Online Drafting of Integrity Plans (BA0002)

Which public issue will be addressed by this obligation?
Getting acquainted with risk situations that can contribute to undermining institutional integrity and suggesting how to avoid said situations in the future. In April 2018, the Agency prepared and published the draft Guidelines for drafting and implementation of integrity plans in BiH institutions, thus initiating the second cycle of drafting integrity plans. In order to facilitate the institutions accessing the creation of the document and at the same time modernize the self-assessment process that is being done in this way, access to the creation of a web application for online drafting of integrity plans will make this process quicker and easier. People who will be in charge of drafting integrity plans will undergo the necessary training by employees of the Agency.

What is the obligation?
Web platform created and installed in BiH institutions, coordinators trained to use platforms. The second cycle of drafting integrity plans in BiH institutions has been successfully completed.

How will the fulfilment of the obligation contribute to the solving of the public problem?
In a single document (electronic format document), the institution will have a complete list of risks threatening to undermine the integrity of the institution and propose measures to minimize defined risks. Realizing the proposed measures to improve integrity in practice strengthens the confidence of citizens and the general public in the work of public institutions.
Given that the integrity plan is a preventive anti-corruption mechanism whose purpose is not to solve individual cases of corruption but establishing mechanisms that will influence the reduction of the risk of corruption and other irregularities in all areas of functioning of the institution, by electronic drafting and by the publication of this document of public institutions will affect solving the problem of corruption in society.

Why is this obligation relevant to OGP values?
When making a document, objective self-assessment is important, ie relevant and realistic identification and risk analysis, assessment of their intensity and suggesting adequate measures to reduce the risk. Objective self-assessment does not imply recognition of the existence of corruption or other irregularities in the institution but of the perception and identification of opportunities and disadvantages that may lead to corruption and other irregularities in the work of the institution. Given that the document should be public, thus are fulfilled obligations such as: disclosing information and improving the availability of information to the public or providing the right to information, creation or improvement of rules, regulations and mechanisms in order to make civil servants responsible to the public for their actions.

Additional information
• The obligation to develop integrity plans stems from the Anti-Corruption Strategy 2015-2019 and the accompanying Action Plan.

Goals/activities
Creating a Web Platform
Creating and publishing manuals for web platform use, training of coordinators, test phase of web application
Installing a software in institutions of BiH, on-line drafting of integrity plans

2. Development of a web platform for online drafting of integrity plans in institutions

Main Objective

"Getting acquainted with risk situations that can contribute to undermining institutional integrity and suggesting how to avoid said situations in the future. In April 2018, the Agency prepared and published the draft Guidelines for drafting and implementation of integrity plans in BiH institutions, thus initiating the second cycle of drafting integrity plans. In order to facilitate the institutions accessing the creation of the document and at the same time modernize the self-assessment process that is being done in this way, access to the creation of a web application for online drafting of integrity plans will make this process quicker and easier. People who will be in charge of drafting integrity plans will undergo the necessary training by employees of the Agency.

• Web platform created and installed in BiH institutions, coordinators trained to use platforms. The second cycle of drafting integrity plans in BiH institutions has been successfully completed."

"In a single document (electronic format document), the institution will have a complete list of risks threatening to undermine the integrity of the institution and propose measures to minimize defined risks. Realizing the proposed measures to improve integrity in practice strengthens the confidence of citizens and the general public in the work of public institutions.

Given that the integrity plan is a preventive anti-corruption mechanism whose purpose is not to solve individual cases of corruption but establishing mechanisms that will influence the reduction of the risk of corruption and other irregularities in all areas of functioning of the institution, by electronic drafting and by the publication of this document of public institutions will affect solving the problem of corruption in society."

Milestones

"2.1.Creating a Web Platform.

2.2. Creating and publishing manuals for web platform use, training of coordinators, test phase of web application.

2.3. Installing a software in institutions of BiH, on-line drafting of integrity plans."

Editorial Note: For the complete text of this commitment, please see Bosnia and Herzegovina's action plan at https://www.opengovpartnership.org/documents/bosnia-and-herzegovina-action-plan-2019-2021/.

Commitment Analysis

The commitment aims to support development and adoption of the second phase of integrity plans in all institutions in the country through a web platform, which should facilitate and speed up this process. The integrity plan is a preventive internal mechanism based on the results of an institution's self-assessment of the risks of corruption, corrupt acts, and other forms of irregularities and unethical and unprofessional behavior. It does not resolve individual cases of corruption. [16]

The Anti-Corruption Strategy of Bosnia and Herzegovina 2015–2019 and its accompanying Action Plan [17] outline development and adoption of four-year integrity plans in all public institutions at all levels of government in the country. So far, a majority of public institutions in the country have developed their integrity plans, including the judiciary. [18] However, during this process, legal gaps were noticed, such as ambiguities in definitions and missing information, [19] and in 2018, the new rules on development and implementation of integrity plans were adopted. [20] Considering the need to improve the existing procedure and the expiration date of already existing integrity plans, the second phase of development of integrity plans is foreseen. For this purpose, the commitment aims to implement a software application that should facilitate and harmonize this process across institutions. It would guide public officials and civil servants in all phases of integrity plan development as formulated by the rules: Phase 1) Adoption of decision on developing the integrity plan and development of a workplan of the working group for the development of the integrity plan; Phase 2) Risk identification, risk factor analysis, and risk intensity assessment, which includes deployment of a survey among all employees in the institution; Phase 3) Propose measures to improve integrity, prepare a report on the state of integrity in the institution, and draft the integrity plan; and Phase 4) Adoption of the integrity plan, monitoring of its implementation and submission of an annual report to the agency and other relevant authorities. [21] The guidance and accompanying materials have been developed already but would be transitioned onto the software to make the whole process automated.

Institutions are obliged to publish their four-year integrity plans on their websites after they are adopted and report annually on their implementation to the agency. [22] This does not always happen, and the software solution in this commitment does not address this nor enable individuals to see whether institutions have published the plans on their websites.

Through phase 2, public institutions raise awareness of corrupt behavior and potential risks, formalize anti-corruption procedures, and openly commit to a set of internally defined measures that should mitigate potential risks and foster good governance practices. Compared with the earlier approach, this process aims to engage all employees of the institution through the survey but does not entail engagement with the public. [23] The software aims to assist the agency and institutions in harmonizing the process across different levels of governments and automate the monitoring and reporting tasks. [24]

Implementation of this commitment is primarily related to the OGP value of public accountability because it seeks to streamline the process of this anti-corruption mechanism. The commitment is coded as having no potential impact because it will only streamline and harmonize the process of developing integrity plans across public institutions rather than change the process at all. [25] It is not clear how the plans would be used to raise awareness of corruption risks inside institutions or improve anti-corruption mechanisms, reducing potential impact. Furthermore, while the information in the reports is part of extensive annual institutional reports, the absence of requirements to publish the integrity reports themselves makes the whole process obscure to the public and thus limits potential impact. [26] To have minor or even moderate impact, implementation needs to mandate the publishing of these Integrity Plans and provide mechanisms that give citizens and civil society organizations the opportunity to provide input and feedback.

Commitment 2. Development of a web platform for online drafting of integrity plans in institutions

Limited:

Although software for the web platform was developed, deployment of the platform did not occur since the Agency for the Prevention of Corruption and Coordination against Corruption of BiH could not secure external funding to purchase a host server. [14] The platform would include an interactive template for integrity plans, which could be adjusted to the needs of different institutions. [15] Training coordinators for integrity plans has not been implemented. [16] No significant progress has been made beyond planning for a testing phase and creating a user manual for the platform. [17]