Project: NORMCORM (Non-repressive Model to Reduce Corruption at Mu- nicipal Level) implemented by RiskMonitor Foundation - Sofia Development Association - MEPCO, Czech Republic MODEL SYSTEM OF INDICATORS FOR MONITORING THE CORRUPTION LEVELS AT SOFIA MUNICIPALITY Tool for Identifying and Measuring Corruption Risks SOFIA, 2014
40
Embed
MODEL SYSTEM OF INDICATORS FOR …riskmonitor.bg/js/tiny_mce/plugins/ajaxfilemanager/...Model system of indicators for monitoring the corruption levels at sofia municipality 5 corruption
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Transcript
Project: NORMCORM (Non-repressive Model to Reduce Corruption at Mu-nicipal Level) implemented by RiskMonitor Foundation - Sofia Development Association - MEPCO, Czech Republic
MODEL SYSTEM OF INDICATORSFOR MONITORING THE CORRUPTION LEVELS AT SOFIA MUNICIPALITYTool for Identifying and Measuring Corruption Risks
SOFIA, 2014
1Model system of indicators for monitoring the corruption levels at sofia municipality
MODEL SYSTEM OF INDICATORSFOR MONITORING THE CORRUPTION LEVELS AT SOFIA MUNICIPALITYTool for Identifying and Measuring Corruption Risks
Project: NORMCORM (Non-repressive Model to Reduce Corruption at Municipal Level) implemented by RiskMonitor Foundation - Sofia Development Association - MEPCO, Czech Republic
SOFIA, 2014
2 Model system of indicators for monitoring the corruption levels at sofia municipality
With the financial support from the Prevention of and Fight against Crime Programme of the European Union
European Commission - Directorate General ‘Home Affairs’
Research team and consultants: Diana Kovatcheva, David Koppitz, Milan Puček, Rada
This publication reflects the views of the authors only and the Commission cannot be held responsible for any use, which may be made of the information contained therein.
3Model system of indicators for monitoring the corruption levels at sofia municipality
Table Of Content
INTRODUCTION 4
PROBLEMS IN TACKLING CORRUPTION IN LOCAL GOVERNMENT 6
OBSTACLES IN THE FIGHT AGAINST
CORRUPTION IN SOFIA MUNICIPALITY 8
ASSESSING THE LEVEL OF CORRUPTION AND THE CORRUPTION
RISK IN THE LOCAL ADMINISTRATION 12
INDICATORS FOR CORRUPTION RISK ASSESSMENT AT SOFIA MUNICIPALITY 14
I. CORRUPTION-RISK INDICATORS (GENERAL) 17
II. INDICATORS FOR TRANSPARENCY AND ANTI-CORRUPTION MEASURES 22
III. INDICATORS OF CORRUPT BEHAVIOR 28
CONCLUSION 34
Annex 1: DETERMINING THE INDICATOR FOR FREQUENCY OF OCCURRENCE (EXAMPLE) 35
Annex 2: SAMPLE QUESTIONNAIRE TO COLLECT INFORMATION REQUIRED TO DETERMINE THE INDICATOR FOR MONITORING OF CORRUPTION RISKS 37
4 Model system of indicators for monitoring the corruption levels at sofia municipality
Introduction
Corruption has been an indelible part of society’s development since ancient times. Consistent attempts to fight corruption, globally, begin to emerge in the 1980s of the 20th century. The process can be traced back primarily in documents and the work of international organizations which have aimed to streamline their standards through the introduction of international anti-corruption legislation.1
Nevertheless, the continuous process of harmonization and improvement of the anti-corruption law in countries around the world, mainly through the ratification of international legal instruments, has so far been an effective but insufficient mechanism. Equally important in this respect is the efficient implementation of the national legislations as well as a strong political will to tackle corruption. State and non-state actors alike must recognize that the poor enforcement of the national anti-corruption legislation, coupled with a weak institutional system for the detection, investigation and prosecution of corruption-related crimes, undermines democracy and the rule of law, destroys fair competition and hinders economic development.2
For Bulgaria, the fight against corruption is a critical issue with implications at national, European and international level. Bulgaria is a party to all international anti-corruption treaties; the country’s legislation is fully compliant with the European and international standards currently in place. A number of anti-corruption strategies and action plans have been adopted by public bodies. Despite all efforts in the last years, the country has failed to make sufficient progress and Bulgaria has repeatedly ranked in the bottom of international
1 See the following international documents: Council of Europe, Committee of Ministers, RESOLUTION (97) 24 ON THE TWENTY GUIDING PRINCIPLES FOR THE FIGHT AGAINST CORRUPTION (Adopted by the Committee of Ministers on 6 November 1997 at the 101st session of the Committee of Ministers); The Criminal Law Convention on Corruption, promulgated in State Gazette Issue 42/27.04.2001; Additional Protocol to the Criminal Law Convention on Corruption, in force from 1 Feb. 2005; The Civil Law Convention on Corruption, in force from 1 Nov. 2003, promulgated in the State Gazette issue 42/23 May 2000; the Code of Conduct for Public Servants, Recommendation No R (2000)10 of the Committee of Ministers, adopted 11 May 2000; Recommendation Rec(2003)4 of the Committee of Ministers to member states on common rules against corruption in the funding of political parties and electoral campaigns; Convention on the protection of the European Communities’ financial interests, made on the basis of art. K 3 of the Treaty of the European Union, Official Journal C 316 of 27.11.1995; Convention against corruption involving officials or officials of Member States of the European Union, [Official Journal C 195 of 25 June 1997], Framework Decision2003/568; OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, State Gazette issue 61/6 July 1999; United Nations Convention against Corruption, in force from 14 Dec. 2005; State Gazette issue 89/3. Nov. 2006, in force from 20 Oct. 2006 for the Republic of Bulgaria.
2 UN Secretary General Ban Ki-Moon, Official statement on the occasion of Anti-Corruption Day, 9 December 2009.
5Model system of indicators for monitoring the corruption levels at sofia municipality
corruption studies.3 In addition, corruption is one of the areas subject to monitoring by the European Commission as part of the Union’s Cooperation and Verification Mechanism.4
Studies show that the political and high-level institutional corruption undermines the citizens’ trust in the public bodies, significantly obstructs the country’s development, blocks the work of the judiciary and deters foreign investments. Political corruption threatens the entire social fabric and opens the door to “state capture”, whereby private interests significantly influence a state’s decision-making processes to their own advantage through illicit and unobvious channels.5 Not less damaging are the effects of corruption on local governments, because the citizens are directly affected by the lack of accountable and transparent administration in their home towns. Most prevalent at this level is the so-called petty corruption.
Therefore, the fight against corruption demands the full attention and daily efforts by everyone at each level of governance. Key element in this process is the use of well-chosen methods, to best tackle the issues at hand. The successful counteraction of corruption requires a comprehensive approach, targeting corruption at both the central and the local level of administration.
This report presents a system of indicators for corruption risk assessment, developed on the basis of good practices from local administrations in EU member-states. Тhe system has been adapted to meet the needs and requirements of Sofia Municipality, providing the local administration with a tool for identifying the areas with higher corruption risks; the tool will enable the municipal administration to conduct its own ongoing corruption risk assessment without external monitoring or external interventions and recommendations.
3 See Transparency International Corruption Perception Index and the World Corruption Barometer at www.transparency.bg
4 See the EC reports at http://ec.europa.eu/cvm/progress_reports_en.htm 5 World Bank (2000). Anticorruption in Transition: Contribution to the Policy Debate. World Bank Publications,
ISBN 9780821348024, http://books.google.co.uk/books?id=gpBvS3O17S4C&pg=PA3#v=onepage&q&f=false
6 Model system of indicators for monitoring the corruption levels at sofia municipality
Problems in Tackling Corruption in Local Government
Corruption in local government is usually the result of the lack of transparent governance (non-transparent allocation of public resources, corruption practices in public procurement/concession procedures, non-transparent decision making process). Complicated administrative procedures create a fertile ground for corruption pressure on citizens and businesses (e.g., the heavy procedures of licensing and issuing of permits), as well as the everyday operations of the administration in the enforcement of the law and various regulations. Corruption activities are easier to observe and identify at the local level. Corruption is likely to affect the quality and timeliness of the administrative services provided by the local administration, and most petty corruption at this level is enabled by the direct communication between the administration and the citizens. Often, corruption in the local government is regarded as an incentive for the administration to perform better or what is frequently referred to as “greasing the wheels” of the administration. Both of these views are not only deeply mistaken, but they stay in the way of developing strong state and local administration built on the principles of professionalism, stability and good governance.6
6 For good governance, cf. art. 2 of the State Administration Act, State Gazette 130/5 Nov. 1998, last amended, State Gazette 27/25 Маrch 2014.
7Model system of indicators for monitoring the corruption levels at sofia municipality
The lack of efficient control mechanisms, the inability to identify corruption practices and to punish the wrongdoers, coupled with the overall perception of the unavoidable wide-spread existence of corruption (i.e., „everybody does it”), are the main stumbling blocks to tackling corruption at the local level. An additional barrier is the fact that local administrations do not have designated units in charge of the analysis and assessment of corruption risks (compliance offices), for handling corruption reports and claims, and imposing disciplinary actions, as for example are the inspectorates in the state administration.
Numerous studies have identified bottlenecks such as these. What is required to tackle them successfully are specific corrective measures, both legislative and organizational, as well as organizing and conducting specialized anti-corruption training of the public servants along with measures to increase the capacity of the public and the local businesses to reduce corruption at the local level.
8 Model system of indicators for monitoring the corruption levels at sofia municipality
Obstacles in the fight against corruption in Sofia Municipality
The counteraction of corruption at municipal level is not reflected in specifi-cally designed for the purpose municipal regulations, ordinance or organiza-tional measures7. Sofia Municipality does not have in place an anti-corrup-tion strategy or an action plan with anti-corruption measures. Consequently, any issues linked to the identification of corruption risks, the observance of ethical standards or policies for managing conflict of interests or reporting irregularities by the public servants is not part of the policies of transparency followed by Sofia Municipality8. Nevertheless, it must be noted that the Stat-ute of the Municipality clearly states the basic principles to be observed by the municipal administration, among them transparent governance, dialogue with the citizens, transparent public spending, access to information with re-gard to public spending, etc. (art. 1, para. 2). These principles provide good basis for the development of specific policies aimed at guaranteeing trans-parency and accountability in the work of the municipal administration. In a high-risk corruption environment in all sectors of government, it is imperative for Sofia Municipality to develop its own vision and anti-corruption strategy.
The first task towards the development of a long-term strategic document is the analysis and identification of the corruption risks in Sofia Municipality, followed by developing and adopting an internal system for risk assessment, adapted to the specific needs of the municipal administration. Sofia Munici-pality has already made the first step in this regard: at the end of 2013 was conducted a representative opinion poll among citizens and businesses of the capital city, surveying the level of corruption in the city. The results were analyzed and published in the report, which also identified the high-risk areas and most common corruption practices in the municipal administration9.
7 Municipal regulations list among the responsibilities of specific directorates and departments of the administration the review and reporting on citizens’ complaints and claims.
8 Issues such as ethical standards and conflict of interests fall within the responsibilities of the committees under the umbrella of the local parliament, the Sofia Municipal Council. For instance, the Standing Committee on Ethics, Citizens Rights, Claims and Complaints and the Committee pursuant to the Law on the Avoidance and Identifying of Conflict of Interests.
9 The survey was conducted by Alpha Research Agency for Marketing and Social Research in Nov. 2013 within the project „Non-repressive Model to Reduce Corruption at Municipal Level.”
9Model system of indicators for monitoring the corruption levels at sofia municipality
The survey showed that respondents most often identify the lack of control and inadequate disciplinary actions (51%) as reasons for corruption among municipal officers. Almost half of the respondents indicate the condescending attitude of the administration to the citizens – that is, the administration’s feeling that citizens depend on the public servants - as reason for corruption (45%); 43 percent see it in the poor legislation, while for 38 percent the main reasons are political and party clientelism and protection. As concerns the levels of corruption in the Municipality, 2 percent оf the respondents (citizens) and 17 percent оf the interviewed representatives of the local businesses claim that they have witnessed some form of corruption in Sofia Municipality. With respect to the frequency of corruption activities on the territory of the Municipality, the comparative analysis shows that it differs per district.10
The occurrence of petty corruption in the Municipality is further corroborated by the survey; respondents most often identify as cases of petty corrup-tion cash payments or some type of benefit offered to a public servant in exchange of expediting a customer’s case or solving some problem. The occurrence of such types of corruption in the municipal administration is confirmed by 2.5 percent of all respondents. Notable is also the fact that most of the reported examples of corruption, given by the respondents, fall into this category.
Very often the reported cases are directly linked to or related to the sectors of construction & real estate and the respective municipal services, e.g. an apartment, construction permit, agricultural land, approval of a project, real estate fraud, alienation of property, etc.
10 For example, similar percentages are reported for the districts of Vrabnitza, Ovcha Kupel, Ilinden, Podyane, Krasna Polyana, Serdika, Slatina, Studentski grad and Lyulin. Entirely different is the situation with some other district administrations: for Iskar district, 35 percent of the respondents share that they have witnessed some form of corruption. For Sofia City District, this percentage is 33%; for district Oborishte, 26.3%, for district Bankya it is 20%; for Novi Iskar 19%, for Triaditsa 15%, for Vitosha 15% and for Izgrev, 15%.
10 Model system of indicators for monitoring the corruption levels at sofia municipality
If you have witnessed some form of corruption in Sofia Municipality, please, give specific examples:
Cash on hand 15.7%
Bribe for faster service 7.8%
For housing 7.8%
Building permit 7.8%
For lease of agricultural land 5.9%
To solve a problem 3.9%
Approval of project 3.9%
Misuse of property 3.9%
Clerical/records office 2.0%
Partition of personal property 2.0%
Alienation of property 2.0%
Unlawful recruitment 2.0%
Misuse of funds from dog shelters 2.0%
Lack of transparency 2.0%
Ignorance of the law on access to public information 2.0%
Document fraud 2.0%
Tenders 2.0%
Parking fines 2.0%
Delay in issuing documents for commercial property 2.0%
Unlawful fines imposed by officials of the Center for Urban Mobility 2.0%
Intervention by an MP to reduce an imposed fine 2.0%
Municipal markets 2.0%
No answer / I cannot give a concrete example 15.3%
[Source: Survey conducted within the project NORMCORM]
11Model system of indicators for monitoring the corruption levels at sofia municipality
The survey shows another alarming trend, namely, a very low percentage of the respondents actually know what to do and how to file a report for corruption – only 17.4 percent respond that they know; however, only 4 percent of the respondents state that they would file a report.
The survey data and the data analysis clearly show that the introduction of anti-corruption measures must be a high priority in the development and implementation of other key municipal policies, such as the policy for avoiding conflict of interests, declaration of property and assets (by the municipal councilors), and filing corruption reports and complaints. Equally important is also an ongoing analysis of the level of corruption in the administration. Strengthening the control over the sectors with a higher corruption risk, as well as imposing commensurable penalties on those who have violated the regulations are also regarded as critical for successfully curbing corruption.
Last but not least, along with the prevention and the punitive measures to tackle corruption, it is of utmost importance to improve the expertise and capacity of the municipal employees to understand corruption and to avoid corruption practices. In this respect, it is recommended to know and follow key national documents such as the Code of Conduct for the State Administration Officers (applicable to public servants and employees in the central and local government), as well as sector-specific Codes of Conduct or Codes of Ethics in place in the respective municipal administration or the Sofia Municipal Council. Proper ethical conduct increases the public trust in the administration and is also a key factor for good governance. As a non-repressive measure, ethical conduct is directly linked to the prevention of corruption at the local level.
12 Model system of indicators for monitoring the corruption levels at sofia municipality
Assessing the level of corruption and the corruption risk in the local administration
The level of corruption (prevalence or frequency of corruption incidence) in the local and the central administration is a dynamic process. The degree of corruption occurrence fluctuates, and it may change under the influence of various factors. For anti-corruption policies to be effective it is necessary for the local administration and the leadership to stay informed about the ongoing levels of corruption and the efficiency of the anti-corruption measures in place. Corruption is strongest where the institutions are weak and the control mechanisms and disciplinary sanctions are limited in scope and scale.
The external monitoring of the levels of corruption, the type and prevalence of corruption practices can definitely provide valuable information; yet external monitoring alone is insufficient, mainly because it is done by organizations which may follow different methodologies and pursue their own specific goals.
To successfully curb corruption it is important that the local administration build sufficient capacity to identify and counteract corruption activities. The existence of an internal system for the identification of areas with higher corruption risks facilitates the quick and adequate response in detecting and eliminating corruption-related irregularities and violations.
The experience of local governments in other countries provides successful examples of such internal systems for the identification and counteraction of corruption. When properly implemented, the system can prevent the spread of corruption practices in the long term and diminish the perception of lack of control and impunity in the administration. In addition, similar mechanisms for identifying the corruption risk also help channel the efforts to specific and traditionally high-risk areas such as the allocation of public funds and public procurement. A system of well-defined indicators and the thorough analysis of the results of ongoing monitoring will equip the administration’s leadership
13Model system of indicators for monitoring the corruption levels at sofia municipality
with the tools to recognize promptly the employees prone to corruption or those negligent in their work.
Taking action to identify such weaknesses and negative developments is a way to prevent corruption scandals and to avoid damage to the good name of the local administration and its employees. Fighting corruption is not only a question of the law; it carries significant political implications with a potentially high impact on the quality of governance and the citizens’ assessment of their elected leaders.
Introducing a system of indicators for corruption risk assessment, drawing upon best practices from local administrations in other EU member-states will definitely benefit Sofia Municipality and increase its human resources and institutional capacity for early detection and reaction to corruption risks.
The consistent application of a similar system of indicators will result in improved accountability, openness and transparency in the operations of the local administration. It will contribute directly to establishing an institutional environment and organizational culture based on principles of accountability, in which the employees are internally motivated to follow the law and the requirements of a professional Code of Conduct. This environment will foster and encourage consistent ethical conduct as well, strengthened by the belief that accountability is a value to be promoted and not proscribed.
An accountability-based institutional environment will moreover encourage employees to tackle corruption by reporting corrupt practices or incidents involving other employees (including their superiors and people in highly visible positions of power), who may be prone to taking bribes or other violations/wrongdoings. The added benefit of this type of environment would be in giving people assurance that reporting corruption is not useless; in the long term, this will help remove the employees’ doubts and fear of persecution, and possible repression for whistleblowers inside the Municipality. The expected impact on the employees will be the creation of an environment with zero tolerance for corruption; employees will know that the system for identifying corruption risks works effectively and that in fact corruption may prove to be a high-risk affair.
14 Model system of indicators for monitoring the corruption levels at sofia municipality
Indicators for Corruption Risk Assessment at Sofia Municipality
The indicators for corruption risk assessment in Sofia Municipality have been developed by an expert group involving Bulgarian and European anti-corruption specialists. The system steps upon similar models tested and verified in Vienna municipality, which have reported positive outcomes such as reducing the levels of corruption and significant achievements in identifying corrupt practices and prone to corruption employees.
The implementation of this system of indicators is a key prerequisite for an effective strategic management. In the management of corruption risks, the set of indicators that have been chosen must correspond to the specific needs, the internal organizational capacity and the available data in the municipality. When the set of indicators has been adequately chosen and compiled, it is predicted to produce an accurate picture of the strong and weak sides and risks in the municipal administration, enabling the leadership to make effective strategic decisions.
Following the careful analysis of the expert group, the indicators presented below have been adapted to fit the specific environment and the circumstances at Sofia Municipality. The final number and type of indicators have been selected upon consultation with experts, information from roundtable discussions with municipal employees, as well as surveys conducted with employees of the municipal administration and municipal councilors.
The system of indicators has been discussed and presented to experts and members of the municipal Committee on Ethics, Citizens Rights, Claims and Complaints, the Committee on Local Self-government and Local Regulation; it has also been discussed with the office of the Ombudsman of Sofia Municipality. Input and feedback from the consultations has been taken into consideration and included in the final draft of the system of indicators and the methodology for the system implementation.
As a result of the expert discussions and analyses, three groups of indicators
15Model system of indicators for monitoring the corruption levels at sofia municipality
have been chosen as most adequately matching the needs of Sofia. Each group of indicators includes detailed description of the concrete markers that apply to a specific area of monitoring and guidelines on how to collect relevant and area-specific data in support of the risk-assessment analysis.
The proposed indicators have been divided into 3 groups:
I. Corruption risk indicatorsThese are common and key indicators in terms of corruption. Risk assessment of corruption is one of the very important tools for the anti-corruption strategies. Indicators should help to reduce the risk of corruption and its impact.
II. Transparency indicators and anti-corruption measuresTransparency and open government is one of the very important aspects of reducing corruption and improving the quality of governance. Non-transparent decision-making creates opportunities for corruption.
III. Indicators of corrupt behaviorThe third group does not represent classic indicators, but it is an indication (recognition) of corrupt behavior and its manifestation.
General indicators of the corruption risk and transparency indicators should always be set for the specific area (specific activity), which we consider risky in terms of corruption. Based on the analyses made and the results of the sociological survey, the most relevant areas that will be subject to monitoring of the corruption risk are the following11:
1. Decision making and money redistribution
2. Governance agenda and licensing
3. Public procurement
4. Asset management and contractual relationships
The system of indicators allows measuring the corruption risk for the identified areas on a scale of 1 (low level of incidence) to 10 (high level
11 At the discretion of Sofia Municipality, the indicators for risk assessment can be applied to other priority or strategically important areas.
16 Model system of indicators for monitoring the corruption levels at sofia municipality
of incidence). The scale thus facilitates a detailed and highly differentiated measurement, with the capacity of registering also the fluctuations in degree in the assessment of the corruption risk. The rating scale of 1 to 10 is optional. The table below shows an example of how the rating scale works with a set of indicative values (points):
Table 1
Benefit – benefit for a
corrupted
Points (indicator)
CriterionMonetary benefit related to the level
of salary
very high and attractive
10 exceeds the equivalent of four annual salaries
very high 9 exceeds the equivalent of the annual salary, but less than 4 years equivalent
high 8 exceeds the equivalent of half of the annual salary, but less than one year salary
higher 7 exceeds the equivalent of a monthly salary, but less than 6 monthly salaries
intermediate - higher
6 exceeds the equivalent of 50% of the monthly salary, but less than 1 month salary
intermediate 5 exceeds the equivalent of 10% of the monthly salary, but less than 50% of the monthly salary
intermediate - lower
4 exceeds the equivalent of 5% of the monthly salary, but less than 10% of the monthly salary
low 3 exceeds the equivalent of 1% of the monthly salary, but less than 5% of the monthly salary
very low 2 is very low - less than 1% of the monthly salary
to be omitted – almost null
1 almost no benefit with regard to his salary
17Model system of indicators for monitoring the corruption levels at sofia municipality
I. CORRUPTION-RISK INDICATORS (GENERAL)
The key to an effective system of anti-corruption measures at the local level is a set of indicators of the corruption risk. Depending on the specific area of activity to be monitored, the relevant set of indicators has to be chosen as well.
For example, corruption in public procurement can be assessed using a set of indicators which can map out the risks associated with the activity. The indicators are broadly formulated to allow for easy adaptation and adjust-ment in the assessment of corruption risks in different sectors/departments/areas of operation. In the frame of the initial assessment, the corruption risk is measured against four groups of indicators: incidence, benefit, impact, and detection.
1. Occurance (OC ) = Number of incidences per year
Incidence relates to the number of occurrences/events per year or 12 months. In the example of public procurement, the information that must be gathered is the number of public procurement bids per year, which are needed to calculate the frequency of the activity and the potential risk – the higher the number of tenders in the municipality, the higher the risk of at-tempts to manipulate the bidding procedure or to obtain personal benefits, and thus, the risk for misuse of public funds from the municipal budget.12 The number of public procurement bids is a quantitative indicator which shows what percentage of the municipal funds is expended through tenders.
Measured on a scale of 1 (low level of incidence) tо 10 (high level of incidence).
2. Benefit/Gain (P) = Benefit in monetary value for the corrupted, compared to his/her monthly salary
The second indicator „benefit/gain” presents the correlation between the amount of probable benefits/gains and the average monthly salary in the sector, the municipal department or the concrete job position. The analysis of public procurement practices, for example, may reveal that the municipal
12 The risk increases not simply because the number of tenders increases, but because more public procurement bids implies spending a larger amount of public funds; the bigger number of tenders requires also heightened control as more attempts for unlawful intervention and influences may be expected, too.
18 Model system of indicators for monitoring the corruption levels at sofia municipality
employees are preparing bids for millions of leva from the municipal bud-get but their compensation is inadequately low. Disproportions like this may push the employees to manipulate the tender documentation or to attempt unlawful contacts with potential bidders, in the hope of obtaining personal monetary gains.13 The same applies to decision making, asset management or the conclusion of contracts, which are at the discretion of the administra-tion and where the control mechanisms are not tight.
Measured on a scale of 1 (low level of incidence) tо 10 (high level of incidence).
3. Impact (I) = Impact on the city calculated in money or as a percentage of the municipal budget.
The third indicator „impact” relates to the negative impact of concrete deci-sions or actions by municipal employees on the municipal budget. The deci-sions, actions or inactions in case will bring real damages and losses to the municipal budget or misappropriation of public funds. Examples may include leasing municipal property at lower than market prices or returning project funds to EU donor programs due to reports for corruption activities during the project implementation.
Measured on a scale of 1 (low level of incidence) tо 10 (high level of incidence).
4. Detection (D) = Indicates the probability that the system will detect corruption practices
The fourth indicator „detection” refers to the capacity of the municipality to detect irregularities and corrupt activities, as well as to take disciplin-ary actions against the wrongdoers. Тhis indicator relates to the operations and effectiveness of the bodies responsible for the control and disciplinary sanctions in the local administration. When properly used, the indicator also serves to assess the preventive measures against potential wrongdoers. Data about the number of disciplinary hearings against employees, the penalties
13 It is important to note that modern research on corruption challenges the view that a higher salary/compensation is a corruption deterrent; potentially, any bribe could exceed many times even the highest salary in the administration. Nevertheless, the disproportionately low compensation for municipal employees who are responsible for the allocation and expenditure of sizeable public funds may be tempted to seek other ways to compensate for their low wages. What is more, the very fact that despite the low compensation the employees are not leaving their job may be an indication that they are using their position to obtain unlawful benefits/income.
19Model system of indicators for monitoring the corruption levels at sofia municipality
imposed or the cases that have been filed to other institutions (for example, the prosecution office), demonstrate the capacity of the municipality itself to detect corruption practices and to persecute the people who have committed them. This indicator reveals the dynamic of the process of corruption activi-ties; even in the case of low indicator values during the initial risk assess-ment, the timely actions and prevention measures taken afterwards could significantly reduce the incidence of corruption in a short time span.
Measured on a scale of 1 (low level of incidence) tо 10 (high level of incidence).
As we have seen, the first group of indicators comprises both concrete/tan-gible but also broader (prognostic) indicators. The specific indicators com-prise of:
y the number of public procurement bids during the year,
y the average salary of the employees in the department/section, who are in charge of public procurement,
y the number of disciplinary action or cases filed to the prosecution.
The general indicators encompass, for example, the benefits that an employee might receive; the damage/impact of the corruption act on the municipal budget and the level of probability for the detection of a corruption practice involving municipal employees.
The indicators for the corruption risk (indicators 5-7, Table 2) and the indicator for the risk of competitive advantage through corruption (indicator 8, Table 2), relate to the opportunities for the emergence of a corruption risk, the benefits for the corrupted, and the impact/threat for the city of the detect-ed corruption. Descriptions of each indicator are given in the tables below.
As Tables 2 and 3 show, whenever the frequency of the opportunities for potential corruption along with the probability for considerable gains is high (or the impact on the city would be considerable), while the rate of detec-tion remains low, the corruption risk (RCc) and the indicators for corruption risk (RPNc) are very high as well. To calculate the RPNc, it is necessary to determine the indicator’s scope against the assessment criteria on the scale of 1 to 10 for incidence, benefit/impact, and the rate of detection. The scale is described in the following four tables.
20 Model system of indicators for monitoring the corruption levels at sofia municipality
Tabl
e 2:
Cor
rupt
ion
risk
indi
cato
rs a
nd c
alcu
latio
n
Indi
cato
rs 1
- 4:
1. O
ccur
renc
e (n
umbe
r of
inci
dent
s) o
f cor
-ru
ptio
n op
portu
nitie
s (O
ccur
renc
e - O
C),
Bene
fit o
r im
pact
4. D
etec
tion
– pr
obab
ility
of
iden
tific
atio
n ; (
Dete
ctio
n –
D)2.
Ben
efit
(Ben
efit
for t
he
corr
upte
d in
com
paris
on to
m
onth
ly w
age)
; (Pr
ofit-
P)
3. Im
pact
(sev
erity
) on
the
city
(Impa
ct –
I)
Indi
cato
rs 5
-7:
Valu
e of
the
corr
uptio
n ris
k
5. R
isk
of c
orru
ptio
n va
lue
– be
nefit
(RC CP
): RC
CP =
OC *
P
6. R
isk
of c
orru
ptio
n va
lue
– im
pact
(RC CI
): RC
CI =
OC *
I
7. R
isk
of c
orru
ptio
n va
lue-
RC C
: hig
her o
f the
val
ues
RCCP
, RCCI
Indi
cato
r 8:
Risk
of c
orru
ptio
n pr
iorit
y8.
Ris
k of
cor
rupt
ion
prio
rity
indi
cato
r (RP
N C): RP
N C = R
C C * D
The
tabl
e be
low
giv
es a
brie
f des
crip
tion
of th
e in
dica
tors
.
21Model system of indicators for monitoring the corruption levels at sofia municipality
Tabl
e 3:
Cor
rupt
ion
risk
indi
cato
rs –
des
crip
tion
No.
Nam
eUn
itDe
scrip
tion,
com
puta
tion
1Oc
curre
nce
(num
ber o
f in
cide
nts)
of c
orru
ptio
n op
portu
nitie
s (O
ccur
renc
e - O
C)
Num
ber o
f oc
curre
nces
pe
r yea
r
Num
ber o
f eve
nts
per y
ear (
for e
xam
ple,
pub
lic p
rocu
rem
ents
, act
s of
gov
ernm
ent)
of th
e co
mpa
rabl
e ty
pe p
er y
ear.
Base
d on
the
num
ber o
f the
occ
urre
nce,
the
resu
lt is
indi
cate
d on
a
scal
e fro
m 1
(min
or o
ccur
renc
e) to
10
(ver
y hi
gh o
ccur
renc
e).
2Be
nefit
(Ben
efit
for t
he c
orru
pted
in
com
paris
on to
mon
thly
w
age)
; (Pr
ofit-
P)
Scal
e 1-
10
Pote
ntia
l ben
efit
in m
onet
ary
term
s fo
r the
cor
rupt
ed p
erso
n, c
ompa
red
to h
is m
onth
ly s
alar
y (to
be
agre
ed, i
f it i
s th
e av
erag
e sa
lary
in th
e pu
blic
sec
tor,
or in
the
spec
ific
mun
icip
al o
ffice
, or
in re
latio
n to
the
posi
tion)
. Bas
ed o
n th
e am
ount
, the
resu
lt is
indi
cate
d on
a s
cale
from
1
(littl
e - a
lmos
t non
e) to
10
(ver
y hi
gh a
nd a
ttrac
tive)
. Sal
ary
does
not
nec
essa
rily
corre
late
with
va
lues
of p
ublic
pro
perty
adm
inis
tere
d by
a c
ivil
serv
ant.
3Im
pact
(sev
erity
) on
the
city
(Impa
ct –
I)M
onet
ary
unit
or %
of t
he
budg
et
Impa
ct o
f cor
rupt
ion
on th
e ci
ty (t
he c
ity b
udge
t) in
mon
etar
y un
its. I
n lin
e w
ith th
e ab
ove,
the
impa
ct o
n th
e ci
ty b
udge
t in
% is
indi
cate
d on
the
scal
e fro
m 1
(litt
le- a
lmos
t zer
o ex
pens
e) to
10
(ver
y hi
gh).
4De
tect
ion
– pr
obab
ility
of
iden
tific
atio
n ; (
Dete
ctio
n –
D)Sc
ale
1-10
Pr
obab
ility
that
the
curre
nt s
yste
m o
f wor
k w
ill de
tect
the
corr
uptio
n. V
alue
1 o
n th
e sc
ale
mea
ns th
at th
e de
tect
ion
is a
lmos
t cer
tain
(or t
he c
urre
nt s
yste
m w
ill su
rely
det
ect t
he c
orru
p-tio
n), v
alue
of 1
0 m
eans
that
det
ectio
n is
impo
ssib
le (o
r not
pos
sibl
e on
the
basi
s of
the
proc
e-du
res
that
sho
uld
reve
al th
e co
rrup
tion)
. Val
ues
are
linke
d to
the
exis
ting
syst
em o
f con
trol.
5Ri
sk o
f cor
rupt
ion
valu
e –
ben-
efit
(RC CP
)In
dex
RCCP
= O
C * P
Oc
curre
nce
* Pr
ofit
6Ri
sk o
f cor
rupt
ion
valu
e –
im-
pact
(RC CI
)in
dex
RCCI =
OC *
I Oc
curre
nce
* Im
pact
7Ri
sk o
f cor
rupt
ion
valu
ein
dex
RCC:
High
er fr
om th
e va
lues
RC CP
, RCCI
8Ri
sk o
f cor
rupt
ion
prio
rity
indi
cato
r (RP
N C)in
dex
RPN C =
RC C *
DCo
rrup
tion
risk
* De
tect
ion
22 Model system of indicators for monitoring the corruption levels at sofia municipality
II. INDICATORS FOR TRANSPARENCY AND ANTI-CORRUPTION MEASURES
The second group of indicators is designed to assess the level of transparen-cy in the municipal administration and the specific anti-corruption measures in place. This set of indicators covers issues of major societal consequence and to which by default civil society should have access in order to exercise sufficient level of control. In particular, the indicators are designed to evaluate the extent to which the municipality follows the principles of open and trans-parent governance and offers reliable guarantees for free and easy public access to information about its decision making process as enshrined in the existing legal statutes.
In order to determine the indicator for transparency in the case of corruption risk assessment in public procurement procedures, the municipal administration has to make public the following information, freely and without restrictions:
a) Information has to be provided about the number of public procure-ment bids published on the Internet (including the announcements and the tender documentation; an organization will score high on the scale of transparency if all of the procurement bids are published online). Of significance is the ratio between the value of the procure-ment bids published online, to the total value of all procurement bids.
b) In order to assess the level of transparency it is also necessary to receive information about the number of employees hired through an open call compared to the total number of employees.
23Model system of indicators for monitoring the corruption levels at sofia municipality
c) The value of the indicator depends also on the level of transparency in the management of municipal property (that is, sales, purchases, concessions, leasing). A good practice to improve transparency is publishing the relevant information online or at a designated place in the municipality. Some municipalities go even beyond the require-ments of the law and publish the information in public media or other publicly accessible places. The indicator measures the per-centage of municipal property transactions which are conducted in line with the predetermined transparency regulations. For the indi-cator value to be defined, it is also necessary to monitor all of the transactions with public property, calculating the ratio of all deals compared to those published online.
d) Of significance is also the level of transparency in providing infor-mation about municipal grant making activities and allocation of subsidies. Many of the municipalities in the Czech Republic for ex-ample have grant making procedures for direct beneficiaries, mostly for NGOs. Typically, the funds are allocated through open calls for proposals. However, part of the subsidies are also disbursed direct-ly (by the municipal council) upon request from the organizations. The indicator measures the percentage of grants in absolute mon-etary value disbursed through open calls for proposals compared to the total amount of grant funds. In addition, the number of funded proposals could be considered as well in the determination of the indicator value.
24 Model system of indicators for monitoring the corruption levels at sofia municipality
The second set of indicators in this group refers to transparency measures introduced b y the municipality itself. The key figures to observe here are:
a) The ratio between the salaries for the job position of the employees most at risk of corruption to the average salary in the country (cf. above);
b) The severity of the imposed disciplinary action when irregularities or corrupt practices have been detected and proven. It is necessary to define the scale of the possible sanctions (for example criminal liability, loss of employment).
Indicator value of 1 means severe sanctions which can deter corruption. A value of 10 indicates weak sanctions and no public awareness of them.
c) In this group of indicators we have included also the number of corruption cases per year which are identified and investigated by the legal authorities, as evidence of the authorities’ capacity and ef-fectiveness in tackling corruption. The indicator covers all identified cases, including corrupt activities, lack of transparency, nepotism, cronyism, clientelism, etc.
d) Of critical significance in this respect is the existence of a well-functioning and effective system of reporting corruption by the mu-nicipal employees, in particular, the office of compliance and anti-corruption.14 A well-functioning system for whistleblower protection is key to curbing corruption in any organization.
Indicator value of 1 means that whistleblower protection is high and employees are aware of it. A value of 10 indicates a poor protection system and little interest in enforcing anti-corruption reporting.
14 What is meant here is indeed a system for filing and handling corruption reports submitted by municipal employees, and not simply filing reports and complaints by the citizens.
25Model system of indicators for monitoring the corruption levels at sofia municipality
e) For an objective weighting of this indicator, it is advisable to include statistics about the number of corruption reports per year, the num-ber of reports for fraud, for conflict of interests and lack of trans-parency. The indicator covers the total number of filed complaints and corruption/fraud reports (including complaints for no access to information, nepotism, conflict of interests, breach of regulations, etc.), regardless of the merit of each report. This indicator is closely linked with another one, which is related to the number of actions taken in response to the reports filed.
f) Last but not least, another key indicator relates to the number of employees per year who have received anti-corruption training compared to the total number of municipal employees.
The set of indicators described above represent the triade of prevention, sanctions, and training as an effective method to fight corruption. The municipal administration has to decide which are most suited for its purposes – prevention, disciplinary actions, or emplyee training in order to reach the best results in reducing the incidence of corruption.
The table below describes briefly each of the indicators for transparency and anti-corruption measures.
26 Model system of indicators for monitoring the corruption levels at sofia municipality
Tabl
e 4:
Tra
nspa
renc
y in
dica
tors
and
ant
i-cor
rupt
ion
mea
sure
s- d
escr
iptio
nNo
.Na
me
Unit
Desc
riptio
n, c
ompu
tatio
n1
Sala
ry to
ave
rage
sal
ary
ratio
%Th
e ra
tio o
f the
sal
ary
of th
e sp
ecifi
c po
sitio
ns (w
hich
are
exp
osed
to th
e co
rrup
tion
risk)
to
the
aver
age
sala
ry in
the
coun
try2
Seve
rity
of th
e pu
nish
men
t if c
orru
p-tio
n is
det
ecte
dSc
ale
1-10
Ac
cord
ing
to th
e cl
assi
cal p
rinci
pal-a
gent
theo
ry, t
here
are
thre
e fa
ctor
s th
at h
ave
the
grea
test
im
pact
on
corr
uptio
n: (1
) the
sev
erity
of t
he p
unis
hmen
t, (2
) mot
ivat
ion-
the
sala
ry, (
3) th
e sy
stem
mea
sure
s- th
e ris
k of
det
ectio
n). I
t is
nece
ssar
y to
det
erm
ine
the
rang
e of
pos
sibl
e pu
nitiv
e ac
tions
(crim
inal
liab
ility,
loss
of e
mpl
oym
ent).
A v
alue
of 1
mea
ns th
at th
e pe
nalti
es
are
very
hig
h an
d st
rong
ly d
isco
urag
e co
rrup
tion.
The
val
ue o
f 10
mea
ns th
at th
e pu
nish
men
ts
are
quite
sm
all a
nd th
ere
is n
o ge
nera
l kno
wle
dge
abou
t the
m.
3Le
vel o
f pro
tect
ion
for t
he c
orru
ptio
n de
tect
ors
Scal
e 1-
10
Crea
ting
a pr
otec
tion
syst
em fo
r the
cor
rupt
ion
whi
stle
blow
ers
and
dete
ctor
s co
ntrib
utes
si
gnifi
cant
ly to
figh
ting
the
corr
uptio
n. A
val
ue o
f 1 m
eans
that
pro
tect
ion
is v
ery
high
and
ev
eryo
ne in
volve
d is
aw
are
of it
. The
val
ue o
f 10
mea
ns th
at th
e pr
otec
tion
is s
mal
l - a
lmos
t no
n-ex
iste
nt a
nd it
is n
ot v
alue
d to
repo
rt th
e co
rrup
tion.
4Nu
mbe
r of c
ompl
aint
s re
late
d to
the
corr
uptio
n, fr
aud,
non
-tran
spar
ent
beha
vior
or c
onfli
ct o
f int
eres
ts.
Num
ber
per y
ear
This
indi
cato
r cov
ers
all c
ompl
aint
s an
d re
ports
rega
rdin
g co
rrup
tion
or fr
aud
(incl
udin
g co
m-
plai
nts
abou
t the
lack
of t
rans
pare
ncy,
cron
yism
, con
flict
of i
nter
est,
dive
rgen
t pra
ctic
es)-
re-
gard
less
of w
heth
er o
r not
they
are
just
ified
. Thi
s in
dica
tor c
an b
e as
sign
ed to
ano
ther
- bea
ring
the
num
ber o
f act
ions
take
n, w
hich
are
bas
ed o
n th
ese
com
plai
nts.
5Nu
mbe
r of i
ncid
ents
indi
cate
d by
the
cont
rol b
odie
sNu
mbe
r pe
r yea
rTh
is in
dica
tor c
over
s al
l of t
he fi
ndin
gs th
at re
late
to d
iverg
ent p
ract
ices
, lac
k of
tran
spar
ency
, cr
onyi
sm, e
tc.
6Tr
ansp
aren
cy in
dica
tors
- num
ber o
f pu
blic
pro
cure
men
ts%
Num
ber o
f the
mun
icip
al p
ublic
pro
cure
men
ts p
ublis
hed
on th
e In
tern
et to
the
tota
l num
ber o
f pu
blic
pro
cure
men
ts. I
t is
nece
ssar
y to
set
a v
ery
low
thre
shol
d fo
r whi
ch th
e pu
blic
dis
clos
ure
wou
ld n
ot b
e m
ade.
7Tr
ansp
aren
cy in
dica
tors
- num
ber-
publ
ic p
rocu
rem
ents
- mon
etar
y un
its%
Valu
e of
the
mun
icip
al p
ublic
pro
cure
men
ts p
ublis
hed
on th
e In
tern
et to
the
tota
l vol
ume
of
cont
ract
s.
27Model system of indicators for monitoring the corruption levels at sofia municipality
8Tr
ansp
aren
cy in
dica
tors
- num
ber o
f pu
blic
pro
cure
men
ts fo
r the
offi
ce%
Ratio
of t
he n
umbe
r of j
ob v
acan
cies
fille
d in
thro
ugh
an o
pen
tend
er a
cces
sibl
e to
all
appl
i-ca
nts
to th
e nu
mbe
r of t
otal
vac
anci
es.
9Tr
ansp
aren
cy in
dica
tors
– a
sset
s%
The
indi
cato
r mon
itors
the
trans
pare
ncy
in p
rope
rty m
anag
emen
t (sa
le, p
urch
ase,
leas
e, lo
an,
etc.
). It
is n
orm
ally
requ
ired
to d
iscl
ose
all o
f the
se in
adv
ance
on
the
notic
e bo
ard
and
on th
e In
tern
et. S
ome
mun
icip
al b
odie
s ca
rry
out t
his
task
in a
ver
y tra
nspa
rent
and
cle
ar w
ay a
nd
ofte
n be
yond
the
law
requ
irem
ents
(mor
e tra
nspa
rent
dis
clos
ure,
pub
licat
ion
in o
ther
med
ia).
The
indi
cato
r wou
ld m
easu
re th
e sh
are
of th
e pr
oper
ty m
anag
emen
t tha
t mee
ts th
e pr
edef
ined
ru
les
for t
rans
pare
ncy.
The
indi
cato
r mon
itors
all
of m
anip
ulat
ion
with
pub
lic p
rope
rty –
we
mea
sure
ratio
of a
ll ca
ses
and
case
s pu
blis
hed
on th
e in
tern
et.
10Tr
ansp
aren
cy in
dica
tors
– c
ontra
ctua
l re
latio
nshi
ps%
The
indi
cato
r mon
itors
the
trans
pare
ncy
in th
e di
sclo
sure
of c
ontra
cts.
In th
e Cz
ech
Repu
blic
, th
ere
is n
o ob
ligat
ion
for m
unic
ipal
ities
to p
ublis
h al
l sig
ned
cont
ract
s on
the
Inte
rnet
yet
(it i
s in
pre
para
tion)
. In
orde
r to
ensu
re tr
ansp
aren
cy, s
ome
mun
icip
aliti
es a
re a
lread
y do
ing
such
st
eps.
The
indi
cato
r wou
ld m
easu
re th
e %
of t
he c
ontra
cts,
whi
ch w
ere
publ
ishe
d on
the
inte
r-ne
t to
the
tota
l num
ber o
f con
tract
s. T
he d
iscl
osur
e ex
clud
es c
erta
in ty
pes
of c
ontra
cts
– e.
g.
empl
oym
ent c
ontra
cts.
Disc
losi
ng c
ontra
cts
prev
ents
us
to a
hig
h ex
tent
from
cor
rupt
ion
– pu
blic
pro
cure
men
t doc
u-m
enta
tion
does
not
incl
ude
final
dra
fts o
f con
tract
s, n
or th
e fin
al p
rices
tend
ered
.11
Tran
spar
ency
indi
cato
rs –
dis
cret
ion-
ary
gran
ts%
The
indi
cato
r mon
itors
the
trans
pare
ncy
in th
e al
loca
tion
of s
ubsi
dies
and
gra
nts.
Mun
icip
ali-
ties
in th
e Cz
ech
Rep.
allo
cate
dis
cret
iona
ry g
rant
s (e
spec
ially
to n
on-p
rofit
org
aniza
tions
) fro
m
thei
r bud
gets
. Mos
t mun
icip
aliti
es a
nnou
nce
the
calls
for p
roje
ct s
ubm
issi
ons.
How
ever
, som
e pa
rt of
the
subs
idie
s is
dis
tribu
ted
dire
ctly
(e.g
. by
the
Coun
cil o
r Ass
embl
y) u
pon
requ
est.
The
indi
cato
r will
mon
itor t
he %
of d
iscr
etio
nary
gra
nts
in m
onet
ary
units
dis
tribu
ted
on th
e ba
sis
of c
alls
to th
e to
tal a
mou
nt o
f dis
cret
iona
ry g
rant
s. A
ltern
ative
ly, th
e nu
mbe
r of g
rant
s ca
n be
ob
serv
ed a
s w
ell.
12Em
ploy
ees
train
ed a
nnua
lly o
n th
e to
pic
of c
orru
ptio
n%
Num
ber o
f em
ploy
ees
train
ed in
ant
i-cor
rupt
ion
beha
vior
to th
e to
tal n
umbe
r of e
mpl
oyee
s in
th
e or
gani
zatio
n.
28 Model system of indicators for monitoring the corruption levels at sofia municipality
III. INDICATORS OF CORRUPT BEHAVIOR
Indicators of corrupt behavior are not typical indicators. They are signs and warning signals that solely indicate a higher risk of corruption. Their higher presence does not represent any evidence or proof of corruption yet, but should lead to increased attention of colleagues and superiors. Therefore, in these cases it is advisable to step up the control mechanisms, by undertak-ing unannounced inspections at the work place or by conducting additional checks of a person’s income and property.15
Indicators in this group refer to the following three areas:
a) Group one comprises indicators which are designed to identify cor-rupt behavior in personal contacts. The following sub-indicators also have to be taken into account: contacts with companies and suppliers; style of life and patterns of decision-making; behavior at the work place, involvement in out-of-work activities.
a.1.) In the determination of the indicator “contacts with companies” it is important to gather information about unlawful contacts with sub-contractors, suppliers of business representatives, which could raise doubts about the loyalty and trustworthiness of the employee. Frequent personal meetings with any of the agents referred to above, close per-sonal contacts between the employee and representatives of compa-nies, invitations to lunches or dinners, company parties or seminars are all indications about possible corrupt behavior.
a.2.) The indicator „style of life” presupposes a lavish style of life, ex-pensive hobbies inconsistent with the person’s actual income, changes in the behavior (for instance, self-isolation from colleagues); weak-nesses in character (e.g., gambling), driving expensive automobiles, receiving special offers from one or more companies, etc.
15 This group of indicators has been successfully applied by the municipality of Vienna.
29Model system of indicators for monitoring the corruption levels at sofia municipality
a.3.) With regard to the indicator „decision-making” we have to consider incidents like the following:
y unauthorized intervention on behalf of a company,
y recommendations on behalf of a company or advice against it,
y rejection of a company,
y unjustified change of opinion,
y unfounded decisions,
y repeated favoring of a company or offers of reducing the expens-es of a company,
y appeal to non-regulated procedures,
y attempts to reach concrete solutions in the process of negotia-tions with companies, etc.
a.4.) For the indicator „involvement in out-of-work activities” the moni-toring bodies should pay attention to consulting services, agreements which may become confidential, developing work relations with the companies linked to the office, hiring persons known to be connected to these companies, etc.
b) The second group is comprised of indicators designed to detect corrupt behavior in the municipal administrative procedures. Тhey can be described on the basis of several sub-indicators: general administrative procedures, public procurement and organizational structure of the municipality.
b.1.) For the indicator „general procedures” of significance is the infor-mation about:
y unjustified reduction in the number of public procurement bids,
y violations of legal procedures,
y conflicting decisions on similar cases involving different candi-dates/companies,
y extending or speeding up deadlines and decisions on contracting,
30 Model system of indicators for monitoring the corruption levels at sofia municipality
y sudden changes in the agenda,
y time pressure,
y last minute decisions,
y differences in the interpretation of the legal procedures and the contents of the accompanying documentation.
b.2.) With respect to public procurement bids, specific attention should be paid to the following:
y changes in the contract at variance with the initial offer,
y speeding up the process of contracting,
y violations or avoidance of the regulations for contracting.
b.3.) As concerns the indicator „оorganizational structure of the munic-ipality” red flags are, for example, the concentration of tasks in one employee, lack of transparency, lack of efforts/reluctance to introduce anti-corruption measures.
c) The third group includes indicators designed to detect corrupt behavior in relation to the external environment.
For this set of indicators the following activities must be taken into account:
y information about expensive gifts,
y sponsorships,
y unexpected rise in the expenditures,
y changes in the price of supplies,
y unannounced public procurement bids, thus favoring cartels,
y long-term relations with suppliers,
y receiving unusually expensive gifts inconsistent with the position of the recipient,
y inside information benefitting a specific company, etc.
31Model system of indicators for monitoring the corruption levels at sofia municipality
The three groups of indicators require that the oversight and control bodies in the municipality monitor more closely the work of the municipal officers. It may be hard at times to distinguish between the personal and the professional conduct of the employees (for example, personal life style, stereotypical behavior, sudden wealth, which may be lawfully acquired, contacts with other people.) Information like this, which is necessary for the definition of the indicators, can be received from corruption investigations or corruption reports from employees or citizens, as well as drawing upon similar experience in other cases. These are not the core indicators required to determine the corruption risk, but they can supplement the data in the other indicator groups or offer explanations about processes which could not otherwise be associated with corruption risks in the municipality.
32 Model system of indicators for monitoring the corruption levels at sofia municipalityTa
ble
5: In
dica
tors
of t
he c
orru
pt b
ehav
ior
Area
of i
ndic
atio
nGr
oup
Desc
riptio
n of
the
beha
vior
- exa
mpl
es
1) Indi
catio
n of
the
corr
upt b
ehav
ior i
n pe
rson
al c
onta
ct
1.1
Cont
act w
ith s
up-
plie
rs/
com
pani
es
• in
form
al a
gree
men
ts w
ith c
ompa
nies
inst
ead
of w
ritte
n ag
reem
ents
• fre
quen
t per
sona
l con
tact
with
sup
plie
rs a
nd b
usin
ess
repr
esen
tativ
es•
frequ
ent v
isits
to re
stau
rant
s an
d fre
quen
t tra
vel t
o em
ploy
ees
of th
e co
mpa
ny•
rece
ivin
g an
invi
tatio
n to
cor
pora
te p
artie
s w
ithou
t job
dut
ies
1.2
Life
styl
e
• ex
pens
ive li
fest
yle
or e
xpen
sive
hob
bies
in c
ontra
st to
the
actu
al in
com
e•
chan
ges
in b
ehav
ior (
e.g
. tra
nsiti
on to
the
isol
atio
n an
d de
tach
men
t )•
pers
onal
wea
knes
s•
the
use
of e
xpen
sive
car
s, d
istri
bute
d by
one
com
pany
• sp
ecia
l offe
rs (e
.g. h
olid
ays)
from
one
com
pany
1.3
Deci
sion
mak
ing
• un
just
ifiab
le in
terv
entio
n in
favo
r of o
ne c
ompa
ny•
reco
mm
endi
ng a
spe
cific
com
pany
, or v
ice
vers
a to
sup
pres
s a
parti
cula
r com
pany
• qu
ick
chan
ge o
f min
d / a
ttitu
de•
unju
stifi
able
dec
isio
ns o
f all
kind
s•
repe
ated
unj
ustif
ied
prov
isio
n of
exc
eptio
nal t
erm
s of
con
ditio
n or
forg
ivene
ss o
f the
cos
ts fo
r the
pa
rticu
lar c
ompa
ny•
utiliz
atio
n of
the
unor
dina
ry p
roce
dure
s w
ithou
t obv
ious
reas
ons
• st
rikin
g ap
peas
emen
t in
nego
tiatio
ns w
ith c
ompa
nies
1.4
Wor
k be
havi
or
• sp
endi
ng to
o m
uch
time
at w
ork,
refu
sing
vac
atio
n•
hand
ling
som
e bu
sine
ss m
atte
rs a
t hom
e•
impe
ding
job
cont
rol t
o th
e su
perv
isor
or r
epre
sent
ative
s•
exce
ssive
lack
of i
nter
est o
r exc
essi
ve w
ork
(wee
kend
s in
the
offic
e)•
refu
sal t
o tra
nsfe
r to
anot
her p
ositi
on, e
ven
in th
e ca
se o
f pro
mot
ion
1.5
Ext
ra a
ctiv
ities
• co
nsul
tatio
ns, a
gree
men
ts, w
hich
may
give
a ri
se to
the
conf
iden
tial r
elat
ions
• w
orki
ng re
latio
nshi
ps w
ith c
ompa
nies
rela
ted
to th
e of
fice
• th
e em
ploy
men
t of p
erso
ns fr
om c
ompa
nies
, who
are
clo
se to
the
offic
e
33Model system of indicators for monitoring the corruption levels at sofia municipality
2)
Indi
catio
n of
the
corr
upt b
ehav
ior
in m
unic
ipal
pr
oced
ures
2.1
Gene
ral m
unic
ipal
pr
oced
ures
• un
just
ified
sho
rteni
ng o
f the
pub
lic p
rocu
rem
ent
• fa
ilure
to re
spec
t leg
al p
roce
dure
s•
diffe
rent
dec
isio
ns o
n th
e sa
me
subj
ect a
t diff
eren
t app
lican
ts/ c
ompa
nies
• ac
cele
ratio
n or
stre
tchi
ng o
f im
porta
nt d
ecis
ions
, sud
den
chan
ges
in p
riorit
ies
• cr
eatin
g tim
e pr
essu
re, d
ecis
ions
just
bef
ore
the
dead
line
• di
ffere
nces
bet
wee
n th
e ac
tual
con
duct
of t
he p
roce
edin
gs a
nd s
ubse
quen
t doc
umen
tatio
n
2.2
Publ
ic p
rocu
rem
ent
• no
ticea
ble
shift
of t
he c
ontra
ct fr
om th
e or
igin
al p
rice
offe
r•
acce
lera
tion
of th
e pr
ocur
emen
t pro
cess
• ci
rcum
vent
ion/
bid
avoi
danc
e •
depa
rture
from
nor
mal
pro
cedu
res
in th
e pr
ocur
emen
t pro
cess
2.3
Orga
niza
tiona
l st
ruct
ure
of th
e m
unic
ipal
ity
• co
ncen
tratio
n of
the
task
s to
one
per
son
• la
ck o
f tra
nspa
renc
y•
unpr
epar
edne
ss /
unw
illing
ness
to e
nfor
ce a
nti-c
orru
ptio
n m
easu
res
3) Indi
catio
n of
the
corr
upt b
ehav
ior
in re
latio
n to
th
e ex
tern
al
envi
ronm
ent
• co
stly
pro
mot
iona
l gift
s•
spon
sors
hip
• un
expl
aine
d de
viat
ions
from
the
prev
ious
ly e
stim
ated
cos
ts, c
hang
es in
the
supp
ly p
rices
• to
o qu
iet p
rocu
rem
ents
bec
ause
of t
he c
arte
ls•
long
-term
bus
ines
s re
latio
nshi
ps w
ith s
uppl
iers
• su
spic
ious
val
uabl
e gi
fts d
urin
g oc
casi
ons,
inad
equa
te to
the
posi
tion
of th
e re
cipi
ent
• un
expl
aine
d in
form
atio
n ad
vanc
e of
som
e co
mpa
nies
34 Model system of indicators for monitoring the corruption levels at sofia municipality
Conclusion
The methodology for corruption risk assessment enables us to develop a comprehensive system for risk assessment and prevention of corruption ac-tivities in the central or local government. Provided that it is consistently and effectively implemented, a well-defined and well-designed system will ensure the required level of transparency in the administrative procedures and work, the prevention of corrupt behavior and activities, as well as will tackle exist-ing or potential corruption schemes.
The introduction of this system will equip the municipal administration with an effective internal mechanism for fighting corruption, at the same time en-able the municipality to conduct ongoing corruption risk assessment so as to avoid potentially high damage to its public image. Successful implementation of the system relies on several sets of indicators adapted to the needs of the municipal administration and taking into account both the general man-agement practices of the institution and the operations of each department/section. A corruption monitoring report that uses these indicators must be prepared at least once per year, in order to compile data for longitudinal sur-veys and analyses, as well as further improvements of the system. As it was mentioned above, for the system to function successfully, it is very important to integrate anti-corruption training modules, including on the anti-corruption indicators, in the annual training and development program of the municipal HR department. Such training will contribute greatly to the employee’s exper-tise and knowledge in detecting and preventing corruption in the municipal administration and their daily communication with citizens.
35Model system of indicators for monitoring the corruption levels at sofia municipality
Annex 1: DETERMINING THE INDICATOR FOR FREQUENCY OF OCCURRENCE (EXAMPLE)
In 2013 Sofia Municipality organized 257 public procurement tenders and 103 direct contracting procedures with suppliers. The total number of the public procurements for the year is 360.
Using the scale for the frequency of occurrence (see Table 6 below), we can calculate the indicator, i.e. the probability for the occurrence of the corruption activity. This will show us the potential risk, regardless of whether this activ-ity has been identified or not as corruption. The number of procurements per year falls in the range of <100-499>, with an indicator point value of 8 for the frequency of occurrence. This means that the public procurement proce-dures represent an area with a very high risk for potential corruption activity.
36 Model system of indicators for monitoring the corruption levels at sofia municipality
Table 6: The range of frequency of occurrence
Occurrence - the in-cidence of corruption
opportunities
Points (indica-
tor)
CriterionOpportunity of corruption occurs:
Very high and repeating 10usually several times a day, repeat-edly, annual frequency is higher than 1000
Very high 9daily, annual frequency is in the range <500-999>
High 8usually daily, annual frequency is in the range <100-499>
Higher 7weekly or several times per week, the annual frequency is in the range of <52-99>
Intermediate - higher 6approx weekly, yearly frequency is in the range of <20-52>
Intermediate 5approx monthly, yearly frequency is in the range <5-19>
Intermediate – lower 4Every year, the annual frequency is in the range of <1-4>
Low 3less often than once a year, but more often than every 5 years
Very low 2 approx once every 5 years
Insignificant 1probable or almost certain, that the opportunity doesn´t occur
37Model system of indicators for monitoring the corruption levels at sofia municipality
Annex 2: SAMPLE QUESTIONNAIRE TO COLLECT INFORMATION REQUIRED TO DETERMINE THE INDICATOR FOR MONITORING OF CORRUPTION RISKS
Тhematic priority Public procurement
1. Total number of public procurement procedures in the municipality
Per year Per month
Tenders
Direct contracting (single source procurement)
2. Total value of the public procurement bids in the municipality
Per yearPer month
Tenders
Direct contracting
3. Average monthly salary for: Per month
Management/expert personnel in the department
Administrative personnel in the department
4. Average salary for the municipal administration
Per month
5. What percentage of the budget for public procurement comes from European funds?
2013 2014
Total value of public procurement per year
% funded with EU money
6. Is there a system for reporting irregulari-ties and corruption (by the citizens and the employees)? If yes, how many reports have been filed?
2013Number of
reports
2014Number of
reports
Reports filed by citizens
Reports filed by municipal employees
7. Are there procedures (internal rules) for handling such reports?
Yes No
By citizens
By municipal employees
38 Model system of indicators for monitoring the corruption levels at sofia municipality
8. How many cases for public procurement violations have been detected and how many of them have been submitted to the investigation/prosecution office?
2013 2014
Number of detected violations
Number of cases filed with the prosecution
9. What types of penalties have been im-posed?
Number for 2013
Number for 2014
Disciplinary actions
Criminal liability
10. Is there a whistleblower protection sys-tem in the municipality?
Yes No
11. Are there instructions/internal rules/ and a separate document filing and handling system for the protection of whistleblow-ers/people who have filed reports?
Yes No
12. How many complaints/reports for cor-ruption/fraud/conflict of interests have been filed?
2013 2014
By citizens
By municipal employees
13. How many inspections have been carried out for irregularities/corruption/fraud/conflict of interests?
2013 2014
Total number
Linked to public procurement
14. Does the municipality conduct anti-corruption training for the employees? If „yes,“ how many trainings have been conducted and for how many employ-ees?
Yes(number)
No
Number of trainings
Number of employees who have received anti-corruption training