Community of Practice for Anti-Corruption and Transparency (IT0075)

What is the problem that the commitment will address? There is a general need for sharing and exchanging experiences, as well as for places of collaborative learning between actors, the corruption and transparency prevention officers, the anti-fraud officers and the 'managers' of suspicious transaction reports under the antimoney laundering regulations, who play a key role in the implementation of decentralised prevention strategies and in enabling better synergy and integration between them. In addition, t he effective management of whistleblowing and support to potential whistleblowers, as well as the proper fulfilment of the duties of reporting suspicious transactions under the anti-money laundering regulations, represent, in the implementation phase of the NRRP, crucial activities for monitoring the quality of works and services, the cost-effectiveness of expenditure, the integrity of procedures, and in general the presence of anomalies, conflicts of interest, and corruption. To this end, the competencies of those who handle reports (RPCT) should be strengthened, as well as the knowledge of civic services to support people who experience the reporting dilemma. The sharing of practices, experience and methodologies between the RPCTs and the 'managers' of STRs within administrations should also be strengthened.

What is the commitment? 21 The commitment entails a networking of actors relevant to the implementation of corruption prevention strategies in Italy, able, in the implementation phase of the National Recovery and Resilience Plan (NRRP), to support the main actors of corruption prevention (the Heads of Corruption Prevention) in addressing the challenges that the implementation of the NRRP poses to their institutions.

How will the commitment contribute to solving the problem? 2.02.1 Networks supporting the persons in charge of the prevention of corruption (RPCT) Creation, by the National School of Administration (SNA), of an inter-institutional PRACTICE COMMUNITY of the persons in charge of the prevention of corruption, open to the contributions of the CSOs and in synergy with the Forum of the RPCTs established at ANAC. Taking into account the evolution of the sector's legislation, the community of practice aims to: ● promote and test prototypes of participatory Integrated Activity and Organization Plans (PIAOs introduced by Article 8 of Decree-Law No. 80 of 2021), that are participatory, with particular reference to the PAs implementing the NRRP, also on the basis of the National Anti Corruption Plan (NAP) indications ● innovate training and skills development models in order to improve the quality of training plans, focusing on the relational aspect of corruption risk and the approach based on concrete cases and ethical dilemmas; ● contribute to the development of a model for assessing and managing the risk of interference by interest groups in the NRRP implementation phase; ● enhance the interrelations and synergies between the functions of the RPCT and the 'manager' of suspicious transaction reports for anti-money laundering purposes. 2.02.2 Support for the management of reports ● Following the establishment of the PRACTICE COMMUNITY of the persons responsible for the prevention of corruption, exchanges of experience will be promoted and training courses will be organised to increase the knowledge and strengthen the skills of the RPCTs handling reports and enhance the comparison with other figures also responsible for the protecion of integrity . ● Innovative training models for managing whistleblowing will be promoted. ● Innovative training models to increase awareness of the institution among public employees.

Why is this commitment relevant to OGP values? 22 The commitment is relevant to public accountability because it calls upon institutional actors and civil society organisations to set and ensure high standards in the implementation of decentralised corruption prevention strategies.

Activities Activities Start date End date Awareness and communication activities aimed at the involvement of RPCTs in the Community of Practice and the dissemination of products in synergy with ANAC. 1st May 2022 1st May 2023 Within the Community of Practice, activation of participatory workshops with CSOs on, for example: Participatory PIAOs, training plan, transparency of relations between public decision makers and interest groups, other working groups of interest to the community and production of the groups' deliverables, in synergy with the RPCT Forum established at ANAC. 1st of July 2022 31st of December 2023 Within the Community of Practice established through action 2.02.1, a working group dedicated to the 'management of reports' will be created with the aim of producing deliverables. 1st of September 2022 31st of October 2023

Action Plan Review

Commitment 2.02: Community of practice of those responsible for the prevention of corruption and transparency

● Verifiable: Yes

● Does it have an open government lens? Yes

● This commitment is clustered as: Cluster 2 – Corruption prevention and culture of integrity (Commitment 2.01 and Commitment 2.02)

● Potential for results: Modest

Commitments 2.01 and 2.02: Corruption prevention and culture of integrity

National Anti-Corruption Authority (ANAC), National School of Administration (SNA); Banca d’Italia (UIF), CONSIP, Court of Auditors, Ministry of Foreign Affairs, Ministry of Economy and Finance, Ministry of Justice, Ministry of Education, Ministry of Economic Development, DFP, Department of Cohesion Policies (DPCoe), Liguria Region; Fondazione Etica, Libenter, Libera, Osservatorio Civico PNRR, The Good Lobby, Transparency IT, Re-act

For a complete description of the commitments included in this cluster see Commitments 2.01 and 2.02 in Italy’s 2022-2023 Action Plan (original and amended versions): https://www.opengovpartnership.org/documents/italy-action-plan-2021-2023-december/

Context and objectives:

Corruption continues to be a key area of attention for Italy. Recent Eurobarometer surveys on public and business attitudes towards corruption highlight that the perception of widespread corruption remains high, as indicated by 89 percent of individual respondents [23] and 92 of businesses, respectively. [24] Gaps and challenges remain in key areas of the legislative and regulatory framework. For example, although Italy adopted a whistleblower protection law in 2017, [25] the country has yet to transpose Directive 2019/0366/EU on Whistleblowers, which it was supposed to do by December 2021. [26] The Directive would introduce higher standards and more robust safeguards for whistleblowers, broaden the scope of misconduct that could be reported, and enlarge the spectrum of individuals who may file a report.

Monitoring reports by ANAC also highlight the need to strengthen the skills of public officials for monitoring, identifying, and addressing corruption risks within PAs. [27] Smaller PAs in particular experience more challenges in identifying corruption risks. [28] With regard to whistleblower protection, ANAC’s latest report to the Italian Parliament indicated that it opened more than 513 case files on reported whistleblower cases in 2021; 105 reports concerned alleged retaliatory measures against whistleblowers. [29] According to a recent Transparency International report, ANAC triggered sanctions in only three of these cases. [30] In June 2021, ANAC updated its guidelines for the protection of whistleblowers within public administrations. [31]

The COVID-19 pandemic has exacerbated corruption risks, both in sectors traditionally vulnerable to corruption such as public procurement as well as in areas more specifically tied to the pandemic itself, such as the distribution of personal protective equipment and abuse of access to personal clinical data. [32] Both government and civil society actors expressed significant concerns about the possible infiltration by organized crime in the legal economy through corruption following the disbursement of the PNRR funds, and have called for increased transparency on the management of these funds [33]. As part of the effort to strengthen anti-corruption safeguards in this area, the Bank of Italy has requested that each PA appoint a ‘manager’ responsible for monitoring interventions financed via the PNRR and submit Suspicious Transaction Reports (STRs) to the Financial Intelligence Unit (FIU) [34].Against this background, the networking component of this cluster seeks to bring together relevant actors for the prevention of corruption to promote the greater involvement of civil society in corruption prevention; strengthen RPCT’s skills through dedicated training; and foster the exchange and dissemination of national and international best practices. This is done, inter alia, through the creation of a multi-stakeholder Task Force led by the National Anti-Corruption Authority (ANAC) and of a Community of Practice of RPCTs. Particular attention is placed on identifying and promoting approaches that can facilitate the prevention of corruption and anti-money laundering throughout the implementation of the PNRR.

To strengthen support for whistleblowers, the commitments include activities to raise awareness on the existence of whistleblower support services implemented by CSOs. PA and CSO representatives stated that the components of this cluster related to whistleblowing originate from a direct request of CSOs, and that there is a need to enhance the provision of support to potential whistleblowers during the early stages of the process. [35] Only two organizations currently officially provide early-stage guidance in Italy – Libera and Transparency International. [36] It is not a formally recognized service by ANAC or the national anti-corruption framework which, according to interviewees, contributes to limiting awareness among would-be whistleblowers of the existence of this service. [37]

The IRM notes that the two commitments included under this cluster are the ones which have been most significantly revised in the amended version of the action plan. The main changes have been made to structure of the commitments, [38] and Commitment 2.01 now also includes a component on reinforcing anti-money laundering safeguards within public administrations, in particular in the implementation of the PNRR. Written feedback from the OGP Task Force confirms that the changes were made in agreement with all parties involved in implementation. [39]

The IRM considers that the dilution of activities resulting from this updated structure weakens the potential impact of the two commitments, if taken individually. For clarity purposes, this analysis will treat activities related to the creation of networks and communities of practices as part of one individual component, and those related to whistleblower protection, considered as the most promising ones, as part of another.

Potential for results: Modest

Corruption prevention remains a key area of attention for Italy, in particular with a view to ensuring an appropriate and transparent management of the funds disbursed via the PNRR.

However, the IRM notes that commitment components related to the Task Force and the Community of Practice are vague, which makes it challenging to assess concrete activities and expected outputs, as well as the potential for results. Interviewed representatives from PAs and CSOs confirmed that there was no concrete plan on what the newly-created Task Force led by the National Anti-Corruption Authority (ANAC) and Community of Practice of RPCTs would look like when the action plan was first created (although it is being discussed through a structured process as implementation progresses). [40] There is also limited clarity on how to ensure synergies rather than overlap with existing mechanisms (such as the Forum of RPCTs). [41] A civil society representative confirmed that while ANAC is responding to civil society’s needs, there are concerns that the results are more likely to be a proliferation of several structures (e.g. Task Force, Community, etc.) rather than concrete outputs. [42] ANAC representatives highlighted their intention to use the Task Force as a way of coordinating active involvement of civil society in the national anti-corruption strategy, requesting input on subjects to be dealt with in the early stages of the drafting process. Following through with this novelty in the process for drafting the strategy could be a considerable result considering the limited opportunities civil society has had to influence the development of national anti-corruption strategies in the past. [43]

Other activities aim at facilitating the networking between actors responsible for the prevention of corruption and appointed managers of STRs, including through the exchange of best practices. The commitment could benefit from a more detailed description of what activities “sensitizing public offices to the adoption of [anti-money laundering] safeguards” entail. Recent reports have highlighted how local public administrations (i.e., regions, provinces, and municipalities), who are for the most part responsible for the implementation of interventions financed under the PNRR, have a deficient and very limited anti-money laundering prevention system. [44] Training activities specifically targeting these actors could therefore contributing to increasing the potential impact of this commitment.

The most promising components of this cluster remain those related to whistleblower support, split in commitment 2.01 and 2.02 following the amendments made to the original action plan.

Ensuring the existence of a strong framework for reporting wrongdoings is of key importance within the context of the implementation of the PNRR and the high risks for corruption posed in the allocation of these funds (and the complementary fund set up by the government) which amount to EUR 222.1 billion. [45] If successfully implemented, the commitments included in this cluster reinforce the support framework surrounding whistleblowers, thus contributing to increased public accountability in the allocation and spending of PNRR funds, but also more generally in the Italian public administration.

Support at the early stages of the whistleblowing process would help potential whistleblowers identify the best possible solution for their individual case if they decide to continue with the reporting, including the appropriate reporting channel. A recent Transparency International report highlights the existence of cases where whistleblowers were not protected due to the selection of an incorrect reporting channel. [46] The report argues that formal acknowledgement through official channels of existing services provided by CSOs which can support would-be whistleblowers in the identification of appropriate reporting channels could contribute to enhancing the level of available protection. The EU Whistleblower Directive, once transposed, can provide the necessary framework to legitimize the activity of CSOs in this field as it requires that “competent authorities provide reporting persons with the support necessary for them to access protection effectively”. [47] There has been no civil society involvement so far on the transposition of the Directive into national law, so it is not clear if government will acknowledge CSO support through legislation, which may limit the ambition of this commitment. [48] As stated earlier, two CSOs currently provide this service in Italy, but are not formally acknowledged by the national anti-corruption framework. Promoting and acknowledging the role of CSOs, including through the publication of a list of associations who can provide whistleblower support, would raise awareness, and could increase use of this service and consequently lead to ANAC (and others) to successfully open cases on a higher percentage of whistleblowing reports. [49] The inclusion of an activity establishing a formal Working Group made up by CSO and PA representatives on “Support and Accompanying Activities for Whistleblowers” in the updated version of the action plan is a positive addition which can contribute to formalizing further a cooperative approach to the practical implementation of the Directive once transposed.

Implementation of trainings and exchanges of experiences among RPCTs could increase the quality of whistleblower reports and of the process of handling them. Interviewed SNA representatives clarified that they would focus on fostering exchanges of experiences and strengthening the competences of RPCTs dealing with whistleblower reports. [50] Particular attention would be placed on promoting innovative ways of training for the management of reports. A CSO representative said that additional training is necessary for RPCTs on the channels available for reporting and the management of reports, as well as further awareness-raising activities to promote the existence of RCPTs within public administrations. [51] Annual training for RPCTs on general aspects of transparency and corruption prevention is compulsory by law. [52] Jointly with ANAC, SNA has been regularly providing basic training courses on whistleblowing. [53] It remains unclear to civil society what “innovative training models” (as written in the commitment) might entail in practice, but according to interviewees focusing on practical case studies would be highly beneficial. [54]

Opportunities, challenges, and recommendations during implementation

Interviewed civil society representatives had originally regretted that the commitment lacked a clear reference to the involvement of CSOs in the transposition of the Directive. [55] According to one interviewee, this highlighted limited openness to civic participation on these themes outside of the OGP framework. [56] The updated version of the action plan partly mitigates this challenge by including the creation of the joint Working Group under the framework of the ANAC Task Force, although CSOs will still not be able to provide input on the contents of the Directive itself.

Potential challenges were also raised regarding the implementation of innovative training models among RPCTs, as without a clear understanding from the beginning on what these entail their possible impact remains limited. The same applies to the activities related to sensitizing public offices to anti-money laundering safeguards newly added as a result of the amendment of the action plan.

To maximize the impact of this commitment, the IRM recommends the following:

• In the transposition of the EU Directive on Whistleblowers, include formal acknowledgment of the support services provided by CSOs. Although the transposition of the Directive is now in its final phases and possibilities for influencing the results remain limited, the government could try to at least include a reference to the fact that support services provided by CSOs exist. This would further legitimize the role of CSOs currently providing support to whistleblowers and raise awareness at least within public administration on the existence of the service. To facilitate dissemination of the existence of these services, ANAC could consider linking the list of associations directly on its website as a formal acknowledgement of the existence of this service (similar to what is currently available for the list of RPCTs) as well as directly on the platforms and internal channels used for reporting purposes. Dissemination of this information could also form part of a broader awareness-raising campaign, as has been planned in the Czech Republic as part of its 2020-2022 action plan. [57] Italy could also collaborate with other countries on the topic of whistleblowing, such as the Republic of Korea which is implementing a promising commitment introducing whistleblower protections. [58]
• Promote the dissemination of this service to other CSOs. Training activities currently focus on institutional actors dealing with the management of whistleblowing reports. Only two CSOs formally provide support services through dedicated platforms for whistleblowers. Consider organizing seminars and training sessions also for CSOs that deal with this topic to expand the availability of the service nationally, regionally, and locally. Including a broader pool of CSOs among the providers of this service can contribute to further strengthening the network of support for whistleblowers.
• Encourage peer learning and ongoing collaboration between RPTCs as part of developing “innovative training models” with CSOs. RPTCs have already begun to receive innovative training models that are developed in collaboration with CSOs. Beyond this, ANAC and SNA could facilitate peer learning among RPCTs that could identify common challenges or opportunities, then draw on the experiences of the group to explore how to address these effectively. The overall goal could be learning how to leverage whistleblower reports most effectively for accountability and oversight. The peer learning insights could then be captured and turned into a resource to be used in the future. Civil society could continue to deliver training or provide materials and examples from actual real-life cases that enrich understanding of the whistleblowing experience and process from the perspective of the whistleblower. This can help improve the process overall for both the public administration and whistleblowers. This activity could take inspiration from the commitment on whistleblower protections in Estonia’s 2020-2022 action plan, which contains training activities and resources for public officials. [59]
• Ensure targeted training is provided to local and smaller public administrations on monitoring, identifying and addressing corruption risks and vulnerabilities. The majority of PNRR-financed interventions will be implemented by local administrations. These, as highlighted above, often present significant limitations in terms of the anti-money laundering and corruption prevention systems they have in place, partly due to the limited number of staff and limited possibilities for training. In the implementation of “sensitizing” and training activities foreseen by this cluster, therefore, particular attention should be placed to offering specific training to these smaller entities. If there is no possibility of implementing specific training exclusively for local administrations, ANAC and SNA should ensure that local public administrations are adequately represented in the Task Force and the Community of Practice.

Results Report

Commitment 2.02. Community of practice of those responsible for the prevention

of corruption and transparency

National Anti-Corruption Authority, National School of Administration, Bank of Italy, Consip, Court of Auditors, Ministry of Foreign Affairs, Ministry of Economy and Finance, Ministry of Justice, Ministry of Education, Ministry of Economic Development, Department of Public Function, Department of Cohesion Policies, Liguria Region, Fondazione Etica, Libenter, Libera, Osservatorio Civico PNRR, The Good Lobby, Transparency IT, Re-act.

For a complete description of the commitments included in this cluster, see Commitments 2.01

and 2.02 in Italy’s 2021–2023 action plan (original and amended versions): https://www.opengovpartnership.org/documents/italy-action-plan-2021-2023-december.

Context and Objectives

Corruption remains a key area of attention for Italy. At the time of publication of this action plan, Directive 2019/0366/EU on Whistleblowers had yet to be transposed, despite being required by December 2021. The provision of support to whistleblowers, officially provided by only two civil society organizations (Libera and Transparency International), was not a formally recognized service by the national anti-corruption framework, which contributed to limited awareness amongst would-be whistleblowers of the existence of this service. Meanwhile, monitoring reports by the National Anti-Corruption Authority (ANAC) highlighted the need to strengthen the skills of public officials for monitoring, identifying, and addressing corruption risks within PAs; and particularly to strengthening anti-corruption safeguards in the management of PNRR funds by appointing dedicated ‘managers’ responsible for monitoring interventions financed via the PNRR and submitting Suspicious Transaction Reports (STRs) to the Financial Intelligence Unit (FIU) [66].

This cluster sought to promote greater involvement of civil society in corruption prevention, strengthen the competencies of institutional actors formally tasked with corruption prevention (RPCTs) through dedicated training, and foster the exchange and dissemination of national and international best practices. This was accomplished, inter alia, through the creation of a multistakeholder task force led by ANAC and of a Community of Practice of RPCTs (CdP). Particular attention was placed on promoting approaches to prevent corruption and anti-money laundering throughout the implementation of the PNRR. [67]

Early Results: Moderate

All of the cluster’s activities were completely implemented and achieved moderate early results, contributing to further institutionalizing collaboration between PAs and anti-corruption CSOs. The multistakeholder institutional task force led by ANAC was set up in 2022 and had a cross-cutting role on the cluster’s activities. The task force had three sub-working groups [68] to facilitate daily operations. ANAC fulfilled its intention [69] to use the task force to coordinate active involvement of civil society in the national anti-corruption strategy. As part of the consultation process preceding the adoption of the 2022–2024 National Anti-Corruption action plan (NACAP), the ANAC task force hosted several meetings with CSOs to present the draft plan and collecting inputs. [70] This was a new practice in the drafting process for the National Strategy; creating a dedicated space for more direct interaction between responsible PAs and CSOs. A similar consultation approach was also adopted for the 2023 update to the 2022 NACAP, which focused primarily on the issue of public contracts. One civil society representative highlighted that it was sometimes confusing that ANAC used its own platforms for public consultation rather than the national ParteciPA platform [71].

Under leadership of the National School of Administration (SNA), the CdP was officially launched on 22 June 2022 with the creation of a dedicated platform on the SNA website. [72] By the end of the implementation period, the CdP included 250 members, exceeding its target of 200. Members included RPCTs, policy officers responsible for anti-corruption policies, and STR ‘managers’. [73] The CdP was a platform for dialogue and capacity building across this cluster’s different themes. The CdP work programme took into account themes of particular importance to RPCTs, collated in a questionnaire before the CdP launch. [74] The CdP met 31 times, touching on topics like whistleblowing, lobbying, and anti-money laundering. [75] All meetings included active involvement of civil society. By Autumn 2023, 87.7% of CdP members felt they had stronger skills in corruption prevention based on a self-assessment questionnaire (exceeding the target of 60%). [76] The strengthening of public officials’ skills to monitor, identify, and address corruption risks represented a key need of the RPCT community. However, it is too early to determine how these skills have been put into practice. Currently there is limited interaction between this new and growing community and the forum of RPCTs led by ANAC. An SNA representative indicated that there was interaction with the forum when the community was first launched to attract the RPCTs and assess their needs via the questionnaire. [77]

The CdP took first steps to strengthen anti-corruption safeguards in the management of PNRR funds. A sub-working group involving the managers responsible for submitting STRs to the FIU was set up in December 2022. Members of this sub-working group received a self-assessment questionnaire to gauge the degree of implementation of mandatory anti-money laundering provisions within each PA. [78] Inclusion of STR managers created, for the first time, a joint space for discussion amongst key stakeholders involved in different levels of public authorities’ prevention activities. [79] In addition to the thematic events on anti-money laundering and beneficial ownership transparency, a joint assessment was carried out to identify enabling factors that had supported the work of the 23 public authorities that had submitted STRs in the last years. The results were published in a report. [80] An FIU representative highlighted the importance of conducting this first assessment as a way to convene experts beyond the usual anti-money laundering community. The IRM notes the importance of continuing to leverage the CdP to design and deploy training activities as is intended in Spring 2024. [81]

The cluster’s strongest results were related to whistleblowers. The cluster led to a series of joint exchanges between CSOs and PAs on the transposition of Article 18 of Directive 1937/2019, [82] due by December 2022. Interviewed civil society representatives indicated that they were positively surprised by the intensity of exchanges and openness to CSOs’ legislative suggestions. [83] In October 2022, a document collecting CSO input was formally presented to the Technical Working Group on the transposition of the Directive. [84] Civil society representatives considered the direct reference of Article 18 to the availability of a list of CSOs providing support to potential whistleblowers on the ANAC website [85] to be a positive result of their input through the OGP platform. The list includes 10 supporting organizations that have signed a formal convention with ANAC between 2023 and 2024. [86] Publication of the list also responds to IRM recommendations. However, civil society representatives were not fully satisfied by the way their input was considered in the formulation of Article 18 [87] of the transposed directive. They also voiced concerns on the limited transparency and involvement of external stakeholders in the process for the transposition of the directive as a whole. [88]

The theme of whistleblowing was given particular attention by the CdP, with 14 meetings, webinars, and workshops focused on strengthening the skills of RPCTs who manage reports and on raising public officials’ broader awareness of whistleblowing. [89] A manual was published in December 2023 to support and guide RPCTs and whistleblowers. [90] As a result of the exchanges between RPCTs, CSOs, and PAs, three good practices related to whistleblowing were also promoted on the CdP website: the importance of adopting a new narrative on whistleblowing to place the whistleblower as a person at the center, the importance of making the support role of CSOs more visible and accessible, and a proposal to amend Article 8 of the Code of Conduct of public officials to align it to the current legislative framework on whistleblowing. [91] Four public authorities have already taken up the good practice on increasing the visibility of CSOs by providing a direct link to their website. [92]

While the design of the action plan did not initially list target indicators to measure achievement of the cluster, [93] these were later added as part of the overall monitoring of implementation. Targets for all activities were met and often surpassed, for instance including a larger number of CdP members and strengthening a higher percentage of the members’ skills than targeted. [94] However, the IRM notes that an important topic tied to this cluster—reinforcing the monitoring of PNRR spending—received limited attention beyond a few CdP seminars and publication of a risk catalogue. [95] This was also identified as a weakness by civil society stakeholders who indicated this as a lack of political engagement. [96]

Overall, the work of the CdP exceeded expectations. Stakeholders highlighted that it paved the way for a more structured and accepted approach to cooperation between PAs and CSOs. An SNA representative observed that this was the first time such open cooperation existed, and that it led to a series of unplanned activities involving CSOs that would have previously been unthinkable. [97] The CdP was included in the compendium of good practices on public participation promoted by the G20 Anti-corruption working group [98] and in the OECD’s “Shaping the values for a sustainable future: Education for the fight against corruption” manual. [99] The good practices identified on whistleblowing were presented at several international forums. [100] The SNA representative indicated that these achievements would not have been possible without the OGP framework. [101] In the future, this cooperation could produce greater open government results, depending on the extent of uptake of CSOs’ input by relevant government actors.

Looking Ahead

Stakeholders of both PAs and CSOs expressed strong interest in continuing the work carried out within this cluster beyond the fifth action plan, both by carrying forward activities in the sixth action plan and independent of the OGP framework. [102] For example, the CdP sub-working group dedicated to whistleblowing will continue its capacity building work by becoming an Advisory Board to the CdP. [103] This continuity will contribute to the sustainability of the results achieved. As cultural resistance of civil servants to implement integrity measures may be a challenge, [104] SNA intends to continue capacity building work by designing and delivering trainings on the culture of integrity via a bottom-up approach with schools and higher education institutions. [105]

Looking ahead, the IRM recommends using the sixth action plan to carry forward this clusters’ efforts, advising in particular to focus on identifying and finding ways to address ongoing challenges and obstacles to strengthening corruption prevention. The platforms and connections enabled by this cluster can be leveraged to enhance coordination and synergies amongst both individuals and institutions within PAs and CSOs, with a view to advancing the effectiveness of anti-corruption efforts. Emphasis should be placed on equipping institutions with problem-solving, learning, and adaptation skills, continuing the work started with the CdP. The IRM further advises ensuring that the important by-products of this cluster—manuals, risk catalogues, guidelines—are appropriately disseminated amongst the respective target groups and accompanied by formal training to enhance uptake.