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Integrity Policy,
Flemish government authorities
OECD, 24th March 2015
Working Party of Senior Public Integrity
Officials (SPIO)
Session 3 Implementation at the organisational
level
About me
• Degrees: Dutch & English,
Medieval Studies, Business
Communications, Italian Studies
• September 2002: started working
for Flemish Government Autorities
• October 2010: Integrity Officer
• Chairwoman Integrity Office
• 2 co-workers: Josefien De Wachter
(integrity policy assistant) &
Annelies Antheunis (policy well-being
at work)
www.bestuurszaken.be
My organization:
Flemish government authorities
Flanders: Dutch-speaking northern part of Belgium. Selfgoverning region with its own parliament and government.
Flemish government authorities:
27,547 employees (2014, scope integrity)
13 policy domains (to be reduced to 11)
72 entities
158 locations Belgium + 73 abroad (49 countries)
Integrity policy at Flemish
government authorities
Genesis: aftermath credit card scandal city of Antwerp
2005: Flemish government decides to build proper
integrity policy + appointment integrity officer
(founding internal audit, Ombudsman)
2006: first integrity officer, second code of conduct
2006-2010: many key players, initiatives, roles… but
no integrated policy or approach
15th March 2012: official start Integrity Office
Very broad definition & scope
proper use of means
+ proper behaviour towards people (well-being,
equality, non-discrimination)
personnel + organisation
Founded on 3 pillars
Prevention
Detection/Control
Reaction/Sanction
-> balance in 3 pillars
+ Multidisciplinary approach
(4th pillar needed: aftercare)
Multidisciplinary approach
Internal
audit
Ombuds
Service
Complaints
management
Wellbeing
Diversity
Integrity
Rules &
Regulations
Social
service
s
HR
Proces flow (linking 3 (4) pillars)
Prevention
Detection
Evaluation
Reaction
Aftercare
Wide array of instruments
Instruments
Competent division
Pillar
Code of conduct, ICT code
Integrity Officer (et al)
Prevention, control
Dilemma training, train the trainer, made
to measure advice
Agency for government personnel
(training & support)
Prevention
Management code
Agency for government personnel
Prevention, control
Unique centre of complaints (Spreekbuis)
(virtual) Integrity Office
Detection
Guidelines integrity policy for entities
(maturity scoring)
Interal Audit
Prevention (control,
detection)
Manual identification vulnerable functions
Integrity Officer
Prevention
Detection audits (based on fraud risk
analysis)
Internal Audit
Detection (prevention)
Forensic audits
Internal Audit
Reaction
Whistleblowers protection act
Ombudsman
Detection
Personnel charter Flemish government
authorities/ employment contracts
Management
Reaction
HR instruments: personnel questionnaire,
bottom up evaluation, competence
management
Management
Prevention
Relevant rules and regulations
EU legislation, federal & Flemish
governments, entities
Prevention
Many key-players
central and in entities
different: responsibilities & competences
Central key players
Players in entities
Integrity Officer
Integrity contact persons
Internal Audit
Managers
Organisational development experts
Ombusman
Complaints managers
Social Services
Trusted intermediaries
Well-being at Work
Diversity
Diversity contact persons
Training and Education
HR experts
706 HRspecialists
84 integrity
contact persons
240 superiors
89 trusted
intermediaries
8 social
services experts
1 Integrity officer
26 well-being
experts
6 forensic
auditors
1 Ombudsman
Integration central key players &
instruments: (virtual) Integrity office
Main goals: integrity – 3 pillars: prevention,
detection, reaction /sanction
Standard activities (core activities):
Policy advice
Developing integrity tools
Measuring and evaluation of policy results
Centre of integrity expertise
Communications
Main projects & results to date
3rd version code of conduct (communications
campaign) 2011 + ICT code of conduct 2014
Central point of contact to report wrong doings
(Spreekbuis + 1700)
Uniform registration cases (online application)
Internal network integrity contact persons
1st integrity network event 10/4/2014
(210 attendants)
Regular network gatherings
(twice a year)
From central policy to entity practice
Integrity practice in entities: responsability of top
manager
Internal Audit: audit screenings on 10 themes incl.
integrity -> resulting in ‘maturity’ scoring and
advice/recommendations for improvement
Results reported to competent ministers
and part of appraisal top managers
Follow up of advice/recommendations
Internal Audit
-> often on integrity policy & plan of action
(support by Integrity officer and relevant experts)
Towards local governments
(cities and municipalities)
Municipality decree, article 112: all cities and
municipalities must have code of conduct
Since 1st January 2014: Internal Audit conducts audits
at local governments (same as at Flemish government
authorities)
More and more local governments turn to
Integrity officer for advice and support
Challenges & wishes
Challenges
No judicial framework (professional secrecy vs discretion)
No budget (only 2 full time employees for integrity policy
and coordination)
Scope & delimitation/professional boundaries (many
players)
Commitment
Wishes
4th pillar: aftercare
Project career long integrity (ethical leadership)
Measuring results (parameters)
Contact
[email protected]
www.bestuurszaken.be/integriteit
http://governance-flanders.be/integrity-0
[email protected]
Tel +32 499 77 20 88
Twitter: @javamoka
LinkedIn: be.linkedin.com/in/kristienverbraeken