regarding anti-corruption compliance programs, and letters written by the MOD DG to registered defence exporters on corruption prevention (5). However, these focus overwhelmingly on exports and there remains a lack of an overarching anti-corruption policy for the sector which would cover other areas such as operations for instance. Moreover, it is unclear to what extent the MOD is included in the government’s anti-corruption strategy as its work plan is not available.

There is an action plan at the ministry level that reflects the institutional weaknesses in the system. For example on the page of the Ministry of Justice, Israel’s Fight Against Bribery in the Framework of the OECD is described. It includes a description of the recommendations of the OECD Workings Group as well as the step that country aims to do (1). In November 2017, Israel submitted a detailed follow-up report which provides information on the progress made by Israel in implementing the recommendations of its Phase 3 report (2). However, this is the only official statement of the state related to an anti-corruption policy which is publically available. In terms of policy there is the “State Comptroller of Israel”, currently holding the position is Mr. Matanyahu Angelman, appointed by the Knesset. He does not hold any authority or power to make and change legislation, yet he is given access to a lot of information, which he later evolves into recommendation and if necessary, criticism over the state’s functioning, which can be further investigated into by the police if necessary. Attached is the detailing of the state comptroller authorities, by the official website of the Knesset (3). Also, in February of 1992 a law was passed in the Knesset, following a bill proposed by Knesset member of “Meretz” political party Mr. Ran Cohen, called “the law for encouraging integrity in the public service”. It was initiated following the report of the State Comptroller which showed signs of integrity. Furthermore, some civil society activity is apparent, including the very important work of an organisation called “the movement for the quality of government”. This non-profit movement was founded in 1990, it is independent from outside sourcing (relies on member fees of its on members) and relies also on volunteer work, the file lawsuits and engage the public in matters of corruption in the public sector, the raise awareness on a lot of problematic issues that require addressing (4). The Department of Justice provides on its website information related to specific laws, amendments and penalties to people in public office who are convicted of receiving or giving bribery (5).

According to Law 190/2012, the so called Legge Severino, the whole apparatus of Public Administration has to adopt an anticorruption and transparency plan [1]. In late 2019, the Anticorruption National Authority published the 2019 National Anticorruption Plan [2] identifying areas of major risk of corruption, also delineating the lines of action public administrations need to comply with, as regulated by law 190/2012, i.e. the Three-year Plan for the prevention of corruption and transparency that has to be updated every year [3]. Accordingly, ex art 1(5) of law 190/2012, the Ministry of Defence publishes every year the updated version of the Three-year Plan for the prevention of corruption and transparency and appoints the Anticorruption Supervisor. Admiral Chief Inspector Sabino Imperscrutabile has been appointed for this function in July 2019 [4]. Section III.2 of the Three-year plan of the Ministry of Defence indicates the main processes and areas of risk of corruption for the Ministry of Defence, which are addressed in the annual report of the Anticorruption Supervisor [5]. Moreover, the Supervisor releases regular administrative acts during the year [6]. In compliance with the Decree of the President of the Republic n. 62/2013 [7], the Ministry updated its own Code of Conduct in March 2018 [8].

Article 1(3) of law 190/2012 [1] also requires public administrations to publish all measures and actions undertaken to counter corruption. The document also defines deadlines whithin which certain actions (mainly annual monitoring activities and reports) need to be performed. In addition to the publicity of current and previous Three-year anticorruption plans [2], it is also possible to access the annual report of the Anticorruption Supervisor [3]. The last one identifies procedural and financial shortcuts that prevent the ministry from fully complying with the national anticorruption requirements and eventual delays on the foreseen timelines. Moreover, the document indicates ascertained cases of corruption, and specifies the sectors in which corruption occurred.

This indicator is marked ‘Not Applicable’ as there is no anti-corruption policy that applies to the defence sector. A search of the webpages of the Cabinet Secretariat for information on corruption did not return any hits after 2015, indicating that anti-corruption has not been a topic of focus by the Government in recent years. [1] Nevertheless, concerns about anti-corruption are stated in issues of the defence white book defence of Japan. A policy of “prevention of the recurrence of misbehavior (不祥事の再発防止) is stated in a section of defence of Japan 2016 which deals with ensuring fairness and transparency to avoid corruption in procurement. [2] The same phrase is used in defence of Japan 2017, in a section which refers specifically to avoiding the recurrence of incidents of padded invoices and falsification of equipment tests by defence manufacturers, as occurred in 2012. [3] The phrase is again used in the same section in defence of Japan 2018. [4]

The Ministry of Defence of Japan does not have an explicit anti-corruption policy (see Q7A), neither does an explicit action plan seem to exist. The ministry has, however, been concerned to avoid the recurrence of corruption, of which there were serious incidents prior to the timeframe of this research. For example, former Administrative Vice-Minister of Defence Moriya was sentenced for accepting bribes in 2008, [1] and two GSDF officials were charged with violating the Bid Rigging Act in 2012 and later sentenced. [2] In 2015, an Acquisition, Technology and Logistics Agency (ATLA) was established by integrating six sections of the ministry that worked with procurement, including parts of the staffs of the three service branches. The aim of this reorganisation was to professionalise and implement compliance measures for procurement. [3] Legislation on defence procurement was overhauled to bring it in line with the compliance requirements of the time. [4] According to Defence of Japan 2017, ATLA was set up with a 25-member internal inspection, audit and assessment unit. This unit was to conduct internal inspection with a focus on legal compliance and preventing collusion and internal audit of project administration, R&D, procurement and accounts. Furthermore, 14 members were to educate ATLA staff about legal compliance. In addition, to avoid further cases of padded invoices and falsification of test results by defence related businesses, which there had been in 2012, further examination of the systems used and reconsideration of penalties, as well as the achievement of effective audit was gradually implemented. Thereby, the Ministry of Defence was making efforts to prevent the recurrence of corruption scandals. [5] According to Defence of Japan 2018, efforts beginning in 2007 to reorganise the Ministry of Defence so as to prevent the recurrence of corruption had largely been completed, and new organisational reforms that are mentioned in this book do not have any clear link to anti-corruption work. [6] While an action plan determined before the timeframe of this research had been implemented with the establishment of ATLA in 2015 (see Q10A), no explicit action plan seems to have existed for the years that followed.

There is an openly and publicly stated anti-corruption policy, and it is applied to all governmental institutions. However, the policy spectrum for the defence sector is unclear [4]. According to Article 16(a) of the JIACC Law, the Commission can prosecute all acts or omissions that are prejudice towards public funds, abuse of power and nepotism in the public administration [1]. Furthermore, the Integrity and Anti-Corruption Commission exercises some oversight on the defence and security services. In its 2016 Annual Report, it indicates the number of grievances received against the Jordanian Armed Forces, the Public Security Directorate, the General Intelligence Directorate and General Directorate of the Gendarmerie, with some of these complaints still under investigation, although none have been exposed explicitly as related to corruption [2]. Additionally, in the National Strategy for Integrity & Anti-Corruption 2017-2025, JIACC sets an objective of establishing a partnership with security institutions to enhance anti-corruption performance [3, 5, 6].

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

It is not clear if defence institutions have anticorruption action plans that relate to the anticorruption policy [1].

Kenya has only recently adopted a National Ethics and Anti-Corruption Policy (NEACP), which was officially launched in October 2020. The policy was developed in line with Kenya’s regional and international obligations stipulated in various conventions among them United Nation’s Convention against Corruption (UNCAC), the African Union Convention against Corruption (AUCPCC) and the African Peer Review Mechanism (APRM). The Conventions require member States to develop, implement effective and coordinated anti-corruption policies including statutory provisions. [1] However, it is not explicitly stated whether the policy applies to defence [1].

Previously, the MOD relied on existing laws that govern the fight against corruption. The Defence Act No. 25 of 2012 section 124, of part VI indicates that corruption or economic related crimes committed by defence personnel will be punished in accordance with the provisions of existing laws among them the Penal Code (Cap. 63), the Anti-Corruption and Economic Crimes Act, 2003, public procurement and disposal act. The act notes that can only be tried in Civil Courts. [2] The Ministry of Defence (MOD) has in the past collaborated with the Directorate of National Cohesion and Values under Office of the President, to train its civilian and uniformed personell as well as to establish Ministerial Committee on national values and ethics at the ministry. The Ministerial Committee, according to the MOD, would among other strategies, be tasked with the role of monitoring and evaluating the implementation of corruption prevention strategies in the Ministry in relation to Leadership and Integrity Act, 2012. [3] In parallel, Executive order 6 of 2015 required all Ministries to integrate and implement ethics and integrity-building measures in public service, including the MOD [4].

As the NEACP was only launched in October 2020, it remains too early to assess its implementation. Nevertheless, the implementation of other corruption-related policies has been limited. For instance, despite the establishment of the Ministerial National Values and Ethics Committee at MOD, there is no known publicly available evidence of its implementation as well as impacts. Furthermore, although Kenya has a number of laws that govern the fight against corruption, various reviews still faces challenges in implementing them. [1]

Open Government Partnership Independent Review Mechanism conducted between 2016 and 2018 noted despite there being a number of initiatives to fight corruption, implementation is half-way and the impact was minor. The review noted corruption remains pervasive and endemic and more importantly it undermines security, accountability systems and access to service across the state. [2] MOD is not exempt from these challenges.

The task force appointed by the Attorney-General to advice the President on appropriate interventions for enhancing the fight against corruption noted among other challenges, not only noted that there was a generally slow implementation of various anti-corruption strategies but also went to the extent of recommending amendement of section 43 of the Leadership and Integrity Act, No. 19 of 2012. The taskforce noted that at the moment according to Article 157(6) (a) of the Constitution of Kenya, the Director of Public Prosecutions cannot institute charges under the Kenya Defence Forces Act. [3]

In this regard, the taskforce recommended that in order to create a nexus between the investigations under the Leadership and Integrity Act and prosecutions under the Kenya Defence Forces Act, 2012, that amendments are introduced to Section 43 of Leadership and Integrity Act, No. 19 of 2012 to add that ‘Where the concerned State officer is subject to the Kenya Defence Force Act, 2012 (No. 25 of 2012), the matter shall be referred to Director of Military Prosecutions appointed under Section 213 of the Kenya Defence Forces Act. This amendment, they argue, will prevent the cases being disposed by a Court Martial when the State Officer is subject to the Kenya Defence Forces Act.

In July 2019 the Ministry of Defence publicly launched the new Integrity Plan (2019-2022) for the Ministry of Defence and the Kosovo Security Forces [1, 2], prompted by the fact that the previous plan ran up until 2018 [3]. The newly launched plan is the main document of the Ministry of Defence for reducing and eliminating corruption risk within the Ministry and the Kosovo Security Forces [4]. It is worth mentioning that this document is a continuation of the previous Integrity Plan (2016-2018) [3] and fits with the current legal framework in Kosovo promoting good governance and the principle of merit in the management of human and material resources, as well as in public expenditure [4]. Additionally, the plan is in line with the international legal standards that Kosovo has unilaterally adopted and it presents the aspirations of Kosovo for membership in the European Union and the North Atlantic Trade Organisation [4]. Therefore, the Integrity Plan is particularly focused on the following five objectives applied at all levels of the Ministry of Defence and the Security Forces [4]:
improve the human resources management system;
prevent conflict of interest;
Improve the procurement and contracting system;
Improve the material, financial resources and asset management system;
Strengthen internal control mechanisms.

The implementation of the previous Integrity Plan (2016-2018) was considered a great success by the Ministry of Defence [1], even though not all measures laid out in the plan [2] were fully implemented. Out of twenty-two determined measures, seventeen of them were fully implemented and seven other measures were only partly implemented [1]. The most challenging issues stated by the Ministry of Defence is the Government’s delay on drafting the Regulation on Procurement for Defence and Security Purposes; the Ministry’s inability to recruit officials with professional knowledge in the field of defence, who are also proficient in English and other languages for researching the international market; and the Ministry’s inability to increase personnel within the Internal Audit Office and the Special Forces Inspectorate due to limitations in the organisational structure [1]. This information on the implementation of the previous plan is reflected within the Integrity Plan (2019-2022) of the Ministry of Defence in a summarised format [1], while detailed information on the implementation of each measure and activity of the previous plan are not publicly available because the reports are not published by the Ministry of Defence.
With regards to the new Integrity Plan (2019-2022), it is still too early to assess the implementation of measures and activities.

Yes, according to the government reviewer, the Regulation on Defense Procurement No. 03/2019 of the GoRK was finally approved by the Government on 20.02.2019 [4]. Moreover, the internal guidelines of the MoD for special procurements have been also approved. Restrictions on increasing the number of staff of the Internal Audit Unit and the Inspectorate have already been exceeded with the approval of the new structure of the MoD by the Government and the start of its functioning in June 2019 [5]. But due to the suspension of the law no. 06/L-114 for public officials for a period of time, recruitment procedures for officials with professional knowledge in the field of defense industry have not been conducted.

The ACA (1) and SAB (2) all have an openly stated policies that explicitly tackle corruption and apply to all state institutions, including the security and defence institutions.

Article 4 of the ACA’s law says that its job is to “fight corruption” in general; “protect state bodies from bribery, trading influence and abuses of power” and “freeze and retrieve money and proceeds produced by” corrupt practices. But ACA can only investigate if it received a tip or complaint, or if there was public anger over something.
The SAB is based on a number of laws that explicitly fight corruption. One of these laws is Law no. 31 of 1970 for crimes (3), outlaws the embezzlement of public funds. Article 44 says that any public servant, including the ones in the security services, can be sentenced to at least three years in jail if they are caught embezzling state funds; if they have stolen services or documents that belong to the Government; or if they are profiteering from them any of the above in any way. To leave no room for doubt, article 2 of Law no. 25 of 1996 (4) for state transaction explicitly gives the SAB the right to review all defence and security agreements, including arms acquisition contracts.

However, this is undermined by article 78 of the SAB’s law (2) which is problematic because it allows the head of the body to reduce the amount of records that would be reviewed in any Government body by up to 50 percent during emergency situations — but the article does not explain what qualifies as an emergency. The only saving grace is perhaps that the SAB is not allowed to tell the agencies which one is getting less scrutiny.

The damage caused by the former article might be mitigated by article 80 of the SAB’s law (2) which says that ministries with secret projects must deliver a report to the SAB every three months, written by the minister himself, which should say how much money has been spent on these projects and the minister must sign a statement vowing that the funds were spent on approved matters only.

Parliament also has openly stated anti-corruption policies but the text does not use the word ‘corruption.’

Article 171 (5) says Parliament must monitor the revenues and expenditure of each state body, and article 163 says state funds cannot be spent on anything without parliamentary consent.

There is an action plan, officials said (1, 2, 3 and 4). The finance departments of each defence and security institution is meant to keep records of all its financial transactions, which are to be reviewed once a month by an auditor from the Finance Ministry. If the internal auditors or the Finance Ministry auditor suspect anything, they can report it to the ACA or SAB anonymously, who would refer the case to the prosecution if their own investigation concludes that there has been foul play, they said. SAB auditors review the finances of the security and defence institutions, like other Government agencies, once a year anyway in compliance with the SAB’s law (5).

The SAB actually reviews spending on secret defence and security projects more regularly given that article 80 of its law says that ministries with secret projects must deliver a report to the SAB every three months, written by the minister himself, which should say how much money has been spent on these projects and the minister must sign a statement vowing that the funds were spent on approved matters only.

This is somewhat counteracted by article 78, which allows the head of the SAB to reduce the amount of records that would be reviewed in any Government body by up to 50 percent during emergency situations — but the article does not explain what qualifies as an emergency. The only saving grace is perhaps that the SAB is not allowed to announce which Government agency is getting less scrutiny.

On paper, the plan is sufficient, auditors say, but in practice, it reveals institutional weakness. For starters, the finance departments in these institutions are only as strong as the minister, their boss who controls their income, allows them to be, and so their reviews can be extremely shallow (1, 2 and 3). There is nothing in place in these ministries that address this weakness, but the state appears to be trying to address it through the ACA, SAB and Parliament.

Virtually all ACA and SAB officials and reports acknowledge the weakness of the internal auditing process and try to address it by continuously raising the issue with the leaders of the executive branch; and demanding the information that the finance departments are too afraid to ask for.

There is a organisational anti-corruption plan in the Ministry of Defence and its subordinate institutions. [1] However, the anti-coruption policy cannot be found on the website of the Ministry of Defence. [2] The ministry pays attention to the anti-corruption policy even the plan is not publicly available: every year, employees of the Ministry have training where corruption issues are discussed. [5] Besides, the special section on the issue of whistleblowers is available on the home page of the MOD. [2] Anti-corruption has not been a frequent topic in the public announcements and speeches of defence sector officials.

The MOD regularly provides information to the KNAB in the form of reports on the implementation of the tasks specified in the Guidelines for the Prevention and Combating of Corruption. The MOD has been identified as responsible for cooperation with the KNAB, and an anti-corruption plan is updated annually. In the Ministry’s internal regulatory enactments, there are plans to determine additional measures for the prevention of corruption risk, such as the procedures employees must follow in case they wish to report possible violations, including measures to ensure the anonymity and protection of the reporting agent, the procedure by which public officials report a conflict of interest situations and procedures for issuing permits for interconnection. [1] Public access to the action plan is limited but it is communicated to employees via the intranet and the code of conduct. When employees sign a contract with the MOD, they also undertake an obligation to respect and follow the anti-corruption policy of the MOD. [2]

Although there is a general political agreement to combat corruption, Lebanon does not have an official anti-corruption strategy. In May 2018, Lebanon launched the “National Anti-Corruption Strategy” and its executive plan in collaboration with UNDP and the Office of the Minister of State for Administrative Reform (OMSAR) (1). The ministerial statement of the new government, from January 2019, included the aim to approve the anti-corruption strategy. (2) However, the government decided to revise the strategy due to the harsh language it adopted. (3) The strategy, however, does not include the defence sector nor the Lebanese Army (4). Although the LAF does not have a policy for anti-corruption per se, anti-corruption measures are integrated into its laws and regulations, according to the DoO (5).

This sub-indicator has been marked Not Applicable because, at the time of undertaking the GDI research, Lebanon did not have an official anti-corruption strategy. However, combating corruption is one of the main concerns the Government of Lebanon is trying to address (1). CEDRE donor countries are offering investment funds that will only be given if serious and effective measures for combating corruption are adopted (2). In September 2018, the Lebanese parliament passed several laws related to combating corruption (3). Although, the LAF does not have an anti-corruption policy, but anti-corruption measures are integrated into the laws and regulations which military personnel are consistently reminded of, according to the DoO (4).

There is an openly stated anti-corruption policy explicit to the defence sector [1]. There is also a plan on how to implement the program for 2017 – 2021 [2].

The action plan at the ministry level reflects the institutional weaknesses in the system, and implementation has progressed according to the estimated timeline. The weaknesses identified include the formal approach to the implementation of anti-corruption measures, insufficient qualification of personnel responsible for corruption prevention, and the insufficient information being published [1]. In addition, the Ministry of Defence provides more detailed and annually-updated information on its website about the implementation of the Action Plan [2]. However, the risks are not prioritised, and some of them are process-oriented rather than results-driven [3].

The new government has stepped up efforts to combat corruption, as a result of the 1MDB grand corruption scandal which saw former Prime Minister Najib Razak charged with numerous criminal offences. [1] [2] Various new institutions have been set up, such as the establishment of the Special Cabinet Committee on Anti-Corruption (JKKMAR) and the Governance, Integrity and Anti-Corruption Centre (GIACC) on top of the national anti-corruption agency MACC. The new government has also formulated the National Anti-Corruption Plan as a measure to eradicate corruption. [3] [4] [5] The anti-corruption policy encompasses all sectors, including defence.

Malaysia has released the formulation of the National Anti-Corruption Plan, [1] in which practical goals based on initiatives to be taken by every government and private agency to address corruption issues are set for the next five years. Under the National Anti-Corruption Policy (NACP), the Ministry of Defence (MINDEF) is currently in the process of drafting an Organisational Anti-Corruption Plan (OACP). [2] [3] However, it is still too early to analyse the effectiveness of its implementation as it is only set to be completed in 2020. Nevertheless, numerous efforts have been made by the MACC to combat corruption in defence, such as the scrutiny of the Ministry of Defence’s land swap deals and a move to reopen the Scorpene case. [3] [4]

The present government has taken measures to combat corruption, but has not formulated a dedicated plan as such. In 2014, the government enacted a law that requires all civil servants, including military personnel, to declare their assets.⁵ ⁷ The maximum punishment for corruption offenses is 20 years’ imprisonment or fines. However, members of parliament and their children are exempt from the declaration requirements.
State employees were supposed to comply with the law by 2017, but following strike action by civil servants, the government agreed to suspend the application of the law and revise the text.⁸ The government has subsequently limited the application of the law to certain categories of civil servants, meaning that now only about 1,500 people will have to declare their assets.⁷ Consequently, the vast majority of military officials (if not all) are now exempt from the law.
In addition, contracts concluded by the Ministry of Defence and Veterans’ Affairs and military outlays are not subject to the procurement rules of the Public Procurement Code. Indeed, a security expert working with the Malian authorities confirmed that they had seen no evidence of the MDAC formulating or adopting an anti-corruption policy.⁴

Mali does not have an anti-corruption policy that applies to the defence sector. Therefore, this indicator has been marked Not Applicable.

There is a National Anticorruption System which establishes the principles, general foundations, public policies, and procedures for coordination between the authorities of all levels of government in the prevention, detection, and punishment of administrative offenses and acts of corruption. [1] This system is also applicable to the defence sector and, therefore, it has had to integrate initiatives in this regard such as CEPCI.

The defence sector has openly expressed its commitment to this fight, mainly through official speeches. [2] However, specialists point out that there is no open anti-corruption policy for the defence sector, as it has not been institutionalised or citizenised as it should be. [3] [4]

The defence sector has integrated an action plan to combat corruption as part of the demands of the National Anti-Corruption System (“SNA” in Spanish). [1] Consequently, it has adopted an approach that tends to cover institutional obligations but that contains actions focused more on reinforcing values among its officials than on addressing the weaknesses of the system. Specialists on the subject have commmented on this action plan and suggest that there are still great challenges in this area, and that SEDENA continues to have a corruption problem despite the existence of SNA. [2] [3] [4]

The Ministry of Defence adopted the Integrity Plan of the Ministry and the Army and an action plan for its implementation. [1] This obligation is set out by the Law on Prevention of corruption for all public institutions. [2]

According to the Ministry’s report on the implementation of its action plan for integrity, only several superficial measures have been implemented. [1] Steps have been taken, for instance, to establish the Integrity Department by The Rulebook on Internal Organization and Systematization of the Ministry of Defence, which deals with the issues of strengthening and building the integrity and fight against corruption in the defence sector, both independently and in cooperation with other institutions. [2] Yet, the action plan does not address institutional weaknesses in the Ministry or in the Army. [3]

The general anti-corruption policy is vague and shows shortcomings in its implementation. No evidence shows that it applies to the defence sector, as it does not appear in the list of sectors addressed by this general anti-corruption policy, which consists in the elements referred to below:

– In 2015 a law was passed to replace the Central Body for the Prevention of Corruption or ICPC (Instance centrale de prévention de la corruption) by the National Body for Probity, Prevention and Right against Corruption or INPPLC (Instance nationale de probité et de lutte contre la corruption) (INPPLC) (1)

– This law was by followed by a series of announcements such as the adoption of a project to fight nationally against corruption; the signing of a framework agreement of ten programmes relating to 239 projects between various sectors; and relevant institutions joining forces for the creation of the Commission Nationale Anti-Corruption. None of them neither explicitly nor implicitly refer to the armed forces or defence as part of the sectors concerned (2)(3)(4)

Moreover, it appears that the National Body for Probity, Prevention and Right against Corruption has not yet been formally recognised.(5) Additionally, the government announced that the National Anti-Corruption Commission was to become an institution in its own right. However, no action has been taken so far in this regard (6)(7)

Morocco does not have an anti-corruption policy that also applies to the defence sector. Therefore this sub-indicator is Not Applicable.

Myanmar has the Anti-Corruption Law of 2013 [1] and the Anti-Corruption Commission according to the law. The Commission takes legal action against corrupt officials. However, the Commission cannot take any action against the military according to Article 20(b) of the 2008 Constitution. Article 20(b) states that the military can administer and adjudicate all of its affairs independently [2]. U Aung Kyi, the Chairman of the Anti-Corruption Commission, said that the Commission cannot take any action against the Ministries of Home Affairs, Border Affairs or Defence, the ministers of which are nominated by the Commander-in-Chief (C-in-C) of the Tatmadaw (military) [3]. In an interview, a retired senior officer said that the rules laid out in the Defence Services Act and Military Misconduct Law, which relate to misuse of power and are distributed to all military personnel, must be strictly adhered to by all personnel, although the Military Misconduct Law is not available to the public [4].

This indicator is marked ‘Not Applicable’, since there is no anti-corruption policy that also applies to the defence sector. U Aung Kyi, the Chairman of the Anti-Corruption Commission, said that the Commission cannot take any action against the Ministries of Home Affairs, Border Affairs or Defence, the ministers of which are nominated by the Commander-in-Chief (C-in-C) of the Tatmadaw (military) [1]. Brigadier General Zaw Min Tun, spokesperson for the military, said that the military does not neglect corruption cases and has taken action against corrupt officials through its own internal mechanism. For example, Major General Nyi Nyi Swe, Head of the Southwestern Command and former Head of the Northern Command, and Brigadier General Maung Maung Zan, Commander of Division 101, were investigated and suspended from their positions for accepting bribes. According to Brigadier General Zaw Min Tun, punishments in the military are harsher [2]. It is rare that action is taken against military personnel for corruption and the action taken is rarely made available to the public.

The model approach for basic standards of integrity’ obliges all Dutch government organisations in public administration and the police to pursue an integrity policy [1]. For the Ministry of Defence, anti-corruption policy is covered in the ‘Implementation of Defence Integrity Policy’ [2]. The policy outlines basic rules of integrity, reiterates the Code of Conduct for Defence and provides more detail with regard to the Code of Conduct by addressing and explaining bribery, gifts and hospitality, conflicts of interest and post-separation activities [2]. Furthermore, Chapter 11a of the General Military Personnel Code (‘Integrity’) includes provisions on bribery, gifts and (financial) conflicts of interest [3]. The awarded score reflects the fact that the policy is both specifically for defence and is publicly accessible.

The policy reflects the institutional weaknesses in the system, notably by describing corruption risks that are (somewhat) specific to the Ministry of Defence. This includes mentions of the power and status that come with being part of Royal Dutch Military Police, who have both military and law enforcement status, and of the likelihood that defence employees will receive gifts and invitations to occasions, as well as the fact that incidents may occur during international missions and that employees are sometimes working in very harsh conditions [1]. Institutional weaknesses (namely the fact that power dynamics will prevent reporting and that reports might not be acted upon or that reporters might not know whom to trust) are also addressed in Chapter 6, which outlines multiple avenues to report a defence employee, ways to escalate the report that do not involve direct supervisors, as well as access to confidential advisors [1]. At the time the policy was published, the instruments and measures described were already in place and the policy came into effect ‘the day following publication on the intranet’ [1].

As per the State Sector Act 1988, Section 57, the State Services Commission’s Standards of Integrity and Conducts has information and regulations around integrity, espousing that work conducted must be fair, impartial, responsible and trustworthy [1]. This forms one of the pillars of the broader integrity and conduct programme, which “aims to build trust by supporting the institutional integrity of agencies and trustworthiness of State servants” [2]. More specifically, this encourages public service departments such as the MoD to create positive and safe workplaces, enhanced public trust, identify and minimise conflict of interest, and gifts, benefits, and expenses [3]. There is also a comprehensive guide to the State Services Commissioner’s Standards of Integrity and Conducts, which provides a useful introduction to employees and interested members of the public [4]. However, the NZDF is not covered by the State Services Commissioner’s Standards of Integrity and Conducts as it is deemed to be a Non-Public Service department [5]. Military personnel are also subject to the Armed Force Disciplinary Act 1971. Section 54 of the act specifically relates to official corruption and bribes [6]. Similarly, civilian employees are held to account by Section 60 of the Code of Conduct issued by the Chief of Defence Force [7]. The Controller and Auditor-General release information on managing conflicts of interest. While the Auditor-General has no “explicit statuary role with regard to conflicts of interest”, it is the independent auditor of the MoD and NZDF and as part of that process examines “an organisation’s systems and processes for managing conflicts of interest” and as such it would be an obvious code of conduct to follow for those organisations [8]. Staff in the Intelligence Community are subject to New Zealand law, which includes the Crimes Act and Secret Commissions Act that include bribery and corruption offences.

Employees in public sector agencies, including the GCSB and NZSIS, are also required to adhere to the Public Service Commissioner’s standards of integrity and conduct as a condition of employment. These include: be honest; work to the best of our abilities; ensure our actions are not affected by our personal interests or relationships; never misuse our position for personal gain; decline gifts or benefit that place us under any obligation or perceived influence; and avoid any activities, either work or non-work, that may harm the reputation of our organisation or of the State Services. The Intelligence Community has a range of internal policies that address potential areas for corruption. Similarly, staff are required to gain and maintain security clearance that assesses their trustworthiness and responsibility. Across the New Zealand Government, the Serious Fraud Office have developed an anti-corruption work programme with other Government agencies. This is intended to reduce the risk of corruption in public sector agencies, and has been collaborated on by the NZSIS and GCSB [9, 10, 11, 12]. Agency work is also guided by ministerial policy statements, which set out principles that the NZIC must apply when planning and carrying out activities. The Intelligence and Security Act 2017 requires that the Minister responsible for the intelligence and security agencies issue Ministerial Policy Statements in relation to the lawful activities of the agencies [13]. Despite the comprehensive policies, regulations, and standards which the Government has in place, there is no single anti-corruption policy document, however the NZDF does have a Fraud Control Framework through which it “applies a set of principles and actions to mitigate risks.” [14] As of early 2021, it appears that this framework has been expanded, or superseded, by a ‘NZDF Fraud and Corruption Framework’ [see question below]. The NZDF has also communicated internally that any references to Fraud within these control frameworks “should be read as references to Fraud and Corruption.” [15]

There is not enough evidence to score this indicator. The NZDF recently formed a Counter-Fraud and Anti-Corruption Advisory Group, the terms of reference of which includes assisting “governance oversight of the effective implementation and ongoing operation of NZDF’s Fraud and Corruption Framework.” [1] [2]. As the Advisory Group and the Fraud and Corruption Control Framework are both relatively new, the level of implementation is unclear.

There is an anti-corruption policy – National Strategy to fight Corruption and its Action plan – adopted in January 2018 by the Council of Ministers (1, 2). The Presidential Renaissance programme for 2016-2021 includes fighting against corruption in the security and defence institutions as part of the improving security governance strategy (3). Nevertheless, specific provisions regarding the implementation of the strategy in the defence and security sectors were not identified by the assessor. However, the 2003 Military Penal Code addresses corruption: art. 228 states that officers found guilty of corruption, theft or general crime can be dismissed, demoted or imprisoned (see question 35 for details) (4).

The National Strategy to Fight Corruption provides an action plan for dealing with the issue (1,2). In April 2018 a steering Committee for the National Strategy was put in place (3). It shows that there is a willingness to implement the strategy. However, it is not clear to what extent the strategy and action plan directly apply to the security and defence sectors. 
On a broader level, Niger has developed a large number of instruments to fight corruption.
One of the most important includes the High Authority Against Corruption and Similar Crimes (HALCIA), created in 2011 (4). It is responsible for the following tasks: “monitoring and evaluating the government’s anti-corruption programme; registering, centralising and acting on any complaints or offences filed with it regarding any practice, deed or act of corruption or similar offences; conducting any studies or investigations, and proposing any legal, administrative or practical measures that are liable to prevent or curb corruption; disseminating and publicising legislation relating to the fight against corruption; identifying the causes of corruption and proposing to the competent authorities any measures liable to eliminate those causes in all public and semi-public institutions; and accomplishing any other task conferred upon it by the President of the Republic” (5). In December 2016, the Niger government adopted a new anti-corruption bill (6), which granted the HALCIA greater powers (among the most important powers, it has acquired a right of self-referral; the lifting of bank secrecy; the direct transmission of reports to the Public Prosecutor and the opening of a judicial inquiry). In April 2017, the government of Niger had recovered more than USD 5 million in bank accounts, real estate and property.
Therefore, even though it is not entirely clear how the action plan of the National Strategy to Fight Corruption (SNLC) applies to the defence and security sectors, authorities have put in place instruments to fight corruption on a broader level.
The action plan of the SNLC, a broad-based toll, was adopted in January 2018. It is not specific to the defence sector. At the time of the assessment, it was not publicly available and it is too early to comment on its effectiveness or its implementation.
This sub-indicator seeks to determine effective implementation at the level of the Ministry of Defence or Ministry of Interior. The SNLC is not tailored to each ministry and cannot be implemented effectively for questions such as high-level arms procurement.

IIt is not clear how the National Anti-Corruption Strategy relates to the military sector as there is no specific reference to the military sector in that document. Similarly, the Procurement Act does not apply to the military sector. The implementation of the National Anti-Corruption Strategy (NACS) is still being discussed (1). The reccomendations in the document suggests that organisational heads should implement the action plan within ministries and departments, including the Ministry of Defence. The strategy identifies who is responsible for dealing with anti-corruption within government ministries, and states what types of actions should be taken to address corruption including the monitoring and evaluation of the success or failure of such policies. It also emphasizes the need for mainstream ethical considerations within government processes and the importance of sensitization and training concerning corruption issues (1), (2),(3).

The National Anti-Corruption Strategy sets out the broad vision and goal, and it is left to the individual units to develop an action plan to implement the strategy within individual units of the Ministries Departments and Agencies (MDAs) (1).
For example, the plan states “within each ACA, MDA, State and Local Government, a Strategy/Change Management Committee [SMC] will be established to drive the implementation of provisions of the NACS. It is recommended that the same change management team will also be responsible for the implementation of the Open Government Partnership Action Plan and other Reform initiatives of the government of Nigeria. This SMC will aim to develop an action plan to implement the strategy within individual units of the Ministries Departments and Agencies [MDAs] [1]. The strategy sets out the very broadest of objectives, and it is left to the MDAs to develop their action plans in the defence sector (1), (2).

The specific target of the NACS relevant to the defence sector includes the objective to “Strengthen the ICPC Anti-Corruption and Transparency Units in MDAs [ACTUs] through professionalization, training/certification, better staffing and more independent funding sources 12 months [4.1.4]; Enforce sanctions for MDAs that do not comply with ACTUS, Freedom of Information Requests” [NACS pg.29] (3). Other elements of the NACS relevant to the area of procurement will also have an impact on the defence sector. The NACS sets out an intention to “Strengthen the implementation of the Public Procurement law by the Bureau for Public Procurement and enforce non-compliance within 12 months” (3). However, the strategy sets out the very broadest of objectives but it is left to the MDAs to develop their action plans in the defence sector.

There is no evidence to the degree of the existence of commitment within the defence sector to realise the objectives identified in the general strategy document. Furthermore, there exists no action plans/implementation strategy specifically that has been developed or published for the military sector.

There is no specific anti-corruption policy for the defence sector at a national level. The country strategy for anti-corruption is reflected in the Law on Prevention of Corruption and Conflict of Interests (2019, which replaced 2002 Law on Prevention of Corruption) and embodied in the State Commission for Preventing Corruption which issues a four years anti-corruption program. It tackles corruption in state, public and private institutions as well as abuses of budget and public funds [1]. New Transparency Strategy 2019-2021 with an Action Plan [2] and National Strategy for Fight against Corruption and Conflict of Interest 2020-2024 [3] cover the defence sector, too.
Fighting corruption within the defence sector is also addressed by the Law.
The 2019 EU Commission Report on North Macedonia notes strengthened legal framework in the fight against corruption and proactive steps taken by the new State Commission, involving investigations against high-level officials across the political spectrum, that already yielded results. [4]

The MoD implemented an Integrity Plan 2016-2019 with an Action Plan. The Integrity Plan is a three year document that focuses on institutional weaknesses. The Plan is drafted upon the recommendations of the 2016 NATO Peer Review Report, presented upon the findings of the Integrity self-assessment process. The IP focuses on five areas and aims to: strengthen the legal and institutional framework, advance the human resources management, reduce the risks of corruption when sending personnel abroad to international missions or operations, advance logistic processes and strengthen of the culture of integrity. [2, 9]
The implementation of the plan, although ongoing, can not be accurately measured. Trainings such as the January 2018 training for building integrity within the Ministry of Defence and Army Chiefs of Departments as well as other high ranking defence officials were indeed implemented [5]. Nonetheless, other trainings are not so publicised, and no public record is available for them. MoD claims that trainings on anti-corruption and integrity have been performed on regular basis. In 2018 MoD started the Train the Trainer Programme with strong support of the NATO BI Programme. [9]
As for the risks of corruption abroad, these have allegedly been minimised. Following the 2016 integrity plan, corruption during deployment in international missions corruption as a strategic issue is taken into account in the forward planning of operations [2].

The MoD also follows the recommendations of the 2016 – 2019 state anti-corruption program [1] in the areas of preventing conflicts of interest, implementing the Law for Protection of Whistleblowers, strengthening the culture of integrity, enhancing access to public information and improving transparency [2]. All these issues, including the Law for Protection of Whistleblowers, have been implemented or are in an implementation phase [3]. However, since the enactment of the above Law in 2016, no application has been submitted by whistleblowers to the State Commission for the Prevention of Corruption, which raises questions around the effectiveness of this Law [4].

Besides this, transparency has noticeably increased. The Ministry of Defence operates according to a Rulebook on Transparency [6] and a Code of Ethics for the Ministry of Defence and Army of North Macedonia employees [7]. Both these documents address issues of corruption. Furthermore, the Ministry of Defence advertises a ‘Report Corruption’ hotline on its website to which citizens can report cases of bribe and corruption to the Ministry of Defence and the Army of the North Macedonia [8].

The long-term anti-corruption policy was outlined in the Action Plan on Attitudes, Ethics and Leadership for the Defence Sector published by the Ministry of Defence in 2009 [1]. The Action Plan summarises actions already implemented, as well as future plans. In 2014 the Action Plan was evaluated by an independent auditor [3]. The report recommended that a new plan for the defence sector was not necessary and that, instead, anti-corruption measures should be implemented in the day-to-day management of the Ministry of Defence’s subordinate agencies. The Defence Annual Report for 2018 highlights anti-corruption work within the Norwegian Armed Forces, in particular close collaboration with the Norwegian division of TI and a comprehensive anti-corruption programme, at first implemented by the Norwegian Defence Materiel Agency, but with plans to expand it gradually to other agencies [3]. However, due to lack of funding on the part of the Norwegian division of TI, the scope of the programme had to be reduced [4].

The Action Plan on Attitudes, Ethics and Leadership for the Defence Sector for the period 2009-2012 recommended a range of measures to address the institutional weaknesses in the system, including evaluations of ethical and attitudinal challenges in military exercises and operations; developing and applying ethical guidelines tailored to the organisation; and following up systems for reporting and following up irregularities (including topics related to attitudes, ethics and leadership in performance assessment and development interviews, service statements, leader pay contracts and leader and employee surveys and evaluations); establishing or continuing systems for internal ethical advice, e.g. various forms of ethics committees (including attitudes and ethics in recruiting systems) [1]. Since the publication of the Action Plan in 2009, the Ministry of Defence has implemented several of the recommended actions. In 2011 the Council on Ethics in the Defence Sector was established [2] and in 2012 the ministry established the Centre for Integrity in the Defence Sector (CIDS) [3]. Whereas the council works primarily with military ethics, the CIDS focuses on managerial ethics. The Ministry of Defence has regularly updated its policy document on ethical guidelines for contact with business and industry in the defence sector. The last time the document was updated was in 2019 [4]. The document clearly describes acceptable, unacceptable and grey area behaviours and makes reference to relevant legal acts, including §276 a-c of the Norwegian Penal Code, which provides for punishment either in the form of fines or a prison term for various forms of corruption. The ministry’s focus on the intersection between the defence sector and business and industry, emphasised also in the latest Defence Annual Report, reflects efforts to address what is believed to be one of the greatest corruption risk areas. In 2015 the Ministry of Defence updated the guidelines for reporting and following up irregularities [5]. The existing system presupposes that all the subordinated agencies have their own reporting channels, but personnel from the defence sector may also report directly the ministry. In 2018 the Armed Forces, in cooperation with the Ministry of Defence and the Defence Research establishment, conducted a comprehensive employee survey on mobbing and sexual harassment in the Armed Forces [6]. In the recent years, the Ministry of Defence has focused on establishing and implementing a comprehensive anti-corruption programme for procurement processes and broadly understood contacts with industry and business [7], and the programme will be gradually expanded to other agencies. The programme was supposed to be developed in collaboration with the Norwegian division of TI but, due to lack of funding on the part of the Norwegian division of TI, the scope of the programme had to be reduced [8]. It is difficult to specify to what extent the government is on schedule or behind schedule with the implementation of its action plan because there is no publicly available timeline for this plan. However, while in the recent years a lot of work has been done to mitigate procurement risk, the results from the present GDI Questionnaire suggest that there has not been sufficient focus on operational risk.

Military law is a primary source for anti-corruption policy, but it does not include all forms of corruption and does not state corruption per se (Law 110/2011), but XXX the misuse of power and mishandling of resources. There is up to three years in prison for accepting or asking for money in exchange for public services (1), (2). The State Audit Institution is linked to combatting corruption; though the website has not been updated since 2017. The focus of this institution is to “eliminate all criminal acts of corruption” in collaboration with the international community (3). The Oman Penal Code (Royal Decree No.7/74) and the Law for the Protection of Public Funds and Avoidance of Conflicts of Interest (Royal Decree No.112/2011) is the legislation used when combatting corruption (4). The Penal Code stipulates government officials are liable for up to ten years in prison, and a fine that is at least equivalent to the bribe they accept or demanded (5). Anti-corruption legalisation is primarily directed at the public sector; however, it is extended to the private sector when the government has a 40% share in the company (5). Furthermore, in November 2015 a court dedicated to public funds was founded to address cases of financial and administrative corruption (4). It is illegal to give gifts to official, and bribery according to the penal code is termed as follows, “Any person who accepted a bribe for himself or for another person, be it in cash or a present or a promise or any other benefit for performing a lawful act of his duties, or for forbearing to do it or delaying its execution.” (5). The law for combatting money laundering and terrorism financing (Royal Degree 79/2010 and 30/2016) is the sole piece of anti-corruption legislation which deals with security issues. There is nothing in the document addressing the military or defence ministry. Only security authorities, along with the judiciary, are considered “competent authorities” to combat money laundering (6). There is no mention that this legislation acts to scrutinise the defence or security sector, but rather these sectors scrutinise other ministries, groups and individuals. Despite anti-corruption policy in place, there is no clear demonstration of its extension to the defence and security sectors. There is no explicit mention of the defence sector in the legislation nor on government websites.

This indicator has been marked Not Applicable because there is no anticorruption policy for the defence sector.

According to UNCAC’s assessment report in 2015, Oman has failed in implementing many anti-corruption measures and has no feasible action plan to do so (1). According to our sources, the lack of an action plan is a result of the strong belief that corruption is not a strategic issue (2).

There is an anti-corruption law that was ratified by the president in 2005 that includes some points in a few articles that mention security agencies (in general) and their work (2). There is also a National Anticorruption Strategy for 2015-2018, which has not been re-evaluated, and is therefore not in force (3).

This indicator has been marked Not Applicable, because no anti-corruption policy (that is currently in force) exists in Palestine.

The Philippines has several anti-corruption policies that applies to the defense sector. These include the Anti-Graft and Corrupt Practices Act, An Act Defining and Penalizing Crime of Plunder, and Government Procurement Reform Act [1]. The Office of the Ombudsman is the one responsible for investigating and prosecuting government officials accused of graft and corruption crimes [2]. Within this office, is the Office of the Deputy Ombudsman for the Military and Other Law Enforcement Offices that has jurisdiction over members of the military and other law enforcement offices [1].

Philippine Defence Transformation Roadmap (PDTR) 2028 is a strategic plan that investigates the performance, governance, and systems of the defence sector [1, 2]. The PDTR 2028 is the follow-on program to the Philippine Defense Reform (PDR) program that ended in June 2016.
The PDR was envisioned to provide institutional, structural, and systemic reforms to address current deficiencies in the defense department that bred corruption, waste, and inefficiency [1]. While steps have been taken to implement the plan especially through the Defence System of Management (DSOM), which is an integrated system of systems (strategic planning, capability assessment and planning, acquisition and resource management) [1], the process of achieving the goals of the agenda has been slow [3].

There is an openly stated anti-corruption policy which also covers the defence sector. The new Government Anti-Corruption Plan for 2018-2020, which is related to all sectors of the state’s activity was adopted in December 2017 and introduced in January 2018 [1]. It replaced the previous Government Anti-Corruption Programme for 2014-2019 [2] set by the previous government.
The main objective of the programme is the reduction of corruption crime in the country and raising public awareness in the fight against corruption. Specific goals are: 1) strengthening of preventive and educational activities; 2) improvement of mechanisms for monitoring corruption threats and monitoring of anti-corruption legal framework; 3) cooperation and coordination of actions between law enforcement authorities at national and international level.
The plan highlights corruption in the defence sector as one of the areas of potentially high risk. One of the main risks, according to the plan, is connected to public procurement (limited transparency connected with secrecy, the high value of tenders and high specializations). Another risk is the human resources policy, which is connected to the lack of administrative court oversight on personnel decisions regarding military personnel [3].
However, the action plan does not include activities designed to mitigate risks specific to the defence sector, even if they are listed in the analytical part of the programme.

The plan was introduced in January 2018 [1]. There is no schedule (as milestones) of implementation of the programme, the only deadline for all the tasks is the end of 2020. The plan has no separate budget and no sanctions envisioned for the failure to perform planned tasks.

The tasks relevant for the defence sector cover mainly such issues as anti-corruption training and education and exchange of information and improvement of cooperation among defence and civilian law enforcement and intelligence agencies. Additionally, some anti-corruption procedures have been established (as for reporting corruption in regional personnel offices and for defence procurements on missions). [2, 3] Consequently it reflects partially the institutional weaknesses in the system.
As there are no interim deadlines in the plan one can not assess whether it is implemented.

As of March 2021, a national anti-corruption strategy was in its final drafting stages [1, 2] and was discussed [3]. There is no actual implementation schedule, and no evidence suggests specific measures or guidelines for the defence sector.

This indicator is marked ‘Not Applicable’, since there is no anti-corruption policy that also applies to the defence sector. As of March 2021, the national anti-corruption strategy is still in draft form [1]; therefore, assessing its implementation was not possible during this assessment.

There is no public evidence of Qatar having an anti-corruption policy that applies to the defence sector. The only document available online to the public in Arabic is Decree no. 31 of 2006. This decree is only relevant to the Qatari Civil Defence, not to the armed forces [1]. Article 127 of the document, which is also only relevant to Civil Defence, briefly discusses bribery and the subsequent punishment. However, this article is lacking in depth. According to our sources, there is an internal abstract anti-corruption guidelines document within the different branches of the armed forces. [2,3]

This sub-indicator has been marked as Not Applicable because Qatar does not have an anti-corruption policy that applies to the defence sector. If we consider the guidelines ( which are not a policy) as an anti-corruption policy, then it is has no action plan. [1,2]

All ministries and state institutions are subject to the national anti-corruption strategy, signed by the president on April 13, 2010 [1] and the federal law ‘On anti-corruption’, signed on December 28. 2008 [2]. These orders direct all bodies to create their own plan to fight corruption. The MoD regularly sets an anti-corruption plan for a two- to three-year period. The current 2018-2020 plan was signed by the Minister on July 2, 2018 [3]. So, I suggest there is an openly stated anti-corruption policy set explicitly for the defence sector.

The MoD anti-corruption plan does not identify any institutional weaknesses or priority items but rather general actions that it stipulates reflect the basic problems in the fight against corruption (i.e. effective regulation of conflict of interests, uncovering and monitoring corruption risks, building cooperation with civil society) [1]. A comparative analysis of the plan for 2016-2017 [2] and the plan for 2018-2020 [1] showed the following: the actions (totalling 35 for both the 2016 and 2018 plan) remain mostly the same and include measures to facilitate the work of committees that monitor conflicts of interest in the army, to conduct audits following anti-corruption law violations, to organise awareness-raising measures about corruption, to facilitate reporting about gifts received in the discharge of duties, etc. Several changes have been identified. For example, clauses 2 and 3 of the 2018 plan detail the requirement to ‘increase the effectiveness of control over anti-corruption law implementation’ and ‘increase control over maintanence of information about servants’ relatives in order to prevent conflict of interests’ [1]. There is also a new addition in clauses 20-21 of the 2018 plan: the requirement to introduce effective cooperation between ministries and interaction with the public to organise workflow and control the implementation of work tasks [1].

Saudi Arabia does have laws and a framework in place to combat corruption and has established bureaucratic agencies and regulations designed to identify and prosecute cases of corruption – most notably the National Anti-Corruption Commission, commonly known as Nazaha. Nazaha is tasked with investigating financial and administrative corruption in the public sector (1). According to the comments of a Saudi-based academic and consultant, Nazaha is “legally not prohibited to work towards more transparency in the defence sector and may be active with the defence community in ensuring best practices and conduct, though this is a “minor role” in the grand scheme of things (2).” A Gulf-based consultant who has worked with the defence sector stated that “while Nazaha’s mandate technically covers the defence sector, whether this happens in practice is a different matter” (3).
According to sources in the MoD, the anti-corruption policy is the same as for the other ministries, and the MoD does not have an anti-corruption policy (4).
Since February 2015, Crown Prince Mohammed bin Salman has been restructuring the traditional networks of procurement in the Saudi defence sector, which was typically predicated on specific personalities or family branches and their relationships with foreign defence companies, for example, businessmen Salah Fustok, according to the French publication Intelligence Online (5), (6), (7). In November 2017, Mohammed bin Salman arrested the commander of the SANG, Miteb bin Abdullah – son of late King Abdullah and the maternal nephew of Salah Fustok – as part of a widespread self-proclaimed anti-corruption purge. This sweep was spearheaded by a newly-formed anti-corruption committee led by the crown prince, with authority to investigate, arrest, issue travel bans and freeze the assets of those it found to be corrupt (8). The committee included heads of several Saudi government bodies, such as the Control and Investigation Board; the National Anti-Corruption Commission; the General Auditing Bureau; the Presidency of State Security; and the Attorney General at the Public Prosecutor’s Office (9).

Charges against Miteb include embezzlement and awarding fake defence contracts to his firms; he later paid a USD 1 billion settlement relating to these charges (8), (10). In addition to Miteb, according to a senior Saudi official, Saudi authorities also arrested 14 retired military officers who previously served in the Ministry of Defence, as well as two, retired SANG officers, on suspicion of involvement in financial contracts which were allegedly corrupt (11). Despite covering aspects of corruption in the defence sector, the anti-corruption drive, in general, appears to be a personal initiative from the crown prince and it is unclear whether these moves have translated into a codified anti-corruption policy.

According to our sources, despite the presence of Nazaha and anti-corruption law, there is no action plan that is available publicly or implemented within MoD (1), (2). According to a Saudi journalist with knowledge of the defence sector, “Nazaha’s mandate includes all government dealings, which should include the MoD. Whether that happens in practice is a different matter” (3).

A regional consultant who has worked with the Saudi defence sector stated that part of the recent changes in the Saudi military and procurement process is intended to “ring-fence” between foreign defence contractors and government/MoD officials so as to restrict potential corruption, though the consultant added there is as yet no evidence of how this has worked in practice through SAMI and GAMI (4).

The Serbian Government has adopted a National Anti-Corruption Strategy for the period 2013-2018, as well as an action plan for its implementation and, has thus expressed its commitment to the anti-corruption policy. However, neither of the documents particularly focus on preventing and tackling corruption in the defence sector [1, 2].
On the other hand, the MoD regularly submits annual integrity plans to the Anti-corruption Agency (ACAS) and publishes them on its website. Integrity plans contain goals, activities and organizational units in charge of conducting the activities divided into six areas: democratic control, anti-corruption policy, human resources, planning and budget, multinational operations and public procurement [3]. The MoD also regularly publishes integrity plan implementation reports.

Integrity plans are partially implemented, mostly the activities aimed at organizational and legal changes. Some of the goals and activities in the integrity plans are vaguely determined and do not recognize the areas most susceptible to the risks of corruption. The tendency of including unrealistic activities in the plans can be observed since realization reviews contain justified explanations for the lack of implementation of certain measures [1, 2]. For instance, the Integrity plan for 2016 calls for the creation of a team in charge of coordinating the implementation of integrity building activities, whereas in the 2016 Realisation report this activity is assessed as redundant thus justifying the failure to implement the envisaged measure [1, 3].

The Ministry of Defence (MINDEF) and the Singapore Armed Forces’ (SAF) anti-corruption framework includes internal directives and codes of conduct with explicit guidelines, mandatory declarations and punitive actions. All personnel are screened and undergo security vetting at regular intervals, in addition to annual and ad hoc declarations of assets and financial positions. Efforts to mitigate corruption risks also include periodic job rotation, compliance leave, training and seminars on ethics and corruption, as well as regular audits at all levels of management. A robust whistleblowing system also exists, with complainants able to file reports through several parties [1]. Singapore maintains a robust anti-corruption policy in the public sector under the Prevention of Corruption Act. In addition to internal anti-corruption mechanisms, MINDEF/SAF is also under the jurisdiction of the Corrupt Practices Investigation Bureau (CPIB), an independent anti-corruption agency, that is mandated to lead anti-corruption inquiries in both the public and private sectors. Members of the public can easily report suspicious activity to the CPIB directly [2]. The CPIB and MINDEF websites offer information on cases of corruption, and offences are reported by the media [3].

Although a zero-tolerance policy and comprehensive measures on corruption have been outlined in the public-facing statements by the MINDEF and the CPIB [1], there are no detailed implementation plans associated with these descriptions. However, it is evident that the government recognises the threat posed by corruption to national security and has in place robust planning and implementation measures, which includes the CPIB – an independent and very effective law enforcement agency under civilian control which is often used as an example of successful institutional response to the problem of corruption and its remit also covers the military [2]. MINDEF/SAF personnel can also be charged under the Prevention of Corruption Act, the Penal Code, and relevant legislation [3, 4].

At the national level, the National Development Plan, Vision 2030 identifies countering corruption as a priority [1]. Anti-corruption measures within the DoD tie into national anti-corruption legislation [2] and other mitigation efforts such as the National Anti-corruption Hotline. An anti-corruption policy applicable to the defence sector is evidenced in the 2017/18 Annual Defence Report, which outlines the role(s) of specific structures within the Department of Defence, intended to monitor and enforce anti-corruption measures. The current DoD Corruption and Fraud Prevention Plan has reportedly been revised and updated and is now subject to a departmental approval process [3].

The Directorate Anti-Corruption and Anti-Fraud (DACAF) provides anti-corruption and anti-fraud prevention services, including serving as a nodal point for forensic auditing, to the DoD. In the 2017/18 period, a detection investigation service, as well as corruption and fraud awareness education within the Department of Defence main programmes, was provided [4]. The DACAF is nested within the office and remit of the DoD Inspector-General [5].

The DoD anti-fraud and corruption initiative, is managed through the DoD Anti-Corruption Nodal Point Forum where information is exchanged between DACAF and DoD Services and Divisions; and the DoD Anti-Corruption Stakeholders Forum where anti-corruption data is verified between the DACAF, the Military Police Division, the Defence Legal Services Division and the Directorate Labour and Service Relations [1].

The Annual Defence Report FY2017/18 notes that 43 whistleblowing reports were detected for investigation, of which the DACAF completed 27 investigations. Of those 27, eight were handed over to the Military Police Division, three were referred to the Defence Legal Services Division, three were referred to Services/Divisions, and 13 were closed, due to no corruption/fraud detected [2].

The DoD stated in the 2018 Performance Plans that, in the 2018/19 financial year, the During the FY2018/19, the DoD Consolidated Corruption and Fraud Register and implementation of the approved DoD Management of Anti-Criminality Policy would continue to manage aspects relating to corruption and fraud ranging from awareness training to the structured reporting of incidents through the departmental ‘whistle-blowing’ mechanism [3].

The DACAF process and implementation plan are explained as follows: “reported corruption and fraud incidents are registered in a DoD Corruption and Fraud Register. The current DoD Corruption and Fraud Prevention Plan has been revised and updated and is now subject to the departmental approval process. Quarterly status reports are provided to top management through the Accountability Management Committee” [1].

In September 2016, the South Korean government implemented the Improper Solicitation and Graft Act (ISG Act), which aims to tackle corruption in the public sector, including the defence sector, and prohibits improper solicitation of officers. The ISG Act is the strongest intervention among a number of anti-corruption measures covering the public sector as it includes criminal prosecution. It is commonly referred to as the Kim Young-ran Act, in reference to the former chairman of the Anti-Corruption Civil Rights Commission (ACRC) who initiated the Act in 2012. [1] This law imposes restrictions on all types of bribes in the public sector and prohibits those in the public sector from receiving gifts or free meals in exchange for services or preferential treatment. Those receiving free meals that cost more than 30,000 Korean won or gifts priced over 50,000 won may be punished with fines. Prior to the enforcement of the law, it dominated headlines as the act could lead to criminal prosecution of officials. Officials found guilty of wrongdoing can be punished with a prison sentence of up to 3 years or a fine of up to 30 million Korean won. [2].

After the ISG Act came into effect in the defence sector, people seemed to be discouraged from engaging in potentially corrupt activities. A senior official at the National Defence Committee at the National Assembly said in an interview that people are fearful of being caught if they engage in corrupt activities. He said that the number of people soliciting him decreased significantly after the Act came into force. [1] [2] Despite the enforcement of the law, corruption within the defence sector still exists. In February 2018, contracting officers at DAPA were charged with receiving bribes in the form of a corporate card and business entertainments, including free golf, from a defence contractor in exchange for preferential treatments. [3] [4] The Department of Defence Veterans Affairs is a division at the ACRC handling complaints and corrupt practices in the defence sector. The Defence Ombudsman Bureau was established in 2006 under this division to deal with complaints from the public. [5] The Bureau was launched after a soldier who was habitually harassed by senior soldiers shot and killed 8 other soldiers at a guard post in 2005. [6] Given this specific context of establishment, the Bureau’s primary role focuses on handling complaints and cases regarding human rights issues in the military and less on monitoring corrupt behaviours in the defence sector. At the ministry level, in October 2018, the Integrity Ombudsman Bureau was launched to handle complaints filed by citizens. This Bureau invited 5 members from civil society organisations in the anti-corruption field, legal professionals and academics. This is a plan at the ministerial level to encourage citizens to take part in confronting corruption issues in the defence sector. [7]

There are no official policy documents from the Ministry of Defence that clearly stipulate a commitment to fighting corruption in no uncertain terms. The key defence document, the SPLA Act 2009, deals primarily with administrative issues regarding the army and is not explicit on combating corruption. [1] The SPLA White Paper on Defence also does not talk about corruption [2]. However, the Southern Sudan Anti-Corruption Act 2009 stipulates the fighting of corruption in all government departments including defence [3].

At a national level, the Southern Sudan Anti-Corruption Commission Act 2009 applies to every government ministry, including defence. According to the Act, the Commission’s duty is to investigate corruption cases across all government domains, including defence. [1] However, the Act predates independence and was drafted when South Sudan was still an autonomous part of Sudan. The Act is incompatible with the stipulations of the 2011 Constitution. The latter grants the Commission prosecutorial powers, while the Act itself does not. [2] This creates a legal loophole that prevents an effective implementation of the anti-corruption stipulations of the Act. For instance, in 2015, the Commission investigated the alleged misappropriation of $12 million by Defence Ministry officials earmarked for procuring military supplies. Because the Commission does not have prosecutorial powers, the case was handed over to the Justice Ministry. To date, there is no public information about the outcome of this case. [2]

There is no specific anticorruption legislation for defence in Spain, but there is a reinforced body and anticorruption norms in Spain which was widely updated in the Penal Code Reform of 2015 [1]. Those norms apply to the defence sector because they regulate corruption generally, not admitting of peculiarities [6]. Those norms are also in combination with a specific military penal code for military personnel in service with regards to corruption [2]. The military criminal code does not include general corruption issues, but it applies to them.

The only one aspect found in Law 24/2011 on public sector contracts in the defence and security sector, Art 12.1, makes reference to corruption in defence contracts, preventing the prohibition of hiring a contractor when a contractor has been convicted of corruption [6]. Moreover, it exists in the code for the fight against fraud and corruption in defence, which consolidates all international and local norms on corruption in force in Spain [3]. Proposals in 2016 to modify the anticorruption law [4] that were debated in Parliament have not yet been approved, and did not incorporate new developments related to defence beyond the general aspects of protection of whistleblowers. Moreover, no changes in the defence sector were incorporated in the reform of the Penal Code from 2015 [5].

Although there is no concrete policy on anticorruption in Spain, there are indicators that show steps forward on anticorruption identified by Transparency International in its report on SDGs in Spain from 2018, by virtue of which there has been an improvement of the actions and powers of regulation and control by responsible institutions, regulatory bodies and bodies of constitutional relevance, such as the Court of Accounts, the Chambers of Accounts, the Anti-corruption Prosecutor’s Office, the Council for Transparency and Good Governance or the National Markets and Competition Commission (CNMC), in addition to the work of the OCU, UDEF and SEPBLAC (Financial Intelligence and Central Police Units for investigation of relevant crimes) [7].

There is no evidence of the implementation of an anticorruption plan in the General Defence Intervention and the General Sub-Directorate of Accounting of the Ministry of Defence, beyond the Social Responsibility Report published by the Ministry of Defence in 2011, which is not facing corruption issues [1]. There is no evidence either of its application or effectiveness, according to a defence expert [2]. In the Organic Law 12/1995 on the Suppression of Contraband [3], the export of defence material or dual-use material appears among the alleged constitutions of a crime of contraband.

While the Sudanese government has signed on to conventions against corruption and, in its transitional Constitution, paid lip service to the need for anti-corruption efforts, none of these measures are specific to the defence and security sector – although there is also no law stating that defence and security institutions are exempt. In addition to the UNCAC, Sudan has ratified the African Union Convention on Preventing and Combating Corruption, but Sudan blogger Sofie Arjon Schutte wrote in 2020 that ‘little’ of either convention has been included in national legislation or is adhered to in practice [1]. Sudan does have an anti-corruption commission and an anti-corruption act. Former President Bashir presented his cabinet with an anti-corruption reform plan in 2014 [2], but there is a lack of evidence that it was ever implemented. He also established an ‘Anti-Corruption Investigation Unit’ that belonged to the National Intelligence and Security Service (NISS) and, in 2018, announced a renewed focus on anti-corruption as a national priority – but this focussed mostly on former government officials and businessmen rather than active government or military officials [3]. The 2019 transitional Constitutional Charter stipulates a requirement to set up an anti-corruption and public funds recovery commission [4]. Extortion, criminal breach of trust, embezzlement and other unethical means of enriching oneself are criminalised in the public sector in general, but not specifically with regard to the defence and security sector [5].

This indicator is marked Not Applicable, since there is no anti-corruption policy that also applies to the defence sector. A review of the Government of Sudan (GOS) websites and news articles about anti-corruption activities in Sudan over the past five years yielded almost no reference to actions taken to implement the anti-corruption act in the defence sector, nor any action plan to do so. All reports suggest that transparency and anti-corruption policies and provisions have not been effectively implemented, including and especially in the defence sector. Sudan has long had an anti-corruption body, but this entity has lacked a leader since 2013 and has therefore been inactive. A formal anti-corruption law was approved in 2016 and former President Bashir established an anti-corruption commission. However, as summarised by a 2020 CIPE report, ‘[I]t soon became clear that the main motive behind these measures was burnishing Al-Bashir’s image before the international community… Al-Bashir’s commission failed to make any significant changes and did not present a single criminal case for prosecution’ [1].

Sudan’s Constitutional Declaration established the ‘Empowerment Elimination, Anti-Corruption and Funds Recovery Committee’ to ‘disempower’ beneficiaries of corruption during former President Bashir’s tenure, but these largely politically motivated efforts have so far almost entirely avoided targeting military officials and military elements that are still active in the new government. As of October 2020, an independent anti-corruption commission had not yet been formed [1]. There is no evidence that codes of conduct have been developed or that public servants or military personnel have been required to agree to follow such codes. Complaints of unethical behavior by public sector personnel can be submitted to an Ombudsman, but no such independent watchdog appears to have the authority to investigate complaints in the security sector. By law, public officials are required to disclose their private interests, but this is not executed in practice. Despite the guidance in the Procurement Act of 2010, public procurement activities are generally not transparent and the public has little visibility into security sector business. Corruption-related criminal law enforcement is almost never executed with respect to security sector business unless such activity is politically motivated. Furthermore, people who attempt to report behaviours that are contrary to policy have experienced reprisals. A 2019 Sentry report reads: ‘Senior members of the government are engaged in extensive corruption, thus undermining the government pledge to combat graft’ [2].

No anti-corruption policy exists for the defence sector in Sweden. The government of Sweden published its first national action plan on anti-corruption in late 2020 [1]. In statements leading up to the publication of the action plan, sources stated that ‘although Sweden appears to be a country free of corruption in international assessements, there are still issues and challenges’ and that in Sweden, corruption may ‘take on different and sometimes more concealed forms than in other countries, such as friendship corruption’ [2]. However, the government does not provide any specific actions or address any specific sector like defence in this plan. In addition, no evidence could be found of other/previous statements or public investigations indicating that the government has any intentions to develop an anti-corruption policy specifically applying to the defence sector [3].

This indicator is marked ‘Not Applicable’, as no anti-corruption policy exists for the defence sector in Sweden [1].

Switzerland is engaged on the international level in anti-corruption efforts in international organisations like OECD, the Council of Europe or the United Nations and implementing the respective instruments as part of its anti-corruption policy on the national level. The Federal Council has put into place the Interdepartmental Working Group to Combat Corruption (Interdepartementale Arbeitsgruppe Korruptionsbekämpfung Korruptionsbekämpfung) (IDAG) and defines its mandate, which was judged to be complete, clear and pertinent in a 2018 evaluation by the Swiss Federal Audit Office (SFAO). The working group produces a regular report with suggestions [1]. The defence sector is represented through the Federal Office for Defence Procurement (armasuisse) [2]. The working group has in its latest report identified specific corruption “risk groups and activities” within the administration and has directly worked with armasuisse to do so. A January 2020 directive for the DDPS explicitly addresses corruption and delegates the responsibility for fighting corruption to its different administrative units [3]. In November 2020, the Swiss Government (through the IDAG) adopted its first anti-corruption strategy for the period, which applies to the Federal Administration as a whole [4, 5]. However, it is noted that this strategy does not explicitly address the defence sector, nor does it outline concrete actions or measures to be taken [6]. In addition, there is the “Codex” that applies to all civil servants and that addresses issues like personal gifts, invitations, favours and bribery (direct or third parties). This codex also applies to the personnel of the ministry of defence [7].

Until very recently there appears not to have been a comprehensive action plan for the defence sector. The Interdepartmental Working Group to Combat Corruption (IDAG) in its latest report and based on an evaluation by the SFAO favours the creation of a more independent body with additional resources that would be in the position of working out a strategy for the whole of the federal administration [1, 2]. However, since 30 January 2020, there is a directive for the DDPS on fighting corruption with detailed provisions and references to the general code of conduct. The directive also defines the tasks of a “Specialist Unit Corruption” (Fachstelle Korruption) and delegates the responsibility of fighting corruption to the different administrative units of the DDPS [3]. Armasuisse appears to address the topic of corruption also systematically [5]. It has also issued a new directive on the acceptance of gifts, invitations and other favours for their employees. There is no evidence that this is accompanied by or part of an action plan [6]. In an audit report on compliance management systems at Rüstungs Unternehmen Aktiengesellschaft (RUAG) done by the SFAO, it appears that at the time some strategies for corruption prevention were in place, but the implementation was patchy [7].

The National Integrity Building Action Plan established by the Executive Yuan seeks to advise institutions and agencies of Taiwan’s Government on issues of integrity and ethics. Under the guidance of the National Integrity Building Action Plan, the Board for Integrity and Anti-corruption is organised by the MND to serve as the major platform for Taiwan to devise and implement integrity, ethics, and anti-corruption policies for the entire defence sector [1, 2]. Policies, directives, regulations, guidelines, and advice provided by the Board for Integrity and Anti-corruption are regularly made available via a range of mechanisms, and particularly via new media such as Facebook and YouTube [3].

The MND’s “Organisation and Guidelines for the Board for Integrity and Anti-corruption of the Ministry of National Defence” serves as the major action plan for Taiwan’s armed forces to achieve anti-corruption goals. A portal page specifically designed and constructed for advancing the Government Defence Anti-corruption Index (GDAI) is established for the MND. There are institutions and agencies within the MND working on government ethics, integrity, and anti-corruption for Taiwan’s military [1]. Policies, directives, regulations, guidelines, and advice granted by the Board for Integrity and Anti-corruption are sorted according to the GDAI architecture of political, financial, personnel, operational, and procurement risks aimied at reducing risks of corruption within Taiwan’s armed forces [2].

There is an openly stated anti-corruption strategy and action plan named National Anti-Corruption Strategy and Action Plan Phase III (NACSAP) formulated in July, 2017. The strategy is for a period of 5 years from 2017 to 2022. NACSAP as a part of public sector reforms does not leave out defence and security organs while fighting against corruption. The security services are considered part of the public sector for such initiatives. [1]

The National Anti-Corruption Strategy and Action Plan Phase III of 2017-2022 [1] has identified some of the institutional weaknesses at a ministerial level. It requires public institutions, including those focussed on defence and security, to develop their own anti-corruption plans to ensure the effective implementation of the NACSAP III. However, it is unclear from the Ministry of Defence and National Service and the Prevention and Combating of Corruption Bureau websites whether this has happened or if it is progressing along the estimated timeline. [2] [3]

The implementation of the National Anti-Corruption Strategy (2017 – 2021) demonstrated the efforts made to eradicate corruption by the government and public officials, including the defence sector [1]. In 2017, the Public Procurement and Supplies Administration Act B.E. 2560 (2017) came into effect, which included anti-corruption policy in the area of public procurement in its general provisions, Chapter 2 (Participation by the Public and Business Operators in Anti-Corruption) and Chapter 3, Part 4 (Anti-Corruption Co-operation Committee) [2]. In 2018, the Act Supplementing the Constitution Relating to the Prevention and Suppression of Corruption B.E. 2561 (2018), a new anti-corruption law, came into effect in Thailand. The new act repeals and replaces the 1999 Organic Act on Counter Corruption and its various amendments by maintaining the key 2015 amendments in the Old OACC, which criminalises bribe-giving between legal entities and Thai state officials, foreign state officials, and officials with intergovernmental organisations [3]. Moreover, there is also the Act on Offences Relating to the Submission of Bids to State Agencies B.E. 2542 (1999), which defines corrupt practices in relation to public procurement such as bid collusion [4]. These laws all apply to the defence sector.

In 2013, the National Anti-Corruption Strategy Phase 2 (2013 – 2017) was implemented by the Ministry of Defence; its key provision was to formulate Service Level Agreements (SLA) in order to increase transparency in the public sector [1]. Four years later, the implementation of the National Anti-Corruption Strategy (2017 – 2021) led to a revision to increase responsiveness to the existing anti-corruption efforts, particularly in corruption cases involving government and public officials [2]. Additionally, the armed forces and agencies under the Ministry of Defence signed an anti-corruption memorandum of understanding (MoU) with the National Anti-Corruption Commission (NACC) as a commitment to perform their duties with transparency and rid the military of corruption [3]. The Strategic Plan on Corruption Prevention and Suppression of the Ministry of Defence Fiscal Year 2020 was implemented in accordance with the National Strategy on Corruption Prevention and Suppression Phase 3 (2018-2021) and the Strategic Plan on Corruption Prevention and Suppression of the Ministry of Defence 2018-2021 in order to operate the ministry’s activities effectively and transparently [4]. The strategic plan was formulated based on relevant prior research and academic papers, including evaluations of performance in key missions [5]. According to the National Strategy on Corruption Prevention and Suppression Phase 3 (2018-2021), the MoD had organised the ‘Transparent and Non-Corrupted Defence Sector’, which requires partnerships from internal and external stakeholders at both domestic and regional levels, as well as the MoU on Corruption Prevention and Resolution with the NACC [6].

Nonetheless, in most cases where corruption scandals were exposed in the defence sector, the perpetrators got away with it and the cases were eventually buried. This is illustrated by the lack of scrutiny of the military’s accumulation of wealth during the process of asset declaration to the National Anti-Corruption Commission in 2014, which is believed to be a result of the appointment of five new commissioners to the NCPO who were regarded as being pro-junta and therefore unlikely to take a stand against any potential corruption by the regime or the military [7].

Tunisia adopted a national strategy for good governance and fighting corruption (2016-2020) and an action plan (2017-2018) in December 2016 (1). The charter of this strategy was signed by the President of the Government, the President of the Anti-corruption Authority, the Vice-President of the Judiciary Authority and the President of the Journalists Union (2). The action plan of this strategy contains measures concerning security (establishment of islands of integrity in the security sector) and states that a sectorial action plan in the security sector will be established (1). However, this strategy and its action plan does not explicitely mention the defence sector nor the Ministry of Defence (3,4).

According to our sources, there is an action plan within the Tunisian National Strategy for Good Governance and Fighting Corruption. The action plan, whilst it does not mention the defence sector, it does apply to it as part of the state’s department(1,2). This plan is unclear how it will be implemented within the MoD(1)

On 18 June 2019, a cooperation agreement was signed between the supervisory structures of the Ministry of National Defence and the High Instance for Administrative and Financial Control, which operates under the supervision of the Presidency of the Republic of Tunisia (3). The Ministry of National Defence has implemented the provisions of the Government Decree No. 1158, dated August the 12th 2016, on the Establishment of Governance Cells and their Control. Tunisia has adopted the action plan of the SNAC 2 project adopted by the European Union, through which the Tunisian State seeks to harmonise its national legislation with the European standards in the field of combating corruption. (4) The General Inspection of the Armed Forces follows a program with respect to the integrity assessment of the armed forces in cooperation with NATO (5). A cooperation and partnership agreement was signed with the National Anti-Corruption Commission on 17 September 2018 (6).

Turkey does not have a general anti-corruption or bribery law written specifically for the defence/security sector. However, other Turkish laws contain provisions on anti-corruption and both military and civilian personnel in charge of financial activities in the sector, along with other government employees, are obliged to observe these provisions. These are primarily the Turkish Criminal Code (5257) [1], the Law on Declaration of Property and Combating Bribery and Corruption [2], the Law on the Ethics Board for Public Officials and the Civil Servants Ethical Principles and Application Procedures and Principles (the ‘Ethics Regulation’).

The absence of a robust anti‑corruption strategy and action plan in Turkey in the field of defence/security and defence industry indicates a lack of political will to decisively fight corruption [3]. There is neither a permanent, functionally independent anti-corruption body within the sector, nor a CSO with a specific focus on this topic present in civil society. It should also be noted that there is no specialised prosecution service to lead anti-corruption investigations related to the defence/security sector. There is no anti-corruption law in the defence sector, despite the fact that defence procurement is especially prone to corruption due to its complexity, technicality and frequent use of ‘urgent requirements’, as well as a weak auditing system that makes oversight difficult. Moreover, major factors that aid the implementation of anti-corruption measures, such as the external auditing mechanism, the public procurement regime, corruption investigations by state prosecutors and the office of the Ombudsman and Ethics Council, have become subject to political intervention. Finally, there has even been backsliding in several policy areas. Since its adoption in 2002, the law on public procurement has been modified more than 41 times to increase the number of exemptions. These exemptions create serious political risks, as the amount of contract value remains outside the tender procedures stipulated in procurement law. More importantly, these exemptions have expanded the public authorities’ discretionary power in the contract award process [4].

Under the parliamentary system, there used to be the Board of the Fight Against Corruption attached to the Prime Ministry, but this board was abolished on December 3, 2015 [5]. Currently, there is no such board under the executive presidency. There is no board that may play the role of a monitoring and oversight mechanism in any defence-related state organisation, such as the Ministry of Defence or the Presidency of Defence Industries. Interviewee 6 suggested that, at the Ministry of Defence, the Financial Audit Department provides auditing services to the Minister pursuant to the Procurement Law, the Turkish Criminal Code and the Regulation about the Code of Conduct of the Public Servants, documents that will be referred to in the coming sections [6].

In addition to this, there is no law or ministry regulation that focusses specifically on the fight against cooruption and anti-bribery issues in the defence/security sector. The most recent publicly available report on anti-corruption efforts in Turkey is Transparency International Turkey’s report on anti-corruption efforts in Turkey [7]. This report does not contain a single sentence about the defence/security sector. Interviewee 1 emphasised that Vice President Fuat Oktay and his office appear to be in charge of the fight against corruption and ethical issues within the government, however there is neither a clearly defined anti-corruption policy nor a body in charge of these issues within the government [8].

It should be noted that the assessor could not find anything through open-source research of all available online sources from the past two years about the government’s development of an anti-corruption policy for the defence/security sector or the formation of a mechanism for this.

Turkey does not have a general anti-corruption or bribery law written specifically for the defence and security sector. As such, this indicator is marked ‘Not Applicable’. However, other Turkish laws contain provisions on anti-corruption and both military and civilian personnel in charge of financial activities in the sector, along with other government employees, are obliged to observe these provisions. These are primarily the Turkish Criminal Code (5237) [1], the Law on Declaration of Property and Combating Bribery and Corruption, [2] the Law on the Ethics Board for Public Officials and the Civil Servants Ethical Principles and Application Procedures and Principles (the ‘Ethics Regulation’).

The country does not have an anti-corruption policy. However, some laws apply to the defence sector, including Section 118 of the Ugandan People’s Defence Force (UPDF) Act 2005 [1] that provides the Code of Conduct for the UPDF, which warns about any form of corruption. According to a deputy army spokesperson [2], Section 178 talks about the conduct prejudicial to good order and discipline while subsection (1) states that any act, conduct, disorder or neglect to the prejudice of the good order and discipline of the defence forces shall be an offence. Subsection (2) states that a person convicted of an offence under subsection (1) is liable to dismissal with disgrace from the Defence Forces. The government of Uganda established several anti-corruption agencies, including the Inspectorate of Government (IG), the Office of the Auditor General (OAG), the Directorate for Public Prosecution (DPP), the Directorate for Ethics and Integrity (DEI), the Anti-Corruption Court, State House Anti-corruption Unit, among others, to fight endemic corruption in Uganda. Many laws are in place: the Inspectorate of Government Act 2002; the Leadership Code Act 2002; the Public Finance and Accountability Act 2003; the Public Procurement and Disposal of Public Assets Act 2003; the Access to Information Act 2005; the Audit Act 2008; the Anti-Corruption Act 2009; and the Whistle Blowers Protection Act 2010 have been put in place [3].

Uganda does have an anti-corruption policy that applies to all government ministries. It has a comprehensive anti-corruption legal framework that is provided by the Anti-Corruption Act (2009) [1], the Penal Code Act (Cap. 120), the Anti-Money Laundering (Amendment) Act (2017) [2], the Inspectorate of Government Act (2002)[3], the Public Finance Management Act (2015) [4] and the Leadership Code Act (Cap. 168) [5]. As enshrined in these legal instruments, corruption is described to include several offences, including abuse of office; bribery; causing financial loss; soliciting and or receiving gratification; diversion of public resources; embezzlement; fraudulent or false accounting; and illicit enrichment. Central to Uganda’s institutional and regulatory framework is the Inspector General of Government (IG), the agency legally mandated to eliminate corruption and the abuse of authority and public office. Apart from these policy documents, there is no publicly known action plan at the ministry level which reflects the institutional weakneses in the system.

There is an Anticorruption strategy adopted by the CMU and aims to create an effective national system of prevention and counteraction of corruption [1]. The strategy provides anti-corruption measures for three years (2015-2017); a new one should have been adopted in 2018 and has been already approved by the National Agency for Corruption Prevention [23]. Based on the anti-corruption strategy, each executive authority develops its specific anti-corruption programme aimed at adherence to the requirements of anti-corruption legislation as well as the implementation of the anti-corruption strategy. Ukraine does not have an explicit anti-corruption policy for the defence sector. Yet each executive authority (like the Security Service of Ukraine, Ministry of Interior etc.) has developed and adopted explicit anti-corruption programmes. The MoD developed one as well and adopted its anti-corruption programme for 2015-2017 [32]. It has already published a draft anti-corruption programme for 2018-2020 [4].

The first specialized anti-corruption unit within the MoD was created in 2009 in pursuance of the Resolution of the CMU on the establishment of the specialized units (assignment of persons) for corruption detection and prevention in central and local executive authorities. At first, it was a separate section (three employees), then division (five employees) being a part of the department of internal audit. From 2014 to 2016 there was a separate directorate for corruption detection and prevention (11 employees) subordinated directly to the minister of defence. After reducing the MoD by 200 employees in July 2016, the directorate transformed to department consisting of seven employees. The department’s activities are regulated by the Resolution of the CMU № 706 “On approval of Model provisions on the authorized unit (person) for corruption detection and prevention” (2013). Resolution of the Cabinet of Ministers of Ukraine № 706 “Issues of corruption detection and prevention” (2013) [3]. This resolution, like the previous one of 2009, provides for the existence of such units or designation of the named civil servant in all agencies of central and local executive authorities.

In 2016 aiming at strengthening of the integrated system of corruption prevention in the MoD and AFU, according to the general directive of the MoD and GS AFU organizational measures were taken and five regional territorial subdivisions (territorial groups) for corruption detection and prevention with three military servants in each of them were formed. Territorial subdivisions were created in Dnipro, Kyiv, Odesa, Lviv, Kharkiv.

The anti-corruption action plan at the level of the MoD is Annexe 1 to the MOD Anticorruption programme for 2015-2017 [1]. Annexe 1 also addresses institutional weaknesses in the system, which the MoD planned to overcome through the development of anti-corruption programmes, the introduction of a systemic approach to preventing corruption based on the results of corruption risks analysis, and establishment of departments responsible for corruption prevention [1]. An active MoD officer stated that the MoD Anti-corruption Action Plan for 2015-2017 was 90% implemented [2]. The detailed measures for effective implementation of anti-corruption policy in MoD can be found in the report of MoD anti-corruption unit about the fulfilment of the anti-corruption program in 2017 [3].

In accordance with Article 2 of the Federal Law, the SAI is considered a federal committee within the FNC, responsible for detecting fraud and financial corruption and auditing public funds. However, there is no evidence that the SAI has the power to audit the defence sector (1). The Anti-Corruption policy available on the SAI’s website includes anti-corruption policies; however, there is no explicit mention of defence, and there appears to be no history of the defence sector being audited by the SAI before. According to our sources, the anti-corruption policies of the SAI do not apply to the defence sector (2), (3).

This sub-indicator has been marked as Not Applicable, as there is not an anti-corruption policy that applies to the defence sector. The penal code contains regulations that prohibit bribery, and deem it an offence. In 2015 the legislation was amended to cover foreign as well as domestic bribes, as well as the public sector, international organisations and the private sector (1), (2), (3). However, this does not explicitly apply to the defence sector, and for this reason, assessing implementation is irrelevant for this sub-indicator.

The UK Anti-Corruption Strategy 2017-2022 explicitly mentions defence and security as a high risk area for corruption [1]. Similarly, the latest Strategic Defence and Security Review identified corruption as a cause of conflict and instability [2]. In terms of a defence-specific anti-corruption policy, the MOD’s Financial Management and Charging Policy does include a fraud policy which addresses fraud, theft, bribery and corruption, as well as unethical behaviour [3]. The policy outlines some key corruption risks and provides guidance for personnel and commanders on how to proceed in such events. Details for a confidential hotline for reporting irregularities are also provided in the policy.

The ‘Year One Update’ of the UK Anti-Corruption Strategy 2017-2022 outlines the steps taken to implement the Strategy in the Defence and Security Sector [1]. It makes reference to the MoD’s engagement with CSOs, hosting an anti-corruption conference in the defence supply chain, as well as developping a security fundamentals learning package that covers a range of security issues facing defence staff, including insider threat [1].

The update also identifies areas of weakness and future priorities to implement the strategy. No further updates appear to have been published. The anti-corruption update published as a “newsletter” in 2020 by the ACC makes no mention of the strategy [2]. However, Fraud Defence and Counter Fraud Function for Defence and Building Integrity UK formally report against the commitments made in the UK AC Strategy every quarter. Both work closely with the Home Office’s Joint Anti-Corruption Unit, and most staff are members of the Government Counter Fraud Profession, and contribute written articles to the journal and provide speakers for conferences/seminars etc [3]. Equally, the Government has introduced the Government Functional Standard on Counter-fraud, Bribery and Corruption, which sets standards of compliance with the anti-corruption strategy, and implements its provisions [4].

There is no anti-corruption policy in place, beyond a number of laws (such as the Foreign Corrupt Practices Act (FCPA), which applies to the government or specifically the defence sector. The FCPA is the government’s primary tool for combatting bribery of foreign officials by US companies [1]. This, however, does not explicitly apply to the defence sector.

In 2019, Senator Warren introduced the ‘Department of Defense Ethics and Anti-corruption Act’ to the Senate, which would ‘promote ethics and prevent corruption in Department of Defense contracting and other activities, and for other purposes’. The bill was read twice and referred to the Committee on Armed Services. It has yet to progress as of early 2021 [2].

This indicator is marked ‘Not Applicable’ since there is no anti-corruption policy for the government or the defence sector and therefore it cannot be implemented.

Venezuela does not have a public anti-corruption policy programme, nor do any specific plans exist in the defence sector. However, a legal framework for anti-corruption can be identified, as can short-term campaigns which have sought to address the problem as an emergency issue [1].

In 2014, a package of laws was passed through enabling act to initiate an anti-corruption operation, including a reform of the Anti-Corruption Law [2], the creation of the National Anti-Corruption Body, and reforms of the National Security Laws and the LOFANB [3]. These changes in legislation did not create a specific anti-corruption policy, but rather focused on granting greater powers to security and intelligence forces to access information so as to address corruption as a national and transnational security factor [4, 5].

Lately, anti-corruption legislation has been affected by the political crisis within Venezuelan state institutions. In 2016, the NA approved a new reform to the Anti-Corruption Law that introduced definitions of corrupt behaviour such as conflict of interest and the use of public goods for personal benefit. It also introduced a “sworn statement of interests” and strengthened the responsibilities of the Comptroller’s Office [6]. However, this law has not been implemented by the different entities of the state.

In 2018, in announcements made before beginning a new presidential term, Nicolás Maduro stressed that his government plan would include a National Anti-Corruption Plan, which so far has not been made public [7]. In 2019, a draft bill was announced for presentation by the Supreme Court to the ANC for reform to the Anti-Corruption Law [8]. This proposal to update the law is a Supreme Court initiative brought before the ANC, entirely ignoring the legislative functions of the National Assembly.

Despite this legislation and periodic anti-corruption plans, civil society organisations have criticised the inaction of these programmes, for which very few resources are allocated without evidence of action [9]. In addition, specifically for the defence sector, experts have pointed to worsening levels of corruption due to a weakening of external controls [10] and a lack of interest in addressing corruption risks or clear cases of corruption [11].

Although there is no public policy on anti-corruption, periodic plans and anti-corruption legislation are recorded; however, the application of this legislation is difficult to evaluate since detailed information on the anti-corruption plans is not recorded and the legislation is applied in a superficial and limited way by some State entities.

Especially since 2016, as the political crisis worsened with the suspension of the NA, the legislation and the few campaigns for which there are records have ceased to feature in the speeches of representatives of the regime, and are not applied to the open contraventions that have occurred through the implementation of resources without the legislative control required by the constitution. Within the framework of anti-corruption legislation – in which entities such as the National Anti-Corruption Body and local comptrollers were created to strengthen control in the management of public resources [1] – there is no evidence of concrete plans for the defence and security sector that go beyond demanding compliance with general regulations for contracting and managing public resources. The Comptroller General of the Republic (CGR) has not made any long-term anti-corruption policies public, but has restricted itself to announcing an increase in personnel for carrying out audits [2, 3].

Indeed, there is currently a reproduction in the legislation since the Anti-Corruption Law approved by the NA in 2016 introduced new obligations that are not being met by the public authorities. One example is the lack of forms for or mention of the sworn statement of interests introduced by the 2016 reform by the Comptroller’s Office, which only submits the forms and information for the sworn statement of assets [4].

There is a National Anti-Corruption Strategy, and it applies to the defence sector. The National Anti-Corruption Strategy defines the country’s priorities, objectives and actions to prevent and combat corruption from 2020 to 2024. It includes action plans and a monitoring and evaluation plan to track the progress of the implementation. The strategy has the following objectives:
“1. Support citizen empowerment and awareness of their rights and responsibilities relevant to the fight against corruption.
2. Enhance the structures for deterrence, detection, adherence, and enforcement through improved compliance with anti-corruption and integrity management obligations and mechanisms across sectors.
3. Increase public demand for transparency and accountability and rejection of corruption in government offices, ministries, agencies and State-owned enterprises (SOEs)/parastatals, public institutions, media houses and the private sector.
4. Ensure protection of whistle-blowers and victims of corruption, thereby encouraging active participation in anti-corruption efforts by members of the public.
5. Recover assets and proceeds from corruption crimes, and compensate damages inflicted on the state and corruption victims.
6. Increased level of political parties’ transparency, political will, and accountability.” [1].

There is not enough evidence to score this indicator. The National Anti-Corruption Strategy was adopted in July 2020, and at the time of this research, there was no action plan yet to implement the anti-corruption strategy. There are no known actions at the Ministry of Defence (MoD) that have been taken to operationalise the National Anti-Corruption Strategy within the MoD [1].

Country Sort by Country 7a. Anti-corruption policy Sort By Subindicator 7b. Effective implementation Sort By Subindicator
Albania 75 / 100 25 / 100
Algeria 50 / 100 0 / 100
Angola 0 / 100 NA
Argentina 75 / 100 50 / 100
Armenia 100 / 100 75 / 100
Australia 25 / 100 NA
Azerbaijan 50 / 100 25 / 100
Bahrain 50 / 100 NA
Bangladesh 0 / 100 NA
Belgium 50 / 100 0 / 100
Bosnia and Herzegovina 100 / 100 75 / 100
Botswana 0 / 100 NA
Brazil 100 / 100 50 / 100
Burkina Faso 100 / 100 25 / 100
Cameroon 100 / 100 25 / 100
Canada 100 / 100 75 / 100
Chile 100 / 100 75 / 100
China 75 / 100 50 / 100
Colombia 100 / 100 25 / 100
Cote d'Ivoire 100 / 100 0 / 100
Denmark 100 / 100 25 / 100
Egypt 0 / 100 NA
Estonia 75 / 100 NA
Finland 25 / 100 NA
France 100 / 100 75 / 100
Germany 100 / 100 75 / 100
Ghana 50 / 100 25 / 100
Greece 100 / 100 50 / 100
Hungary 75 / 100 50 / 100
India 100 / 100 75 / 100
Indonesia 50 / 100 NA
Iran 50 / 100 NA
Iraq 25 / 100 0 / 100
Israel 50 / 100 75 / 100
Italy 100 / 100 75 / 100
Japan 0 / 100 NA
Jordan 50 / 100 NEI
Kenya 50 / 100 0 / 100
Kosovo 100 / 100 75 / 100
Kuwait 75 / 100 50 / 100
Latvia 100 / 100 100 / 100
Lebanon 50 / 100 NA
Lithuania 100 / 100 75 / 100
Malaysia 100 / 100 75 / 100
Mali 0 / 100 NA
Mexico 75 / 100 25 / 100
Montenegro 100 / 100 25 / 100
Morocco 25 / 100 NA
Myanmar 0 / 100 NA
Netherlands 100 / 100 100 / 100
New Zealand 75 / 100 NEI
Niger 100 / 100 25 / 100
Nigeria 50 / 100 25 / 100
North Macedonia 75 / 100 75 / 100
Norway 100 / 100 75 / 100
Oman 0 / 100 NA
Palestine 0 / 100 NA
Philippines 100 / 100 75 / 100
Poland 100 / 100 75 / 100
Portugal 0 / 100 NA
Qatar 0 / 100 NA
Russia 100 / 100 25 / 100
Saudi Arabia 25 / 100 0 / 100
Serbia 75 / 100 50 / 100
Singapore 100 / 100 75 / 100
South Africa 100 / 100 100 / 100
South Korea 100 / 100 75 / 100
South Sudan 50 / 100 0 / 100
Spain 50 / 100 25 / 100
Sudan 0 / 100 NA
Sweden 25 / 100 NA
Switzerland 100 / 100 75 / 100
Taiwan 100 / 100 75 / 100
Tanzania 100 / 100 50 / 100
Thailand 100 / 100 25 / 100
Tunisia 100 / 100 50 / 100
Turkey 0 / 100 NA
Uganda 50 / 100 0 / 100
Ukraine 100 / 100 75 / 100
United Arab Emirates 50 / 100 NA
United Kingdom 100 / 100 100 / 100
United States 25 / 100 NA
Venezuela 25 / 100 0 / 100
Zimbabwe 100 / 100 NEI

With thanks for support from the UK Foreign, Commonwealth and Development Office (FCDO) and the Dutch Ministry of Foreign Affairs who have contributed to the Government Defence Integrity Index.

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