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Q10.

Are there regular assessments of the areas of greatest corruption risk for ministry and armed forces personnel, and are the findings used as inputs to the anti-corruption policy?

10a. Risk assessments

Score

SCORE: 0/100

Assessor Explanation

Assessor Sources

10b. Regularity

Score

SCORE: NA/100

Assessor Explanation

Assessor Sources

10c. Inputs to anti-corruption policy

Score

SCORE: NA/100

Assessor Explanation

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The MoD has not conducted defence specific risk assessments on corruption. However, this is not exclusive to the MoD as no other institution has conducted corruption risk assessments so far.
Objective 8 of the Inter-Sectoral Strategy against Corruption (ISSC) adopted in 2015 provides for the “systematic use of the mechanism of identifying areas of corruption” [1]. Under this objective, risk analysis in the form of the evaluation of corruption proofing of legislation was introduced. Some efforts have been made to adopt corruption proofing methods to identify and address corruption risks in the legislation during the process of drafting laws; however, this approach was only partially implemented [2, 3].
The Action Plan 2018-2020 adopted in May 2018 provides for all ministries, including the MoD, to develop and implement risk assessments as a tool to identify and address corruption vulnerabilities. According to the Action Plan, risk assessments will be completed by 2019. Under Objective 9 of the ISSC, Strengthening the integrity of public officials, the current Action Plan 2018-2020 provides for the use of corruption risk assessments to be used as a tool for the adoption of the ministries’ integrity plans (including the MoD) [4].

This indicator has been marked Not Applicable, due to the fact that risk assessments are currently not conducted.

According to the Action Plan 2018-2020 of the Inter-Sectoral Strategy Against Corruption 2015 – 2020, the risk assessments for all ministries, including the MoD, were planned for 2018, based on guidelines adopted by the Ministry of Justice [1]. However, the guidelines for conducting the risk assessment were not adopted in 2018, so the entire process of conducting a risk assessment and adopting integrity plans has been postponed [2, 3].

This indicator has been marked Not Applicable, due to the fact that risk assessments are currently not conducted.

According to the Action Plan 2018-2020 of the Inter-Sectoral Strategy Against Corruption 2015 – 2020, the risk assessments for all ministries, including the MoD, were planned for 2018, based on guidelines adopted by the Ministry of Justice [1]. However, the guidelines for conducting the risk assessment were not adopted in 2018, so the entire process of conducting a risk assessment and adopting integrity plans has been postponed [2, 3].

There is no evidence that a defence-specific assessment of corruption has been commissioned since the last assessment of the country, which came to the same conclusion (6). It appears that such assessments have also not taken place in other sectors. In the summer of 2018, for example, the ONPLC and the finance ministry set up a working group that should determine how to implement corruption risk mapping in the financial sector (4). At the end of 2018, it seems that the group was still working on it (5).

The president of the AACC, Djilali Hadjadj, has emphasized that there is a “lack of political will on the part of the government to fight corruption” (1). In October 2018, unprecedented detentions of military officers happened, when five generals were arrested for alleged corruption offences. They were accused of “squandering” public funds and “mismanagement” (2). No evidence could be found that these cases have already had an impact on the ministry’s risk assessment concerning corruption. As has been outlined before, “corruption is an essential feature of the country’s system of governance” (3, p. 19), which makes it doubtful that changes have taken place.

No assessment on the regularity is therefore possible and the answer is scored “Not Applicable.” There is no evidence that a defence-specific assessment of corruption has been commissioned (see the answer to question 10A). The ONPLC and the finance ministry set up a working group to determine how to implement corruption risk mapping in the financial sector, which, at the end of 2018, was still working on it (1) (2).

No assessement on inputs to anti-corruption policy is therefore possible and the answer is scored “Not Applicable.” There is no evidence that a defence-specific assessment of corruption has been commissioned (see the answer to question 10A). The ONPLC and the finance ministry set up a working group to determine how to implement corruption risk mapping in the financial sector, which, at the end of 2018, was still working on it (1) (2).

No evidence could be found that defence-specific assessments of corruption risk have been commissioned or conducted in the last few years.

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

No evidence could be found that defence-specific assessments of corruption risk have been commissioned or conducted in the last few years. Thus, this indicator has been marked Not Applicable.

No evidence could be found that defence-specific assessments of corruption risk have been commissioned or conducted in the last few years. Thus, this indicator has been marked Not Applicable.

There is awareness of the risks posed by corruption to the public administration, but evaluations of corruption risks specific to the area of defence and armed forces have not yet been carried out. However, section 119 of the 2019-2023 Anti-Corruption Plan establishes the preparation of a Map of Integrity Risks for the entire defence jurisdiction which must take into account the particularities of the sector. Prior to this, the creation of work tables for the development of a methodology is indicated, but it is not possible to assess its progress. Control bodies, both external to the Ministry and part of their functions, annually carry out a risk assessment based on the auditable organisations’ plan. For example, SIGEN, in its 2018 risk map, considers the sectors of the defence jurisdiction as probable and of moderate impact: General Directorate of Military Fabrications, National Meteorological Service, Ministry of Defence, and the National Geographic Institute. As possible and moderate to: General Staff of the Army, Argentine Aircraft Factory, and Joint General Staff of the Armed Forces. For its part, the AGN in its Annual Operational Plan for 2019 considers auditable institutions of the defence jurisdiction only to the financial statements of Fabricaciones Militares and COVIARA (Construction of houses for the Navy). [1] [2] [3] For civil society, the focus around the assessment of corruption risks focuses on other issues. For example, CIPPEC proposes a mapping of risks to the integrity of State companies and their procurement and contracting processes. [4]

There is no evidence on the official website of the Ministry of Defence or in the Secretariat of Institutional Strengthening, [1] which since 2018 keeps track of transparency policies in the different state agencies, regarding the existence of a schedule for risk assessments of the defence sector. [2] The existing schedule is based on the risk map that SIGEN carries out to annually coordinate the agencies of the State that it audits and the Annual Operational Plan of the AGN, which establishes the guidelines for government control work. [3] [4]

This indicator has been scored Not Applicable. There are no specific risk assessments for the defence sector. An anti-corruption policy is postulated through the 2019-2023 Plan and from this the need arises for mapping specific risks to the defence sector. In this sense, Pablo Secchi and Karina Kalpschtrej point out that it is first necessary in Argentina to get to know the corruption matrix and generate a new matrix/gear to fight it. These gears have to do with the control agencies, with the Judicial Power, with the prosecutors, with the laws, with the control of money laundering, and with the capabilities and probity of the tax agencies. Currently, there are only separate agencies that each do their job, outside of a framework of interaction and convergent objectives. [1]

The Ministry of Defence (MoD) Human Rights and Integrity Centre was established to ensure human rights and strengthening integrity (anti-corruption behaviour inclusive) within MoD. The centre is authorized to initiate, organize, implement, monitor and evaluate programs promoting human rights and integrity both within the MoD and through international partnerships [1]. “The conference [on Building Integrity] brought together representatives of the Ministry and NATO with international experts, to explore the principles of integrity, transparency and accountability as factors for sustainable reforms. The participants also looked at the conditions to embed changes at the policy level. The enhanced Building Integrity Self-Assessment Questionnaire was handed over to the NATO BI representatives” [2]. To identify corruption risks and evaluate potential risks in the MoD, the Centre for Human Rights and Good Behavior of the Republic of Armenia carries out general investigations and analyses.
The purpose of these investigations is to identify not only existing and potential corruption risks but also to find out if the staff of separate units understand the risks that may occur during the activities of their subdivisions. One of the selected methods of conducting the above-mentioned investigations is the survey conducted for the MoD and Armed Forces General Staff subdivisions, the “Test of Honesty”, the results of which, combined with the findings of the investigations conducted during the NATO Self-Assessment Questionnaire development, allowed outlining of the corruption risks in the defence sector’s most vulnerable and risky areas. Another mechanism for revealing corruption risks by the Center is the statistical analysis of its “hotline” calls about the elements of apparent corruption offences of the MoD that, unlike the “Honesty Test,” provides an opportunity to outline corruption risks within the whole armed forces [3].

There is not enough evidence to score this indicator. During the management process, the Internal Audit Department of the MoD performs risk management following the ISO 31000-2018 standard. According to ISO 31000-2018, risk management at all stages is continuous [1]. However, it not clear whether corrutpion risk analysis conducted by Human Rights and Integrity Centre is performed systematicaly as methodologically based risk assessment which gives a risk map of defence sector at one point or is continuous activity out of methodological standards.

There is not enough evidence to score this indicator. Corruption risk analysis conducted by the Human Rights and Integrity Centre seems to be used to improve activities of the centre but has not been verified. There is no specific anti-corruption policy for the defence sector (see 7A)

While Defence is required to carry out regular fraud risk assessments in line with the Commonwealth Fraud Control Framework 2017 [1] and the Public Governance, Performance and Accountability Rule 2014 [2], it is unclear to what extent these assessments investigate corruption risks and what level of focus these assessments have. The assessment guidelines and policy outlined in the Framework and Rule indicate that Commonwealth entities should carry out fraud risk assessments at least every 2 years or when significant governance changes occur, and that the assessment process should be tailored, rigorous, and continuous [1]. These risk assessments then inform the development of a Fraud Control Plan [1, pC11]. As recently as 2015, Defence was planning to add an anti-corruption element to their fraud control plan, and presumably to the risk assessment process, as well [3]. However, though the Defence Annual Report 2018-19 refers to a “fraud and corruption control program,” [4] it is unclear to what extent fraud corruption risks play into risk assessments Defence is required to carry out, what the level of focus is, and whether there is a formal anti-corruption component in the previously mentioned “program”. This is because, while the Defence Fraud Control Plan was a publicly available document as recently as 2015 [3], it is no longer publicly available. Defence fraud risk assessments do not appear to have ever been publicly available [5]. The external Australian National Audit Office does conduct regular performance audits on defence procurements and processes, which includes an examination of the probity of management [6]. Repeated attempts by the Country Assessor to contact officials of the Defence Fraud and Audit Control Division – who have internal responsibility over risk assessment matters – and the Defence media team were unsuccessful. A score of 2 is justified because, although the content of Defence risk assessments are not clear, it is required for Defence to regularly carry out fraud risk assessments and these are very likely to include analysis of corruption risks.

As elaborated in Q10A, Defence is required by the Commonwealth Fraud Control Framework 2017 [1] and the Public Governance, Performance and Accountability Rule 2014 to carry out fraud risk assessments “regularly” [2], and these very likely include a corruption component. However, it remains unclear how often these risk assessments are carried out by Defence. The Framework recommends that government entities carry out a risk assessment “at least every two years,” and that bigger and more risky entities – presumably including the Department of Defence – should assess more frequently [1, pC9-C10]. However, there is no information in the Defence Annual Report [3] or other publicly available documents how often these assessments are being done [4]. Repeated attempts by the Researcher to contact officials of the Defence Fraud and Audit Control Division – who have internal responsibility over risk assessment matters – and the Defence media team were unsuccessful.

According to the Commonwealth Fraud Control Framework 2017, referring to requirements under the Public Governance, Performance and Accountability Rule 2014 [1], “fraud risk assessments must be followed by the development (or update) and implementation of a fraud control plan to deal with identified risks” [2]. However, as elaborated in Q10A and Q10B, because of the increasing government secrecy surrounding official Defence documentation, including relating to fraud control, and a lack of willingness by Defence to engage with Transparency International Defence & Security, it is impossible to say if policy or practice is reflected in risk assessment findings.

Corruption risks are not clearly identified. There is no evidence of regular assessments by the defence and security institutions in internal (1) or external documents (2). According to experts, risk assessments within military units is likely to take place, but the public is not informed about them. There is some awareness regarding risk areas. One of the historically corrupt institutions was the State Service for Mobilization and Conscription of Azerbaijan. However, since 2013, there have been many changes in this institution. New regulations were approved in 2015, and an Action Plan for the Development of the Service for 2013-2018 was been developed, approved and implemented (3). Corruption cases in the conscription process have become much more transparent, although the struggle to combat corruption remains largely ineffective

This indicator has been marked Not Applicable, as there is no evidence on the regularity of assessments by the defence and security institutions. According to experts, the implementation the risk assessments does not seem credible (1, 2).

This indicator has been marked Not Applicable, as the defence and security sector is closed and not transparent. As such, no information is given to the public about the risk assessment of military structures and its consequences. (1, 2).

Purportedly, there is a lack of assessment of corruption risk in general in Bahrain, which means there is no assessment risk in the defence sector in the country [1, 2, 3]. The researcher conducted an online and offline search, and there are no traces of any assessments of corruption risk in Bahrain in general.

This indicator has been marked ‘Not Applicable’, due to the fact that corruption risk assessments are not conducted [1, 2, 3]. The researcher conducted an online and offline search, and found no traces of any assessments of corruption risk in Bahrain in general.

This indicator has been marked ‘Not Applicable’, due to the fact that corruption risk assessments are not conducted [1, 2, 3]. The researcher conducted an online and offline search, and found no traces of any assessments of corruption risk in Bahrain in general.

There is no public information available suggesting that Bangladesh conducts regular assessments of corruption risks for defence personnel, nor has the Ministry of Defence commissioned or performed such assessments in the past. Two international reports by TI UK [1,2] placed Bangladesh in Band D, meaning that Bangladesh’s defence sector is susceptible to the greatest risks of corruption.

This indicator is marked ‘Not Applicable’, given that there is no evidence to suggest that risk assessments are conducted [1].

This indicator is marked ‘Not Applicable’, given that there is no evidence to suggest that risk assessments are conducted [1].

Since 2016, as the government wished to centralize all federal internal audits, the responsibility for auditing and risk assessment lies with the Federal Interal Audit (FIA) [1]. It carries out yearly audit programs, based on an annually updated risk assessment, which by its nature includes attention to corruption. Should any irregularities come forward, this will be taken up politically, which may result in the codification of anti-corruption measures through laws or deontological frameworks.

At the moment, these include two main frameworks. The Code of Conduct outlines how members of Belgian Defence should handle corruption risks [2]. On procurement specifically, which is judged by the area most vulnerable to corruption in Belgian Defence due to its financial and political character, the Code of Ethics in Public Procurement provides detailed guideiines on risk assessment and anti-corruption measures in the procurement process [3].

Secondly, the Court of Auditors (‘Rekenhof’, ‘Court des Comptes’) is an independent body with budgetary councillor and financial inspector as its main responsibilities [4]. It conducts yearly financial controls of all public institutions. It also conducts performance audits, which revolves around the three criteria of economy, effectiveness and efficiency [4]. Apart from annual audits, audits can also be instigated at the suspicion of financial irregularities, but this is a posteriori.

Since 2018, the Federal Internal Audit (FIA) carries out annual audits based on risk assessments. The risk assessment is updated annually every autumn and adapted when necessary [1, 2].

The Federal Internal Audit (FIA) has as its main goal to improve processes and procedures within the federal government. This includes the codification of means to counter corruption into anti-corruption policies or laws [1, 2].

In 2016, the Ministry of Defence of Bosnia and Herzegovina (MoD) adopted a Rule Book on Assessing Risk Corruption which foresees the risk assessment of working places in all organisational units and defines procedures of conducting the assessment of the vulnerability of corruption [1]. After the assessment was finished, measures were taken to reduce the recognised risks. Following the completed assessment of corruption risk at the end of 2017, measures for each job position were created in conjunction with the assessed level of risk. BiH MoD ordered realization of such measures with the aim of risk mitigation [1]. Job positions were classified by their risk level into five groups from G1 to G5. Positions classified as G1 have the lowest risk, with the risk level rising to G5 which is the highest risk of corruption. The assessment included all job positions within the MoD [1]. In 2017, the minister of defence confirmed that the Mod, within the framework of its Action Plan for Combating Corruption, produced a Methodology for Risk Assessment of the working places at the MoD [2].

According to the Plan for Integrity and the Fight Against Corruption of the Ministry of Defence of Bosnia and Herzegovina for the Period 2015-2019 every organizational unit of the MoD, including the Joint Headquarters of the Armed Forces of Bosnia and Herzegovina, during the period of implementation of the Plan, will analyze the content of the Plan itself and produce an annual action plan for every upcoming year that will be amended by their own needs. Consequently, at the end of every year being covered by the annual action plan, an analysis of the level of realization of the annual action plan itself will be produced [1]. The action plan which forms an integral part of the MoD’s 2015-2019 Integrity and Anti-corruption Plan specifies which MoD’s organisational units are designated as implementers of the measures and tasks defined under the Plan. The MoD’s organisational units are bound to fulfil the obligations falling within the scope of their remit as defined under the MoD’s 2015-2019 Integrity and Anti-corruption Plan and, with a view to their fulfilment, prepare their internal integrity and anti-corruption action plans. Upon approval at the level of the organisational unit, the action plans of organisational units are submitted to the MoD’s Office of the Inspector General for monitoring and analysis of the implementation of activities and, possibly, for publication. The activity described above is part of Strategic Goal 5 – Establishment of efficient mechanisms for coordination of the fight against corruption, as well as monitoring and evaluation of the implementation of the Strategy, Strategic Programme 5.3. Regular monitoring of the implementation of activities under the Action Plan for the Implementation of the MoD’s Integrity Plan and ensuring continuous operation of the reporting system on the implementation of the activities under the Action Plan, Activity 5.3.1. Analyze the implementation of the annual action plan and submit it to the MoD’s Office of the Inspector General [2].
The overview of the implementation of activities under the MoD’s 2015-2019 Integrity and Anti-corruption Plan prepared based on reports on the implementation of the activities that the MoD’s organisational units had submitted to the MoD’s Office of the Inspector General and show that 132 measures out of 186 were implemented [3].

As explained in subsection 10B, the MoD and the Joint Headquarters of the Armed Forces of Bosnia and Herzegovina, are obliged to annually analyze the content of the plan itself and to produce the amended action Plan for every upcoming year which will be harmonized with their recognized needs [1, 2]. The MoD’s Office of the Inspector General, as the main agent and coordinator of the overall activities in MoD in the field of building integrity and fighting corruption, once a year organises an analysis of the implementation of tasks of MoD’s organisational units under the Integrity Plan [1]. The findings are reported to the committee for implementation of the Policy for building integrity and fighting corruption in MoD by the MoD’s Inspector General in his capacity as the chairman of the Group of Experts for the implementation of the Policy for building integrity and fighting corruption in the MoD [2]. The overview of the implementation of activities under the MoD’s 2015-2019 Integrity and Anti-corruption Plan prepared based on reports on the implementation of the activities that the MoD’s organisational units had submitted to the MoD’s Office of the Inspector General and show that 132 measures out of 186 were implemented [3].
In 2016, the Ministry of Defence of Bosnia and Herzegovina adopted a Rule Book on Assessing Risk Corruption which foresees the risk assessment of working places in all organisational units and defines procedures of conducting the assessment of the vulnerability of corruption [4].

There is awareness of risk areas within the Defence sector [1]. However, as it has been alluded to earlier, in the absence of a Defence Anti-Corruption Policy, it is difficult to know exactly what has or is being done with regards to the risk areas [1]. These risk areas are mainly in procurement and have been reported in the media. The BDF has attempted to respond to some of these allegations [2]. It is also important to note that Defence does not have its own specific Ministry as it falls under the Ministry of Defence, Justice and Security [2]. This means that if there any risk assessments, they are carried out for the entire Ministry and not specifically for the Defence [2].

Risk assessments are not conducted on a scheduled basis [1]. There are no published risk assessments that have been done in recent years. However, the country has demonstrated its willingness to deal with corruption [1]. For example, Botswana has just completed a National Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) Risk Assessment [2]. The National Risk Assessment (NRA) was supported by the World Bank, which resulted in the adoption by officials of a National AML/CFT Risk Assessment Report and Action Plan presented at a three-day workshop. Botswana is the eleventh country in Africa to do so [2].

There are no corruption risk assessments that have been carried out or documented. As such, this indicator is scored ‘Not Applicable’. Whatever available information is not official. Inputs to the anti-corruption policy can be done as has been demonstrated elsewhere. [1] According to UNODC, the main aim of the draft National Anti-Corruption Policy is to enhance Botswana’s capacity to fight corruption by setting a framework for legal, institutional and social reforms.[2] To achieve this main goal, the draft policy sets out several objectives, among others:
(i) to advocate for laws that enhance transparency and for the revision of the existing laws to ensure relevance to new complexities;
(ii) to ensure harmonisation of all laws dealing with corruption;
(iii) to ensure Botswana enters into extradition treaties and to advocate for the domestication of important anti-corruption conventions;
(iv) to facilitate efficient coordination of all institutions involved in anti-corruption;
(v) to promote and guide anti-corruption activities in all organisations. This demands inputs from other stakeholders.

In comparison to the 2015 assessment, there were advances: the assessor found two audits related to projects of the armed forces on the Court of Auditors’ (TCU) website. One was related to the Navy’s PROSUB project, and it was conducted in 2014 [1]; another one relates to humanitarian operations in the Northeast of Brazil, which the Army is responsible for [2]. The Comptroller General (CGU) also set a series of integrity actions that mandated the armed forces to elaborate plans to assess the issue of corruption. On the CGU’s website [3], the assessor found the Integrity Plans of the Ministry of Defence [4], the Army [5], the Navy [6] and the Air Force [7]. These integrity plans are a result of Decree 9.203/ of 2017, that established their mandatory elaboration, and were launched in 2018 [8]. Thus, it is still difficult to investigate their efficiency since it has been approximately only one year since the first version. Additionally, the TCU answered an information request signalling that between 2015 and 2019, six assessments were made (TC 014.387/2014-0, 025.650/2014-9, 029.775/2016-7, 020.474/2017-2, 030.452/2019-8 and 031.659/2019-5) [9].

Decree 9.203/2017 [1] and the CGU’s internal regulation 1089/2018 [2] estimate that risk assessments should be reviewed periodically, but neither of these documents stipulates in how many years (or months) this should be done.

There is not enough information to score this indicator. Due to the very recent nature of the Integrity Action Plans, it is not possible to assess whether they influence anti-corruption planning [1, 2]. It is unknown if the results will generate action plans within the internal inspector’s offices.

No defence-specific assessment of corruption risk has been commissioned or taken place in the last 2-3 years. However, the ASCE-LC assesses many institutions on an annual report, along with some recommendations (1). From 2015, the ASCE-LC was granted power to investigate and prosecute cases of corruption. It should be able to expand its assessment to many public institutions, including the defence ministry. Assessments by the ASCE-LC usually results in recommendations being sent to each ministry, but the assessed ministries do not take them into account (1), (2). Additionally, there is the Supreme Audit Institution, which assesses public accounts managed by the government institutions. There are also civil society organizations, which assess corruption in public institutions. The REN-LAC has also identified key areas of greatest corruption risk (3). According to the DOS 2017 report, the National Anti-Corruption Network (REN-LAC) has identified the Municipal Police as the most corrupted government institution (4). The report also mentions that the REN -LAC also reported that “pervasive corruption in the customs service, gendarmerie, tax agencies, national police, municipal police, public health service, municipal governments, education sector, government procurement, and the Ministry of Justice, Human Rights, and Civic Promotion” (3).

No defence-specific assessment of corruption risk has been commissioned or taken place in the last 2-3 years. As such this indicator has been marked Not Applicable.

No defence-specific assessment of corruption risk has been commissioned or taken place in the last 2-3 years. As such this indicator has been marked Not Applicable.

No systematic assessment has been carried out of corruption risks for the Ministry of Defence and Armed Forces personnel, but it is believed that there is a growing awareness amongst military personnel of the risks of being charged with corruption as names of some corrupt military personnel are being broadcast over the state media [1] [2] and top military officials are allegedly charged with corruption. As reported by the head of the communication division at the Ministry of Defence, there is no tolerance or complacency in the face of differences in behavior in the Cameroonian army (speaking in an interview with the national daily Cameroon Tribune in June 2017). This was in connection with acts of corruption perpetrated by two non-commissioned officers of the gendarmerie to which Mindef (Ministry of Defence) reacted by levying heavy sanctions, including imprisonment [2]. The head of the communication division reported that there is a structure within the gendarmerie which, for example, sanctions both gendarmes and the military when cases of abuse are proven. Military Security receives many complaints from the public, including those posted on social media. These are taken with the utmost seriousness by the Minister Delegate to the Presidency in charge of Defence and all his colleagues. Naturally, investigations are always opened when the the complaint is well-founded. [2].

However, widespread corruption in the defence and security sector suggests that there are no such measures carried out systematically on a consistent basis. The GAN Business Anti-Corruption Portal reports states that “Cameroon’s police force is inefficient, poorly trained and plagued by corruption. Bribery is widespread among the police, and officers often demand payments at checkpoints and in exchange for granting unlawful freedom to detainees (HRR 2016). Further, corrupt police officials arrest and abuse individuals in exchange for monetary rewards from influential entities and individuals (HRR 2016). Over half of Cameroonians consider the police to be corrupt (GCB 2015). The government has taken some steps to hold officers accountable for abuse of functions, yet impunity remains widespread in the institution (HRR 2016). Cameroonian police cannot be relied upon to enforce law and order, and more than one in four firms identify crime, such as theft, and disorder as a major constraint (GCR 2016-2017, ES 2016). Companies attribute significant costs to crime; three out of five firms pay for their own security.” [3].

There is no information to indicate that regular and consistent assessments are conducted. Investigations are only carried out when there has been a reported case of corruption and abuse of power that was already publicised on social media [1] [2]. Thus, this indicator has been marked Not Applicable.

Risk assessments are not regularly conducted [1]. Thus, this indicator has been marked Not Applicable.

The Auditor General and the Chief Review Service both publish regular investigations into mismanagement, corruption, and operations of the military, but the reports tend to be concerned with particular programs or the Canadian Armed Forces (CAF) as a whole, rather than individual departments within the Department of National Defence (DND). [1] [2] [3]

Multiple assessments are carried out each year, as per the activities of the agencies listed. [1] [2] [3]

Recommendations from the Chief Review Service of the DND are regularly used to update policy and practices, and the degree to which these recommendations are implemented is itself audited in select cases by the CRS, with examples cited involving personnel, service delivery within DND, and capital equipment maintenance and costs. [1] [2] [3] However, there is no indication of the regularity of risk assessment findings by programme (or topic) and their respective inputs to anti-corruption policies.

There is some evidence of assessments of risks of corruption within the defence sector, but efforts are recent, and there is still no evidence of their effectiveness in deterring wrongdoing. After the unveil of cases of fraud in the army in 2014, the Ministry of National Defence (MDN) created a set of initiatives to strengthen probity and transparency [1]. These initiatives involved a working plan based on five pillars: measures for the prevention of administrative offences, the creation of risk matrices, the revision of the Register of Special Providers, the revision and strengthening of acquisition and purchases, and the reinforcement of the compliance with the regulation of lobby. A Committee for External Audit was in charge of defining a matrix of risks and controlling the execution of the audit [2]. The committee was integrated with senior members of the armed forces and the MDN as well as the Government Council of General Internal Audit (CAIGG). The committee developed a model of management and control of real and potential risks, promote probity issues, and reviewed governance schemes in the sector [3]. In 2018, the army should have had in place a Model of Risk Management. However, it must be noted that this system focuses mainly on organisational risks, and the specific risk of corruption has been partially tackled.

While there is no specific regularity for an overall risk assessment in the sector, the MDN established by-annual revisions to the Special Registry of Defence Sector Suppliers [1]; and by-annual revisions to the process of acquisitions and procurement in the armed forces, both for acquisitions that belong to the Law of Purchases and Contracting of the Public Sector and the Restricted Law of Copper [2].

There are specific cases that evidence the implementation of risks assessments and the elaboration of risks matrixes in institutions of defence and the armed forces [1], but their findings and subsequent use for improvement and reform are not always clear. There are cases, for instance, following the 2014 fraud case, when the army created a matrix of risks to map possible weaknesses in processes of acquisition and accounting and to elaborate institutional action plans [2, 3]. However, it is not possible to establish that this practice is systematic and periodic.

The government and the army have not published information on risk assessments in the defence sector. Since 2016, however, there has been an intensification of audits targeting military officers and units. [1,2] However, these audits do not have a preventive character as risk assessment exercises do. Audits are geared towards identifying existing caces of corruption rather than assessing risk in order to prevent corruption.

This indicator has been scored Not Applicable, as there is no evidence that risk assessments are conducted.

This indicator has been scored Not Applicable, as there is no evidence that risk assessments are conducted.

In accordance with Article 73 of Law 1474 of 2011, [1] the Anti-Corruption Statute, each government entity must annually develop an “Anti-Corruption and Citizen Care Plan” that includes “the corruption risk map, concrete measures to mitigate these risks, anti-process strategies and mechanisms to improve citizen care,” for which there is a standardized format. [2] The risk map presentation format should include the following elements: the analysis component, processes or subcomponents, activities, goal or product, managers, and the scheduled date. [3] Public entities, including the defence sector, must publish their anti-corruption plan including a risk map by 31 January, [4] where follow-up is carried out by each public entity. As for the military forces, they publish their report according to their entity, which means that there are reports by the Armed Forces, the National Army, the National Navy, the Air Force, and the National Police. In 2018, the General Management Unit of the Ministry of Defence and the Military and Police Forces carried out the Integrity Assurance and Corruption Prevention Plan carried out in 2015, [5, 6] this includes 5 components focused on citizen care, transparency and access to information, accountability, risk policy, and additional measures to combat corruption under the principles of effectiveness, efficiency, transparency, and accountability. It is emphasized that, in terms of citizen care, various information campaigns were promoted via various formats to publicize the Offices of Citizen Care and Orientation. Generally speaking, risk assessments are carried out by the Ministry of the Interior and by each force, but they do not focus on individual departments in particular.

Article 73 of Law 1474 of 2011 states that the “Anti-Corruption and Citizen Care Plan” referenced in 10A needs to be elaborated in a yearly basis. Article 73 states that “Every entity at the national, departmental and municipal level must elaborate annually an anti corruption and citizen’s service strategy.” This strategy will include, among others, corruption risks maps of the entity, concrete measures to mitigate risks, anti-red-tape strategies and mechanisms to improve services to citizens. [1] It includes a (short) section on risk assessment. The regulations stipulate that the process of monitoring compliance with the guidelines and obligations identified in the corruption risk map is carried out by the internal control offices of each entity, they must verify, make the document and make it public, through the website of the respective entity. [2] According to Decree 1081 of 2015, the construction of a Plan and the Risk Map must be carried out on April 30, August 31 and December 31, and its publication is carried out within 10 working days. [3] Monitoring is carried out by the planning manager of each entity. The risk map is published on the websites of the national police and the Ministry of Defence, however, although there is a stipulated timetable for the delivery of these risk reports, there is no evidence that all entities in the defence sector have such information published on their websites. [4, 5]

Following the guidelines of the Administrative Department of the Civil Service, it is possible to adjust and/or modify the Anti-Corruption and Citizen Service Plans for the purposes of improvement. To this end, such changes must be justified and reported to the internal oversight office; and public servants and citizens should leave them in writing, and in public, on the entity’s website. However, the conclusions derived from the evaluation of the plans are not necessarily useful for their improvement and feedback, since they are usually general and focus on indicating the state of execution or not of activities. Thus the plans do not reflect the experience of each of the entities/units responsible for the Plan in such a way that it may or may not be possible to identify good practices. As such, it cannot be said that these conclusions are being used to improve policy, but at the same time there is also no information to support the contrary. [1, 2]

There is a lack of evidence in the last 2-3 years that the government or the NA has subjected the areas most at risk of corruption within the MoD or the armed forces to regular assessments.

MoD: No evidence that at-risk areas (arms procurement, military expenditure) are assessed for corruption risk regularly.
armed forces: No evidence that at-risk areas are being assessed.
Police Nationale, Douanes, Protection Civile: No evidence that at-risk areas are being assessed.

The Plan National pour la Bonne Gouvernance et la Lutte Contre la Corruption, established in 2013 as a broad-based anti-corruption plan, does not include regular assessments of at-risk areas, and certainly not at the MoD or armed forces. In general, anti-corruption initiatives in Côte d’Ivoire are driven by actions against specific people accused of bribery/corruption rather than being preventive by nature. For example, the Loi de Programmation Militaire (LPM 2016-2020) allocated resources (2.254 billion FCFA; about USD 745 million per year) to the different military budgets through 2020, an increase in expenditure compared to the previous Law. The reasons for increased spending included the need to reequip the armed forces, the strengthening of border controls (especially in the more unstable western regions) and the fight against terrorism (1). The LPM 2016-2020 was approved by the NA Commission de Sécurité et Défense (CDS) on 4 January 2016. It has been characterized by the minister of defence as a reform bill driven by the professionalization of the armed forces. It seeks to reduce the number of soldiers in the armed forces to save on personnel expenditure. The executive hired Jefferson Waterman International (JWI), a US-based consultancy, to help draft the terms of the program. The document does not appear to mention areas in the military budget (such as arms procurement) that should be regularly audited for corruption risk (2), (3), (4), (5).

There is no evidence of regular assessments of at-risk corruption areas in the defence sector. Therefore, this indicator has been marked Not Applicable.

There is no evidence of regular assessments of at-risk corruption areas in the defence sector. Therefore, this indicator has been marked Not Applicable.

Research indicates that the Defence Internal Audit Office identify such risks as part of their auditing of the Defence [1]. Namely, the MoD internal auditing office compiles on a yearly basis an audit plan. The audit plan is made up on the basis of a systematic risk assessment, including the risk of corruption on all MoD areas. The risk assessment is done independently with contributions from all MoD agencies. [7].
Also, the 2018 Defence Internal Audit investigation (as mentioned in Q8) of the financial corruption risk within the agencies of the Ministry of Defence indicates that such risk assessments can take place on an ad hoc basis. The investigation in question was set in motion after a large corruption case within The National Board of Social Services was exposed [2, 3], which indicates that extraordinary events may provoke such an institutional response. The Danish National Audit Office conducts assessments on an ad hoc basis, as seen with the 2019 assessment of financial corruption risk within the Ministry of Defence Estate Agency. This investigation was launched in response to corruption accusations made by a whistleblower [4]. In turn, the findings of the investigation has resulted in further (and ongoing) investigations by the Danish National Audit Office, and these are expected to uncover bad practices and risk areas and present recommendations to mitigate these [5, 6].

The MoD internal auditing office compiles on a yearly basis an audit plan. The audit plan comprises the basis of a systematic risk assessment. This includes corruption risks in all MoD areas [1]. The risk assessment is undertaken independently with contributions from all MoD agencies [2].

There is evidence to suggest that risk assessment findings are not incorporated into policy or practice on a regular basis. This is first and foremost illustrated by the case mentioned in Q8, where warnings and recommendations from the Defence Internal Audit were ignored for years [1]. However, the Danish National Audit Office’s ongoing investigation of the purchase practices within the Ministry of Defence (in relation to the case of fraud in the Ministry of Defence Estate Agency as reported in Q8) is done with the intention and expectation of policy reccomendations. This at least indicates an intention to incorporate risk assessment findings into practice [2]. There is evidence that the Ministry of Defence incorporate reccommendations from the Danish National Audit Office in other areas than anti-corruption policy [3].

After surveying the Constitution, the anti-corruption strategy, all defence-related laws and media platforms, no evidence has been found to suggest that defence-specific assessments of corruption have taken place in the last three years. Interviewees agree that there have not been any risk assessments within the army for at least ten years (1), (2), (3).

As our sources indicated there are no risk assessments, this sub-indicator has been scored Not Applicable (1), (2), (3).

As our sources indicated there are no risk assessments, this sub-indicator has been scored Not Applicable (1), (2), (3).

There is a governmental anti-corruption action plan developed regularly for every seven years. In accordance with the State Budget Act [1] it is submitted to the Riigikogu for debate and consultations and then to the government for approval. The current strategy covering the period 2013-2020, [2] was written by the head of the Analytics Department at the Ministry of Justice and comprises eight pages. It gives a short overview of the current situation. According to the plan, corruption in Estonia is not very prevalent largely due to transparent decision-making processes within institutions. However, there are areas that could be more transparent, the report concludes. The strategy assesses that even though corruption is perceived as an important topic, in reality there is a lack of resources to tackle it. One of the reasons is a lack of understanding of what corruption really is, and the other is a belief that corruption should be tackled by using more control and sanctioning rather than creating more awareness. The latter, the author of the strategy claims, is a more effective way of fighting corruption.

The strategy does not mention the defence sector specifically.

One of the tasks of the Estonian Internal Security Service (EISS) is to fight corruption. Amongst other institutions and official positions, they scrutinize the Commander of the Defence Forces, the deputy Commander of the Defence Forces, Commander of Estonian Defence League, commanders of structural units, or any other employee in management position (who is not an active servant) at the Defence Forces or Defence League.

EISS assesses corruption risks in their public annual review. In 2017 and 2018 [4] they gave an overview of the situation and the risks, but not specifically about the defence sector. The reports cover the biggest case studies involving major security risks throughout the year. Some of them have occured within the defence sector, but there is no particular assessment of the greatest corruption risks for the defence ministry and armed forces personnel. [3,4]

EISS also collects information on and assesses corruption risks on a daily bases. In case of an occuring corruption risk, specific offices and institutions are approached together with suggestions on how to mitigate the risks. If a corruption-related crime or offence occurs, a procedure is started. There is no regular assessment of corruption risks at EISS. [5]

The rest of the corruption offence cases in the defence field are processed by the Police and Border Guard Board. [6]

The EISS publishes its reviews annually. [1] The reviews include risk assessments for government institutions, but not specifically for the defence sector. However, the review points out specific case studies, including those in the defence sector. The current anti-corruption strategy is in force for seven years [2], but implementation plans are published more frequently, as well as additional annual reports. None of those corruption risk assessments focus on the defence and security sector or institutions, but rather on Estonian society in general. These reviews barely mention the defence sector. The National Audit Office of Estonia scrutinises procurement cases in the defence sector, but focuses more on what has been done than on mitigating the risks. [3] There is no evidence of corruption risk assessments within the Estonian Defence Forces. [4]

This indicator has been marked Not Applicable. This is because there are no corruption risk assessments specifically within the defence sector, nor an anti-corruption policy specific to the defence secto.

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

The legal department also hosts an investigatory sector, which has specialised in investigating malfeasance and has a central role in anti-corruption activities in the Defence Forces. In addition, the Defence Forces has a representative in the anti-corruption network coordinated by the Ministry of Justice. [3] The aim of this network is to contribute to the minimisation of corruption in Finland. The National Audit Office inspected the management system of the Defence Forces in 2017 (yet without a specific focus on corruption risk).

According to the inspection report, the high amount of managerial models and processes complicates the overall picture and makes it difficult to clearly understand the different responsibilities, resources and procedures, even if the different models and processes are carefully depicted in documents. Management processes between the Defence Forces and the Ministry of Defence in general function smoothly, but measurability of efficiency goals and transparency remain challenges. [2] Assessments of the functionality of the Defence Forces’ systems are thus carried out, for example, by the National Audit Office. However, no defence-specific assessment of corruption risk has been commissioned or taken place.

This indicator is scored ‘Not Applicable’, given that there is no evidence that risk assessments are conducted.

This indicator is scored ‘Not Applicable’, given that there is no evidence that risk assessments are conducted.

There is some evidence that the Ministry is moving toards a comprehensive assessment of corruption risks, but many initiatives are relatively new. The Contrôle Général des Armées (CGA) has a risk-assessment “mission plan”, but it does not involve corruption. The dedicated webpage has not been updated since 2014. [1]
The new « Ethics Committee » of the Armies (part of the « Sapin 2 » law package on Anti-corruption of 2016) will implement a methodology based on risks, but this will focus on tackling conflicts of interests within the army. [2]

The Ministry of the Armed Forces (MOAF) undertook in 2020 a “corruption-risk mapping” (with a broader definition of corruption than defined the Penal Code, encompassing embezzlement and misappropriation of funds), [3] in the form of two separate questionnaires: one sent to over 60 departments at risk of corruption-exposure (procurement, subcontracting, exports, subsidies, HR, etc.) within the Ministry, and a second one, anonymous, sent to operators working with the Ministry. The “contrôleur général des armées” and “ethics chief” of the MOAF, Jean Tenneroni, indicated that this risk mapping would feed into the development and subsequent publication of the new ministerial Code of Conduct published in December 2020. [4]

In 2020, and in accordance with the “Sapin 2” law, the Ministry of the Armed Forces (MOAF) undertook in 2020 a “corruption-risk mapping” assessment. [1] This covered over 60 departments at risk of corruption exposure (procurement, subcontracting, exports, subsidies, HR, etc.) within the Ministry. This assessment was the first of its kind, and there is no publicly available evidence to indicate the regularity of this process (or whether another process is planned at all).

In 2020, and in accordance with the “Sapin 2” law, the Ministry of the Armed Forces (MOAF) undertook in 2020 a “corruption-risk mapping” assessment. [1] This covered over 60 departments at risk of corruption exposure (procurement, subcontracting, exports, subsidies, HR, etc.) within the Ministry. The “contrôleur général des armées” and “ethics chief” of the MOAF, Jean Tenneroni, stated that this risk mapping would feed directly into the development and subsequent publication of the new ministerial Code of Conduct, which was published in December 2020. [2] There is no evidence that such risk assessments will be conducted regularly, and therefore, nor is there evidence that findings will be regularly used to update policy or practice.

Corruption risks are identified, but risk assessments are conducted for the ministry or armed forces as a whole, rather than focussing on individual departments. Corruption risks are referred to in the context of the ‘identification of “corruption-prone work areas”‘ and are updated. The last official risk assessment was published in 2012 [1]. However, the risk analysis for the identification of particularly corruption-prone work areas must be carried out regularly at least every five years or as the need arises (in the event of a major restructuring). According to the BMVg, subsequent assessments were conducted in 2018 and 2021 but they have not been published [2]. Each individual job position is analysed and checked for possible corruption risks according to predefined criteria. These results are recorded in writing in a risk map and appropriate measures are taken for the affected post-holders. This applies to both civilian and military personnel, since the BMI guidelines on corruption prevention in the Federal Administration also apply directly to the armed forces. In cases of suspected corruption, work processes are analysed and checked for weaknesses. If necessary, appropriate measures are taken to prevent corruption from occurring again [3].

Risk assessments may also be carried out more frequently: assessments on work areas that are particularly at risk of corruption must be repeated no later than five years after the completion of the previous assessment. If organisational decisions result in a complete or extensive change in the structure of an organisational element or the tasks assigned to it, non-routine investigations must be carried out as early as possible (see A-2100/1, i.e. BMVg-specific implementation of the anti-corruption directive [4]).

For instance, there is the ‘Sustainability Report 2018 of the Federal Ministry of Defence and the Bundeswehr’, which refers to the 2016-2017 period. Page 18 states: ‘4.2.1 Hazard and risk analyses: A key preventive measure of the directive against corruption is the identification of particularly corruption-prone positions. In this so-called risk analysis, Unit R II 6, together with the staff members of the Federal Ministry of Defence, assesses which posts are particularly at risk of corruption, based on their job description and the contacts and decision-making powers that come with them. Factors such as a concentration of responsibilities or a reduction of assessment bodies generally lead to an increase in corruption risk. The risk analysis therefore focusses particularly on the following questions: Does the post allow for discretionary decision-making? Does the post involve executing security-sensitive activities, managing budgets, maintaining regular external contacts or managing procurements? Above all, however, the risk analysis focusses on the central question of whether third parties can be given a material or immaterial advantage or whether a disadvantage can be averted. This risk analysis must be carried out in a five-year cycle. Of the 2,620 current posts in the Federal Ministry of Defence, 2,223 posts were conclusively assessed as part of the current risk analysis. Ultimately, 767 of them were classified as being particularly prone to corruption. For downstream departments, the respective head of department is responsible for implementing the risk analysis in their own area of ​​responsibility. Higher/command authorities may develop their own procedures in this regard. If a post is classified as being particularly prone to corruption, risk analyses must then be carried out by the respective superiors. This analysis must examine how corrupt practices can be minimised by adapting organisational and procedural measures, among other things’ [5].

There is a schedule for risk assessments, but they are conducted on a less-than-annual basis [1]. The last official risk assessment was published in 2012. The risk analysis for the identification of particularly corruption-prone work areas must be carried out regularly at least every five years or as the need arises (in the event of a major restructuring). According to the BMVg, subsequent assessments were conducted in 2018 and 2021 but they have not been published [2]. Risk assessments may also be carried out more frequently: assessments on work areas that are particularly at risk of corruption must be repeated no later than five years after the completion of the previous assessment. If organisational decisions result in a complete or extensive change in the structure of an organisational element or the tasks assigned to it, non-routine investigations must be carried out as early as possible (see A-2100/1, i.e. BMVg-specific implementation of the anti-corruption directive) [3]. Each individual job post is analysed and checked for possible corruption risks according to predefined criteria [4]. For instance, there is the ‘Sustainability Report 2018 of the Federal Ministry of Defence and the Bundeswehr’, which refers to the 2016-2017 period [5]. There is not any information available on the publication of the next official risk assessment; there is only some general information [6].

Risk assessment findings may be used to develop an anti-corruption policy or action plan, but they are not used to regularly update either policy or practice [1]. For example, each individual job post is analysed and checked for possible corruption risks. These results are recorded in writing in a risk map and appropriate measures are taken for the affected post-holders. This applies to both civilian and military personnel, since the BMI guidelines on corruption prevention in the Federal Administration also apply directly to the armed forces. In cases of suspected corruption, work processes are analysed and checked for weaknesses. If necessary, appropriate measures are taken to prevent corruption from occurring again [2].

There are no publicly available corruption risk assessments for ministry and armed forces personnel. However, activity 11 of the NACAP “Strategic Objective 1: to build public capacity to condemn and fight corruption and to make corruption a high-risk, low-gain activity” includes, “conduct[ing] assessment of institutions/agencies on the integration of corruption prevention measures in their work programmes” with an indicative budget allocated of 500,000 USD (1), (2), (3), (4). No information about its implementation has been found.

This indicator is scored Not Applicable because there is no evidence that risk assessments are conducted.

This indicator is scored Not Applicable because there is no evidence that risk assessments are conducted.

No defence-specific assessment of corruption risk has been commissioned in recent years [1, 2].
It may be improved in the near future, as The National Transparency Authority has developed a Fraud Risk Management Manual for the Hellenic public administration, which feeds in the preparation of the 2022-2025 National Action Plan against Corruption (NACAP). MoD is providing inputs to this exercise through its participation in ESOEL in order to develop tailored and hands-on policies to enhance integrity and transparency in its core functions and processes. [3]

This indicator is scored ‘Not Applicable’ as the MoD and other relevant ministries do not conduct regular assessments of corruption risks [1, 2].

This indicator is scored ‘Not Applicable’ as the MoD and other relevant ministries do not conduct regular assessments of corruption risks [1, 2].

There is an annual risk assessment procedure; however, the report only lists the approved strategies and tasks [1]. There is no information on risk areas or any cases. The published information suggests that annual assessment tends not to reveal any weaknesses, and although they should receive reports from whistleblowers, due to a lack of trust, they have not received any reports on a single corruption case so far.

According to the integrity plan and law [1], integrity reports are submitted annually as an attachment of the annual budget report of the ministry at the end of every financial year. The plan should include the assessment of corruption risk for the personnel of both the ministry and of the armed forces. However, risk assessment reports have no real findings [2] that could anyhow develop into any anti-corruption policy or practice.

The Integrity Report of the Ministry of Defence [1] has no real findings that could develop any anti-corruption policy or practice. Since no problems or weaknesses were revealed in the report or prior reports, no policy development could be identified; that part of the report that lists problems regularly remains empty.

There is no evidence of regular assessments of the areas of greatest corruption risk for Ministry of Defence (MoD) and Armed Forces personnel. However, under the New Functional Paradigm for Internal Audit in the Defence Accounts Department (DAD) introduced in 2016, each organisation is to have an “internal audit and risk management” framework. This process includes “assessing, monitoring and responding to risks in order to reduce their impact is achieved through the implementation of a risk management framework which consists of risk identification; risk prioritization; risk mitigation; implementation of mitigation plans; and review and monitoring of mitigation plans”. It is believed that a risk management framework serves as an “effective governance model” [1]. Periodic reviews by the Audit Advisory Committee for the risk profile are suggested every three years. There is no evidence of any such review in the public domain. Neither is there evidence of defence-specific corruption assessments in the last few years such as Transparency International’s Government Defence Anti-Corruption Index in 2013 or 2015 [2].

Following corruption scandals, the government at times identifies vacuums where corruption can arise, primarily in procurement. The implementation of Integrity Pacts and ratification of UNCAC are examples of this [3][4].

As alluded to above, there is evidence to suggest a paradigm shift in the MoD and its incorporation of a risk management framework. There is no evidence of regular assessments of the areas of greatest corruption risk for MoD and Armed Forces personnel, in the past few years [1][2][3].

As mentioned above, there is no evidence of regular corruption risk assessments but there is evidence of identification of corruption risks that affect policy [1][2][3].

Ad hoc and partial assessments may have been conducted by the government. In 2017, for instance, the state’s Audit Board (BPK) scrutinised a list of what was considered high-risk projects after conducting risk assessment on risk assessment on all weapon procurement projects in the MoD [1]. However, it was not clear whether the recommendations were translated into policies in the MoD. A relatively large amount of the allocated budget, especially in the field of operation and procurement of defence equipment, is considered vulnerable to fraud [2]. In the field of ‘alutsista’ (main equipment and weapon systems) procurement, corrupt practices are suspected to occur from the purchase or procurement stage all the way up to maintenance processes. These practices can occur in the form of mark-ups, purchase of ‘under-specification’ defence equipment and trimmed maintenance costs. There are several factors considered to play a role in perpetuating a culture of corruption in the defence sector, including the limited capacity of independent civilian institutions such as the KPK to investigate corruption cases involving TNI personnel, the involvement of third parties (brokers) in the procurement of defence equipment and the use of ‘state secrets’ as an excuse, which complicates efforts to handle corruption [3]. Although the potential for corruption within the Ministry of Defence and the TNI has been widely voiced by the public, there has not been an in-depth and regular assessment of the risks or potential for corruption within the Ministry of Defence and the TNI [4].

This indicator is marked ‘Not Applicable’. There has been no specific assessment of corruption risk in the last 2-3 years and there is no evidence of a regular schedule for risk assessments.

This indicator is scored ‘Not Applicable as there has been no specific assessment of corruption risk in the last 2-3 years. It is not known whether ad hoc risk assessment that occured following revelation of corruption case has produced recommendations that were translated into anti corruption policy [1]. As noted in 10A, there is no evidence that the 2017 high risk audit investigation resulted in any substantive changes.

There is no evidence to indicate that a defence-specific assessment of corruption risk has been commissioned or taken place in the last two to three years [1].

This indicator is marked Not Applicable, as there is no evidence to indicate that risk assessments are conducted [1].

This indicator is marked Not Applicable, as there is no evidence to indicate that risk assessments are conducted [1].

There is no evidence in Arabic and English sources of published reports by defence officials or bodies measuring or assessing high corruption risk in its own or associated institution, in spite of renewed defence risks. While the state officially exercises command over all security agencies, the PMF command structure, “does not necessarily go up to the prime minister, who serves as commander-in-chief” (1). The fact that the organization competes with other forces commanded by the state, “over checkpoints and operations” raises new defence concerns the government of Iraq is yet to address (1). The fragmented nature of the armed forces, a retired military officer explained in an interview (2) with Transparency International, reflects the “lack of agreement on which areas represent the greatest corruption risks” (2). Recent calls from State of Law MP Aliyah Nassif for the integrity and judicial commission to resume their investigation of ex-defence minister Obeidi goes against not guilty verdict issued by Iraq’s courts (3), in another example of political infighting which continues to hamper Abadi’s corruption reform. While investigations are, by law, handled by Iraq’s integrity commission alongside inspector generals, there is no evidence of assessments of risks they have examined in the case of the military or armed forces. In November 2017, the Parliament voted to abolish the inspector general’s offices (4), as one article states “a clear indication of their abject failure” (5). Some inspectors, are additionally implicated in corruption cases themselves. Therefore, a score of ‘0’ has been chosen in the absence of assessment risks, as far as Iraq’s security actors/institutions are concerned. The impact of corruption risks on Iraq’s military and defence sector is better assessed by INGO’s, including NATO (2018), to tailor their training programmes intended to professionalize and develop the capacity of Iraq’s security forces and defence establishment.

No evidence was found to support the claim that scheduled risk assessments are enforceable by Iraq’s security and defence establishment. This is all the more likely in light of ever-shifting political developments (1), (2), (3), (4) that would disrupt planned scheduling, including the potential reemergence or continued attacks by the ISG.

In the absence of a national anti-corruption strategy and compliance programmes, it cannot be proven that corruption risk assessments are conducted or scheduled, although the responsibility on Inspector Generals within the respective ministry concerned, which ought to serve as an internal control system (1), (2). In spite of that, few effective measures have been adopted by IGs within their respective ministries (1).

There is partial assessment of corruption risks on a regular basis, but it does not clearly articulate risks for the ministry or armed forces (1). While there have been initiatives to conduct risk assessments at a top-level, to date, there have been none that focus explicitly on the ministry of defence or armed forces. The 2017 National Risk Assessment on money laundering for instance is “designed to assist the public and private sectors in identifying the risks of money laundering in the country, to understand the potential risk of these phenomena to the financial system and to national security, and to become familiar with the measures taken by the state to deal with these risks. In addition, the risk assessment is meant to serve as a basis for setting policy and priorities in the field of prohibition of money laundering and terror financing, for the application of a risk-based approach and the efficient allocation of resources. The risk assessment was conducted under the instruction of the Attorney General, during a period of two years, as part of a comprehensive process which included all relevant counterparts, and was coordinated by the Israel Money Laundering and Terror Financing Prohibition Authority (“IMPA”)”(2). However, the report does not make a mention of the MoD or IDF in particular and there are no other risk assessments that focus on these areas.

The last risk assessment was conducted by the Ministry of Justice over a period of two years and officially published in 2017 (1). There isn’t any information available when the next assessment is expected. The last National Risk Assessment is “combined of three main documents: (a) National ML risk assessment – includes an analysis of risks stemming from two different perspectives: Predicate offenses and ML typologies, methods and instrumentalities. Analysis includes data and insights produced by LEAs combined with the sectorial risk assessments of the financial system. (b) Financial system risk assessment – a set of sectorial risk assessments in which the supervisors of financial institutions assessed the specific ML risks that are relevant to each sector. (c) National TF risk assessment – risk assessment produced by intelligence and security agencies together with additional relevant partners, and includes an assessment of terror and terror financing risks (a non-restricted version will be published separately). It should be mentioned, that in recent years, a range of risk assessments, including focused assessments of specific sectors or themes, and assessments at national level of issues relevant to ML/TF, were produced within inter-governmental committees. These assessments relate to risks of serious and organized crime, tax offenses, gambling, Money Service Businesses, cash, corruption, and alternative payment methods. Those risk assessments were updated and included in the ML NRA.” (1) However, from time to time the Knesset can assign “Special investigative committees” like the one between 2005 to 2006 that was designated to look for corruption in the government (2)

Risk assessment findings may be used to develop an anti-corruption policy, however they are not used to regularly update either policy or practice. For instance, it is written in the National Risk Assessment that “Israel is not rated as highly corrupt country. However, measures to prevent and counter domestic and foreign corruption were given high priority by all law enforcement agencies. The Government has funded and encouraged a combined and joint effort against corruption in general and corruption in public systems in particular, and has acted to minimize illegal financial activity. As part of Israel’s unwavering commitment to combat corruption, it is also an active member to international conventions in the field of Anti-corruption and Bribery.” (1) Furthermore it is written that: “The Government has funded and encouraged a combined and joint effort against corruption, although the assessed financial scope of bribery is not significant (compared to other predicate offenses), but the financial and social consequence is significant. Appropriate measures to prevent and combat domestic and foreign corruption were given high priority by all authorities. A strong tradition of professional independence and impartiality enables all relevant authorities to investigate and inquire into any suspicion.” (2)

Assessment of the areas of greater risk of corruption is foreseen by law. The National Anti-corruption Authority identifies the area of major risks of corruption [1], that have to be taken into account by each administration in the formulation of their Three-year Anticorruption and prevention plan, which is assessed and updated every year [2]. According to the latter (section III.3), identification of risks is carried out by each director of organisational units, that can be defined as groups of human and instrumental resources entrusted with homogeneous skills.

According to section III.9 of the Three-year plan, a report on the monitoring activities on the implementation plan has to be filled out by each referee by the 15th of November of every year [1]. The archive of the reports can be found on the website of the Ministry of Defence [2].

The Three-year plan is updated every year [1] in order to consider recommendations and inputs coming from the annual reports by the Anticorruption supervisor [2] and by the national anticorruption authority.

Beginning in January 2006, some executive civil servants in the Japanese Ministry of Defence (MOD) were arrested and prosecuted by the Tokyo District Prosecutor’s Office on charges of obstructing competitive bidding (collusion). [1] Former Administrative Vice-Minister of Defence Takemasa Moriya was also arrested on charges of receiving bribes and making false testimony in the Diet and received a prison sentence and a fine. [2] A committee established with members from the Defence Agency as well as external members held 14 meetings in 6 months and produced a report that assessed corruption risk. One of its main conclusions was that the lack of an Inspector General’s Office was a corruption risk. [3] Furthermore, the Ministry conducted meetings and took initiatives to consider how to avoid the reoccurrence of corruption. In 2013, it set down an investigative committee on reform of the MOD, with a mandate that included risk assessment for corruption. The committee’s 11th meeting was held in 2015, but no subsequent meetings are listed on the homepages of the Ministry. [4] Several risks with regard to procurement were identified, and these were one of the justifications for the establishment of the Acquisition, Technology and Logistics Agency (ATLA) in 2015, which was to handle the increasing amount of administrative tasks connected with defence procurement. [5] Documents from seven meetings of the Expert Committee on Defence Equipment and Technology, the first dated February 2016 and the last dated April 2018, have been posted on a page of the MOD website. [6] All documents found here deal with ATLA, but only the first raises the question of the strengthening of internal inspection and audit as a measure to prevent corruption. [7]

Information on the webpages of the Japan Ministry of Defence (see Q10A) indicate that a thorough assessment of the corruption risk was made following the 2006 incident. The conclusions of this assessment provided input into anticorruption policy (see 10C). However, a search on the webpages of the Ministry of Defence, [1] as well as those of the Board of Audit [2] and the two mainstream national newspapers Asahi Shimbun [3] and Yomiuri Shimbun, [4] did not turn up any mention of corruption risk assessment. Corruption risk assessment therefore seems to have been comprehensive in the years following the 2006 incident, but not since the institutional changes following the 2006 incident had been well implemented.

The assessment of the 2006 collusion incident was justification for the establishment of an Inspector General’s Office in 2007. [1,2] The Ministry of Defence implemented the recommendations of the Investigative committee on reform of the MOD (see Q22A), through two initiatives. One initiative was the establishment of an internal inspection and audit unit in ATLA when it was set up in 2015. This measure was described in detail in the section “Measures to increase fairness and transparency” in a chapter on procurement in the 2016 issue of the annual white book Defence of Japan. [3] It was also mentioned or described in the same section of the issues of this book from the years 2015 and 2017 – 2020. The same section in Defense of Japan from 2016 [3] and subsequent years also described how ATLA’s own internal inspection was supplemented by inspections of ATLA by the Inspector General’s Office, [4] and assessment of its work by the Defence Procurement Deliberation Committee, [5] both of which have preventing corruption as part of their mandate. In the same section, the Ministry also explained how it had followed up cases where procurement had been managed in unfair or opaque ways with measures designed to prevent recurrence, for example [6]. According to the 2017 issue, an IGO special inspection in 2016 concluded that the selection of multi-purpose helicopters for the MSDF had not been fair. To avoid recurrence, the Ministry was strengthening oversight of the selection of vehicles and making the rules in a circular on vehicle selection more stringent, although it is not clear specifically what changes were made based on the recommendations. [7,8,9] In subsequent issues of Defence of Japan, the Ministry reported that it was continuing to implement the measures introduced after the above 2012 inflated invoices and the 2016 vehicle selection incidents.

The second of the Ministry’s initiatives to implement the recommendations of the Investigative committee on reform of the MOD sought to achieve greater control by the Minister and SDF, and to strengthen the capacity of both the Ministry and the SDF to perform their separate functions. A report by the MOD Reform Council from 2008 found that insufficient political leadership and lack of attitudes of professionalism in the Ministry had allowed former administrative vice-minister Moriya to continue to receive bribes over several years and had also contributed to an accident and information handling scandals unrelated to corruption. [10] Building on the 2008 report and briefer reports from subsequent years, a report by the Investigative committee on reform of the MOD in 2013 proposed four reforms: (1) To introduce parallel posts of civil service officials and SDF officials in both the Ministry proper and the SDF staff; (2) To conduct procurement and maintenance with an aim to strengthening the SDF as a whole rather than each of the service branches; (3) Under clear control by the Minister, to assign planning tasks to Ministry civil servants and management of operations to the SDF staff; (4) To strengthen the policy making and public information functions of the Ministry. [11] The first of the reforms was implemented in FY 2014 when new SDF official posts were established in the Ministry proper and civil servant posts in the SDF staff. The three remaining reforms were implemented in FY 2015 when the Ministry proper was reorganised to strengthen its planning, policy making and public information capacities and the SDF was reorganised to strengthen its management of the operations of its forces. [12] The Ministry refers to these reforms and describes minor initiatives to strengthen them in each of the annual issues of the white book Defence of Japan from 2015 to 2019 in the section “Reform of the Ministry of Defence” in a chapter on the organisation of the MOD and SDF. The 2020 issue has no section on “Reform of the Ministry of Defence”, implying that the reforms had by then been implemented. Hence, the risk assessment findings described in Q10A were used to develop an anti-corruption action plan. Policy and practice is not updated regularly however, action is taken after there have been salient incidents, such as the 2016 vehicle selection incidents.

There is no evidence to support that the defence sector conducts corruption risk assessments in Jordan. In fact, the only entity that could possibly run such assessments is the Audit Bureau, which does not seem to have much oversight power over defence institutions. According to the list of ministries, institutions and authorities audited by the Jordanian Audit Bureau, the General Intelligence Directorate and the Public Security Directorate are included in the audited entities section [1]. However, there is no indicator or any evidence that the Armed Forces have been audited at all in the past three years [3, 4]. The lack of an effective defence ministry in the country, and accountability reasons in matters related to defence, also makes it difficult to carry out audits. In recent parliamentary discussions, amendments have been proposed to the mandate of the Audit Bureau in order to ensure its independence and partiality, when auditing all governmental institutions [2]. These assessments of security and defence in the country are irregular and do not apply to all entities relevant to defence, and they also fail to provide recommendations around corruption risks [5].

This sub-indicator has been marked Not Applicable because corruption risk assessments are not conducted in relation to defence [1,2,3].

This sub-indicator has been marked Not Applicable because corruption risk assessments are not conducted in relation to defence [1,2,3].

The EACC conducts system assessments for corruption risk in public bodies, however there is no publicly available evidence that this has been done for either the KDF or MOD. While not risk assessments per se, the Public Service Commission does conduct evaluation and monitoring surveys on of all public ministries including Ministry of Defence (MOD) on various issues of related corruption. [1] The evaluation is conducted as part of Status of the Public Service Compliance with the Values and Principals in Article 10 and 232 of the Constitution report. Issues of corruption in the ministries that are covered are primarily in one of the key pillars of the assessment tool, that is Good Governance, transparency and accountablility. The issues covered include: reported cases of corruption in the organisation, declaration of gifts, declaration of conflict of interest, submission of initial and final declaration, mainstreaming of values and principles in the scoring criteria in appointments, the existence of a communication strategy, access to information by citizens, existence of a functional Board or Council. One of the main setbacks with the report is that aggregates outcomes from all the ministries, and therefore it is challenging to attribute and single out results from the ministry.

This indicator has been marked ‘Not Applicable’, as there is no evidence that risk assessments are conducted. An evaluation survey is conducted annually and there are records since 2012, with results are published in Status of the Public Service Compliance with the Values and Principals in Article 10 and 232 of the Constitution report. These reports are generally accessible from the Public Service Commission website however some from the previous years were not all online from the time this review was conducted. [1]

This indicator has been marked ‘Not Applicable’, as there is no evidence that risk assessments are conducted. One of the objectives of the annual evaluation survey is to make recommendations to the President and Parliament for policy interventions. [1] Findings from the evaluation are also used to inform development of anti-corruption to fight corruption. For instance, recommendations from past evaulation reports in 2014-2015 were used to, among other initiatives, develop a national ethics and anti-corruption policy in 2018, as well as develop the Anti-corruption laws (Amendment Bill for 2016). [2] [3] In the past, evaluation reports are published annually, but the last one to be published was for the year 2017/18.

The team involved in drafting the Integrity Plan (2019-2022) assessed the integrity framework of the Ministry of Defence based on a pre-defined methodology applied to nine South East European countries [1]. The methodology used is based on standards of ethics and integrity; best practices of governance and oversight of anti-corruption programs; and accountability to stakeholders through transparency and public reporting. Moreover, this methodology ensures that human resources policies and procedures support the anti-corruption program; drafts an anti-corruption program based on full risk assessment; implements detailed policies and procedures to combat the major corruption risks; manages relationships with third parties to ensure that they perform under an anti-corruption standard equivalent to that of state institutions; uses communication and training to introduce the anti-corruption program; provides safe and accessible advice for whistleblowing channels; and monitors, assesses and constantly improves the implementation of the anti-corruption program [1]. It is important to note that the plan contains a “Matrix of Measures and Activities for Implementation of the Integrity Plan of the Ministry of Defence (2019-2022)” [2] which acts as an action plan with specific measures and activities to be implemented within the given timeframe [3]. The drafting process of the matrix involved all stakeholders from the Ministry of Defence [3] as stipulated by the Integrity Plan (2019-2022) [2]. In the framework of drafting the Integrity Plan (2019-2022), the Secretary General of the Ministry of Defence established a technical working group to deal with the research, analysis, assessment and implementation of the plan [4]. This technical working group comprised representatives of the Ministry of Defence and Kosovo Security Forces, including officials from the field of policies and planning, procurement and contracting, personnel, logistics, finance, internal auditing, legal and the Kosovo Security Forces Inspectorate [4]. Additionally, members of the group also represented the Ministry of Public Administration, the Anti-Corruption Agency, and two advisers of the North-American Trade Organisation Advisory Team in Kosovo which operates within Kosovo’s Ministry of Defence [4].

Reporting on the implementation of the measures and activities laid out in the Integrity Plan (2019-2022) will be conducted every six months by the Department on Planning and Assessment within the Ministry of Defence [1]. Furthermore, based on the Integrity Plan (2019-2022), a permanent committee should be appointed by the Minister of Defence and its Secretary General to monitor, analyse and assess on a regular basis the extent to which the measures and activities of the matrix are being implemented [1].

Based on the Integrity Plan (2019-2022) of the Ministry of Defence, risk management is conducted to identify, analyse and assess the corruption risks within the Ministry of Defence and the Kosovo Security Forces [1]. This is an objective-setting process for all units of the Ministry of Defence and the Kosovo Security Forces to define the level of risk within the bodies’ organisational units [1]. The Integrity Plan states that process managers are responsible for monitoring work processes and managing the most important risks that may impact the achievement of the stated objectives [1]. The Internal Risk Management Guide requires revision with regards to the military and defence mission of the Kosovo Security Forces [1]. There is little information on how updates and potential revisions are made, despite the fact that the Plan’s implementation is closely monitored and assessed every six months by the Department on Planning and Assessment of the Ministry of Defence [2].

Corruption risks are not clearly identified and the internal financial departments of the security agencies do not have a culture of corruption risk assessment — but that appears to be changing. The SAB created, in 2017, a unit whose sole job will be to establish a guide for auditors to use to identify risks in Government agencies that lead to the squandering of public funds, the SAB said in its annual 2017 report (1).

So far nothing has emerged to suggest that this unit will address every department in every ministry, or if it will simply examine defence and interior ministries as a whole.

This sub-indicator has been marked as Not Applicable because the SAB unit was created in 2017 and at the time of the GDI research the 2018 annual report was not published. In this regard, access to information about regularity can be further assessed only after the SAB releases its 2018 report. The 2017 report does not say how often the institution will conduct the risk assessments, but it does talk about how they intend to change their (yearly) system based on this new unit’s findings, so it would not be unreasonable to assume that they will be conducting these risk assessments at least once a year starting from 2018 (1).

This sub-indicator has been marked as Not Applicable because the SAB unit was created in 2017 and at the time of the GDI research the 2018 annual report was not published. We will not see the effects of this unit until the 2018 report is available.

The MOD fulfils the tasks mentioned in the KNAB anti-corruption guidelines. The MOD has started using the International Risk Assessment Tool, implementing the recommendations contained in the self-evaluation report on the Promotion of Welfare, including relevant measures in the MOD Anti-Corruption Action Plan. The MOD organisational anti-corruption plan is also mandatory to the National Armed Forces (NAF). To date, three different instruments are available for corruption risk assessment in the defence sector: internal audits, the Auditor General’s annual specialised reviews and general oversight by the Corruption Prevention and Combating Bureau. The Ministry of Defence also uses the NATO Building Integrity Program. [1]

Each year, according to the anti-corruption plan, the responsible institutions such as the MOD carry out corruption risk assessments and an anti-corruption plan is updated accordingly. [1]

Regular assessments of defence sector corruption risks are carried out at various levels, and risks are annually identified and dealt with. The MOD also uses the international risks assessment tool provided by NATO, and closely follows the latest updates. [1] Often the requirements from anti-corruption agency KNAB are fulfilled sketchily, due to poor information flow. [2] All the same, the State Auditor Office’s audits are available and demonstrate external audit procedures and recommendaitions against identified deficiencies.

The anti-corruption policy, is based upon these regular risk assesment. Moreover, the recommendations indicated by the State Audit Office, KNAB and Internal Audit are incorporated into policy documents and internal action plans. [3]

No evidence of regular defence specific assessments of corruption risks done by the Ministry of Defence was found. The Ministry of State for Combating Corruption did not conduct such assessment before it was dissolved, which source 1 confirmed (1). The DoO has indicated that anti-corruption measures are integrated into the laws and provisions regulating the LAF which military personnel are continuously reminded of by their seniors (2).

This sub-indicator has been marked as Not Applicable, as there is no evidence of defence specific corruption risks assessments being conducted (1). However, the DoO has indicated that anti-corruption measures are integrated into the laws and provisions regulating the LAF (2).

This sub-indicator has been marked as Not Applicable, as there is no evidence of defence specific corruption risks assessments being conducted. Although the research found no risk assessments conducted (1), the LAF’s Directorate for International Humanitarian Law and Human Rights conducted anti-corruption training on two rounds at the Fouad Chehab Military College. The training was led by two colonels who had undergone combating terrorism and money laundering training in the US (2).

Corruption risks are clearly identified. Annual records since 2010 can be found online. The Corruption Prevention programme (approved in 2017) also identifies spheres where the highest possibility of corruption may exist. Moreover, this programme includes information about the Government Defence Anti-Corruption Index 2015 and an assessment of Lithuania’s defence sector [1]. Risk assessment as such has been done at least several times by external bodies as well, namely by the Special Investigation Service of the Republic of Lithuania (documents found on the website of Ministry of National Defence date back to 2017. However, risks assessments do not focus on individual departments, but rather on the Lithuanian defence system as a whole. Most recently, it seems that public procurement has been as one of the main focuses for risk assessments [2]. The latest risks assessment was conducted in 2017 [2].

Self-assessments of corruption risks have been undertaken since 2010 by each body of the defence system. Based on desk research, the summary of corruption risks within the Ministry of Defence was published publicly since 2010. There are also several risk assessments conducted by the Special Investigation Service of the Republic of Lithuania dating back to 2017 [1,2]. Since the last risk assessment was conducted in 2017 [1], it is evident that they are conducted on a less-than-annual basis.

The Corruption Prevention Programme (2017-2025) was prepared in accordance with Republic of Lithuania Law on Prevention of Corruption and the National Anti-corruption Program of the Republic of Lithuania for 2015-2025, as well as with other recommendations including from the 2014 Report of the European Commission on the Fight against Corruption in the European Union [1]. In addition, priority risk areas are addressed based on the self-assessment of corruption risks carried out by the Ministry of Defence and the Special Investigation Service [2,3]. However, it is not entirely clear to what extent these risk areas inform practice.

Both the Internal Audit and Investigation Division (BADSA) and the Integrity Unit are tasked with conducting corruption risk assessments. While the Integrity Unit oversees the Ministry of Defence (MINDEF) as a whole, [1] BADSA comprises several teams each tasked with overseeing specific sections or activities in the ministry. BADSA offices are also established in several select states. [2] The Auditor General also provides regular assessments and reports on MINDEF. [3] Furthermore, national anti-corruption agencies such as the Malaysia Anti-Corruption Commission (MACC) and the National Centre for Governance, Integrity and Anti-Corruption (GIACC) may conduct assessments based on received complaints or corruption reports.

The Auditor General provides an annual assessment and report. [1] However, the Internal Audit and Investigation Division (BADSA) and the Integrity Unit regularly conduct assessments throughout the year. In 2018, eleven audits were carried out by BADSA within the Ministry of Defence. [2]

The Ministry’s annual report incorporates both the Internal Audit and Investigation Division (BADSA’s, page 28) and the Integrity Unit’s (page 53) activities and assessments [1] and is used to highlight corruption risk areas and practices. Measures are also taken in light of the published Auditor General’s Report. [2] [3] However, whether these corruption risk areas will be reflected in the OACP which is currently in its formulation process is yet to be seen. In November 2020, MINDEF published an Organizational Anti-Corruption Plan (OACP) which outlines its commitment to enhancing integrity, accountability and good governance; however, this document was not accessible for full review. [4]

In 2014, the Minister of Economy and Finance and the Minister of Justice and Human Rights requested that the IMF conduct an assessment of the primary corruption risks in Mali. The report was commissioned in the wake of the controversial off-budget purchase of a new presidential jet for USD35-40 million without parliamentary approval. Curiously though, the IMF report, which was completed in December 2014, focuses on corruption risks in real estate, banking, mining and the use of shell companies. It does not analyse the risks of corruption in either government ministries or in defence procurement. Since then, there is no public record of any further assessments being undertaken. This was confirmed by a security expert working in Bamako, who said that they had no knowledge of the MDAC instigating any kind of risk assessment for corruption during the past three years [3].

There is no regular schedule for risk assessments. Therefore, this indicator has been marked Not Applicable.

No risk assessments were conducted after 2014. Therefore, this indicator has been marked Not Applicable.

There is evidence of a National Military Plan for Joint Defence, [1] a document focused on defending Mexico from foreign attacks/invasion. This is a confidential document, the contents of which are not acessible to the public, but articles surrounding it suggest that it mentions combatting corruption as an important goal for the defence sector. There are no specific details related to the definition of corruption in the sector, how it can be tackled, or on potential measures being enforced. Despite recent data indicating that the Secretariat of Defense (SEDENA) had been involved in cases of money laundering, [2] there is no mention of anti-corruption measures or strategies in recent reports from the Defense or the Maritime Secretariats. [3] [4]

It is also possible to find international evaluations, which position corruption as a serious problem in Mexico, not only in the armed forces but throughout the public administration. [5]

This indicator is scored ‘Not Applicable,’ given that risk assessments are not conducted. There is enough information to indicate some level of awareness regarding corruption as a problem in these public sectors, including the possibility that SEDENA and SEMAR may have taken steps towards prevention, however documents that could shed light on this are not made publicly available and there is no evidence to suggest the existence of regular risk assessment. [1] [2]

The risk assessment findings may be used to develop anti-corruption policy. In fact, this is how the SNA was born, derived from concern about the degree of corruption that existed in Mexico. And although specialists point out that the results of the evaluations constitute an opportunity for improvement, they are not always used to update institutional policies and plans. [1] [2] [3]

The Ministry of Defence formally conducted a risk assessment within its Integrity Plan, [1] in line with new obligations emerging for all public institutions implemented in the Law on Prevention of Corruption. [2] However, the analysis is very superficial and some major risks are not identified at all. [3]

For example, risks missing in the Integrity Plan include those related to high level corruption and the procurement of arms, especially in relation to government-to-government contracts that are signed in a very non-transparent process. [1]

The Integrity plan, containing superficial risk analysis, is adopted for at least four years, and reviewed every two years, while the action plans for the implementation of the Integrity Plan are adopted for period of two years, and reviewed every year. [1] According to the MoD, moreover, risk assessments are conducted on an annual basis (in Action Plan for that year).

Also, the Action Plan for the implementation of the Integrity Plan in the Ministry of Defence and the Army of Montenegro for the period 2018-2020 is an executive document of the Integrity Plan. This Action Plan focuses on improvement in the following areas of risk: General areas (1. Leadership and management; 2. Personnel policy, ethical and professional behavior of employees; 3. Financial planning and management; 4. Storage and security of data and documents) and Special areas (1. Disposal of state property; 2. Military operations; 3. Cooperation of the Ministry of Defence and the Army of Montenegro with the private sector; 4. Work environment; 5. Control mechanisms; 6. Affirmation of the work of the Ministry of Defence and the Army of Montenegro).

Public authorities are required to submit reports on the implementation of the integrity plan to the Agency for prvention of corruption by April 15 of the current year for the previous year. Based on the submitted integrity plans and reports on their implementation, the Agency may make recommendations to the authorities for the improvement of integrity plans. Based on the plans, reports and recommendations referred to in paragraph 2 of this Article, the Agency shall prepare a report on the adoption and implementation of integrity plans in government bodies. The report referred to in paragraph 3 of this Article is an integral part of the annual report on the work of the Agency (Article 77 of Law on Prevention of Corruption) [2,3,4,5,6].

Many planned reforms are delayed [1] and simply transcribed to newer versions of action plans, [2] which remain superficial and fail to include important risk areas. [3] The Action Plan for the implementation of Integrity Plan includes procurement as an important risk area.

No evidence of a defence-specific assessment of corruption risk that has been commissioned or taken place in the last 2-3 years was found (1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)(12)(13)(14)

Risk assessments are not conducted, and this sub-indicator is therefore Not Applicable

Risk assessments are not conducted, and this sub-indicator is therefore Not Applicable

No defence-specific assessment of corruption risk has been commissioned or taken place in the last 2-3 years. 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 [1]. The military has its own audit body called the Account Department (KaKaNgwe) under the Ministry of Defence [2]. From 2015 to the present, there has only been one case in which action was taken by the military relating to corruption. 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 receiving bribes [1]. There is the Account Department for the Ministry of Defence but there is no publicly available information about the assessment of corruption risk. There has only been one case in which action has been publicly taken against corruption in recent years. That was in 2015 and there has been no such case since then as of 2020. So, there has been no defence-specific assessment of corruption risk in the last 3 years.

This indicator is scored ‘Not Applicable’, given that risk assessments are not conducted. From 2015 to the present, there has been one case in which action was taken by the military relating to corruption: 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 receiving bribes [1]. There is only the Account Department for the Ministry of Defence but there is no publicly available information about the assessment of corruption risk.

This indicator is marked ‘Not Applicable’, given that risk assessments are not conducted. 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 [1]. 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) [2]. There is only the Account Department for the Ministry of Defence but there is no publicly available information about the assessment of corruption risk.

Risk assessments on integrity are conducted by the Central Defence Integrity Organisation (COID) as a means to highlight vulnerabilities to commanders and supervisors [1]. However, these assessments appear to focus on social cohesion and personal integrity as opposed to explicit corruption, bribery and coercion. All the same, personnel policy does exhibit some awareness of instances where corruption may occur [2].
Further, assessments concerning financial corruption are conducted within the directorates such as the Defence Materiel Organisation (DMO), dealing with the greatest risks, such as financial management, procurement and senioir officials [3]

A form of risk assessment is conducted regularly in the sense that all military personnel and most civilians working in defence must undergo security clearance processes administered by the Military Intelligence and Security Service (MIVD) prior to employment [1]. This screening searches for ‘data on membership in or provision of support to organisations that pose a threat to the democratic legal order’ [1]. New screenings are conducted every five years or when changes occur, such as the personnel having a new position or a new partner or if they receive a criminal conviction [1].

There is not enough information to score this indicator. As stated previously, integrity risk assessments have a broader scope than anti-corruption alone and as such have not fully fed into anti-corruption policy. However, some recent developments highlight how efforts are being made to ensure better coordination between the two. The MOD is currently working on a concept policy on Integrity Management, which follows on from several risk assessements and reports, as well as interviews with employees. The document, however, is still in draft format (as of August 2021) [1]. Secondly, a steering -working group on ‘External Partnership and Integrity’ has been established and its initiation document underlines how risk assessments are akey subject matter for the committee, which will be charged with policy development concerning business integrity and corruption. Nevertheless, this, too, is a very recent development according to the MOD [1], making its effectiveness impossible to determine at present.

The Office of the Auditor-General (OAG) is the main conductor of independent assessments for the defence sector. Apart from audits as part of the regular Annual Reports, the OAG announces upcoming assessments within its Annual Plan, of which the 2020/21 version has indicated that a “review of New Zealand Defence Force processes and capability for managing significant service contracts” will be conducted [1]. However, there is no Inspector-General of the Defence Force that provides comprehensive oversight in administration and operations, although this is likely to be created in the near future [2].

The NZDF Risk and Assurance Committee provides high-level advice and recommendations on the risk management framework. The NZDF risk management framework is contained within Defence Force Orders 081 Risk Management and is supported by Defence Force Instructions 0.81 to aid in consistent application. According to the NZDF Fraud Control Framework, “together these documents set out the policy, requirements and responsibilities for risk management in the NZDF” [3]. Corruption risks are also identified through CDF Directive 41/2020, which promulgates the NZDF policy for managing fraud (the Directive interprets fraud in the broader sense). It does so by expanding fraud to cover issues relating to honesty and values, to include deceit or avoiding obligations, and not only monetary concerns [4]. The NZDF operates the Three Lines of Assurance Model to assure effective risk management through multiple redundancy screenings, the first of which is directly applied by NZDF management to assess, control, and mitigate risks [5]. With respect to fraud and corruption, an assessment of NZDF’s fraud risks was carried out by the MoD independent review team in 2016. In June 2019, a high level re-assessment of the MoD review was carried out at the request of the NZDF Risk and Assurance Committee. The re-assessment highlighted the top 10 fraud risks faced by the NZDF. In addition to this, NZDF Internal Audit published organisation wide guidance in 2020 with regard to changes in Fraud risk levels. Specifically, a Counter-Fraud Toolkit ‘staying alert to the risk of fraud in a COVID-19 environment’, was issued in response to a sudden shift in Fraud risk conditions. [11].

Regarding the MoD, risk management is “considered as part of the Leadership team’s consideration of the Ministry’s strategic risk” and includes fraud and corruption [6]. A close-reading of the Ministry’s Annual Reports for 2019 and 2020 suggests that risk management is incorporated with departments’ every-day approach, however specific details of an equivalence examined for the NZDF could not be found [7, 8].

Regarding the New Zealand Intelligence Agencies (NZSIS and GCSB), the IGIS does not have an internal role in implementing anti-corruption policy within the agencies though it could in principle recommend that such policy is followed or introduced, although the State Service Commission or the Auditor-General might be the lead external agencies for such a recommendation. Moreover, within the IGIS, the Security Officer advises staff of any security issues that may arise and the agencies have similar processes in place [9]. This creates an added barrier against potential avenues leading to corrupt activities. Nonetheless, according to the Agencies themselves, and in keeping with good governance practices, they maintain strategic risk registers which are used to manage areas of serious risk. This is based in part on internal auditing and trends from reporting on compliance with relevant legislative requirements, rather than on specific assessments into areas of perceived risk [10].

The Office of the Auditor-General performs annual assessments but may “at any time examine” a public entity’s efficiency and effectiveness in carrying out its duties, compliance with statutory obligations, an act or omission of wastage or potential wastage, a lack or potential lack of probity, and financial prudence on behalf of the public entity [1]. The Auditor-General may also enquire “into any matter concerning a public entity’s use of resources” [2].

As per the NZDF Three Lines of Assurance Model, risk assessments are conducted on a gradually increasing gradient, which starts with the NZDF management directly, and progresses through to specific internal oversights bodies/units/departments [3, 4]. The exact regularity of risk assessments could not be determined. Actually, assessment of NZDF’s fraud risks was carried out by the MoD independent review team in 2016. In June 2019, a high level re-assessment of the MoD review was carried out at the request of the NZDF Risk and Assurance Committee. Moreover, A single risk register is maintained for all capability projects. Risks are reported at a project level to individual project boards, which meet monthly and to strategic governance boards – both the Capability Governance Board and the Ministry’s Leadership Team.[6]

Within the Intelligence Agencies, lessons identified through risk management are incorporated into a range of internal policies, which are periodically reviewed, the frequency of which are not disclosed [5].

The Office of the Auditor-General conducts assessments as part of its statuary mandate, but may arrange with the Financial Markets Authority to initiate a quality review of systems, policies, and procedures applying to employees of the Auditor-General, for the purpose of testing its own compliance and auditing standards [1]. In the Auditor-General’s 2018/19 audit overview, the NZDF was found to be taking active steps in adopting the Government’s new financial reporting standard PBE IPSAS 39: Employee Benefits [2]. In 2017 newly appointed Chief Internal Auditor led a process to ensure that the internal audit function met stakeholders’ needs and the evolving risk profile of NZDF. This contributed to the establishment of the “Value Change Journey for Internal Audit” in June 2017, and led to the dissemination of a proposal document around improving the assurance value of NZDF Internal Audit in May 2018 [3]. Ultimately, a decision was made that allowed the NZDF to “make much-needed step change to keep pace with the evolving risk profile of NZDF, and the stakeholder demand for modern audit support” [4].

Regarding the intelligence community, 90 percent of IGIS recommendations to the agencies are published and as per the Legislation, any recommendation can be accepted or rejected by them. The agencies usually comment on draft recommendations, and once the report is finalised the agencies will formally signal whether they accept the recommendations. It can be trickier to identify the degree to which recommendations are implemented, although the IGIS and the agencies maintain a register of all recommendations made by the IGIS. This register is revisited and updated periodically. As a further means of strengthening risk assessment recommendations, the IGIS can also go to the minister to convince the minister of a need for change in his/her intelligence agencies [5]. In any case the Minister in charge must respond to an inquiry report from the Inspector-General [6]. A recent example of risk assessment recommendations being implemented into policy is the State Services Commission’s External Security Consultants inquiry (TCIL report), which stated that more awareness is required by the NZSIS in dealings with private security firms [7, 8, 9].

No defence-specific assessment of corruption risk has been commissioned or taken place in the last 2-3 years. Even though an official risk assessment has not been conducted (1), interviews with officials in the Defence and the Interior ministries have revealed that there is a specific awareness of the risk areas, namely on the positions requiring direct contact with the population for instance at the border checkpoints as well as during the procurement process (2,3). 

Risk assessments were not conducted, therefore, the section is marked Not Applicable.

Risk assessments were not conducted, therefore, the section is marked Not Applicable.

The Anti-Corruptions Units have not developed and published their action plans, despite requirement by the NACS that such assessments should be carried out. Despite the publication and adoption of the NACS there is little information about its operationalisation. The anti-corruption strategy does call for regular and periodic reviews of action plans and makes provision on paper for monitoring of the implementation plan (1), (2).

The operations of Anti-Corruptions Units are unknown. Although the NACS has mandated the ACU to conduct assessments regularly, there is no evidence of such assessments taking place. Therefore, this indicator is marked Not Applicable.

The operations of Anti-Corruptions Units are unknown. Although the NACS has mandated the ACU to conduct assessments regularly, there is no evidence of such assessments taking place. Therefore, this indicator is marked Not Applicable.

Until 2015, no specific corruption-risk assessment had been carried out within the Ministry of Defence. Corruption cases that emerged were not actioned against by the Ministry of Defence, but by other organisations such as the police, the prosecutor’s office, the judiciary and State Commission for Corruption Prevention [1]. Since 2016, in accordance with the Ministry of Defence’s Integrity Plan, the areas estimated to be at greatest risk of corruption for the employees of the Ministry of Defence and Army are subject to regular supervision and various forms of training are implemented to fight corruption within the defence sector. Under the supervision of a High Ministry of Defence official, any findings related to these inspections and trainings are then used to update the Integrity Plan and are listed in all by-laws of the institution. Any potential sources of corruption in the defence sector are clearly identified [2]. In addition, the Internal Audit Department performs strategic and annual internal audit plans drawn up on the basis of objective assessment of the risks to which Ministry of Defence and Army of North Macedonia have been exposed. Within these estimates, an assessment is also made of areas of corruption risk [3].

The 2016 Ministry of Defence Integrity Plan is built up over three years. It is reviewed on a regular and case by case basis, and the findings of these reviews are then re-introduced into the Plan as well as into institutional by-laws of the institution [1]. The Internal Audit Department for its part, performs risk assessments at least once a year. Its strategic and annual plan for the implementation of the internal audit are documents that, on the basis of objective risk assessments and established priorities, determine the organisational structures, programs, activities and processes in the Ministry of Defence and the Army of the North Macedonia [2].

The risk assessment mechanisms within the defence sector have significantly improved since 2015. The Integrity Plan offers an institutionalised and functional approach on a general level, which covers general corruption risks in the Ministry of Defence and the Army. Updates to the plan and relevant policy changes are processed [1]. Individually, the Internal Audit Department has also carried out consistent risk assessments which also affect anti-corruption policies in the defence sector [2]. Still, both on a general and individual level, it is unclear which findings have shaped the updates of the integrity plan and how regularly these updates are implemented. They are not clearly articulated and remain relatively abstract, including orders such as ‘regulate detection’; ‘continuously impede corruption risks’ etc. Moreover, when it comes to the implementation of the measures and updates of the integrity plan on a policy level, no publicly available information can be found.

The Centre for Integrity in the Defence Sector (CIDS) is a unit responsible for promoting and enhancing professional integrity and good governance in the defence sector, with a clear focus on anti-corruption. The centre’s task is also to conduct regular risk assessments which focus on individual departments [1]. Due to the reorganisation of the CIDS, such assessments have recently not been conducted on regular basis [2, 3]. Moreover, the Internal Auditor Unit and the Office of the Auditor General provide a risk assessment mechanism in some areas through their regular audits of individual departments [3]. The Internal Auditor Unit informs the top management of its findings. It also prepares an annual plan, available for the entire personnel, where the findings are used to help develop anti-corruption policy [4].

On it website the CIDS states that it conducts a biannual quality assessment of a chosen area of the defence sector (for example HRM, openness, procurement, impartiality, financial management). However, the last published assessment, which deals with post-employment restrictions in the defence sector, was in 2017 [1]. Recently the centre has focused on reorganisation [2]. The CIDS aims to conduct a biannual corruption risk assessment of the intersection of the national defence sector and the defence and security industries and it sees this as one of its main tasks. The centre has already developed a method and is ready to apply a maturity model to assess selected suppliers and the Norwegian Defence Material Agency. The CIDS plans to present its findings next year [2].

Risk assessment findings are generally used to develop and update anti-corruption policy [1]. For instance, the CIDS recommendations contributed to updated procedures on revolving door limitation in the Ministry of Defence and its subordinated agencies [2]. However it should be noted that risk assessments have been irregular in recent years.

There has never been any risk assessment of corruption within the sultan’s armed forces or the defence ministry. Corruption is not seen as a risk within the armed forces and therefore, there is no need for risk assessment (1). Capacity building by the National Centre for Financial Information website contains annual reports to combat money laundering and terrorist financing; this involves workshops and collaboration with armed forces (2), (3). No explicit mention is made to risk assessments of corruption targeted at dealing with corruption within the defence ministry or armed forces personnel. Importantly there exists no indication that there have ever been defence-specific assessments of corruption risks, at least publicly available.

This sub-indicator has been marked as Not Applicable, as there is no evidence of any risk assessments conducted around corruption risks either within the Ministry of Defence or the armed forces in the country (1), (2).

This sub-indicator has been marked as Not Applicable, as there is no evidence of any risk assessments conducted around corruption risks either within the Ministry of Defence or the armed forces in the country (1), (2), (3).

There has not been any risk assessment within any of the PA armed services institutions (1), (2).

This indicator has been marked Not Applicable, because there has not been any risk assessment within any of the PA armed services institutions (1), (2).

This indicator has been marked Not Applicable, because there has not been any risk assessment within any of the PA armed services institutions (1), (2).

The Philippine Defence Transformation Roadmap (PDTR) 2028 was formulated to carry on the institutionalisation of the reform measures identified in the Philippine Defence Reform programme that ended in June 2016 [1]. Areas of concern specified in the PDTR 2028 include human resource, organisational and fund management. Using PDTR as a common framework, and in partnership with the Institute for Solidarity in Asia (ISA), each service of the armed forces conducted its own assessments to clearly identify corruption risks before crafting its own plan to mitigate these risks [2]. ISA is a non-profit organisation that works with government agencies, including the Defence Ministry and its services, to design and implement anti-corruption reforms [3].

Using the Institute for Solidarity in Asia’s Performance Governance System, the timeline of the assessment is based on how the armed forces and its services can satisfy each stage of the framework, namely Initiation, Compliance, Proficiency, and Institutional [1, 2, 3]. To guide the defence sector in its professionalisation and modernisation agenda, a Multi-Sectoral Governance Council, composed of members from business, academia and civil society has been established [4]. Within the Council is the Philippine Army Multi-Sector Advisory Board that convenes every quarter to review the army’s performance using strategy documents and provide feedback and insights on operations [5]. However, it is not known whether this occurs for other institutions than the Army.

The armed forces has established a multi-sectoral governance council (MSGC) composed of members from business, academia and civil society to guide the armed forces in its professionalisation and modernisation agenda [1]. Risk assessment findings are used to develop an anti-corruption policy [2]. For example, the Philippine Army has published a Risk Management Handbook in 2021, where it describes how a review of the institution (e.g. corruption risks), can help improve the policy [3]. However, it is not known whether this occurs for other institutions.

Ministry of National defence carries out regular, comprehensive risk assessment as part of its governance procedures. The risk assessment is based on methodology which is in line with international standards. There are no evidences that risk of corruption has been identified and included in the risk register.

The Bureau of the Minister of National Defence analyses corruption risk at selected areas and undertake activities to identify and minimize risks. It is nor clear whether the same or another methodology is used. The bureau is still at the stage of filling areas of the activity of the Armed Forces with particular risks, and some areas are only partially covered, and some are not yet covered by the systematic analyses to date.
The results of analyses are used in the course of ongoing operations and during the preparation of action plans of the Ministry of National Defence. The analyses concern both individual matters (e.g. a specific public order) as well as systemic ones (e.g. introduction of a new procedure).
[1, 2, 3, 4]

There are no evidences that risk of corruption has been identified and included in the risk register in a frame of general, annual MoD risk assessment.
Corruption risk assessment carried out by The Bureau of the Minister does not cover regularly all MoD activities. It covers selected areas subsequently.
[1, 2, 3].

There are no evidences that risk of corruption has been identified and included in the risk register in a frame of general, annual MoD risk assessment.
Corruption risk assessment carried out by The Bureau of the Minister does not cover regularly all MoD activities. It covers selected areas subsequently. Consequently, it may be used to update selected policies only.
In 2017, as a result of risk monitoring analyses, rules of conduct in contacts with contractors were developed and implemented. The document is publicly available in the Official Journal of the Ministry of National Defence of July 14, 2017 [1, 2, 3, 4, 5].

Within the Ministry of Defence, the Secretariat-General of the Ministry of Defence (SGMoD) [1], the DGDR [2], the Directorate-General of Defence Resources (DGDP) [3], the Inspectorate-General of National Defence (IGND) [4] and the Military Criminal Investigation Police [5] have published a Plan for the Prevention of Corruption Risks and Connected Violations within the last five years. The National Defence Institute’s (NDI) latest published plan dates to 2010 [6]. All updated documents assess corruption risks and put mitigation measures in place. As reported in Q10B, there is no set schedule for conducting risk assessments, which appear to occur at the behest of each unit.
With regards to armed forces’ branches, the Joint Chief of Staff’s Office [7] and the Army Service Chief’s Office [8] have published plans in the last five years. The Airforce Service Chief’s Office published a plan in 2014 [9], and the Navy Service Chief’s Office has not published a plan at all, although evidence exists that it has submitted a plan to the Council for Prevention of Corruption [10].

Existing evidence shows that there is no set schedule for risk assessments. While the SGMoD [1], the DGDR [2], the DGDP [3], the IGND [4] and the Military Criminal Investigation Police [5] have published at least one Plan for the Prevention of Corruption Risks and Connected Violations within the last five years, the NDI’s latest published plan dates to 2010 [6]. While existing recommendations by the Council for the Prevention of Corruption suggest a need for reporting regularity [7], there is no legal requirement for regular assessments.

Plans for the Prevention of Corruption Risks and Connected Violations are built, at their core, risk assessments. Evidence suggests that such plans (as detailed in Q10A and Q10B) result from explicit risk assessments across organisational units. However, a lack of regularity and reporting on plan execution either by Ministry of Defence (MoD) organisational units [1] or armed forces branches [2, 3] suggests that inputs are either limited or insufficiently considered.

There are no committees within the Qatari Advisory Council that are tasked with carrying out risk assessments of the areas of greatest corruption risk within the defence sector. The Qatari Audit Bureau is also not mandated or authorised to carry out assessments for either the Ministry of Interior or the Ministry of Defence and the Armed Forces [1]. It is explicitly stated that ‘matters within the scope of military and security requirements of the accounts of Ministry of Defence, Ministry of the Interior and other military and security entities as determined by their competent higher command, shall be excluded from the Bureau review and audit’ [1]. According to our sources, there is no regular assessment of the areas of possible corruption due to the belief that there is no corruption in the armed forces. [2]

This sub-indicator has been marked as Not Applicable as no risk assessments of the areas of greatest corruption risk within the defence sector have been conducted.

This sub-indicator has been marked as Not Applicable as no risk assessments of the areas of greatest corruption risk within the defence sector have been conducted.

Corruption risks, such as conflicts of interest, lacunae in procurement contracts and bribes and gifts to officials, are identified and defined in the biennial anti-corruption plan (see section II) for the whole Ministry [1]. Section IV of the Anti-corruption plan stipulates anti-corruption measures and actions specifically for MoD work.

A risk assessment is conducted on a regular basis for the whole Ministry, rather than individual departments [2]. It is not clear, however, to what extent the risk assessment process has been formalised and on what methodology (if any) it was based. Its findings are publicly published on the MoD website.

There is no clear information on the exact frequency of the reports. However, an analysis of the MoD website shows that a report about incoming information on potential corruption-related crimes in the MoD is published every quarter [1]. A report on the implementation of the ACC’s decisions seems to be published regularly (the latest available reports are dated July 2018, December 2017 and August 2017) [1]. A report on personnel revenue is published annually [2]. Risks are assessed within the regular framework of the MoD anti-corruption plan, which is defined every two to three years – in the last five years, there have been three anti-corruption plans – for 2014-2015, for 2016-2017 and for 2018-2020 [3, 4,5].

An analysis of the previous anti-corruption plans suggests that the risk assessment findings are either the same from year to year or they are not taken into consideration when the new anti-corruption plan is drafted. A comparison of reports on anti-corruption work done in 2016 and 2017 [1,2] with the anti-corruption plans for 2015-2016 and 2018-2020 [3,4] suggests that the same findings and the same prospective work are reported every year. The anti-corruption plans are not updated in accordance with the findings at all. For example, the analysis of the anti-corruption prevention measures taken in 2017 states that a) anti-corruption plans are only general and lack any specific description of concrete steps and events and b) the functional responsibilities of military officials responsible for anti-corruption prevention and personnel revenue collection do not comply with the standard forms and require narrower definition [2]. The following anti-corruption plan for the years 2018-2020 a) keeps stating general recommendations without any detailed plan of action and b) does not recommend providing a narrower definition of functional responsibilities mentioned above.

According to our sources, there has not been any defense targeting assessment of corruption been taken place. There is no, in general within the Saudi Government any corruption and corruption risks assessments(8,9). The General Auditing Bureau (GAB) is responsible for auditing the state’s revenues, expenditures, and assets, and technically has oversight over all ministries and government departments. According to its charter, this includes the auditing of military sector accounts (1). The GAB submits its annual report to the king and the Council of Ministers (the country’s Cabinet which is chaired by the King), however it does not have any real authority to independently assess potential corruption in those sectors given they are the domain of Crown Prince Mohammed bin Salman, the de facto ruler of the country.

In November 2017, Mohammed bin Salman arrested the commander of the Saudi Arabian National Guard Miteb bin Abdullah, the son of late King Abdullah, as part of a widespread 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 (2). 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 (3). French publication Intelligence Online characterized the arrest as a move designed to remove the informal deal-making channels that were prevalent in the defense industry, including those previously managed by Miteb’s maternal uncle Salah Fustok (4). Charges against Miteb include embezzlement and awarding fake defense contracts to his own firms; he later paid a USD 1 billion dollar settlement relating to these charges (5,6). 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 (7).

While this does appear to represent scrutiny of corruption specifically in the defense sector and of the armed forces and personnel, it was carried out in an ad hoc manner by the Crown Prince and does not reflect a formalized or regular process that feeds into an overall anti-corruption policy.

Risk assessments on high-risk areas for corruption are not conducted, so this sub-indicator is not applicable (1), (2).

Risk assessments on high-risk areas for corruption are not conducted, so this sub-indicator is not applicable (1), (2).

Risk assessments are carried out by the Military Security Agency (MSA). Organisational units do not conduct their own risk assessments. The MoD is also subject to risk assessments conducted in cooperation with the Anti-corruption Agency, independent state body tasked with tackling corruption. Finally, the MoD uses research on corruption risks conducted by international and civil society organisations [1].

The MSA regularly conducts risk assessments based on which annual integrity plans are being developed. Evaluation of corruption risks carried out in cooperation with the Anti-corruption Agency happens every three years. Within the defence system, 13 institutions have participated and developed integrity plans two times so far, and the third assessment is expected by the end of 2019 [1].

Results of the risk assessments are used to develop annual integrity plans for 13 institutions within the defence system. Integrity plans cover six areas: democratic control, anti-corruption policy within the MoD and SAF, human resources, education and training, planning and budget, multinational operations and business with defence companies and other business entities [1].
The quality of risk assessments can be discussed based on the balance between the goals and activities foreseen in the annual plans and reports on its realization. Certain measures envisaged in integrity plans are often later characterized as unnecessary or obsolete in the reports, which might point out the necessity to conduct detailed risk assessments in individual organizational units.

Although there is no evidence suggesting that comprehensive risk assessments take place within the Ministry of Defence (MINDEF) and the Singapore Armed Forces (SAF), a clear implicit understanding of risks is evident in the aforementioned system of audits and administrative measures. There is evidence of implementation, including the exposure of various cases. The government has put in place a robust set of procurement policies and open competition that appears to provide a strong deterrence against corruption [1, 2]. The Secretariat of MINDEF Anti-Corruption Committee (MACC) works with the various stakeholders in MINDEF to identify appropriate criteria, based on risks assessment, for determining corruption-prone appointments. [5]
However, there is limited information on how regularly these corruption risk mitigation measures take place. There are also provisions for the involvement of independent institutions such as the Corrupt Practices Investigation Bureau (CPIB), while expenditures are externally audited by the Auditor-General’s Office (AGO) and are scrutinised by the Parliamentary Public Accounts Committee (PAC). Lapses surfaced via such independent inquiries have been reported by media and responded to directly by the MINDEF [3, 4]. However, there is neither detailed information on the scope and frequency of such assessments nor are there reports on the effectiveness of its risk mitigation measures.

The MINDEF’s Internal Audit Department (IAD) submits an annual report detailing its risk assessment and findings [1, 2].

The IAD is mandated to develop and regularly update the MINDEF and the SAFs’ anti-corruption policy and institutional action plans [1, 2]. Political leaders have testified in Parliament that IAD inputs have been invaluable in refining the ministry’s anti-corruption framework and processes [3].

The Department of Defence (DoD) exercises risk management activities, guided by the 2013 “Policy, Process and Procedures for Risk Management in the Department of Defence” as well as the Public Sector Risk Management Framework [1, 2]. With regards to corruption, in particular, the DoD displays cognisance of the broad threat of corruption and fraud and appears to indicate an annual process of revision for risk vectors, but these assessments remain somewhat broad [1]. The Auditor-General criticised the DoD and Military Veterans in a 2017/18 qualified audit finding, among numerous other failings, a failing to “implement effective risk management to prevent recurring audit findings and address significant matters” [3].

The Department of Defence appears to conduct an evaluation of risks on at least an annual basis – but the reported detail on the specifics of how this process is undertaken is vague.

The 2017/18 DoD annual report mentions the achievement of ‘maturity level 5’ for the Enterprise Risk Management system, without specific detail on what that entails [1]. More specifically, a quarterly DoD Corruption and Fraud Prevention Nodal Point Forum was established during FY2017/18, to expedite anti-fraud and corruption efforts across the DoD [2]. It is unclear from publically available material, whether, or to what extent the Fraud Prevention Nodal Point Forum undertakes risks assessments.

A section on DoD Enterprise Risk Management and Mitigation for FY2017/18 details specific risks and mitigation measures undertaken with regards to fraud and corruption. This self-reported progress section outlines identified risks and mitigation efforts taken over the course of the reported year. While some of the threats and responses are somewhat vague, it appears that there is some degree of responsive updates of policies and action plans, which occurs on an annual basis [1].

For instance, the identification of faults were identified, as well as an action plan recommended. This took the form of noting an increase in fraud and corruption, tied to weaknesses in key internal controls – and resolving to review, approve and implement the DoD Fraud Prevention Plan to counteract this. More specifically: fraud and corruption cases were to be continuously monitored and reported on at the DoD DACAF Forum meetings and all corruption and fraud incidents and cases are monitored and progress reported quarterly at the DoD Corruption and Fraud Nodal Point Forum, and multi-disciplinary teams were formed to speed up the process of combatting corruption and fraud in the DoD [1]. It is unclear to what extent risk assessment findings are integrated into the DACAF.

While the Anti-Corruption and Civil Rights Commission assesses corruption risks in public institutions, including the MND, it appears that the assessment does not focus on corruption risks for military and armed forces personnel. Article 12 of the Act on the Prevention of Corruption and the Establishment and Management of the Anti-Corruption and Civil Rights Commission requires the ACRC to conduct assessments to measure corruption risks for all public institutions on a regular basis. [1] This assessmenst, the Integrity Index for Public Institutions, measures the integrity of the MND with survey methods, rather than targeting individuals, such as military and armed force personnel. [2]
Moreover, material available in the MND’s trusted network show that the MND and the armed forces specify corruption risks in the areas of logistics, facilities, information, funds, service members’ welfare. Accordingly, related departments established their monitoring plans. In 2016, for example, the MND and the armed force launched massive anti-corruption campaigns comprsing monitoring tasks, 15 insitutional improvement tasks and 20 tasks of self-audit reinforcement. [3]

There is evidence of regular risk assessments conducted by the ACRC. Although the assessments do not clearly articulate risks for the ministry or armed forces, they are conducted annually and published via the ACRC’s website. [1] [2]

Although the MND’s 2018 Defence Statistic Annual Report states that “the results of the integrity index will be reflected in the future policy development”, there is no clear evidence of how the findings are used as inputs to anti-corruption policy in the defence sector. [1] However, as “the Integrity Index for Public Institutions” conducted by the ACRC is publicly available and is compared by each public institution, the ministry is likely to take it seriously, according to an interview with a defence expert. [2]
Moreover, the MND’s anti-corruption and integrity policy is being publicized to its members through the trusted network. In addition, risk assessment findings continue to be reflected in inspection team’s plans. In the case of the Defense Acquisition Program Administration, it is making efforts to improve itself by releasing self-audit results on its website [3]. Meanwhile, reflecting risk assessment findings, the MND’s ‘Administrative Rules on Corruption Prevention and Whistle Blowing’ has been revised five times (2013, 2014, 2016, 2018, 2019) since its enactment in October 2010.[4]

There is no publicly available information to score this indicator, therefore, it has been marked ‘Not Enough Information’. Sources contacted for information have not been forthcoming. Based on the assessor’s local knowledge, there have also been no public statements by senior Defence Ministry or military officials showing a dedicated committment to combating corruption in the defence sector.

There is no publicly available information to score this indicator, therefore, it has been marked ‘Not Enough Information’. Sources contacted for information have not been forthcoming. Open source searches do not reveal that anything of this nature has occurred in South Sudan in the last 10 or 15 years.

There is no publicly available information to score this indicator therefore, it has been marked ‘Not Enough Information’. Sources contacted for information have not been forthcoming.

No other government report has been found that refers to corruption in Defence beyond the one mentioned in the 2015 Transparency International Report, the Defence Social Responsibility Report 2010 [1], in which a brief reference was made to the percentage and the total number of business units analysed for risks related to corruption, the percentage of employees trained in anti-corruption policies, and procedures of the organisation and the measures taken in response to incidents of corruption.

There is no definition of areas of greatest risk for corruption, nor is there an evaluation in this regard [2]. In the opinion of the interviewee, contrary to what might initially be thought, the assumption of military values [3], among which is honour or exemplariness, may be an impediment to the implementation of policies and actions that put them in question.

This indicator is scored ‘Not Applicable’, given that risk assessments are not conducted (see Q10A).

This indicator is scored ‘Not Applicable’, given that risk assessments are not conducted (see Q10A).

No evidence could be found suggesting that a defence-specific assessment of corruption risk took place or was commissioned in the last 2-3 years, or that one has yet been commissioned for the future. For decades, Sudan’s defence sector has been a source of personal wealth aggrandisement for the former regime and both armed and civilian partners who served its interests. Therefore, most regime-allied authorities had little interest in investigating corruption or corruption risk in Sudan [1,2].

This indicator is scored ‘Not Applicable’, given that risk assessments are not conducted. No evidence could be found suggesting that there is a regular schedule for defence-specific assessments of corruption risk, or that there is any readiness to conduct regular or rigorous assessments. During Bashir’s regime, occasional declarations and efforts were made to address corruption, but such events were almost always politically motivated and short-lived, certainly were not ‘regularised’ and almost never targeted the security sector. For example, former President Bashir presented his cabinet with an anti-corruption reform plan in 2014 [1], but there is a lack of evidence that it was ever implemented or that it would have included a risk assessment. 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 current government or military officials [2]. The 2019 transitional Constitutional Charter [3] stipulates a requirement to set up an anti-corruption and public funds recovery commission, but an anti-corruption committee has only been formed to investigate corruption by former regime officials and recover stolen resources; an independent commission has not yet been formed, and no news of a risk assessment plan has been broadcast.

This indicator is marked Not Applicable, given that risk assessments are not conducted. Since no evidence can be found of a past risk assessment, it follows that anti-corruption policy and practice are not informed by risk assessments. A review of the Ministries of Defence, Interior and Finance [1,2,3] websites and of the Central Bank’s website [4] did not yield any information about risk assessments undertaken to inform anti-corruption policy or practice. Moreover, the anti-corruption body established by the transitional government is focussed entirely on the past – holding former regime officials accountable and recovering assets derived through corruption – rather than on preventing corruption in the future. 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 [5].

No defence-specific assessment of corruption risk has been commissioned or taken place in the last 2-3 years [1] [2].

This indicator is marked ‘Not Applicable’ as no defence-specific assessment of corruption risk has been commissioned or taken place in the last 2-3 years [1] [2].

This indicator is marked ‘Not Applicable’ as no defence-specific assessment of corruption risk has been commissioned or taken place in the last 2-3 years [1] [2].

In its first report covering the years 2011 to 2013, the Interdepartementale Arbeitsgruppe Korruptionsbekämpfung (IDAG Korruptionsbekämpfung) only recommended identifying specific groups at risk for corruption in the federal administration and targetting them for training (Recommendation 5) [1]. In its second report, the Secretariat of IDAG Korruptionsbekämpfung reportedly identified in collaboration with armasuisse seven groups and activities at risk. They followed up with the general secretaries of the seven ministries. They agreed with the selected groups and activities but had reservations concerning additional bureaucratic burden and the use of resources at the ministerial level. They preferred the responsibilities to remain at the level of the Directorates (“Direktionen”) and Federal Offices (“Bundesämter”). The working group concluded that the groups and activities at risk have been “sufficiently identified” and they will be targeted with relevant training [2]. 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 [3]. This strategy defines corruption risk and states that internal audits, supplemented by independent audits from the Swiss Federal Audit Office (SFAO), will be used to mitigate these risks [4]. It also indicates that specific provisions will be implemented for federal administrations that are particularly exposed to corruption risks, though it does not name these departments. However, the DDPS reportedly identified Armasuisse as a high corruption risk entity and that for that reason, the employees receive special anti-corruption training [5].

There is not enough information to score this indicator. As of 30 January 2020, there is a directive for the DDPS on fighting corruption that defines the tasks of a “Specialist Unit Corruption” (Fachstelle Korruption) and delegates the responsibility of fighting corruption to its different administrative units [1]. A specialised VBS Corruption Unit evaluates annual reports from these “Specialist Units” and makes recommendations for improvement, as part of an annual techincal meeting; however, it is not explicitly clear that such evaluations include risk assessments. The November 2020 anti-corruption strategy, which applies to the Federal Administration as a whole, mentions corruption risk but does not provide further details on the assessment process or the regularity of such checks [2]. The strategy indicates that the IDAG will develop guideines to identify which federal departments are most exposed to corruption risks, however no further information on this could be found.

There is not enough information to score this indicator. The November 2020 anti-corruption strategy, which applies to the Federal Administration as a whole, mentions corruption risk but does not provide further infromation on the assessment process or the regularity of such checks [1]. There is also some evidence that a DDPS directive on fighting corruption includes annual evaluations and recommendations for improvement, however it is not clear from the data available that this specifically includes assessments of potential risks [2].

Generic risk factors for corruption are employed for corruption risk assessment. GI serves as an important resource for the MND to scheme the “Organisation and Guidelines for the Board for Integrity and Anti-corruption of the Ministry of National Defence”. Processes of corruption risk assessment are often conducted through the mechanisms of internal audit, external audit, self-evaluation, or personnel appraisal in the MND and Taiwan’s armed forces [1, 2].

For the MND and Taiwan’s armed forces, internal audit and self-evaluation of risk assessments are held regularly every three months, and external audit and personnel appraisal of risk assessments are held regularly each year [1]. In practice, Transparency International Taiwan is financially supported by the MND to constuct a system of “Government Integrity Index Evaluation and Forecasting” (政府廉潔指數評鑑預測) for Taiwan’s armed forces which examines risk factors including political risks, financial risks, personnel risks, operational risks, and procurement risks [2].

Regular assessments of areas of the greatest corruption risk for the MND and Taiwan’s Armed Forces are carried out by MND’s Ethics Office by conducted surveys and research on contractors and suppliers who have had business deals with the Ministry of National Defense. Findings and conclusions derived from these surveys and questionnaires often serve as counter-measures for bribery & corruption and are used as inputs to refine MND’s anti-corruption & ethics policies [1].
For example, the “Annual Corruption Risk Assessment Countermeasures Report” published in 2020 [2] was used by The Ethics Office to target high risk areas. The office held 7 inspections and 2 project audits. Moreover, the report was used to update policies and anti-corrutpion measures. Among them new “Anti-corruption Guidelines for Military Personnel” were published. They assist military personnel to assess, inspect, and reduce corruption risks. [3,4]

According to a senior official from the PCCB headquarters, corruption risk assment is a regular practice, pzrformed by the PCCB and not an independent department at ministerial level. [1] The PCCB is vested with the power to conduct the risk assessment in all sectors of the government including the defence and security organs at institutional and personal level. The risk is clearly identified based on analysis of the progress activities performed by PCCB from District to Regional and National level. It is mandatory for the PCCB office at District and Regional levels to prepare quarterly reports based on the number of bribery/corruption cases reported, the number of investigations ongoing at that particular time, the number of cases in progress in court, and the public awareness and opinion on issues of bribery and corruption in that particular moment. The compiled report from each region is the sent to PCCB headquarters at the Research department for further analysis in order to determine the area of greatest corruption risk, including the defence and security organs. This report is then submitted to the Presidents’ office for action taking. These reports are classified, hence they are not for public consumption.

At an individual level, the Public Leaders Code of Ethic Act provides a framework whereby all public leaders as mentioned in Part I Section 4 (i-xxvii) of the Act, must declare their assets or property annually to the Ethics Secretariat. For example, Part II Section 2 (a) and (d) emphasise the issue of honesty, compassion, sobriety, continence and temperance among public leaders, which aims at upholding the highest possible ethical standards so that public confidence and trust in the integrity, objectivity and impartiality of government are conserved and enhanced. [2] The Act requires the public leaders to declare all property or assets owned by, or liabilities owed to him/her and his/her immediate family members. In the end, the information provided helps in the analysis of corrupt practices of public leaders at personal level as well as determining risk of corruption.

As explained in 10A, the risk assessment is done quarterly by the PCCB and annually by the Ethics Secretariat for specific public leaders. [1] [2]

According to a PCCB senior officer, the findings from the risk assessment report for the likely areas of potential corrupt practices are usually incorporated into daily action plans of the Bureau as well as annual action plans. [2] Apart from that, the findings are a building block for the development of the National Anti-Corruption Strategy and Action Plans phase III which is a current referenced document for all anti-corruption activities in the defence sector and elsewhere. [1]

There is currently an internal risk assessment of conflicts of interest and corruption conducted for each department in the MoD every five months by the Office of the Inspector General under the Royal Thai Armed Forces Headquarters. This assessment covers four major kinds of risks related to corruption, such as strategic risks, financial risks, operational risks and compliance risks. The most recent risk assessment (fiscal year 2019) was the assessment of corruption risks between October 2018 and March 2019 [1]. Apart from that, the NACC has implemented the Integrity and Transparency Assessment (ITA) and used it to assess corruption risks in each ministry since 2013. These areas of risk assessment related to corruption include operations, budget, misuse of power, public property exploitation, corruption resolution, performance, communication, organisational improvement, data disclosure and corruption prevention. Each ministry is expected to continually improve its integrity and transparency based on the annual assessment results [2].

In 2019, 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 [3]. The strategic plan was formulated based on relevant prior research and academic papers, including evaluations of performance in key missions [4].

Internal risk assessments of conflicts of interest and corruption are conducted every five months by the Office of the Inspector General under the Royal Thai Armed Forces Headquarters, Ministry of Defence [1]. Furthermore, assessments of corruption risks in each ministry (which is called the ‘Integrity and Transparency Assessment (ITA)’) are conducted by the NACC on an annual basis [2]. The report of the Integrity and Transparency Assessment Fiscal Year 2019 is available online [3].

According to the Office of the Inspector General, because the Corruption Perceptions Index (CPI) had scored Thailand less than 50 out of 100 throughout the past two decades, each ministry was ordered to conduct internal risk assessments in accordance with the National Strategic Plan on Corruption Prevention and Suppression 2017-2021 in order to raise the scores above 50 and maintain confidence through regular improvements [1]. Moreover, the Integrity and Transparency Assessment (ITA) is also conducted every year by the NACC, the results of which are institutionally expected to be used to improve the integrity and transparency of each ministry [2].

For instance, the Office of the Inspector General under the Royal Thai Armed Forces conducted an operational seminar to report the annual risk assessments of corruption within the MoD and promote the application of the risk assessments to the following year’s defence policy [3]. However, according to Interviewee 1, a political scientist, these assessments are not used to effectively reform defence and security institutions. Therefore, these assessments often tend to be merely superficial [4]. For instance, in 2019, the NACC ranked the army as the most transparent governmental agency, with a score of 97.96 out of 100. The NACC’s decision to grant the top transparency award to the army was questioned by many in terms of the credibility of rankings, demonstrating the public concern over the NACC’s levels of integrity and efficiency, which have been considered extremely low since the 2014 coup [5].

According to our sources, there are no defence-specific assessments of corruption risk. The MoD does not consider corruption as a great risk and therefore there is no such assessment(1,2,3).

This indicator is marked Not Applicable because there is no evidence of the existence of defence-specific assessments of corruption risk.

This indicator is marked Not Applicable because there is no evidence of the existence of defence-specific assessments of corruption risk.

Interviewee 5 suggested that there are no regular assessments of the areas of greatest corruption risk, either at the Ministry of Defence or the General Staff [1]. He emphasised that all auditing/investigation mechanisms within the Ministry of Defence operate as on-call systems following the report of an abuse/violation [2].

However, according to Interviewee 3, in the new system of executive presidency, following the abolishment of the military judicial system, there is some awareness regarding risk areas, but no official risk assessments have been conducted for the Ministry or Armed Forces, either as a whole or within individual departments [3].

This indicator is marked ‘Not Applicable’ because, as explained in 10A, there is no regular schedule for risk assessments in the Ministry of Defence or within the military [1,2,3].

This indicator is marked ‘Not Applicable’ because, as explained in 10A, there is no regular schedule for risk assessments in the Ministry of Defence or within the military [1,2,3].

The Internal Audit Department of the Uganda People’s Defence Force (UPDF) [1], the Office of the Auditor General [2, 3], and Public Procurement and Disposal of Public Assets Authority [4] conduct risk assessments of the Ministry of Defence and Veterans Affairs (MoDVA) annually or at least every three years. Much as these risks are conducted, many times, it is not easy to ascertain whether the ministry implements what have been raised in these reports. For example, corruption risks are clearly identified, but risk assessments are conducted on the ministry or armed force as a whole, rather than with focus on individual departments.

The Internal Audit Department of the Uganda People’s Defence Force (UPDF) [1], the Office of the Auditor General [2, 3], and Public Procurement and Disposal of Public Assets Authority [4] conduct risk assessments of the Ministry of Defence and Veterans Affairs (MoDVA) annually or at least every three years.

According to military spokesperson [1] and an interview with the chief of legal services, MoDVA [2], risks assessments are used to develop and regularly update the anti-corruption policy and institutional action plans in the MoDVA. The Defence policy[3] states that accountability remains at the core of the operations of the Uganda People’s Defence Army. The defence policy also stress the need for efficient finacial management system, which ensures apporpriate control and oversight, in line with public sector procedures.

There is evidence of the MoD given the task to conduct corruption risk assessments [1], and the MoD calling civil society organisations to participate in such assessments [2]. Both the MoD Anticorruption Program for 2015-2017 as well as the MoD Draft Anticorruption Program for 2018-2020 have identified steps to be taken, deadlines, responsible authorities, indicators and information on resources for the steps, each of them allegedly aims at mitigating particular corruption risk [3, 4]. There are also publicly available documents with clearly identified corruption risks [5]. Corruption risks are identified not by an individual department, but by an ad-hoc commission conducting a risk assessment of the MoD as a whole [6]. The commission does not focus on individual departments but rather on potential spheres of corruption like HR issues, AFU forces in operations, procurement, etc. [7].

There are regular (once every three years) fundamental assessments of the areas of corruption risk for the MoD and the AFU. For instance, the last assessment was carried out in 2017, resulting in the MoD Draft Anticorruption Program for 2018-2020 [1]. The next-to-last assessment was carried out in 2015, which resulted in the MoD Anticorruption Program for 2015-2017 [2]. Additionally, each year a commission on corruption risks reviews the MoD Anticorruption Program and amends it as appropriate, engaging civil society, expert community and foreign partners [3].

The risk assessment findings are used to develop and regularly update the MoD anti-corruption policy [1]. Thus, for instance, the MoD drafts and adopts every three years an Anti-corruption Program following a fundamental risks assessment. At the same time, the commission reviews it each year and amends it as appropriate [2, 3].

There is no evidence available that shows that any risk assessments for the defence sector have been commissioned in the last 2-3 years. The websites of the Ministry of Defence and the State Audit Institution include no information about corruption risk assessments. (1), (2), (3), (4), (5).

This sub-indicator has been marked as NA, as no assessments of corruption risks have been commissioned in the past few years, and for this reason, assessing the regularity of the non-existent assessments is not relevant in this context (1), (2), (3), (4).

This sub-indicator has been marked as NA, as no assessments of corruption risks have been commissioned in the past few years, and for this reason, assessing the regularity of the non-existent assessments is not relevant in this context (1), (2), (3), (4).

Fraud Defence conducts regular risk assessments which identify corruption risks, although there is little publicly available evidence of this. According to the MOD, Fraud Risk Discipline regularly conducts risk assessments across the MOD and has trained and embedded Fraud Risk Assessors in each of the MOD’s six Top-Level Budget (TLB) organisations to undertake fraud risk assessments independently. Upon completion of a risk assessment, it is reported back to the Head of Fraud Risk Discipline for oversight and inclusion into the Department’s risk register. Once this is done, mitigation strategies are drawn up into action plans that include interventions such as training, oversight, policy recommendations and control improvements [1].

Similarly, the MoD has a Defence Internal Audit (DIA) function which provides internal audit across the MOD, however, evidence of their activity is not available in the public domain [2]. According to one of the interviewees, with the exception of Military Operations, all business systems, processes, functions and activities within the MOD may be subject to internal audit work. The DIA annual risk-based audit plan defines what activities will be reviewed by DIA and is formally approved by a sub-committee of the Defence Board [2]. Disclosures of DIA progress reports to the DAC suggest that audits are strategic and in line with a risk-informed process [3].

According to the MOD, all risk registers are subject to reviews every 12 weeks by the Fraud Risk Discipline team and the Senior Risk Owners, to ensure that corruption risk is monitored on an ongoing basis [1]. Information on fraud risk is also presented to the Defence Audit and Risk Assurance Committee for review when they meet, normally 6 times per year [2]. The Committee then provides quartlery risk reporting to the Board, based on this information [3].

According to the MOD, the MOD Counter Fraud and Corruption Strategy, and subsequent action plan, all consider the consolidated output of all the risk registers in order to draw up the Department’s counter fraud priorities. In line with the regular reviews of the risk register themselves, the Counter Fraud and Corruption Strategy is also regularly updated should new risks be identified [1]. Additionally, Building Integrity UK contributed to the government’s Anti-Corruption Strategy in relation to the links between corruption and hybrid threats [2].

No defence-specific assessment of corruption risks has been undertaken at any point in recent history. However, the DoD OIG produces an annual ‘Top DoD Management Challenges’ report, which identifies the top 10 management challenges facing the DoD and reflects on previous recommendations made to the DoD. In the 2018, 2019 and 2020 reports, ‘ensuring ethical conduct’ has been one of the 10 challenges [1,2,3], which has included a focus on public corruption investigations as undertaken by the Defense Criminal Investigative Services (DCIS). Although these reports do not mention a specific corruption risk assessment, nor are they themselves a risk assessment, the reports do provide evidence that the DoD OIG recognises corruption as a management challenge.

The DoD OIG also produces an annual compendium of the IG’s recommendations to the DoD that remain open. The 2020 report outlines 1,602 open recommendations that have been raised by the OIG since August 2014 [4]. There is no mention of corruption in these recommendations. There is evidence that fraud risk assessments take place, but it was difficult to find any information on these assessments [5].

The Government Accountability Office (GAO) produces an two-yearly high-risk list, which identifies programmes and operations that are at ‘high risk’ due to “vulnerabilities to fraud, waste, abuse, and mismanagement, or that need transformation” [6]. The 2021 list includes six DoD programmes, all of which have been flagged as high risk for 16 years or longer [7].

No defence-specific assessment of corruption risks has been undertaken at any point in recent history. The ‘Top DoD Management Challenges’ report is produced annually. However, the GAO’s two-yearly high risk list covers some DoD programmes [1].

No defence-specific assessment of corruption risks has been undertaken at any point in recent history. There is no evidence that risk assessment findings are used to inform anti-corruption policy or practice.

Some corruption risk assessments take place, but these are independently carried out by civil society organisations and do not benefit from government cooperation, neither in terms of financial resources nor information. National social organizations have published studies on corruption risks, but these do not cover the entire defence sector – rather, aspects of its management [1, 2, 3]. Reports published by these organisations consistently denounce the government’s blocking of access to information so that only unofficial and summarised information is available for such analysis [4].

This indicator is marked ‘Not Applicable’. Risk assessments are not conducted by the government. Organisations that conduct risk analysis studies, on a general level and on the functioning of the FANB, do not have a fixed schedule. While annual reports can be found, other organisations typically publish reports covering longer periods. Although some organisational annual reports identify corruption risks, not all publications contain information specific to the defence sector [1, 2, 3]. Moreover, difficulties in access to information complicate the updating of these reports [4].

This indicator is marked ‘Not Applicable’. Risk assessments are not conducted by the government. Reports produced by civil society organisations identify clear risks of corruption, as well as denouncing specific cases involving evidence of corrupt practices [1, 2, 3]. However, these findings receive no response from government, and since Venezuela does not have an anti-corruption policy, either in the defence sector or at a general level, these findings are not even considered within the short-term anti-corruption measures announced by government [4, 5]. The little information available on the comptroller’s office of the defence sector (CONGEFANB), the administration of the MPPD, and the activities of the Strategic Command Operations of the FANB (CEOFANB) does not indicate any analysis of corruption risks produced within these entities [6]. Together with the lack of access to official information alleged by civil society organisations, this demonstrates the sector’s lack of interest in identifying and addressing corruption risks [1, 2].

A defence specific corruption risk assessment has not been commissioned in recent times. There is not a publicly available one [1, 2].

This indicator is marked “Not Applicable,” since risk assessments are not conducted.

This indicator is marked “Not Applicable,” since risk assessments are not conducted.

Country Sort by Country 10a. Risk assessments Sort By Subindicator 10b. Regularity Sort By Subindicator 10c. Inputs to anti-corruption policy Sort By Subindicator
Albania 25 / 100 NA NA
Algeria 0 / 100 NA NA
Angola 0 / 100 NA NA
Argentina 25 / 100 0 / 100 NA
Armenia 75 / 100 NEI NEI
Australia 50 / 100 25 / 100 50 / 100
Azerbaijan 0 / 100 NA NA
Bahrain 0 / 100 NA NA
Bangladesh 0 / 100 NA NA
Belgium 100 / 100 100 / 100 75 / 100
Bosnia and Herzegovina 100 / 100 100 / 100 100 / 100
Botswana 25 / 100 0 / 100 NA
Brazil 75 / 100 0 / 100 NEI
Burkina Faso 0 / 100 NA NA
Cameroon 0 / 100 NA NA
Canada 75 / 100 100 / 100 50 / 100
Chile 50 / 100 50 / 100 50 / 100
China 0 / 100 NA NA
Colombia 75 / 100 100 / 100 50 / 100
Cote d'Ivoire 0 / 100 NA NA
Denmark 75 / 100 100 / 100 50 / 100
Egypt 0 / 100 NA NA
Estonia 50 / 100 0 / 100 NA
Finland 0 / 100 NA NA
France 75 / 100 0 / 100 50 / 100
Germany 75 / 100 50 / 100 50 / 100
Ghana 0 / 100 NA NA
Greece 0 / 100 NA NA
Hungary 50 / 100 100 / 100 0 / 100
India 50 / 100 0 / 100 25 / 100
Indonesia 25 / 100 NA NA
Iran 0 / 100 NA NA
Iraq 0 / 100 NA NA
Israel 50 / 100 0 / 100 50 / 100
Italy 100 / 100 100 / 100 100 / 100
Japan 50 / 100 0 / 100 50 / 100
Jordan 0 / 100 NA NA
Kenya 25 / 100 NA NA
Kosovo 100 / 100 100 / 100 50 / 100
Kuwait 25 / 100 NA NA
Latvia 100 / 100 100 / 100 100 / 100
Lebanon 0 / 100 NA NA
Lithuania 75 / 100 50 / 100 75 / 100
Malaysia 75 / 100 100 / 100 50 / 100
Mali 0 / 100 NA NA
Mexico 25 / 100 NA 50 / 100
Montenegro 50 / 100 100 / 100 50 / 100
Morocco 0 / 100 NA NA
Myanmar 0 / 100 NA NA
Netherlands 50 / 100 50 / 100 NEI
New Zealand 100 / 100 50 / 100 100 / 100
Niger 0 / 100 NA NA
Nigeria 0 / 100 NA NA
North Macedonia 75 / 100 100 / 100 50 / 100
Norway 75 / 100 50 / 100 75 / 100
Oman 0 / 100 NA NA
Palestine 0 / 100 NA NA
Philippines 100 / 100 50 / 100 75 / 100
Poland 50 / 100 0 / 100 50 / 100
Portugal 100 / 100 50 / 100 50 / 100
Qatar 0 / 100 NA NA
Russia 50 / 100 50 / 100 0 / 100
Saudi Arabia 0 / 100 NA NA
Serbia 75 / 100 50 / 100 75 / 100
Singapore 75 / 100 100 / 100 100 / 100
South Africa 50 / 100 100 / 100 75 / 100
South Korea 75 / 100 100 / 100 75 / 100
South Sudan NEI NEI NEI
Spain 0 / 100 NA NA
Sudan 0 / 100 NA NA
Sweden 0 / 100 NA NA
Switzerland 50 / 100 NEI NEI
Taiwan 75 / 100 100 / 100 100 / 100
Tanzania 75 / 100 100 / 100 100 / 100
Thailand 100 / 100 100 / 100 0 / 100
Tunisia 0 / 100 NA NA
Turkey 0 / 100 NA NA
Uganda 75 / 100 100 / 100 75 / 100
Ukraine 75 / 100 50 / 100 100 / 100
United Arab Emirates 0 / 100 NA NA
United Kingdom 100 / 100 100 / 100 100 / 100
United States 25 / 100 25 / 100 0 / 100
Venezuela 0 / 100 NA NA
Zimbabwe 0 / 100 NA NA

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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