HELLENIC REPUBLIC MINISTRY OF JUSTICE, TRANSPARENCY & HUMAN RIGHTS GENERAL SECRETARIAT FOR TRANSPARENCY & HUMAN RIGHTS

“TRANSPARENCY” NATIONAL ANTI-CORRUPTION ACTION PLAN

JANUARY 2013

GENERAL SECRETARIAT FOR TRANSPARENCY & HUMAN RIGHTS

Secretary General for Transparency & Human Rights Georgios I. Sourlas

“TRANSPARENCY” NATIONAL ANTI-CORRUPTION ACTION PLAN

Compiled by: Dr Stylianos Galoukas Special Scientific Consultant, Hellenic Parliament

JANUARY 2013

CONTENTS

LIST OF ABBREVIATIONS............................................................................................................... 1 INTRODUCTION ............................................................................................................................... 2 1. THE PROBLEM OF CORRUPTION .............................................................................................. 5 1.1. CORRUPTION ........................................................................................................................ 6 1.2. INTERTWINING OF INTERESTS ........................................................................................... 7 1.3. TRANSPARENCY .................................................................................................................. 8 1.4. IMPACT OF CORRUPTION .................................................................................................... 9 1.5. CORRUPTION IN GREECE .................................................................................................. 12 1.6. ORGANISATIONS AND CONTROL MEASURES ................................................................. 13 1.6.1. INTERNATIONAL - EUROPEAN BODIES AND ORGANISATIONS ........................... 13 1.6.2. ORGANISATIONS, BODIES AND AUTHORITIES IN GREECE ................................. 20 1.7. INTERNATIONAL PRACTICES ............................................................................................ 23 1.7.1. SUCCESSFUL STRATEGIES .................................................................................... 24 1.7.2. STRATEGIES AND EVALUATION............................................................................. 25 1.7.3. CAUSES OF STRATEGY FAILURES ........................................................................ 26 2. CAUSES OF CORRUPTION – NEED FOR A NATIONAL PLAN................................................. 28 2.1. EXISTING PROBLEMS OF THE SYSTEM ........................................................................... 29 2.1.1. BAD ADMINISTRATION ............................................................................................ 29 2.1.2. SOCIAL INEQUALITIES ............................................................................................ 30 2.1.3. CONFLICTS BETWEEN OLD AND NEW ................................................................... 30 2.2.

KEY PRINCIPLES OF THE NATIONAL PLAN ........................................................... 32 2.2.2. JOINING ALL FORCES TOWARDS A NATIONAL GOAL .......................................... 33 2.2.3. SINGLE PLANNING AND COORDINATION BODY .................................................... 33 2.2.4. STRENGTHENING – UTILISATION OF THE ANTI-CORRUPTION FRAMEWORK .. 33 2.2.5. UTILISATION OF INFORMATION AND COMMUNICATION TECHNOLOGIES ......... 35 2.2.6. PROFESSIONALISM OF PERSONNEL ...................................................................... 36

2.3. SOCIAL REQUIREMENTS FOR THE IMPLEMENTATION OF THE PLAN........................... 37 2.3.1. ETHICAL AND SOCIAL BACKGROUND................................................................... 37 2.3.2. ETHICS – DUTY......................................................................................................... 37 2.3.3. (ETHICAL) CONSCIOUSNESSES ............................................................................. 38 2.3.4. (MORAL) VALUES..................................................................................................... 38 2.3.5. INSTITUTIONS........................................................................................................... 39 2.3.6. EDUCATION AS THE FOUNDATION OF THE POLITICAL SYSTEM ........................ 39 2.3.7. ETHICS AND POLITICAL WILL ................................................................................. 40

2.3.8. CODES OF CONDUCT .............................................................................................. 40 2.4.

NATIONAL ACTION PLAN DEVELOPMENT AXES ........................................................ 43

3. “TRANSPARENCY”: NATIONAL ANTI-CORRUPTION ACTION PLAN ..................................... 47 3.1. ANALYSIS - PLANNING ...................................................................................................... 48 3.1.1. STRATEGIC OBJECTIVES........................................................................................... 50 3.2. IMPLEMENTATION.............................................................................................................. 96 3.2.1. IMPLEMENTATION PRINCIPLES................................................................................. 97 3.2.2. RESEARCH, DATA AND INFORMATION..................................................................... 98 3.2.3. FINANCING ................................................................................................................ 100 3.2.4. SCHEDULE – EXECUTION STAGES ......................................................................... 100 3.3. MONITORING AND CONTROL .......................................................................................... 102 3.3.1. COORDINATION, SUPPORT ...................................................................................... 102 3.3.2. FUNCTIONAL INDEPENDENCE AND RESOURCES ................................................. 104 3.3.3. MONITORING AND IMPLEMENTATION MECHANISM .............................................. 105 3.3.4. INTERNAL CONTROL STRUCTURES ....................................................................... 106 3.3.5. THE ROLE OF THE MINISTRIES ............................................................................... 109 3.4. EVALUATION AND SELF-EVALUATION........................................................................... 112 3.4.1. EVALUATION ............................................................................................................. 112 3.4.2. REGULAR UPDATES AND IMPROVEMENTS OF THE “TRANSPARENCY” PLAN .. 113 3.4.3. ANNUAL CONSOLIDATED REPORTS IN COLLABORATION WITH EXTERNAL INDEPENDENT ASSESSORS .............................................................................................. 113 3.4.4. REGULAR CONSULTATIONS WITH EUROPEAN AND INTERNATIONAL PARTNERS FOR IMPROVEMENTS IN THE FIGHT AGAINST CORRUPTION ........................................ 114 3.4.5. REGULAR PRESENCE IN THE MEDIA WITH HIGH-PROFILE DEBATES ON PRINCIPLES, VALUES AND CORRUPTION INVOLVING DISTINGUISHED MEMBERS OF THE SOCIETY ...................................................................................................................... 114 4. ANNEXES ................................................................................................................................. 116 4.1

SOURCES ........................................................................................................... 117

4.1.1.

ORGANISATIONS TOWARDS WHICH WE HAVE NATIONAL OBLIGATIONS .. 117

4.1.2.

SOURCES WITH PROPOSALS BUT WITHOUT OBLIGATIONS ........................ 117

4.1.3

. OTHER SOURCES ............................................................................................ 117

GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

LIST OF ABBREVIATIONS

HP

: Hellenic Parliament

GSTHR

: Secretary General for Transparency & Human Rights

NC

: National Coordinator

LA

: Local Authorities

SoP

: Speaker of Parliament

PPSSAC

: Public Private Sector Synergies Against Corruption

CC

: Coordination Committee

AB

: Advisory Board

MJTHR

: Ministry of Justice, Transparency and Human Rights

MΑRΕG

: Ministry of Administration Reform and e-Governance

MFA

: Ministry of Foreign Affairs

MoI

: Ministry of Interior

MF

: Ministry of Finance

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“TRANSPARENCY” - Anti-Corruption National Action Plan

INTRODUCTION

It has been shown that corruption and its consequences are the main cause of the multifaceted ethical, social, political and economic crisis that have led the country to impoverishment and national humiliation. Corruption has become a threat to the function of our political system, our social cohesion and our national status. The current situation and the extent of the problem require the implementation of a well structured and integrated national anti-corruption strategy plan. The "TRANSPARENCY" plan, through its three aspects – Education, Deterrence, Prevention – involves the whole society, the administration (public and private) and the political system. It is the only tool that exists today in Greece for the evaluation of the risks of corruption, the coordination of actions and their promotion in the public and private sector, policies and plans for the control of corruption in different sectors and industries. All participating bodies are supported in order to make the promotion of transparency a priority and undertake the obligation to publicise annual reports and produce monthly reports on the actions taken to fight against corruption. This national plan includes a detailed analysis of the existing situation in order to clarify the concept of corruption with references to the existing problems of the system, their impact and results to the society and the political system.

However, for a national anti-corruption programme to be functional, viable and efficient and in order for it to meet the requirements for the prosperity of the nation and the society, there must be an ethical and social background. It is imperative that we know how we got to this situation, be aware of the actions and failures which led us to the crisis and move forward to the control of corruption through this national plan. The ultimate goal, as mentioned in the UN Convention against Corruption, is the

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promotion of values which counteract the corrosion of society caused by corruption. This is why there is a special reference to these social factors that must be the continuous and constant focus of the state. The current government has decided to show zero tolerance to corruption and its intention to enforce this must be communicated by all possible means to all directions. The present “TRANSPARENCY” plan aims to:  put an end to the indecisiveness that resulted from the endless discussions of a series of governments with regards to the best possible way of promoting transparency  get the country out of a state of supervision and leads to the fulfilment of our international commitments and obligations relating to issues of corruption, responding at the same time to the commitments arising from the memorandum and the relevant road maps  identify high-risk areas of corruption and creates prevention mechanisms  take seriously into account the technical expertise from different sources  reinstate the reliability of the country internationally and make it an equal international partner and leader in the fight against corruption  reinstate and redefine transparency, both as a word and as a concept, in the consciousness of our society, since the often inappropriate use of the term, has turned transparency into a meaningless word, unreliable in terms of its intended enforcement  re-establish the trust of society in moral values and principles such as truth, earnestness, trust, meritocracy, political commitment and responsibility It is proposed that the present "TRANSPARENCY" plan should function as a political umbrella, which will accommodate all joint government-society actions towards transparency and will convey the clear message that “TRANSPARENCY”:  Benefits primarily the poor  Improves quality of life and reduces everyday stress through good level of

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“TRANSPARENCY” - Anti-Corruption National Action Plan

service provided by public and private bodies  Increases the credibility of politicians, institutions and the political system  Increases the meritocracy and credibility of government choices  Supports development and healthy competition  Develops entrepreneurship and attracts investment  Strengthens the social fabric and social solidarity  Creates a positive atmosphere and gives citizens hope for a better future  Acts as a positive example which is followed by adults and educates children, who are the citizens of tomorrow. However, regardless of how comprehensive and realistic is a National Plan and regardless of any prerequisite conditions, corruption cannot be controlled unless there is a real and honest political will. It must be made clear that where there is corruption there is no political will and where there is political will there is no corruption.

Georgios I. Sourlas Secretary General for Transparency & Human Rights

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

1. THE PROBLEM OF CORRUPTION

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“TRANSPARENCY” - Anti-Corruption National Action Plan

1.1. CORRUPTION

Corruption is the exploitation of a position of power by a person for their own benefit. It is the abuse of power by political party and government officials, employees and public figures. This is also the definition given by the Parliamentary Assembly of the Council of Europe in 1998 concerning the rights to privacy (Resolution 1163, point 7) for persons who are in public positions and/or use public resources and generally all those who play a role in public life, whether this is in politics, the economy, the arts, social life, sports, or any other area. Corruption does not only have a financial dimension and benefits for certain people, but can also take other forms of favourable behaviour, such as offering services to people or groups of people for money, offering in return, jobs, promotions, transfers etc. There are two aspects of corruption. The first one is defined based on the actions that deviate from a specific legislative and regulatory framework. The other one relates to the moral awareness of society, as well as the time when the action of corruption occurs.

Corruption also exists in the private sector. This is about the transactions between people involved in businesses which are in competition with each other. Employees of a business collaborate with a competitor by providing them with information, trade and industry confidential data, in return for large financial benefits and better professional prospects.

Corruption is not something general, vague and abstract any more. During the last few years, it has caused a lot of turbulence on a national and an international level. It appears as a threat to democratic institutions, but also to social goods. It has attracted the interest of international organisations, which put effort in protecting the international community through the modernisation of its political, social, economic and legislative arsenal.

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

1.2. INTERTWINING OF INTERESTS

The intertwining between politics, media and organised economic interests is an issue of utmost importance for democracy, the society and the economy. The prevalence of intertwined interests leads to the concentration of power in a limited number of economic forces which can even reach the point that they dictate the policies followed by governments or even choose who is in power. The term “intertwining of interests” is similar in meaning with the term “corruption”. The intertwining of interests and corruption are two sides of the same coin and one cannot exist without the other. The key element of intertwined interests and lack of transparency is the abuse of power. If there were no intertwined interests, then it would be easy to identify and control incidents of corruption efficiently. Corruption corrodes the social base and makes the intertwining of interests easier. If a government has zero tolerance to corruption, starting first from itself, it is impossible or almost impossible for corruption to exist. It is the government that is responsible but also has the ability to control it, as the overwhelming majority of organisations and citizens will be supportive in the effort to fight corruption. SCANDAL: The term scandal does not only have an economic dimension but it is also the attitude in the public domain through words or actions, which are in conflict with rules of ethics and legality, decency, human integrity and it is the subject of resentment and disapproval. When a scandal involves government officials, public figures and generally persons that are highly respected, then they attract the attention of the public and become the subject of discussions. In addition, the person responsible for the scandal, whether elective or not, does not only harm himself, but also causes damage to the organisation or social body in which he operates.

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“TRANSPARENCY” - Anti-Corruption National Action Plan

1.3. TRANSPARENCY

Transparency is the basic principle and condition of the rule of law and for safeguarding public interest and must govern all public life and all aspects of law. With transparency and the ability of everyone knowing anything relating to the function of the state in all aspects and levels of the administration, it is possible to uncover unlawful phenomena and activities which are made easier by unclear and inadequate laws. Phenomena that relate to the operation of the rule of law, the legality and the meritocracy in the good management of public money, the smooth operation and good management of services. Phenomena that break up social cohesion and affect social solidarity encourage lawlessness and impede development, poison social justice and lead to moral and social decline.

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

1.4. IMPACT OF CORRUPTION

The impact and cost of corruption is multiple and inestimable. Corruption destroys moral values and principles, undermines democracy, corrodes institutions, affects the national economy and impedes development. It has negative impact on a political and social level, it is the main cause of the current situation in Public Administration, the function of Justice and the degradation of the environment. ECONOMY: A decade ago, the discussions and studies on the impact of corruption on the economy were almost completely absent. Over the years and as the cases of corruption became more frequent and the impact became obvious, various studies started being carried out. The phenomenon of corruption is particularly interesting for Greece, in relation to the economic impact, as it is ranked among the countries of the European Union with the highest corruption and black economy indicators. Corruption has an impact on the economy, because it favours monopolies, afflicts healthy competitiveness, encourages tax and revenue invasion, discourages investors, has a negative impact on employment and burdens taxpayers It actually acts against the poor and hits the most vulnerable part of society. Healthy competition is afflicted, when these interests are undisturbed in breaching regulations and when they operate within legal provisions which have been designed especially for them. This destroys any concept of equal opportunities for citizens. It also affects free competition and the development of economy. Investments are discouraged, as they have to pay the cost of "greasing the palms” of public employees and politicians and function in an uncertain and unreliable environment. The damage to the Greek economy due to corruption is estimated to be 20 billion Euros, i.e. 8% of GDP. ENVIRONMENT: The protection of the environment is an imperative demand of modern society for the survival of human kind and for ensuring ecological balance

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“TRANSPARENCY” - Anti-Corruption National Action Plan

The lack of education and awareness for the protection of environment, the lack of a national “TRANSPARENCY” land development plan, but also a special planning framework for tourism, industry and renewable energy sources, the lack of land and forest registry, they all work in favour of corruption. Trespassing of public land by individuals, arson forest fires for development purposes, breaches of planning legislation, pollution from industrial facilities even with toxic waste, are some examples of the gloomy picture of the abuse of the environment. JUSTICE: More than any other power, justice requires safeguarding and protection from corruption. Many judicial officials have been in the dock of disciplinary councils and the High Court and have been given warnings and penalties or even punished with temporary or permanent suspension or imprisonment. INSTITUTIONS: The extent and continuous spreading of corruption, the tolerance from politicians and citizens and furthermore the rewarding of corruption, fraud and abuse of power by some people, are phenomena which have almost institutionalised corruption in our country.

Corruption, immorality, bribery,

profiteering, irresponsibility, have become to a large extent a way of life and they are tolerated by society. WELFARE STATE: The system of social values of a society plays a key role in the development of corruption. The mechanisms of corruption are a disruption to equality, egalitarianism, meritocracy and social justice. This is how people lose their trust in institutions and develop tendencies of becoming part of the corruption mechanism themselves, or become passive against the call for defending principles and values. In a society where moral values and principles are being degraded, the ties between its members are destroyed. The State does not show the necessary resistance and society disintegrates further. Corruption damages democratic institutions and leads to non-compliance with the law. POLITICS: The intertwining of interests affects primarily politics and politicians,

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

their credibility and responsibility. Only if the disturbed relationship between citizens and politicians is restored and they join their efforts for increased transparency, they can put an end to the corruption that has poisoned the political life of the country and has had a negative impact on society and the economy. LAW ENFORCEMENT: Corrupt individuals, take advantage of the fact that the State is either willingly or unwillingly unable to control the legality of their various activities, such as construction or other business activity, they breach the law and benefit financially by doing so. When corruption becomes so dominant that it becomes more powerful than the law and the decisions of courts, then it is inevitable that his encourages lawlessness with all its consequences to the smooth operation of the State. Corruption does not have anything to act upon, when the law is respected and it is enforced be everyone and about everything. It must be understood by everyone that law is the key instrument of the State in a democratic regime. MORALITY AND CULTURE: Politicians, public officials and public servants must confirm on a daily basis through their actions the fact that they operate within the boundaries of morality and integrity. Morality must be based not only on rules of legality but also mutuality. There needs to be a solid moral base, on which every member of the society can function. This is how people can be creative without losing their integrity and without falling victims to corruption. PUBLIC ADMINISTRATION: Bad administration in Greece is undoubtedly a fact. Its extent and impact understandably raise a lot of concern. The European Parliament and the European Commission define as bad administration "the incidents of bad administration, which occur, when a public body fails to act in accordance with the rules or principles by which it is bound". Bad administration usually comes from corruption relating to specific causes, as these are mentioned in a separate chapter.

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“TRANSPARENCY” - Anti-Corruption National Action Plan

1.5. CORRUPTION IN GREECE It is very important to know the extent of corruption in each case and also whether this is rising or declining in order to evaluate the seriousness of the situation and prioritise anti-corruption actions and the control of the causes of these phenomena. Based on the measurements of the International Transparency global barometer, in 2009 Greece was, together with Bulgaria and Romania, among the most corrupt countries of the European Union. While in 2008, Greece was in the 57 th place, in 2009 had already gone up to the 71 st place, 14 places lower than the previous year. Transparency International - Hellas, based on the findings of the global corruption barometer, has found the following regarding Greece: Increase of corruption in the last three years. Political parties remain in the first place of the list of the most corrupt bodies. Micro-corruption is widely spread. The main cause of bribery is the avoidance of problems with public authorities. The actions of governments for the control of corruption has been ineffective. Citizens are prepared to take action against corruption. During the last three year period, citizens (59% of them in 2007 and 66% in 2010) believe that the work of governments for the control of corruption has been very ineffective. The reasons for this particularly worrying situation, according to Transparency International, are: The insufficient implementation of anti-corruption measures. The delays in preliminary investigations and judicial procedures. The large number of corruption scandals in public and private sector enterprises.

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

1.6. ORGANISATIONS AND CONTROL MEASURES

Corruption is not an issue of a single country, but an international phenomenon, affecting all societies and economies. The prevention and control of corruption requires international cooperation. Apart from technical support, there is also a need for appropriate institutions. It requires not only the support of the public sector but also the support of the private sector, individuals, social groups and non-governmental organisations. The organisations that exist today and are concerned with the control of corruption, operate on: Global level (international organisations), European level (European Union bodies), National level All international and European organisations – each one within their area of activity – have established specific rules for fighting against corruption. They have created bodies responsible for the implementation of these rules in membercountries, as well as guidance and progress monitoring mechanisms for each country with specific penalties in cases of breach or non-implementation of these rules. The measures that are proposed to member-countries aim at establishing a strong single institutional framework, as well as preventive and repressive measures.

1.6.1. INTERNATIONAL - EUROPEAN BODIES AND ORGANISATIONS

As part of their duties, these bodies are responsible for: Establishing anti-corruption strategies on a global and European level and monitoring compliance. Designing joint action plans for their member-countries, specifying priorities,

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“TRANSPARENCY” - Anti-Corruption National Action Plan

monitoring their progress and making recommendations for achieving the agreed targets. They are constantly supervising and systematically monitoring the progress of our country in issues of corruption, in accordance with international standards and international agreements, in which Greece participates. They submit memoranda to governments with the necessary measures that must be taken for addressing and eliminating corruption. They carry out ad-hoc inspections in the country and get in contact with primary, secondary, government and social bodies (political parties etc.), in order to be able to have the best possible overall picture of the phenomenon of corruption in Greece. This is then compared to international standards which have been established and agreed between all countries participating in each international organisation. Finally, these international organisations issue recommendations or regular reports, collating information on the agreed measures for each country, the progress made so far, the things that have not been done according to the agreed schedule and that require to be given particular emphasis until the next inspection. 1.6.1.1. UNITED NATIONS (UN)

The current, eighth Secretary General of the UN, Ban Ki-moon from the Republic of Korea, gives particular importance to issues of principles and values, ethics and transparency, as expressed by him when he took office: “I will make transparency and accountability the cornerstones of my term of office”. The United Nations has declared the 9 th of December as “International AntiCorruption Day". The United Nations Anti-Corruption Convention is the strongest global legal tool for strengthening moral integrity and fighting against corruption. Also, with the establishment of an additional mechanism, countries are judged based on what they do in order to fight against corruption and not only the promises that they make.

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

According to the UN, the private sector must not be excluded. Businesses must also fight corruption within their structures and systems and eliminate bribery in tender and procurement procedures. The UN calls for the private sector to adopt the anti-corruption measures specified by the United Nations Convention. Businesses must commit to not deceive anyone and to allow to be inspected by similar companies, in order to ensure that the same rules apply to all. Greece has adopted the provisions of the UN Anti-Corruption Convention in its domestic legal system by ratifying it through law 3666/2008.

1.6.1.2. ORGANISATION FOR ECONOMIC COOPERATION AND DEVELOPMENT (OECD)

Through the OECD, governments can compare their experiences from the implementation of policies, look for answers to common problems, identify good practices and coordinate local and international policies on a long-term basis. Among other areas, the OECD plays an important role in the coordination of international action against bribery and corruption, by establishing the OECD anticorruption Convention (officially "Convention on Combating Bribery of Foreign Public Officials in International Business Transactions") which was signed in 1997 and came into force in 1999. This Convention attempts to reduce the corruption caused by businesses in developing countries by taking anti-bribery deterrent measures in international transactions, which take place between businesses from OECD member countries. The aim is to establish true egalitarianism in the current business environment. The legislative integration and the implementation of the measures are responsibilities of the governments. The OECD is not responsible for enforcing the Convention but for supervising its integration by member countries. The OECD carries out its supervisory role in two inspection phases: The first phase involves reviewing the legislation, into which the Convention is integrated, in order to assess the adequacy of the laws. During the second phase, the OECD assesses the effectiveness of the implementation of legislation.

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Greece has signed the OECD anti-corruption Convention, making a commitment to following its rules, as well as be subjected to subsequent inspections and comply with recommendations made by the competent OECD Committee.

1.6.1.3. INTERNATIONAL MONETARY FUND (IMF)

The main aim of the IMF is to ensure the stability of the international monetary system, i.e. the exchange rate and international payment system, allowing countries (and their citizens) to carry out transactions between them. In order to succeed in its mission, the IMF has been given the role of supervising the international monetary system and review the economic policies and practices of its 187 member countries. The activities of the IMF take place both on a global as well as a national level, where it identifies risks to stability, but also offers recommendations, when necessary, to countries with respect to the required corrections to their policies.

1.6.1.4. EUROPEAN UNION (EU)

The EU follows a global anti-corruption policy, by encouraging its institutional bodies to take specific measures (establishing specific anti-corruption bodies on a European level) and promote them to its Member States, while at the same time it participates itself, or through its competent bodies, in collaborations with other international organisations and bodies, which have as a goal the control of corruption on a global level. In addition to the measures taken by the EU and its bodies for the global control of the phenomenon of corruption, particularly interesting efforts have also been made for the coordination of EU joint actions with the USA and all international anticorruption organisations.

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1.6.1.5. EUROPEAN CENTRAL BANK (ECB)

In its transparency policy, the ECB, with its decision of 3 July 2007 with regards to the award of contracts, bans the participation of those who have been previously convicted for fraud, corruption, money laundering, taking part in any other illegal activity that is contrary to the economic interests of countries, the ECB or national Central Banks.

1.6.1.6. GROUP OF STATES AGAINST CORRUPTION (GRECO)

Its mission is to monitor the compliance of member countries with its anticorruption standards based on a number of legal tools, that have been developed for the criminalisation of corruption in the public and private sector, the responsibility and compensation for damages caused by corruption, the compliance of public officials and the funding of political parties. The approach of the Council of Europe in the fight against corruption is multidimensional and consists of 3 interconnected elements: the specification of European standards and rules, the monitoring of compliance with the standards, the contribution towards Member States through programmes of technical cooperation. GRECO assesses the progress by collecting information from questionnaires, through field visits of assessment committees, allowing the collection of more information, through high-level discussions with local agents and through assessment reports. These reports contain recommendations to the assessed countries, in order for them to improve their level of compliance with regards to the issues in question. The measures taken for adhering to the recommendations are then examined by GRECO through a separate compliance monitoring process. The assessment is carried out per theme. So far GRECO has carried out three rounds of assessments in relation to specific requirements of the 20 principles and the relevant criminal conventions, which include:

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Available means for the prevention and control of corruption in different countries. Extent and purpose of immunities. Identification and confiscation of proceeds of corruption. Pubic Administration and corruption (control systems, conflicts of interests). Efficiency and transparency against corruption. Provision, in order for the legal world to be a shield of protection against corruption. Taxation and economic legislation against corruption, links between organised corruption, organised crime and money laundering. The most recent round of assessment by GRECO deals with two distinct subjects: The criminalisation of corruption and the transparency in political party funding, in accordance with the recommendations for compliance with common anti-corruption rules in the funding of political parties and their election campaigns. It is worth highlighting the repeated warnings made by GRECO: “particular importance must be given to the control of gifts and donations received by political parties, the control of their pre-election campaign expenses and the source of the funds which are given to them in the form of loans”, have so far been ignored by all Greek governments.

1.6.1.7. FINANCIAL ACTION TASK FORCE (FATF) The Financial Action Task Force (FATF) was founded by the G7 Summit in Paris and the President of the European Commission as a result of recognising the risks posed to the banks and the international financial system by money laundering. The economic impact of terrorist activities was also added later. It consists of 34 member countries (all countries that participate in G7, all EU Member States as well as other countries).

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When FATF was established, it was given the role of examining the techniques and trends of money laundering, reviewing actions and measures which had already been taken on a national or international level, specifying additional measures required for the control of money laundering, and developing techniques and measures against the funding of terrorism. In order to do this, it tries to prevent and control the use of the financial system by economic criminals and terrorists. It designs the policies that need to be implemented and works towards producing the necessary political will, in order for the appropriate local legislation to be established and implemented efficiently on a local level. It has concluded to a system of 40+9 recommendations. The forty (40) recommendations are a detailed “TRANSPARENCY” plan of the actions required for the control of money laundering and covers the systems of criminal justice and law enforcement, the economy and its regulation as well as international collaborations. The nine (9) special recommendations, which relate specifically

to

the

control

of

terrorism

funding,

combined

with

the

40 recommendations on money laundering, create the basic framework for identifying, preventing and controlling terrorism and terrorist activities. Although these 40+9 FATF recommendations are not the product of an international convention, all participating countries have undertaken a mutual political commitment to fight money laundering and terrorism, by adhering to these 40+9 recommendations and integrating them to their political, judicial and economic systems. FATF continuously monitors the new techniques that are being developed for money laundering and terrorism funding as well as the measures against them, and updates these 40+9 recommendations and communicates them to its member countries, in order for these measures to be always up to date and fulfil their purpose. FATF monitors and reviews the progress of its members on a regular basis, with regards to the necessary measures, issuing progress reports with specific guidelines

for

each

member

country

for

adhering

fully

to

the

40+9

recommendations and integrating them to their law.

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1.6.1.8. WORLD BANK (WB) The World Bank, as also mentioned elsewhere, plays a leading role in the fight against corruption, giving emphasis to the dimensions of corruption affecting primarily the economy and the good governance of countries. For these purposes, it has designed strategies and action plans, together with assessment indicators for their progress, in order to be able to monitor its plans, take corrective actions and propose their implementation to the countries that it supervises.

1.6.1.9.

INTERNATIONAL ANTI-CORRUPTION ACADEMY (IACA)

The International Anti-Corruption Academy, is a joint initiative, primarily between the UN Office on drugs and crime, the Austrian Government and the European Anti-Fraud Office. Its aim is the in-depth study of corruption and its control practices and operates as an independent centre for research and specialisation for education, training, provision of technical expertise and development of anti-corruption partnerships.

1.6.2. ORGANISATIONS, BODIES AND AUTHORITIES IN GREECE

The bodies that operate in Greece are concerned with the collection of data from foreign bodies and organisations and from surveys or other sources in order to reach conclusions in the form of publications or reports. At the same time, on an institutional level, there are also bodies which have the mission and the corresponding institutional responsibility: 

for the adaptation of the legal framework, in order for the recommendations of foreign bodies and the agreements signed with them or other countries to be integrated into Greek law.



for the practical implementation of the recommendations of foreign bodies and of the laws that relate to them, the immediate identification and

20

GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

control/combating of corruption. They receive raw data (directly from the society or government bodies), carry out inspections, identify possible cases of corruption, and take necessary actions which are then recorded in the form of reports. 1.6.2.1. PARLIAMENTARY COMMITTEE ON INSTITUTIONS AND TRANSPARENCY 1.6.2.2. MINISTRY OF JUSTICE, GENERAL SECRETARIAT FOR TRANSPARENCY & HUMAN RIGHTS (GSTHR) 1.6.2.3. COURT OF AUDITORS 1.6.2.4. AUTHORITY FOR THE CONTROL OF MONEY LAUNDERING AND T ERRORISM FINANCING AND CONTROL OF STATEMENTS OF ASSETS. 1.6.2.5. SINGLE INDEPENDENT AUTHORITY FOR PUBLIC PROCUREMENTS AND CENTRAL ELECTRONIC PUBLIC PROCUREMENT REGISTRY 1.6.2.6. GENERAL INSPECTOR OF PUBLIC ADMINISTRATION 1.6.2.7. ECONOMIC CRIMES ENFORCEMENT AGENCY (ECEA) 1.6.2.8. THE GREEK OMBUDSMAN 1.6.2.9. BODIES AND AUTHORITIES WITHIN MINISTRIES Apart from the above bodies, we also list briefly here, bodies and authorities responsible for the control of various forms of corruption such as bribery, blackmailing, preferential treatment, embezzlement, forgery, venality and abuse of power. 1.6.2.9.1. Inspectors - Controllers Body for Public Administration (ICBPA) 1.6.2.9 .2. Health and Welfare Services Inspectors Body (HWSIB) 1.6.2.9.3. Inspectors – Controllers Body of the Ministry of Transport and Communications (ICBMTC) 1.6.2.9.4. Directorate General of Financial Auditing 1.6.2.9.5. Inspectors Body for Public Works (IBPW) 1.6.2.9.6. Hellenic Police Internal Affairs Department 1.6.2.9.7. Internal Affairs Office of the Ministry of Mercantile Marine, Aegean and Island Policy 21

“TRANSPARENCY” - Anti-Corruption National Action Plan

1.6.2.9.8. Other Authorities Apart from the above, there are also other inspection and control bodies and authorities that exist in the wider public sector, such as the Authority for the Control of Expenses of Social Security Organisations, the Fiscal Control Committee, the Control Body for Correctional Institutes, the Control Body for Detention Authorities, the Special Environmental Inspectors Authority, the Employment Inspectors Body, the Economic Police, the Financial Investigation Authority, the Authority for the Control of Electronic Crime, the General Secretariat of Tax and Customs Matters and the General Secretariat of Public Revenue. 1.6.2.10. TRANSPARENCY INTERNATIONAL HELLAS It is the Greek branch of the global non-governmental organisation under the name “Transparency International”. It is a non-governmental organisation which has the form of a union. Transparency International – Hellas conducts studies and surveys on the corruption in Greece and publishes their results on a regular basis. It also publicises the results of studies carried out internationally by Transparency International and which also include Greece.

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

1.7. INTERNATIONAL PRACTICES

Many good anti-corruption practices have been recorded internationally. Recently, there have also been efforts made by the European Union, however the best practices remain those implemented in very corrupt environments and had fast and impressive positive results on a global scale. After all, corruption is not a phenomenon which is limited to one country only or a Union of countries but the whole world. This is why every good practice must be examined objectively, regardless of where it showed results. This is the reason why the most important of all anti-corruption agreements is the agreement of the United Nations which has been accepted and is respected on a global level. Some of the most effective and radical good practices implemented on a global level as part of national anticorruption plans are the following: 

In South Korea, where the Public Sector, the Business Sector and the civil society have joined forces in the fight against corruption. More than 800 organisations and bodies signed the implementation agreement of an agreed "TRANSPARENCY" plan, while there was also agreement on annual monitoring of its progress by an international evaluation team.



In the Philippines, a team of experts conducted a detailed integrity inspection in all ministries and submitted proposals on the measures needed for each ministry separately for fighting internal corruption problems.



In New Zealand, all heads of government authorities must submit every year an anti-corruption “TRANSPARENCY” plan.



In Canada, all public servants must report cases of corruption by law.



In Pakistan, the Philippines and Indonesia, special courts were established specifically for cases of corruption.



In Nigeria, government officials and politicians are not allowed to have any bank accounts abroad.



In Singapore, public servants are not allowed to have debts greater than three times their monthly salary.

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“TRANSPARENCY” - Anti-Corruption National Action Plan

1.7.1. SUCCESSFUL STRATEGIES

Among all successful anti-corruption strategies, of the 138 countries assessed every year by Transparency International, it is worth focusing on the case of Hong Kong, mainly because it started from a large degree of corruption and managed to fight it effectively and also keep it under control. In Hong Kong, the Independent Commission Against Corruption (ICAC) was established in 1974, when corruption was very widespread in all citizens and institutions and everyone believed that the establishment of this new institution would be yet another attempt which was condemned to failure. According to the director of ICAC: "Hong Kong was certainly one of the most corrupt parts of the world in the 60s and the beginning of 70s. Corruption was widespread and was considered to be a ‘way of life’, ‘from the womb to the tomb’. Corruption in the public sector and particularly law enforcement authorities were well organised and had formed unions, making a mockery of the criminal justice system. As a TAXI driver, you could even buy a monthly badge from a corrupt union, which you could stick on your taxi and this would guarantee immunity from any traffic offence for a whole month! Such was the scale of corruption in Hong Kong". However, within three years, this authority managed to destroy all sources of corruption within the government, convicting 143 police officers and 247 government officials. This is how "this authority drastically changed the overall attitude against transparency in the government, private sector, the elections, the everyday life of citizens and transactions with the state. It even had an impact among citizens on a private level, by creating almost zero tolerance to any form of corruption, resulting in making Hong Kong today one of the most corruption free societies in the world. The impact of the work of this authority on the society became obvious in 2000, when at the turn of the millennium there was a large survey on the most important events until then, according to which the citizens of Hong Kong ranked the establishment of the anti-corruption authority as the 6th most important event in the 150 years of the history of Hong Kong! 24

GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

Among the major successes of the activities of ICAC are the following: 

It uprooted all obvious forms of corruption in government. Corruption exists now as a particularly secretive crime and often includes only those who benefit from it. Citizens rarely suffer from the blackmail of senior government officials.



It is one of the first countries in the world which effectively enforced the protection of the private sector against corruption, providing an excellent business environment and a clean development environment for all investors.



Innovative solutions were implemented through prevention studies in areas which were more prone to corruption and spread the best possible practical guidelines for each sector such as public procurement, construction, financial sector, personnel management etc.



It changed the attitude of citizens toward society, who stopped tolerating corruption as a way of life and started to actively support the fight against corruption by reporting it not only voluntarily but also publicly. Before the establishment of ICAC, the majority of reported cases of corruption were anonymous. Today more than 75% of reported cases are reported publicly. This shows the trust that people have in ICAC.

The case of Hong Kong was considered to be one of the few successful examples of a very degraded country converted to a very clean one. However, it demonstrates that there is a way for effectively controlling corruption regardless of how serious or widespread it is.

1.7.2. STRATEGIES AND EVALUATION

One of the key objectives of "TRANSPARENCY" will be to improve the image of Greece concerning its performance in the fight against corruption as this is shown through regular measurements or evaluations which are carried out. Generally, the evaluation

of

a

country

(and

therefore

the

implementation

of

the

25

“TRANSPARENCY” - Anti-Corruption National Action Plan

"TRANSPARENCY" plan) can be done on three levels: 1. On a high level through the evaluation methodologies of the international community 2. On an internal level, through the self-evaluation systems and mechanisms which the authorities of the country may have 3. On a low level from national evaluations, from NGOs and the society There are organisations that develop general or specific indicators for measuring corruption, but they all have some common factors which can be summarised in the following point-indicators for the health of a country, as far as corruption is concerned: Voice and accountability Political stability and absence of major violence and terrorism Government effectiveness Regulatory quality Rule of law Control mechanisms From the in-depth study of the performance of each country in each one of the above points, it seems possible to identify the particular weaknesses of each country and determine the solutions for controlling corruption on a practical as well as a political level. 1.7.3. CAUSES OF STRATEGY FAILURES Almost all countries with serious corruption problems have established anticorruption authorities, but only some of them have had the desired result of an actual reduction of corruption. On the contrary, in many countries there was an increase in corruption after the establishment of these authorities. A comparison of these failed strategies to successful models (such as Hong Kong, Australia, Singapore, Georgia, Bulgaria and others) shows that the failure of these strategies is due to:

26

GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

o Lack of understanding of the causes of corruption o Lack of resources for the control of corruption o Lack of real independence of anti-corruption authorities o Lack of sufficient legal framework o Lack of public recognition o Lack of unity, cooperation and anti-corruption “alliances” o Lack of professionalism o Lack of internal control o Corruption in justice The one and only reason which is the most important than all the above and can lead a good strategy to failure is the lack of political will. If there is political will, all the above can be dealt with, since they are a matter of political will. It has been shown that anywhere in the world where political will was a fact, national strategies were implemented and managed to offer quick and longlasting results which in some cases became even permanent. In other words, they changed the overall attitude of society. Even complex socio-political problems such as these of nepotism, corruption and bribery which in the past where the norm in places like Hong Kong, experience has shown that with effective public education campaigns as well as strict law enforcement, these problems can be solved. The essence of the problem is the lack of true political will in the form of commitment, in order for a successful model to be fully adopted. From all the successful national anti-corruption strategies in the world, it has been proved that (in order of importance): o political will through actions o a dedicated anti-corruption authority and o the correct strategy can change even the most corrupt place in the world into a clean society.

27

“TRANSPARENCY” - Anti-Corruption National Action Plan

2. CAUSES OF CORRUPTION – NEED FOR A NATIONAL PLAN

28

GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

2.1. EXISTING PROBLEMS OF THE SYSTEM Research shows that the sectors with the biggest problems of bad administration and corruption in Greece are those of Health, Local Authorities, Planning Authorities, Tax Offices, as well as NGOs which are not currently under any control. These are sectors in which administration is in direct contact with citizens. The administration in these sectors has increased economic powers, which are capable of leading both administration and citizens to corruption. The elements responsible for causing corruption and bad administration are the following: 

Lack of appropriate mechanisms for the control of public sector. Today these mechanisms, where they exist, they are scattered in various ministries.



Vague or overlapping responsibilities of control authorities.



Slow control procedures, insufficient, vague or late recommendations, reports etc. and lack of responsibility.



Politically influenced decision making.



Lack of transparency in providing information with the excuse of personal data protection.



Slow judicial procedures and irrational legal framework against corruption.



Weakness of Courts in enforcing the law especially in economic crimes and corruption crimes.



Excessive concentration of power at the top.



Asymmetry between duties and resources.

2.1.1. BAD ADMINISTRATION Bad administration in Greece is undoubtedly a fact.

The control of bad

administration is at the core of the efforts for the reconstruction of the state. The most important causes of bad administration which act as sources of corruption for 29

“TRANSPARENCY” - Anti-Corruption National Action Plan

the Greek Public Administration are the following:

2.1.1.1. ATTITUDES OF CLIENTELISM 2.1.1.2. VIOLATION OF LAW - DISCRIMINATION 2.1.1.3. PROLIFERATION OF LAWS 2.1.1.4. DELAYS 2.1.1.5. IMPUNITY, TOLERANCE, POSTPONEMENTS

2.1.2. SOCIAL INEQUALITIES

Where there is an unequal distribution of wealth, there are no equal opportunities for access in education, health and quality of life. There is always room for solving problems that relate to geographic, as well as social inequalities. After all, this is the primary element that characterises the quality of Democracy. It is an expectation of society that the rule of law applies to everyone. It is therefore the duty of the State to ensure this, and the duty of governments to implement it.

2.1.3. CONFLICTS BETWEEN OLD AND NEW

Modernisation requires the establishment of procedures and legislative provisions for the increase of productivity and the development of competitiveness. It is therefore understandable that a new code of behaviour is developed within these circumstances in order to reach these targets. For example, an action that would have been condemned or even seen as corruption until yesterday, today might be considered to be necessary due to “particular circumstances” and “new attitudes”.

30

GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

This is supported by the idea that modernisation targets must be reached at all costs, violating our code of ethics or even compromising social cohesion. In response to all these, the state has a duty to assert the message that, in reality, corruption poisons healthy entrepreneurship and productive efforts by having a negative effect on the sense of fairness and creating uncertainty and a negative environment for investment. It becomes an obstacle to development. Corruption is a crime against society and above all against future generations. There cannot be any justification of corruption.

31

“TRANSPARENCY” - Anti-Corruption National Action Plan

2.2. KEY PRINCIPLES OF THE NATIONAL PLAN

2.2.1. ZERO TOLERANCE TO CORRUPTION The message of the determination for the fight against corruption must be conveyed to society in a clear and not a vague manner. There must not be double standards which confuse society. This is why the same emphasis must be placed regardless of whether corruption is in the public or private sector. There must not be any exceptions, sub-clauses and categories. Corruption must be controlled horizontally regardless of where or by whom it is carried out and regardless of its scale. The criminalisation and consequences must be the same in all cases of corruption. Similarly, the emphasis must be the same whether it is a natural or a legal person and whether it is in the public or the private sector. After all, the number of private sector employees is significantly greater than the number of public sector employees. In order to have a balanced implementation of transparency in society, we must use the same ethical standards at both ends of the scale. From a quantitative point of view, private corruption can cause bigger damage to society than public sector corruption. For example, the serious corruption in financial institutions can cause instability of the market. Corruption in the construction sector can lead to dangerous constructions. Corruption in media can cause the disorientation of the political system and society. Finally, the efficient control of corruption in the private sector must be seen as a form of protection of foreign investment and a way to ensure equal opportunities for business activities, creating therefore a competitive advantage in attracting foreign investments.

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

2.2.2. JOINING ALL FORCES TOWARDS A NATIONAL GOAL

A national effort in the fight against corruption: The fight against corruption will not be successful if it is only a matter for anti-corruption authorities. This is because, corruption is not a commercial product or service which can be fought using commercial organisation rules. On the contrary, it is an idea and an ideological practice which can only be confronted by even greater ideals such as those of morality and integrity. It is therefore a duty and responsibility of the whole society, including public services, but above all the political leadership, to ensure the promotion of accountability and morality as its primary concern and its determination to fight corruption wherever this may be. The “TRANSPARENCY” plan gives emphasis on this broad national effort while at the same time identifies and allocates specific organisational - operational responsibilities.

2.2.3. SINGLE PLANNING AND COORDINATION BODY

A new authority which will act as a single, powerful and independent body which will coordinate all anti-corruption efforts of the state is required. Single, in order to include everyone with an active or passive role in this effort under the same umbrella. Powerful, because its efforts will find many resistances and attitudes which will require the use of powerful and efficient tools. Independent, because on one hand it needs to be accountable in order to ensure its own integrity, and on the other hand in order to not be influenced in its efforts for changing attitudes, fighting organised interests and establishing transparency.

2.2.4. STRENGTHENING –

UTILISATION OF THE ANTI-CORRUPTION

33

“TRANSPARENCY” - Anti-Corruption National Action Plan

FRAMEWORK Concise and easy to use legislation must be established. Action must also be taken in the same direction for the reform and rationalisation of anti-corruption criminal provisions and the regulation, once and for all, of the criminalisation of corruption in Greece. In this context, we must also ensure the harmonisation of these changes with the recommendations of all those organisations that Greece has committed to comply with (e.g. GRECO, OECD, memoranda). As far as different offences are concerned, apart from obvious bribery offences, there must be a greater degree of classification of offences for both public and private employees, for example: o It must be an offence for any employee to receive gifts, loans, discounts, beyond a certain limit, even if this does not affect any other transaction, unless authorised by his or her manager or supervisor. o It should be illegal for any employee to enjoy any privileges or receive loans, which are disproportionate to their salary or live a life which is not justified by their income. o Conflict of interests must be an offence, for any employee who uses their position or power inappropriately for personal benefit or for the benefit of other persons. 2. Anti-corruption control authorities, must not only be authorised to simply investigate corruption cases in the public and private sector, but also investigate all corruption related crimes. Anti-corruption control authorities, must be given increased control powers, in order to be able to check bank accounts, use sworn witnesses, repossess assets which are the result of corrupt transactions and detain travel documents of suspects so they cannot flee the country and avoid justice. Additionally, depending on the circumstances and in serious cases, anticorruption control authorities must be able to implement more dynamic investigation techniques, such as interception of communications, line

34

GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

monitoring, secret procedures etc. 3. Corruption cases must be prosecuted by a competent court or a selected team of anti-corruption prosecutors, ensuring coordination and speed combined with quality and integrity. The anti-corruption prosecutor must be a strong supporter of the fight against corruption, ensuring that all cases of corruption are dealt with in courts by judges who act with professionalism and justice as their sole objective.

2.2.5. UTILISATION

OF

INFORMATION

AND

COMMUNICATION

TECHNOLOGIES

The “TRANSPARENCY” plan must be able to fulfil its multidimensional role in an efficient manner, identifying current priorities (political anti-corruption objectives, legislative, social, moral, economic). This will require the use of modern technologies which can be applied in the following areas: o law enforcement and cross-checking of information o receiving corruption complaints o processing information and managing complaints o keeping informed those who make the complaints, with regards to the outcome or progress of their complaint o communication and exchange of information between anti-corruption authorities o joint monitoring and updating of the implementation of the “TRANSPARENCY” plan o recording of public opinion / assessment of the work of anti-corruption bodies o presentation of progress and communication needs of the “TRANSPARENCY” national action plan The Office of the National Coordinator will have access to an integrated system that will manage all the above, enabling them to provide immediate and up to date

35

“TRANSPARENCY” - Anti-Corruption National Action Plan

information at all times.

2.2.6. PROFESSIONALISM OF PERSONNEL

This is the area where most anti-corruption action plans have failed in the past. Even if the competent control authorities had the best laws and all necessary resources, but their staff behaved unprofessionally, it has been proved that it was impossible to achieve this difficult objective of fighting corruption. If we also take into account that corruption constantly evolves, even the most efficient and specialist personnel must be constantly updated and trained, or they end up being inefficient. The control of corruption, especially at a high level, is a very difficult thing to achieve, because corruption also encourages people to become imaginative and smart as well as experienced and powerful through practice. Consequently, those who fight corruption must be particularly careful and very professional in their work.

36

GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

2.3. SOCIAL REQUIREMENTS FOR THE IMPLEMENTATION OF THE PLAN

There must be a framework of principles and directions, focusing on moral conscience, duty, respect to laws and institutions. Regardless of how perfect a political system might be in terms of its targets and objectives, it will not be able to produce any results, unless citizens can be involved in building it and unless citizens adopt it and leaders serve it with a sense of duty. This is why there must also be a brief reference to the social requirements for transparency and the success of the anti-corruption “TRANSPARENCY" plan.

2.3.1. ETHICAL AND SOCIAL BACKGROUND The proposals for the implementation of the “TRANSPARENCY” plan, with any amendments, improvements and additions, must be implemented by citizens through their representatives in all State bodies. The general realisation that the country is not only going through an economic crisis, but mainly a deep social crisis of principles, values and institutions, highlights the importance of dealing with these social phenomena and ensuring a strong social base. 2.3.2. ETHICS – DUTY

All rules, written and unwritten, must focus on the effort to establish ethical values in order for people to get used to the idea of doing the right thing and avoiding anything unethical: actions which are not only beneficial for ourselves, but the whole society. This is how people can be creative without losing their integrity and without falling victims to corruption. Politicians, citizens, public officials and public servants must confirm on a daily basis through their actions the fact that they operate within the boundaries of morality and integrity.

37

“TRANSPARENCY” - Anti-Corruption National Action Plan

Ethical conscience requires the prioritising of collective over personal interest, social over collective and national over social.

2.3.3. (ETHICAL) CONSCIOUSNESSES

Moral conscience can be cultivated and gives people a sense of duty. It becomes the silent tutor of the soul and does not affect how others see our actions, but how we evaluate our own actions. Moral conscience is the ultimate judge that approves all these actions which are carried out ethically and condemns unethical actions. Moral conscience is the determining factor in the prevention of corruption. LAW: In order for people to coexist, there must be rules of law, which govern their personal behaviour and their interpersonal relations. The law, while it seems that it restricts freedom, it actually protects and safeguards it. Justice and adherence to social rules is the aim of natural law. The law must be accepted and implemented by everyone. Total respect of the laws must be above all and must be the result of free will and a sense of duty.

2.3.4. (MORAL) VALUES

The most important moral value is humanism, which is the faith in the value of human life. This is because human life is the ultimate good. After life, the most valuable virtue of humans, is freedom. The hierarchy of values, is different from person to person, from time to time and from culture to culture. Over the past few decades we have had a crisis of our moral values as a result of technological development. There has been a disturbance of the balance in the development of basic elements of culture, contributing to the material and spiritual progress of humans, as well as their ethical advancement. While from these types of progress, only material progress has been very rapid,

38

GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

humanitarian education and spiritual cultivation of humans continue to be very low. This delay and decline of ethical progress encourage corruption. A different dimension can be given to technological progress, if combined with the spiritual advancement and development of moral values. 2.3.5. INSTITUTIONS

Social, political and cultural institutions define the level of social organisation and play a key role in the education of young people, by supporting and improving the social base of society. 2.3.6. EDUCATION AS THE FOUNDATION OF THE POLITICAL SYSTEM

The primary objective of any organised society must be the education of responsible and free citizens, for the spiritual, ethical and social integration of its members. Education must focus on teaching young people to respect the law and develop their moral conscience. This must be at the core of education of all ages, especially during childhood. Education is delivered through family, school, but also the wider social environment (spiritual, political, cultural). It is the family that lays the foundations for cooperation, solidarity, understanding and generosity, which will determine the attitude of a person in the wider social environment. Unfortunately the institution of family is undergoing a deep crisis, which seems to deepen even further as the time goes on. Education and the development of a moral personality must start at school, so that at least those representing the State but also all citizens put collective interest over personal interest. As far as the wider social environment is concerned, we must create a society which can receive young people and function within a set of values, while creating the necessary conditions for a society dominated by dialogue, criticism, cooperation, solidarity, fairness, higher principles and values. We need to protect young people by offering them ethical rules, as well as 39

“TRANSPARENCY” - Anti-Corruption National Action Plan

teachers, parents and public officials who act as role models and can show through their actions their dedication to the ethical and lawful organisation of the state and the society. We should offer them moral values through a continuous commitment to ethical actions, which is not an inborn virtue, but can be cultivated and developed through education.

2.3.7. ETHICS AND POLITICAL WILL

A leader must have strong will for making serious and important decisions, political intuition, ability to predict and above all moral stature. A leader must aim for the establishment of the rule of law, in order for politics to be "good and fair". A politician, who has voluntarily taken the role of a public official, not only should not move away from his or her principles and personal ethics, but must feel an increased responsibility for defending the ethical principles of the society, through setting a practical example . This is why we must reinstate the relationship between ethics and politics and on that base build a new political system. 2.3.8. CODES OF CONDUCT

Ethics, i.e. the set of rules relating to duties and obligations of leaders, politicians and public officials is a significant factor in the quality of democracy and any form of power. A large study conducted by the Organisation for Economic Cooperation and Development (OECD), about the measures that various countries of the world need to take for the control of corruption, concluded that this can only happen if morality and ethics are strengthened. This is why all countries were encouraged to establish Codes of Conduct at least in the public sector, which will be used as part of good administration. In order for Codes of Conduct to have any results:

40

GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

• The must take into account the international initiatives of other similar organisations, such as the "International Code of Conduct for Public Officials of the United Nations General Assembly" (resolution 51/59, 12 December 1996). •

They must promote the integrity, honesty and responsibility among public

officials. •

Policies, processes and administration practices must comply with ethical

standards. Ethical standards (boundaries) must be clearly defined and associated with legal sanctions. •

There must be a process in place for specific and strict disciplinary or other

measures against public officials who breach codes or standards resulting from these codes. •

All public officials must have access to available guidance, which must be

described in detail. • Public officials must know their rights and obligations. • Politicians must be the first to commit to complying with ethical rules, in order to encourage all other public officials. •

All decision making procedures must be transparent and open to public

scrutiny. •

They must contain detailed and clear guidelines on the interaction between

public and private sector. •

Advisers and administrators must commit to showing their dedication to moral

values. •

All employment conditions of Public Administration must comply with codes of

ethics and conduct. •

Public officials must report incidents of corruption to the competent authorities,

as part of performing their duties. •

Public officials must be required to declare to the competent authorities, among 41

“TRANSPARENCY” - Anti-Corruption National Action Plan

others, all external activities, investments, assets and significant gifts or allowances, from which there might be a conflict of interests in relation to their duties as public officials. • There must be mechanisms for accountability and allocation of responsibilities for all the above, in the whole public and private sector.

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

2.4. NATIONAL ACTION PLAN DEVELOPMENT AXES “TRANSPARENCY” plan which is described in the following chapter, which primarily in The "TRANSPARENCY" National Action Plan aims to the improvement of the political, economic, social and legal environment of the country. Through coordinated actions in three axes: Deterrence, Education, Prevention. All three components, in this particular order, are equally important for achieving the intended objectives. Deterrence comes first as it is required for ensuring that corruption is not continued, then there is prevention so that the same phenomena do not re-occur and finally education in order to establish the concept of transparency deep in our conscience and have a long-term effect. PREVENTION: The aim of prevention strategy is to reduce the opportunities for corruption, first on a government and public authorities level. The general principle is to ensure performance, transparency and responsibility in all government activities, especially in areas of high priority, such as public procurements, health, public works, licensing, provision of public services, law enforcement and safety and collection of taxes. In order for the corruption prevention strategy to have any results, it will have to include increased supervision and continuous internal monitoring of processes in the following systems: o Effectiveness Management o Procurements Management o Economic Management o Human Resources Management o Complaints Management The tools required for achieving these objectives are the following: o Clear identification of weaknesses of areas prone to corruption and effective management of problems

43

“TRANSPARENCY” - Anti-Corruption National Action Plan

o Production of effective work guides (manuals) o Increased effectiveness of staff supervision through random inspection systems o Internal control structures everywhere o Keeping records which can be used for identifying problems and also for accountability purposes o Establishment of policies of data security levels o Mechanisms for efficient protection of people who report or witness incidents of corruption o Mechanisms for managing complaints and reporting of corruption cases o Quality management – Development of indicators for measuring efficiency and satisfaction o Electronic governance – Electronic procurement o Ensuring transparency in recruitment, evaluation and promotion of personnel EDUCATION: The strategic choices for education in relation to corruption are the base for supporting the whole society in the fight against corruption. The main elements of the education policy of the “TRANSPARENCY” plan are: o Close cooperation with the Media in order to ensure that convicted corruption cases are publicised widely by the media (print and electronic),

press

conferences

and

press

releases,

even

by

broadcasting series and films based on positive examples. o Large scale advertising campaigns for encouraging everyone to report corruption. Development of public awareness for the negative impact of corruption and the need for a fair and decent society which does not allow corrupt practices. o Integration of ethics programmes in education programmes, starting from pre-school and all the way to University. o Establishment of a website with free members subscription to the anti-

44

GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

corruption authority, in order to gather in one place all volunteers and friends of transparency who are willing to help and offer their practical support in the fight against corruption. o Codes of conduct for members of the parliament and all government bodies and enterprises. o Speeches, events and seminars for collecting good practices and guidance in the control of corruption o The establishment of a Centre for the Development of Ethics, as part of the collaboration with the private sector, which will conduct research and promote business codes of conduct o Exhibitions, public debates, charity events and television programmes promoting the message of a clean society o Wide use of websites in all anti-corruption bodies for reporting and publicising cases of corruption and education young people through the development of moral conscience. o The design of suitable educational and training programmes and seminars for continuous information and education of all personnel involved in the fight against tax evasion. o Establishment of suitable educational structures and means for targeted training in methods and practices that promote transparency, for all personnel

of

government

organisations

that

participate

in

“TRANSPARENCY". o Standardisation and prototyping of educational processes through the establishment of certified transparency standards (ISO). o Introduction of certification processes for skills and methods used by the personnel

of

all

government

organisations

that

participate

in

"TRANSPARENCY".

DETERRENCE: The strategy options for training the personnel that is involved in the fight against corruption (control, suppression, prosecution) are expected to 45

“TRANSPARENCY” - Anti-Corruption National Action Plan

contribute significantly to the outcome of their actions. Mapping of structures, roles and areas/operational sectors for all organisations involved in the prosecution, control and suppression of corruption. Furthermore, activities such as anti-corruption actions in areas of immediate risk and high economic outcome (health, procurement, illicit trade, tax evasion, planning authorities, public administration) will be supported by offering training and coordination, but at the same time respecting fully their operational and organisational independence. Finally, strengthening the judicial system through a reform of laws and processes as well as the introduction of new anti-corruption institutions such as special anticorruption public prosecutors, will play a significant role in the deterrence of corruption.

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3. “TRANSPARENCY”: NATIONAL ANTI-CORRUPTION ACTION PLAN

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3.1. ANALYSIS - PLANNING

This Action Plan includes the strategy, i.e. the general planning and coordination of the actions required for achieving specific objectives, as well as a range of actions or activities which must be carried out in order for these objectives to be achieved. The “TRANSPARENCY” action plan, as this is analysed below, is presented initially with its vision and its five (5) strategic objectives. Then, for each strategic objective, there are two tables:

1.

Analysis Table containing: 

Policy axes that must be achieved (16 in total)



Results that are hoped to be achieved (14 in total)



Measurable results: that are expected to be achieved (35 in total)



Key factors and conditions for achieving the objectives (13 in total)

2. Goal-timescale diagram (Road map): the tool that keeps actions on track, in order to avoid disorientation and deviation from the planned route. Further to the above, the table also includes the following columns: 

Policy axes that must be achieved (16 in total)



Goals (Results) that are hoped to be achieved (69 in total)



Actions: that must be carried out (76 in total) in the three year period of the implementation of “TRANSPARENCY”.



Time: the time scale for completing each specific action and



Person responsible: the allocation of responsibilities per authority.



Indicators (30 in total): the criteria used for the evaluation of progress

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and generally the achievement of the objectives of each road map. Based on the above, “TRANSPARENCY” as the National Action Plan of Greece for combating corruption, will be able to give, at any time, specific answers to question such as: 

Where are we as a country (also from where, why and how we got here)



Where do we want to go (and why)



How we will get there (step by step and in general), i.e.: o

with what means (resources -> human + tools)

o

what stages (steps)

o

when (pace – rate)

o

what is the cost (how much will it cost us)

o

what is the benefit (what is the benefit in relation to the cost)

The specific strategic objectives, actions and allocated responsibilities are stated below. It is important that all public (and also non-public if possible) authorities support responsibly the “TRANSPARENCY” plan and play an active role in the implementation of the actions included in it.

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3.1.1. STRATEGIC OBJECTIVES

Vision A society that requires quality of services and shows zero tolerance to Corruption and a soundly managed public and private sector, working closely together with the political system, with accountability, integrity and transparency.

Strategic objectives: 1.

Efficient political leadership in the fight against Corruption

2.

Increased public demand for accountability and rejection of corruption

3.

Efficient enforcement of anti-corruption measures

4.

Increased compliance and accountability of public and private bodies

5.

Strong implementation of the “TRANSPARENCY” anti-corruption Plan

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Strategic Objective 1: Efficient political leadership in the fight against corruption (E1) Through this objective, the aim is to create a culture in which the faith and trust of people to the political will of the government will transform into a joint and mutual commitment to zero tolerance to corruption and its practices. It must go beyond announcements and statements, and must be reinforced by clear and decisive policies, decisions and actions.

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Α. Analysis of Strategic Objective

Policy axes (A): E1.A1. Demonstration of political commitment to zero tolerance E2.A2. Increased performance and efficiency of institutions

Expected results:

Measurable results:  Consistent and visible political anticorruption action  Establishment and implementation of codes of conduct for political integrity

 Reduction of political corruption

 Planning of anti-corruption statutes that must be voted in parliament

 Increased support of society towards political anti-corruption actions

 Clear boundaries concerning the responsibilities of all bodies/officials involved

 Significant increases in the quality and stability of accountability in public authorities

 Annual comprehensive accountability cycles  Discussion in Parliament with regards to the reports of the various anti-corruption bodies and taking actions based on these reports  Implementation of anti-corruption action plans in all General Government bodies

Key success factors: 

Political commitment for the adoption of the “TRANSPARENCY” plan



Strict adherence to laws and regulations



Adequate staffing by people who will function with integrity and professionalism

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Β. Goal-timescale diagram

Policy axis

Objective

Actions

E1.A1.1. Political endorsement of "TRANSPARENCY"

E1.A1.1.1. Cabinet publicly endorses "TRANSPARENCY"

E1.A1.2. (1.4) Ensure ownership of all stakeholders and political backing for the national strategy by approval of the Parliament. E1.A1. Demonstrate E1.A1.3. Cabinet considers annual political reports on "TRANSPARENCY" Commitment implementation for zero tolerance E1.A1.4. Proven political will of the Government to start from itself

E1.A1.5. Proven parliamentary decision to play a primary role

Timelin e

Order of responsibility

Mar-13

Ministerial Council Secretary

National Coordinator

E1.A1.2.1. Parliament approves "TRANSPARENCY"

Mar-13

Speaker of Parliament

National Coordinator

E1.A1. 3.1. Annual "TRANSPARENCY" implementation review

Dec-13

Ministerial Council Secretary

National Coordinator

E1.A1. 4.1. Cabinet Integrity Code of Conduct

May-13

Prime Minister

National Coordinator

Jul-13

Speaker of Parliament

National Coordinator

E1.A1. 5.1. Integrity Code of Conduct for Parliament adopted by Members of Parliament

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E1.A2. Increased efficiency and effectiveness of oversight institutions

E1.A1.6. (3.10). An effective framework for transparency, supervision and sanctioning of political party financing

E1.A1.6.1. Political Parties funding Bill aprroved by the parliament

E1.A2.1. (3.4). Development further strengthening of internal control mechanisms

E1.A2.1.1. Implement and monitor Internal structures for all General Government bodies and monitor impact

E1.A2.2 (3.5). Effective mechanisms for prevention, detection and removal of conflict of interest and incompatibilities for all categories of public officials, including elected officials

E1.A2.2.1. Action plan implemented in all General Government bodies in all levels including elected officials

E1.A2.3. (3.17). Code of conduct and ethics for public officials

E1.A2.3.1. General Government bodies Integrity Codes of Conduct

Jul-13

Speaker of Parliament

National Coordinator

Jun-13

Ministry of Administrativ e Reform and eGovernance

National Coordinator

Nov-13

Ministry of Administrativ e Reform and eGovernance

National Coordinator

Jul-13

Ministry of Administrativ e Reform and eGovernance

National Coordinator

Minist ry of Interio r

Coordi nation Comm ittee

Advis ory Body

Ministry of Interior

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Dec-13

Ministry of Administrativ e Reform and eGovernance

National Coordinator

Dec-13

Ministry of Administrativ e Reform and eGovernance

National Coordinator

Dec-13

Speaker of Parliament

National Coordinator

E1.A2.6. Parliamentary Reports

E1.A2.6.1. Reports of NC are considered by Parliament on a halfyearly basis

Dec-13

Speaker of Parliament

National Coordinator

E1.A2.7. Improve Local Government institutional oversight and enforcement

E1.A2.7.1. Local Governments Institutional oversight and management functions enhanced

Dec-15

Ministry of Interior

National Coordinator

E1.A2.4. (1.3). Strengthen ‘circles of defense’: inspection bodies within ministries (level 1), general inspection (level 2), law enforcement, prosecution and judiciary (level 3), parliament (level 4).

E1.A2.4.1. Monitor use of and impact of Code of Conduct in all General Government bodies

E1.A2.4.2. Implement Good Governance in all General Government bodies

E1.A2.5. E1.A2.5.1. Programming of "TRANSPARENCY" Timely passage of "TRANSPARENC legislation completed Y" legislation

Efficiency evaluation indicators Consistent political pledges and actions Adoption of Codes of Conduct by the Parliament and the Government

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Adoption of Codes of Conduct by all Local Authorities Voting of anti-corruption statutes Action taken by the Parliament based on the reports of the National Coordinator Voting of law for the funding of politicians and parties

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Strategic Objective 2: Increased public demand for accountability and rejection of corruption (E2) Reinforcing and gaining the trust of the society in the fight against corruption is a challenge for the “TRANSPARENCY” plan. This intervention aims to encourage public opinion to demand accountability and reliable and timely information on corruption cases and the way these are dealt with.

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Α. Analysis of Strategic Objective

Policy axes (A): E2.A1. Reinforcement of the demand of the society for sound management and accountability. E2.A2. Encouragement of the society for resisting to corruption and preventing it. E2.A3. Reinforcement of the framework for the involvement of non-governmental bodies

Expected results:

Measurable results:

 Systematic public review of anti-corruption actions

 Increased public alertness for anti-corruption actions  Increased public demand for information

 Programmes for the monitoring of Local Authority expenses by the society  Regular and systematic analysis of public opinion  Systematic enforcement of criteria for the storage of information  Public alertness and educational programmes through ministries and the media

Key success factors: 

Public faith and trust in the actions of the government against corruption



Public desire for involvement in anti-corruption campaigns

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Β. Goal-timescale diagram

Policy axis

Objective

Actions

Timelin e

Dec-14

Ministry of Administrativ e Reform and eGovernance

National Coordinator

E2.A1.1.2. Biannual public opinion poll NIS (National Integrity System) every year

Jul-14

General Secretariat for Transparency and Human Rights

National Coordinator

Advisory Body

E2.A1.2.1. Research and establish experimental social accountability projects

Dec-13

National Coordinator

Coordinatio n Committee

Advisory Body

Jul-14

Ministry of Administrativ e Reform and eGovernance

National Coordinator

Local Government s

E2.A1.1.1. Publicly available citizen information and citizen -rights impact reports E2.A1.1. (3.7). Strengthening civil society participation, including empowerment of citizens. E2.A1. Strengthen civic competence t o demand for performance and accountability

E2.A1.2. Enhance information on accountability and anti-Corruption action

E2.A1.3. Community reporting on public service performance

Order of responsibility

E2.A1.3.1. Every three months publication of antiCorruption progress reports

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E2.A2.1. Increased public engagement with Corruption issues

E2.A2. Strengthen capacity of the public to resist and prevent Corruption

E2.A2.1.1. Initiate an annual antiCorruption campaign to promote public participation awareness and ownership

Oct-13

Advisory Body

National Coordinator

E2.A2.2. Increased national consensus on integrity based values

E2.A2.2.1. Identify and promote national values as core values for society

Dec-13

National Coordinator

General Secretariat for Transparenc y and Human Rights

E2.A2.3. (4.8). Use of inducement prizes to identify innovative solutions to reduce corruption.

E2.A2.3.1. Initiate a national awards scheme to recognise integrity and exemplary service

Dec-14

National Coordinator

Coordinatio n Committee

E2.A2.4. Increased integrity awareness among young people

E2.A2.4.1. Devise and promote integrity forming programmes aimed at young people

Dec-15

Advisory Body

National Coordinator

Coordinatio n Committee

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E2.A2.5. Increased adherence by professionals and their associations to established standards and codes

E2.A2.5.1. Promote the development and implementation of codes of conduct among all professional groups and associations including the private sector ones

Dec-13

Advisory Body

National Coordinator

E2.A3.1. Develop and Operationalise an Anti- Corruption Public Private Partnership (ACPPP) framework

E2.A3.1.1. Development of a detailed work plan

May-13

Advisory Body

National Coordinator

E2.A3.2.1. Three year Actions Plan operational. Joint activities undertaken in areas of Capacity Building, Research, Policy and advocacy

Dec-13

Advisory Body

National Coordinator

E2.A3.3.1. Engage the private sector and media as key non-state actors in anti-Corruption action

Dec-14

National Coordinator

Coordinatio n Committee

E2.A3. Strengthen th E2.A3.2. e Implement three year ACPPP framework for Action Plan participation o f non-state actors E2.A3.3. (3.9). Increased crosscommunity support including the way the independent media can play a role to tackle corruption

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E2.A3.4. Increased collaboration between state and nonstate actors

E2.A3.4.1. Pursue the development of the concept and operation of public private partnerships to increase effective service

E2.A3.5. Annual assessment on implementation of "TRANSPARENC Y" and ACPPP joint action

E2.A3.5.1. Conduct annual consultative forum to review ACPPP and implementation of "TRANSPARENC Y"

Dec-15

National Coordinator

Ministry of Interior

Advisory Body

Dec-13

National Coordinator

Coordinatio n Committee

Advisory Body

Efficiency evaluation indicators Alertness of society for political anti-corruption actions Implementation of PPSSAC plans in all sectors of increased corruption Joint actions with all anti-corruption non-governmental bodies Comprehensive annual reports

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Strategic Objective 3: Efficient enforcement of anti-corruption measures (E3) This principle must be carried out by tightening the implementation of punishment at a legal and administrative level, as there is currently evidence that punishments are either small or implemented partially and inefficiently. This situation must be reversed as soon as possible, since corruption does not remain the same. It evolves and finds new ways when the Authorities make improvements in old systems. This is why it is of fundamental importance that the judicial and legislative system evolve constantly and act fast, in order to deal with the new challenges posed by corruption. Furthermore, the State and all its bodies must operate in a coordinated manner in developing new structures which also require a national unified response to corruption, with coordinated efforts, under the same umbrella.

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Α. Analysis of Strategic Objective Policy Axes: E3.A1. Strengthening of the legislative, judicial and auditory framework for combating corruption E3.A2. Increase of public trust in the quality and efficiency of anti-corruption actions E3.A3. Reinforcement of compliance to international standards and obligations Expected results:

Measurable results:

 Improvement of public information  Regular legislative reviews  Legislation impact assessment  Increase of public trust in the anticorruption actions of the government  Increase of conviction cases  Increase of local and regional cooperation against corruption

 Internal monitoring structures in all ministries, departments, bodies and Local Authorities  Compliance with obligations and recommendations made by UN, GRECO, OECD  Designation of the coordination of the “TRANSPARENCY” anti-corruption plan  Establishment and operation of an anticorruption governance structure  Interconnection of the actions of this Action Plan with other anti-corruption actions of ministries, departments, bodies and businesses  Compliance with memorandum anti-corruption obligations

Key success factors: 

Available resources for the implementation



Cooperation and support from active participants



Governmental and Parliamentary support

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Β. Goal-timescale diagram

Policy axis

Objective

Actions

E3.A1. Strengthen the legislative and judicial framework to combat Corruption

E3.A1.1a. (6.2). Improvement of the criminal legislation and criminal procedure concerning corruption related offences and white collar crime, including on aspects related to immunity of members of parliament and government including E3.A1.1b. (6.4). introducing and enforcing the Greek Bribery Act

E3.A1.1.1. Special law preparation Committee active and operational

E3.A1.2. (3.15). Procedures for giving and accepting gifts

E3.A1.2.1. Special law preparation Committee active and operational

Timeline

Order of responsibility

Jun-13

Ministry of Justice, Transparency and Human Rights

National Coordina tor

General Secretariat for Transparency and Human Rights

Jun-13

Ministry of Justice, Transparency and Human Rights

National Coordina tor

General Secretariat for Transparency and Human Rights

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E3.A1.3a. (3.12). Strengthen the protection of whistleblowers, following the International Organizations recommendations. E3.A1.3b. (6.9). Withdrawal of the provision regarding anonymous complaints

E3.A1.3.1. Special law preparation Committee active and operational

E3.A1.4. (3.16). Monitoring conflict of interest

E3.A1.4.1. Special law preparation Committee active and operational

E3.A1.5a. (6.5). Improving the timelines that justice is obtained, both in terms of duration of proceedings and statute of limitations E3.A1.5b. (6.6). Giving priority to cases of corruption regarding civil servants and public officials in courts.

E3.A1.5.1. Establishment of anti-corruption prosecutors

Jun-13

Coordination Committee

National Coordina tor

Advisory Body

Jun-13

Ministry of Justice, Transparency and Human Rights

National Coordina tor

General Secretariat for Transparency and Human Rights

Mar-13

Ministry of Justice, Transparency and Human Rights

National Coordina tor

General Secretariat for Transparency and Human Rights

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E3.A1.6. (6.7). Strengthening the administrative legal framework regarding sanctionability

E3.A1.6.1. Establishment of anti-corruption prosecutors

E3.A1.7. (6.8). Explore on the recent withdrawal of the right for the Inspector General to appeal to disciplinary decisions when the case was not initiated by the Inspector General

E3.A1.7.1. To be decided after the appointment of the national coordinator

E3.A1.8. (6.10). Empower obligation of ministries and agencies to respond to observations and proposals formulated by inspection bodies and the Ombudsman

E3.A1.8.1. Specific measures and actions to enforce obligation of ministries and agencies to respond to observations and proposals formulated by inspection bodies and the Ombudsman

Jul-13

Ministry of Justice, Transparency and Human Rights

National Coordina tor

May-13

Ministry of Justice, Transparency and Human Rights

National Coordina tor

Sep-13

Ministry of Justice, Transparency and Human Rights

National Coordina tor

General Secretariat for Transparency and Human Rights

General Secretariat for Transparency and Human Rights

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E3.A1.9. Periodical review of anti-Corruption legislation and harmonization with the international obligations of Greece

E3.A1.9.1. Regular review and updating of anti-Corruption legislation and regulation

E3.A1.10. (2.4). Mapping overall and individual responsibilities in the anti corruption network, to avoid overlap

E3.A1.10.1. Creation of a central registry of anti corruption bodies and detailed responsibilities mapping.

E3.A1.11. Monitor the impact of antiCorruption legislation on enforcement

E3.A1.11.1. Annual analysis of all Corruption prosecutions taken. Annual analysis of the effectiveness of antiCorruption legislation

Apr-13

Ministry of Justice, Transparency and Human Rights

National Coordina tor

Apr-13

National Coordinator

Coordina tion Committ ee

National Coordinator

Coordina tion Committ ee

Jul-13

General Secretariat for Transparency and Human Rights

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E3.A1.12. (5.6). Explore on strengthening mechanisms for disclosure and verification of assets for all categories of public officials, including elected officials

E3.A1.12.1. Prepare a framework to strengthen the confiscation of assets

E3.A1.13. (4.9). Strengthen mechanisms for asset recovery

E3.A1.13.1. New instrument / mechanism to enable confiscation of assets

E3.A1.14. Preparation and presentation of methods for improved Corruption fighting

E3.A1.14.1. Identify and implement measures to improve Corruption technical investigations

National Coordinator

Coordina tion Committ ee

Oct-13

Advisory Body

Coordina tion Committ ee

Jul-15

Coordination Committee

National Coordina tor

Jul-13

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E3.A1.15. (4.7). Strengthen capacity between internal control mechanisms and law enforcement with a view to enhance notification rates for corruption offences or unjustified wealth

E3.A1.15.1. Implement information storage and archive standards

E3.A1.16. Strengthen the use of administrative action as an important mechanism enhance the combination of prevention and sanction

E3.A1.16.1. More effective use of administrative sanction Reduced pressure on judicial system

Dec-13

Dec-14

Ministry of Administrative Reform and eGovernance

National Coordina tor

Ministry of Interior

National Coordina tor

Coordination Committee

Ministry of Administrativ e Reform and eGovernance

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E3.A1.17a. (6.1). Ιntroduction of a corruption proofing methodology. E3.A1.17b.(6.3). Improve the prosecutorial proceedings legal framework.

E3.A1.17.1. Initiate intersectoral consultations to ensure effective coordination of legislative developments

Jul-13

Ministry of Justice, Transparency and Human Rights

National Coordina tor

Coordination Committee

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E3.A2.1a. (2.1). National Coordinator. E3.A2.1b. (2.2). Coordination committee. E3.A2.1c. (2.3). Advisory group including Transparency International and the Task Force for Greece. E3.A2.1d. (2.5). This E3.A2. should have a direct link to Increase public the coordination committee confidence in and being tasked with giving the quality and asked and unasked advice to effectiveness the National Coordinator and of antithe coordination committee. Corruption E3.A2.1e. Coordination actions between inspection and control bodies under the same umbrella. E3.A2.1f. (4.10). Obligation of the Prosecutors to notify the inspection and control bodies (which referred the case to them) of the results of their investigation

E3.A2.1.1. Begin the coordination of the anti corruption efforts at a National level. Establishment and commence of operation of the Governance structure for the coordination of the anti-corruption authorities via a National Coordinator. Issues not covered by the draft law will be further explored and advise will be asked.

Apr-13

Prime Minister

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E3.A3. Strengthen compliance with international standards and obligations

E3.A2.2. Improved information for the public

E3.A2.2.1. Provide regular public information briefings on case management and the delivery of justice (administrative and criminal)

E3.A2.3. Development of user friendly information on antiCorruption legislation and regulation for public distribution

E3.A2.3.1. Public Information documents

Jan-14

Jul-13

National Coordinator

Coordina tion Committ ee

Advisory Body

Coordina tion Committ ee

National Coordinator

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E3.A2.4. Monitor Greece’s compliance with UNCAC and take steps to close the gaps

E3.A2.4.1. Gap analysis / Completed self-assessment Annual benchmarking assessment

E3.A2.5. Initiate mutual legal E3.A2.5.1. assistance arrangements with Mutual legal assistance relevant partner countries. arrangements in place

E3.A2.6. Active participation of the groups working on Taxevasion measures and on the Road Map on Anti Money Laundering (annex)

E3.A2.6.1. Increased harmonisation of anti-money laundering and tax-evasion provisions

Dec-13

Dec-13

May-13

National Coordinator

Coordina tion Committ ee

General Secretariat for Transparency and Human Rights

National Coordinator

General Secretari at for Transpar ency and Human Rights

Ministry of Foreign Affairs

National Coordinator

Coordina tion Committ ee

Ministry of Finance

Ministry of Interior

Ministry of Interior

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Efficiency evaluation indicators Voting of legislation Operation of internal structures for controlling transparency in General Government bodies Full compliance of Greece with international obligations within the period of “TRANSPARENCY” Development of joint legal initiatives for mutual support with at least six other countries Time required for reducing corruption cases by 50%

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Strategic Objective 4: Increased compliance with sound management regulations and increased accountability of public and private bodies (E4) The reform of the Public Sector remains a central issue of anti-corruption policy because the way in which public administration works creates an environment that favours corruption. The interaction between public and private sector must support the reform with every opportunity by developing anti-corruption actions which have an impact on all sectors.

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Α. Analysis of Strategic Objective

Policy axes (A): E4.A1. Strengthening of compliance with the legal and regulatory framework E4.A2. Review and updating of systems, processes and institutional behaviours which obstruct compliance with regulations and accountability E4.A3. Monitoring of compliance with established accountability standards E4.A4. Reinforcement of professional standards in all public bodies and services

Expected results:

 



Increased accountability in all ministries and departments

Measurable results: 

Assessment of risk and anti-corruption methods and annual reports from all bodies and all sectors, including Local Authorities



Targeted training of mid-level personnel in all sectors



Consistent implementation of recommendations made in anti-corruptions reports

Improvement of public faith and trust in the anti-corruption actions  of the government  Implementation of annual comprehensive accountability cycles

Improved information storage standards Assessment of anti-corruption methods and fraud cases relating to the use of EU funds, aiming to improve the Greek management and control systems.



Annual accountability reports from all ministries, departments, agencies, Local Authorities and their various bodies



Annual assessment of accountability level

Key success factors: 

Political and Administrative commitment for enforcing increased accountability



Active promotion of improved accountability standards.



Taking the reform of public services seriously into account

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Β. Goal-timescale diagram

Policy axis

Objective

E4.A1. Strengthen compliance with the legal and regulatory framework

E4.A1.1. (1.7). Consideration of the particular needs in high risk topics and sectors vulnerable to corruption like tax administrations, national health services, public works, (military) procurement and contracts, entrepreneurial investment state loans and local government, and establishes the standards and principles on which the specific administrations / institutions should base their own efforts to enhance the fight against corruption regarding their own activities. For the detection of high risk sectors and for the purpose of keeping it updated there should be a clear risk assessment strategy

Actions

E4.A1.1.1. Annual reporting on antiCorruption action plans in all sectoral areas

E4.A1.1.2. Overall picture of corruption per institution (including Local Govs) and of the proposed sector specific strategy

Timeline

Order of responsibility

Dec-13

Ministry of Interior

Nationa l Coordin ator

General Secretariat for Transparen cy and Human Rights

Jun-13

Ministry of Interior

Nationa l Coordin ator

Ministry of Administrati Ministry ve Reform of and eFinance Governance

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E4.A1.2. (1.8). A focused sector specific assessment and understanding of corruption issues should be set up for certain individual sectors, agencies, and functions. This will provide the basis for concrete actions against corruption which while individually small can add up to significant progress in aggregate.

E4.A1.2.1. Identification of vulnerable areas for corruption inside the General Government's structures and development and implementation of riskassesment strategies and concrete action plans to improve the situation

E4.A1.3. (3.13). Strengthen capacity and skills of internal control units / departments and enhance efficiency of disciplinary procedures and their final outcome

E4.A1.3.1. Core of antiCorruption champions / focal points developed in all General Government bodies

Jul-13

Advisor y Body

Nationa l Coordin ator

Dec-13

Nationa l Coordin ator

Ministry of Interior

Ministry of Administrati Ministry ve Reform of and eInterior Governance

Coordi nation Comm ittee

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“TRANSPARENCY” - Anti-Corruption National Action Plan

E4.A1.4. (3.14). Introduction of public officials and integrity tests.

E4.A1.5. (3.11). Strengthen reporting of corruption by public officials

E4.A1.5. (1.10). Begin iplementation of the sector-specific strategies by the relevant ministries (as soon as each startegy developed)

E4.A1.4.1. Make available antiCorruption information and training for newcomers and key middlemanagement groups and individuals in General Gov ernment bodies E4.A1.5.1. Annual status assessment reports on accountability and antiCorruption issues

E4.A1.5.1. Develop a sound monitoring of results.

Dec-13

Ministry of Interior

Nationa l Coordin ator

Dec-14

Nationa l Coordin ator

Ministry of Interior

May-13

Nationa l Coordin ator

Ministry of Interior

General Secretariat for Transparen cy and Human Rights

General Secretariat for Transparen cy and Human Rights

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

E4.A2. Review and update systems, procedures and institutional behaviour that impede compliance and accountability

E4.A2.1. (1.9). Assess how to tackle corruption and related fraud issues specifically linked to the use of EU funds with a view to improving Greek management and control systems.

E4.A2.1.1. Research on methods and tools to improve Greek management and control systems to tackle corruption and related fraud issues specifically linked to the use of EU funds.

E4.A2.2. Investigate the reasons for a lack of implementation of recommendations of anti-Corruption agencies and make recommendations for resolution of the situation

E4.A2.2.1. Legal and regulatory changes to ensure enforcement of findings of anti-Corruption annual reports

Dec-13

Dec-13

Coordin ation Commit tee

Coordin ation Commit tee

Advisor y Body

OLAF

Nationa l Coordin ator

General Secretariat for Transparen cy and Human Rights

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“TRANSPARENCY” - Anti-Corruption National Action Plan

E4.A3.1. Strengthen the maintenance of records by MDAs and Local Governments and use it as a key partner to accountability

E4.A3. Monitor compliance E4.A3.2. Conduct assessments of with MDA and Local Government established compliance with statutory requirements standards of accountability

E4.A3.3. Review of annual reports submitted to Parliament by the General and Local Govs on actions taken on corruption cases

E4.A3.1.1. Enforcement of regulations

E4.A3.2.1. Annual compliance performance reports

E4.A3.3.1. Annual report of actions taken by General and Local Government on Corruption cases

Jul-15

Ministry of Adminis trative Reform and eGovern ance

Nationa l Coordin ator

Ministry of Interior

Dec-13

Ministry of Adminis trative Reform and eGovern ance

Nationa l Coordin ator

Ministry of Interior

Dec-13

Nationa l Coordin ator

ΒτΕ - HP

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

E4.A4. Enhance the professional standards in public service organisations

E4.A3.4. Research and make proposals for the incorporation of Integrity/Accountability Statements into Budget Cycle requirements and Ministerial Statements

E4.A3.4.1. Increased annual accountability reporting

E4.A4.1. Address performance and accountability in the public service through the implementation of the Public Service Reform Programme

E4.A4.1.1. A more affordable, efficient and accountable public service

E4.A4.2. Monitor public attitudes to accountability issues and service delivery

E4.A4.2.1. Increased knowledge of the impact of professionalization on quality service delivery

Jul-13

Nationa l Coordin ator

Ministry of Interior

Dec-14

Ministry of Interior

Nationa l Coordin ator

Dec-15

Ministry of Adminis trative Reform and eGovern ance

Nationa l Coordin ator

Ministry of Interior

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“TRANSPARENCY” - Anti-Corruption National Action Plan

Efficiency evaluation indicators Reporting of anti-corruption cases in bodies, services and Local Authorities Individual / sectoral anti-corruption actions Identification of high risk areas for corruption Annual reports on integrity / accountability issues Assessment of integrity of public bodies (National Integrity Survey) Implementation of the public sector reform

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

Strategic Objective 5: Reinforced implementation of the “TRANSPARENCY” anti-corruption plan (E5) This objective aims to support the development of the overall ability for strategic implementation and the ability of bodies to plan and manage their actions in the most efficient possible way. Furthermore, it gives high priority in the control of corruption in high risk sectors, concerning important issues of national significance and high economic importance.

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Α. Analysis of Strategic Objective

Policy axes (A): E5.A1. Reinforcement of institutional capabilities, standards and planning E5.A2. Strengthening of planning, coordination and implementation of anti-corruption action plans E5.A3. Commencement of monitoring, control and assessment system for “TRANSPARENCY” anti-corruption action plan Expected results:

Measurable results: 

Agreed policy between anti-corruption bodies in relation to information management, training, resources and role allocation

 

Increased strategic and operational efficiency of anti-corruption bodies

Reinforcement of the institutional capabilities and resources for law enforcement in order to investigate and prosecute cases of corruption and offences relating to economic crime.



Strengthening of anti-corruption actions in  high risk sectors, concerning important issues of national significance and high economic importance.



Increased public trust in the operation of anti-corruption bodies

Coordination of the investigations in areas and sectors which are prone to corruption, such as tax authorities, national health services, public works, (military) procurement and contracts, business state loans and local government



Development of strategic assessment of corruption risk



Anti-corruption research programme



Agreement between anti-corruption bodies on the framework for the coordination of actions

Key success factors: 

Willingness of anti-corruption bodies to cooperate and dedicate time and resources



Available resources

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

Β. Goal-timescale diagram

Policy axis

Ε5.Α1. Strengthen antiCorruption planning, coordination and implementation

Objective

Actions

Ε5.Α1.1. Development of training policy to support longterm anti-Corruption strategic planning and capacity development

Ε5.Α1.1.1. Conduct common training activities and capacity development for antiCorruption agencies and members of the Coordination Committee

Ε5.Α1.2. (4.1). Train staff of Inspector General and the office of the commissioner general of the state, inspection bodies of ministries, SDOE, Financial Police, Financial Prosecutors and FIU in anti corruption investigations. Training of judges should also be considered.

Ε5.Α1.2.1. (4.2). The training program consists of three levels. A general level to trigger identification skills of investigators for larger groups

Timeline

Order of responsibility

Sep-13

Coordinati on Committe e

National Coordina tor

Advisor y Body

Aug-13

Coordinati on Committe e

National Coordina tor

Advisor y Body

Ministry of Adminis trative Reform and eGovern ance

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Ε5.Α1.2.2. (4.3). The second level consists of in depth training for smaller groups of dedicated financial investigators, including specific topics, methods and techniques that can be different per organization

Ε5.Α1.2.3. (4.4). The third level consists of training on the job for a few handpicked professionals on particular topics and ongoing investigations.

Ε5.Α1.3. Undertake a financial, human resource, equipment and logistical study of anti- Corruption agencies to establish the sector needs and assist with future planning

Ε5.Α1.3.1. Resource needs identified / planning exercise undertaken

Aug-13

Coordinati on Committe e

National Coordina tor

Advisor y Body

Aug-13

Coordinati on Committe e

National Coordina tor

Advisor y Body

Jul-13

Coordinati on Committe e

National Coordina tor

Advisor y Body

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

Ε5.Α1.4. Provide support for the improvement of financial and resource planning and capacity

Ε5.Α1.4.1. Improved capacity to plan and manage financial, physical and human resources

Ε5.Α1.5. (5.4). Establishment of a central place /unit where reports on corruption could be received and analyzed.1

Ε5.Α1.6. (5.2). Explore on the possibilities to give access to the tax audit platform Elenxis to the organisations involved in the anti corruption network

Dec-14

National Coordinat or

Coordina tion Committ ee

Ε5.Α1.5.1. To be decided by the national coordinator after his/her appointment

Apr-13

Prime Minister

National Coordina tor

Ε5.Α1.6.1. To be decided by the national coordinator after his/her appointment

May-13

Prime Minister

National Coordina tor

1

For suspicious transactions reports related to money laundering linked to corruption from financial institutions this is clearly the FIU. For reporting between (inspecting and investigating) authorities it might be helpful to consider bundling of information. The national coordinator or an independent anti corruption body could be such a place.

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Ε5.Α1.7a. Drawing up typologies regarding the link between corruption and money laundering, including making use of the Financial Action Task Force Reports on Laundering the Proceeds of Corruption and Red Flag Indicators. Ε5.Α1.7b. (5.1). Explore and advise on the best way to set up a central registry of bank accounts, which is highly beneficial to support law enforcement and creates efficiency benefits for the financial institutions. Ε5.Α1.7c. (5.3). Strengthening the feedback given by the FIU by exploring the possibilities to exchange information, for example by concluding MoU's between the FIU and other participants in the anti corruption network. Ε5.Α1.7c. (1.6). Explore and be adviced on including in TRANSPARENCY as an action the relevant measures from the already agreed Road Map on Anti-Money Laundering.

Ε5.Α1.7.1. Strengthen records and information management within all anti-Corruption agencies including reviewing and improving Management Information Systems, Case Management Systems, data bases and physical records

Jun-15

Coordinati on Committe e

National Coordina tor

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E5.A2. Strengthen antiCorruption planning, coordination and implementation

Ε5.Α1.8. (4.5). Coordinate investigations in high risk areas like tax, health and urban planning.

Ε5.Α1.8.1. Coordination of the investigations and controlling in vulnerable areas and high risk sectors like tax administration, health services, public works, (military) procurements and contracts, bussiness's state loans and Local Govs public expenditure, contracts and budgetary process

Ε5.Α2.1. (3.6). Explore and advise on measures to ensure transparency of public expenditure, public contracts and budgetary process

Ε5.Α2.1.1. Develop internal and external coordination mechanisms to support the work of the Coordi nation Committee and "TRANSPARENCY" implementa tion

Aug-13

Coordinati on Committe e

National Coordina tor

Apr-13

Coordinati on Committe e

National Coordina tor

Advisor y Body

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“TRANSPARENCY” - Anti-Corruption National Action Plan

Ε5.Α2.2. (1.2). Consideration of the particular needs in high risk sectors like tax administration, health, etc.

Ε5.Α2.2.1. Each sector specific strategy is an undivided part of this one and is attached to this as an annex as to conserve its implementation independence

Ε5.Α2.3. Identify the key information needs of the anti-Corruption agencies and devise information gathering systems that will support policy development and implementation for use by "TRANSPARENCY"

Ε5.Α2.3.1. Information systems established

May-13

Coordinati on Committe e

National Coordina tor

Jun-13

Coordinati on Committe e

National Coordina tor

Advisor y Body

Ministry of Finance

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

Ε5.Α2.4. (4.6). Strengthening law enforcement institutional capacities and resources to proactively investigate and prosecute corruption and economic crime-related offences.

Ε5.Α2.4.1. Active and mutually supportive coordination

Ε5.Α2.5. Establish research programme to support policy development and implementation in conjunction with key stakeholders of "TRANSPARENCY"

Ε5.Α2.5.1. Research programme undertaken

Ε5.Α2.6a. (3.2). Provision of tools and mechanisms to monitor anti corruption measure implementation. Ε5.Α2.6b. (3.8). Provision of monitoring tools and proceedings on anti-corruption related measures.

Ε5.Α2.6.1. Initiate joint annual planning with the Accountability Sector to ensure effective coordination

Jul-13

National Coordinat or

Coordina tion Committ ee

Advisor y Body

Dec-14

Coordinati on Committe e

National Coordina tor

Advisor y Body

May-13

National Coordinat or

Coordina tion Committ ee

Advisor y Body

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E5.A3. Initiate "TRANSPARENCY " monitoring and evaluation system

Ε5.Α2.7. (3.3). Introduction of corruption screening mechanisms.

Ε5.Α2.7.1. Coordinated planning mechanism achieved

Ε5.Α3.1. Device and implement a Coordina tion Committee agreed Monitoring and Evaluation policy and practice for the "TRANSPARENCY"

Ε5.Α3.1.1. Coordinated and agreed approach to Methods and Evaluation procedures

Ε5.Α3.2a. Monitoring, implementation and feedback policy to achieve quality and impact of actions against corruption including Ε5.Α3.2b. (3.1). introduction of regularly updated risk assessments

Ε5.Α3.3. (1.5). Update the strategy on a continuous basis, discussing new measures and tools as appropriate

Ε5.Α3.2.1. Quantitative and qualitative assessment of effectiveness of antiCorruption action and cyclic risk re-assesment

Ε5.Α3.3.1. Undertake a Joint Annual Review of "TRANSPARENCY" a ctivities and performance with key stakeholders

Oct-13

National Coordinat or

Coordina tion Committ ee

Aug-13

National Coordinat or

Coordina tion Committ ee

Aug-13

National Coordinat or

Advisory Body

Oct-13

National Coordinat or

Coordina tion Committ ee

Advisor y Body

Advisor y Body

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

Ε5.Α3.3.2. Publication of joint annual review reports

Ε5.Α3.4.1. Evaluation methodology of corruption vulnerability for high-risk areas

Oct-13

National Coordinat or

Coordina tion Committ ee

Advisor y Body

Aug-13

Coordinati on Committe e

National Coordina tor

Advisor y Body

Jul-13

National Coordinat or

Coordina tion Committ ee

Advisor y Body

Ε5.Α3.4. Development of evaluation methodologies Ε5.Α3.4.2. Bi-annual evaluation and review of "TRANSPARENCY"

Efficiency evaluation indicators Systems for collecting information, installed and in operation Strategic decisions relating to the coordination of the fight against corruption Anti-corruption research programme, in operation Detailed reports and work plans submitted for annual joint review Activated mechanisms for the control and assessment of “TRANSPARENCY” Joint policy on education and plan for the joint use of resources, in operation Information and communications systems in operation Resources allocation planning

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3.2. IMPLEMENTATION The “TRANSPARENCY" anti-corruption national action plan gives the strategic direction of anti-corruption policy and the various actions. It helps all anti-corruption bodies to implement their important mission, while at the same time recognises their institutional independence. The important elements for producing results are the efficient implementation and the subsequent control and assessment. It is evident that the current individual measures have not offered any results and in certain cases they were proven to be inadequate. This is the first lesson and this is why the measures of the “TRANSPARENCY” national action plan will be implemented without any exceptions, everywhere and throughout the duration of the plan. At this point in particular, it is important to underline the significance of two elements: the coordination of all the parties involved in the “TRANSPARENCY” plan - anticorruption bodies, public and private bodies - and the provision of technical support to this whole endeavour. In order for this effort to have any results, it requires the highest possible degree of coordination in order to ensure the implementation, progress, efficient management and assessment of the “TRANSPARENCY” plan as this will be implemented horizontally across the whole public and private sector and vertically by penetrating all social classes. This will also be further reinforced by the contribution of the anti-corruption National Coordinator in combination with the nature or the independence of the various bodies involved. These bodies, on their part, will have to demonstrate the highest possible spirit of cooperation and mutual understanding during the implementation of

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the “TRANSPARENCY” plan.

3.2.1. IMPLEMENTATION PRINCIPLES Maximum acceptance of the “TRANSPARENCY” Plan: the implementation of the “TRANSPARENCY" plan requires the support of a wide range of participating people, bodies and groups. They must all feel part of the “TRANSPARENCY” plan, as this is essential for its successful implementation. It is very important that all public bodies as well as private partners and any other third parties respond to this call for participating in the implementation of the “TRANSPARENCY” plan. It is equally important that they all show their faith and dedication to this effort and that they are all involved closely to the development of the “TRANSPARENCY” plan in order for the plan to take its final implementation form and be passed on to experts for feedback. Connection of “TRANSPARENCY” plan with institutions and policies: the success of the “TRANSPARENCY” plan depends to a large extent, as mentioned already, on the willingness and the participation of as many public bodies and services as possible (ministries, departments and services). Consequently, there is an increased responsibility of the National Coordinator for the promotion of the “TRANSPARENCY” plan, who must convince and motivate many people as possible in the private and public sector, in order to create more synergies and maximise the breadth and the performance of the “TRANSPARENCY” plan. The promotion of good practices through accountability as well as anti-corruption policies will not only require training and awareness- raising, but also will trigger a series of actions and changes of attitudes. Even those institutions that are not responsible for being actively involved in the plan must actively participate and take actions in order to at

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least be aligned with the objectives of the “TRANSPARENCY” plan. Determined political leadership: the “TRANSPARENCY” plan must be known to the society and must be synonymous to the Government’s zero tolerance to corruption. The progress in reducing corruption in all sectors depends primarily on the full commitment of the political and administrative leadership. The government must demonstrate its determination for changing attitudes by starting from within. The management of public and private bodies must also lead in setting an example, ensuring the quality (of management and services), accountability and control of corruption within their own structures. Anything less than a full and clear commitment, will be an obstacle to the success of the “TRANSPARENCY” anti-corruption plan and will also give rise to opportunities for corruption and rapid deterioration of the attitude of the public.

3.2.2. RESEARCH, DATA AND INFORMATION

The “TRANSPARENCY” plan is expected to provide support and have an impact on national policies and priorities in government issues (economic policy, activities of ministries, administrative reform, state procurements). There is a significant amount of information in relation to corruption in Greece and many theoretical proposals for fighting against it, but very little research has been carried out on practical and applicable methods which can support a comprehensive anti-corruption policy.

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It will therefore be an important role of the “TRANSPARENCY” plan to promote and, if possible, carry out quality research for gathering useful information for future actions and responses to possible problems. The collection of accurate and reliable information will be very useful during the control process of the implementation of the “TRANSPARENCY” plan. Although this information will be used to fully support the implementation of the “TRANSPARENCY” plan, it is proposed that the data and information collection programme for the “TRANSPARENCY” plan should be interconnected to the Programme for the Control, Coordination and Monitoring of Government Activity, in order to provide it with information which can then be efficiently coordinated on a national level. The action needed for collecting information and data for the purposes of the “TRANSPARENCY” plan, will be the first mechanism for the management of information. Then there will be an agreement between the relevant bodies (e.g. the Hellenic Statistical Authority - ELSTAT) in the context of the “TRANSPARENCY” plan, concerning a more specialised programme for the management and use of collected information and data as well as the sources and frequency. The Hellenic Statistical Authority (ELSTAT) must play a central role by contributing in the collection of information on a systematic basis and by submitting this information, organised in accordance with specific certified standards, to the national coordinator. It is recommended that ELSTAT should be recognised as the official voice of the government concerning the collection and analysis of systematic and accurate information that will support the establishment of an improved policy for transparency based on facts.

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3.2.3. FINANCING

It is important that the financing of the “TRANSPARENCY” plan and any individual or local actions is secured. The National Coordinator must set up a detailed budget and schedule for the provision of resources and the same must also be done with all individual and local action plans. All financing plans and relevant activities must be monitored closely by the National Coordinator and corrective measures must be taken every six months in order to ensure that the programme is always on track also in terms of its finances.

3.2.4. SCHEDULE – EXECUTION STAGES

The development of the “TRANSPARENCY” plan is proposed to be carried out in three stages:

3.2.4.Ι. START During this stage, specific activities that will make the “TRANSPARENCY” plan operational will be implemented: 

Printing, creation and distribution of the “TRANSPARENCY” Plan:



Establishment of all the aforementioned necessary structures for the implementation

as

well

as

mechanisms

for

the

operation

of

the

“TRANSPARENCY” plan.

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS



Finalisation of the schedules of actions and their budgets.

This stage must have been completed before the end of March 2013.

3.2.4.2. INITIAL IMPLEMENTATION The 1st year (until December 2013) will be used as the implementation phase as well as a testing phase, i.e. it will be a pilot year of implementation that may lead to improvements so that the plan will become more effective, as to succeed its aims faster and with more accuracy. During this time, it must be ensured that all planned actions have started, the viability of implementation methods has been tested and lessons have been extracted in order to take corrective measures and actions, if necessary.

3.2.4.3. FULL IMPLEMENTATION During this stage, the full implementation will begin, following strictly on a monthly basis, the detailed annual schedule of the “TRANSPARENCY” plan, with a detailed analysis of all costs for the main as well as individual and local action plans. This phase will start in January 2014. It must become part of the responsibility of all participants of the “TRANSPARENCY” plan (public and private bodies), and they must include it in their strategic and economic planning for 2014. It is very important that all anti-corruption bodies participate actively in the planning and that they heighten their activities as much as possible in order to provide support to public (or private) services in aspects of technical expertise during the implementation of the “TRANSPARENCY” plan.

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3.3. MONITORING AND CONTROL

Fighting against corruption does not and may involve a single person, department or body. It does and must involve all entities of an organised society. Institutions, bodies, organisations, society, individuals. Each entity and each institution plays a role in the fight against corruption. All efforts however must be coordinated by a central point. 3.3.1. COORDINATION, SUPPORT It is proposed that a National Coordinator who believes in transparency (so that he himself will be an example with his way of living and acting) is appointed, with the responsibility to mobilise all entities in all sectors to jointly fight against corruption. The National Coordinator must watch and monitor the progress of the action plan, coordinate its actions, evaluate the progress and submit to the parliament and the government progress reports which will be subject to annual review. It is proposed that, in the structure of the anti-corruption governance, the National Coordinator will be supported by committees. These committees consist of all institutional bodies which will participate in the fight against corruption through the implementation of the “TRANSPARENCY” plan. Among them, an important role is expected to be played by an advisory body, with the participation of senior scientific bodies and other organisations, as required, such as: i.

Scientific bodies

ii.

Chambers of Commerce and Industry

iii.

Professional Associations

iv.

Social Organisations

v.

Educational Institutions

vi.

Mass Media 102

GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

vii.

International Advisory Bodies

The key strategic partners of the National Coordinator are the government departments. The most important decision must be the strong determination of the government to start by fighting against corruption within itself. To safeguard administrative and operational continuity, it is recommended that the office of the National Coordinator will be staffed by permanent civil servants transferred from any other public service). It is also porposed that the necessary funds will be allocated to his/her office for the personnel salaries and operational needs. The exact description of the position, the responsibities and the structure and support of the national coordinator will be decided by the prime minister and will be drafted to a law to be presented and approved by the parliament.

Professionalism - Ethics – Accountability All anti-corruption agencies including the Office of the National Coordinator must ensure the professionalism and ethical conduct of its personnel. Apart from ethical values and professionalism, the entire anti-corruption personnel, in order to support its role, is expected to show a high level of cooperation but also personal responsibility, high level of integrity and accountability, faith in transparency and passion for its implementation. The entire ant-corruption personnel including the Office of the National Coordinator must be selected on the basis of an increased awareness of the importance of their role and the responsibilities that arise from failing to carry out their duties.

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3.3.2. FUNCTIONAL INDEPENDENCE AND RESOURCES

As far as the allocation of resources is concerned, as mentioned above, all three aspects of the “TRANSPARENCY” plan (Deterrence, Prevention, Education) are equally important for achieving its objectives. However, the most successful international practices have shown that the greatest need for resources is in the area of Deterrence (enforcement). Approximately 70% of the resources is usually allocated to the operational part. The reason is that any corruption prevention and education initiatives are destined to fail in a corrupt country where corrupt senior employees are still in power. The key areas of government policy where there will be a significant degree of cooperation between them and will be at the forefront of the implementation of the “TRANSPARENCY” plan, while at the same time maintaining their operational independence, will be the areas of education, administrative reform, economy, justice and public order. Therefore, the efficient enforcement of specific goals is of high priority, in order to overcome any obstacles and demonstrate the political will and determination for the control of corruption to the public. This will also be a sign of efficiency for the anti-corruption mechanism. Without these, it is almost impossible to have any public support, which is one of the keys to success. The successful enforcement will also help in identifying problematic areas for reviewing the anti-corruption prevention measures and can also overcome any possible human obstacle in the review process.

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The success stories of the enforcement of transparency will also provide the basis for public education and act as deterrents for the remaining corrupt senior employees. As far as the required resources are concerned, best international practices show that the success of a national anti-corruption strategy, requires the allocation of 0.010.3% of the national budget, which shows the political determination of the government for the control of corruption. This figure, for the most successful strategies, reaches 0.38% of the budget or 0.05% of GDP.

3.3.3. MONITORING AND IMPLEMENTATION MECHANISM

Within the structures of the National Coordinator, there will be an institutional framework for monitoring the progress of the implementation of the central as well as all individual

anti-corruption

strategies, under

the

name

of

Transparency

Observatory. This will be responsible for the monitoring on a monthly basis of the execution of individual anti-corruption strategies of all organisations and bodies. In the event that deviations are identified, the body concerned will be notified of its obligation to immediately reform its programme in order to be harmonised with the qualitative and quantitative targets and inform the National Coordinator accordingly.

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If one month after the deviation was identified the concerned body continues to present deviations, then a decision will be issued by the National Coordinator and the Minister for Finance, with which this body will have the same consequences that occur in the case of non-compliance with the mechanism for monitoring its financial obligations.

3.3.4. INTERNAL CONTROL STRUCTURES

In order for the above to be implemented, the National Coordinator must have access to direct contact with the leadership of all necessary institutional and administrative structures. This will allow the National Coordinator to have a picture of the current situation of corruption, at any time, as well as provide information on the progress of the implementation of the “TRANSPARENCY” plan. In order for the National Coordinator to have a complete picture, all General Government

or

private bodies, is categorised, for the

purposes of the

“TRANSPARENCY” plan, in one of six (6) levels in total. This ensures that the full range of government activities or interactions between citizens and private or public bodies are covered: Levels of Services 1.

The parliament (its members and all administrative structures).

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

2.

The government (its members and administrative structures that belong directly to it)

3.

The political parties, organisations and their bodies (services and administrative structures)

4.

The leading (political) authority of any service (Mayors, Directors, Councils, Secretary Generals etc.)

5.

The leading (administrative) authority of a service of the previous level (Directors, Managers) and all administrative structures of the above.

6.

The level that includes bodies that interact directly with citizens i.e. any place that offers goods or services directly to citizens, governed either by private or public law, such as Hospitals, Universities, Surgeries, Clinics, Schools, Factories, Ministries, Shops, Banks, Planning Authorities, Municipalities, Prefectures, Tax Offices, Museums, Sports Facilities, Churches etc.

Each service of any level: 

will receive the anti-corruption “TRANSPARENCY” plan by the National Coordinator



will also receive a letter and a document with instructions on developing an individual/local “TRANSPARENCY” plan



will establish, within a specified period, an internal structure (department/office) and a person responsible for the implementation of the “TRANSPARENCY” anti-corruption national action plan locally



will coordinate the services under its control and will keep its superior authority informed or will cooperate with the national coordinator for issues regarding the implementation, monitoring and improvement of the efficiency of the actions of the project.

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Furthermore, the person which is responsible for the implementation of the plan (in collaboration with the office of the National Coordinator): 

will

develop,

within

a

specified

timeframe,

an

individual/local

“TRANSPARENCY" plan and code of conduct (under the instructions of the National Coordinator) 

will submit, within a specified period, the local “TRANSPARENCY” plan for approval (sanctions will be imposed in the case of late or no submission)



will carry out all planned actions for the preparation of the implementation of the local “TRANSPARENCY” plan



will begin the implementation of the programme with the participation of the public



will monitor the progress of the programme and will inform its superior authority



will implement all necessary improvements which are proposed

For the purpose of simplifying the implementation/monitoring and planning, the local/individual

national

plans

and

codes

of

conduct

will

follow specific

standardisation rules and will be divided into two broad categories depending on the type of service: 

action plans: for services which participate actively to one of the implementation stages of the “TRANSPARENCY” plan.



supporting plans: for services which play a supporting but equally crucial role for the efficient implementation of the “TRANSPARENCY” national action plan.

In any case, each service provider, with any role, will distribute and implement the “TRANSPARENCY” anti-corruption plan and all personnel will comply with code of conduct rules in relation to professional behaviour and any actions that concern their work

in

general.

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Notes o

the office of the National Coordinator will record the level of each service provider

o

the role of each service provider will be specified by the National Coordinator in cooperation with the Prime Minister

o

the level, role, number of staff, assessment and other elements of each service will be coded in a single unique code for each service provider, which will be described in detail in an electronic database which will be kept and monitored centrally and will be updated peripherally and will operate in conjunction with other databases which are already in operation for similar purposes.

o

Non-compliance of the above obligations automatically incurs penalties which depend on the service provider, in the same way as in the case of non-compliance with financial obligations or where these do not exist, with the relevant codes of conduct.

3.3.5. THE ROLE OF THE MINISTRIES

All Ministries must play a leading role in the fight against corruption starting from within. As a first step, there must be anti-corruption summits of the political leaders of ministries, chaired by the National Coordinator.

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It is important for them to understand (and for the National Coordinator to convince them) that there are many things that they can and they should do. They must finally reach an agreement on a specific action plan which will be implemented by the ministries, such as: 1)

Establishment of their own internal mechanism/structure for the control of

corruption (internal control department), in the form of internal units for monitoring personnel function as well as internal financial control units 2)

Review of processes and systems in order for them to be more transparent

and for ensuring accountability 3)

Establishment of, or improvement of existing, codes of conduct which include

provisions for the acceptance of gifts and invitations. 4)

Introduction of a system for reporting conflicts of interest

5)

Establishment of an open and fair recruitment and promotion system, as well

as a system for ensuring its integrity 6)

Introduction of personnel training in areas of ethical conduct and corruption

prevention - Point system 7)

Leadership by example

8)

Promotion of zero tolerance to corruption

9)

Strengthening the complaints procedures and providing information about

them (e.g. hotlines), both for public as well as internal and confidential complaints. 10)

Forwarding reported complaints to the competent anti-corruption body and

collaborating fully with them for investigating each case.

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11)

Complete confidentiality in relation to complaints and their investigation.

12)

Establishment of frameworks for the cooperation of anti-corruption bodies,

media and international charity organisations for the development of advertising campaigns and transparency public awareness plans.

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3.4. EVALUATION AND SELF-EVALUATION

3.4.1. EVALUATION

The “TRANSPARENCY” plan will be evaluated at the end of each calendar year. After the first and after the second year, it is proposed that an independent evaluation is carried out in order to determine the progress in all strategic objectives and identify all areas that require special attention. At the end of the first year there will be an initial evaluation which will also act as a guide for future directions. The lessons obtained from the first year will lead to corrective actions where necessary, in order to ensure the correct implementation of the “TRANSPARENCY” plan for the remaining period. Between the second and third year of the implementation of the “TRANSPARENCY” plan, there must be a significant interim evaluation which will examine the overall progress and determine the extent to which the “TRANSPARENCY” plan and the zero tolerance policy have been successful. At the end of the third year (2015), there will be an official, overall evaluation of the whole operation which will examine the qualitative elements of the implementation, its penetration into society and other factors that affected the implementation of the “TRANSPARENCY” plan as well as conclusions that will help future planning. This evaluation will be combined with the subsequent strategic planning for transparency (2016-2021), which is expected to be ready by October 2015.

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3.4.2. REGULAR UPDATES AND IMPROVEMENTS OF THE “TRANSPARENCY” PLAN

The “TRANSPARENCY” plan must not be a static text and therefore also takes into account any development that will take place in the future, since corruption is a continuously changing phenomenon. There are already many parallel activities which can influence the future implementation of the “TRANSPARENCY” plan. This is why the proposed plan provides the necessary flexibility for adapting its actions and its content in order to include any possible future developments.

3.4.3. ANNUAL CONSOLIDATED REPORTS IN COLLABORATION WITH EXTERNAL INDEPENDENT ASSESSORS

It is proposed that the review of the “TRANSPARENCY” is open to the society and external partners. The active participation of the society will promote further the implementation of the “TRANSPARENCY” plan and a greater degree of reliability for the intentions of the government. It is proposed that the independent bodies must be selected based on specific criteria for their participation in the annual review for the progress of the “TRANSPARENCY” plan together with the national coordinator who will be responsible for the overall supervision of the plan. These independent bodies will express their opinions on the purpose and the quality of the implementation of the plan. This opinions and conclusions will be presented all together in a joint annual report. It is also important that this review is prepared well in advance and that it is carried out using a standardised process for producing satisfactory results.

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It is also important that this review of the “TRANSPARENCY” plan which is carried out on a national scale, is linked to other international or domestic (national, individual and local) evaluations which might have been carried out, in order for the review of the objectives of the “TRANSPARENCY” plan to be fully supported.

3.4.4. REGULAR CONSULTATIONS WITH EUROPEAN AND INTERNATIONAL PARTNERS FOR IMPROVEMENTS IN THE FIGHT AGAINST CORRUPTION

The duties of the National Coordinator must also include regular consultations with other countries and international organisations, so that there is sufficient communication on the developments and the use of technical expertise and also for publicising the great efforts made by our country. It is extremely important, that our European and international partners, either as countries or as collective bodies and organisations, are informed on a regular basis regarding the planning and the progress of our country in the control of corruption. This will ensure that, over a period of time, transparency can become Greece's export

to

the

world

and

form the

basis for

attracting

investment

and

entrepreneurship.

3.4.5. REGULAR PRESENCE IN THE MEDIA WITH HIGH-PROFILE DEBATES ON PRINCIPLES, VALUES AND CORRUPTION INVOLVING DISTINGUISHED MEMBERS OF THE SOCIETY

Public information and familiarisation are key ingredients for the implementation of the “TRANSPARENCY” plan. Therefore, it is proposed that distinguished members of the society from politics, business, science, sports, arts etc., must be activated and grouped, and also be invited to participate in debates or shows (regular or 114

GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

periodical) on television. These debates will look at high-level strategies, public opinion and social issues that relate to issues of integrity, transparency and moral principles and values, creating a national dialogue on such crucial issues for society.

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4. ANNEXES

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GENERAL SECRETARIAT FOR TRANSPARENCY AND HUMAN RIGHTS

4.1 SOURCES

SOURCES OF INFORMATION NATIONAL PLAN

USED

FOR

“TRANSPARENCY”

The sources of information were divided into categories depending on the type of information they provide and the way that this information was used.

4.1.1.

ORGANISATIONS TOWARDS WHICH WE HAVE NATIONAL OBLIGATIONS Α. Organisations with future assessments => Need for immediate efficiency (there are implementation deadlines) MEMORANDA ROAD MAPS OECD CONVENTION IMF GRECO Β. Organisations without future assessments UN CONVENTION EU (2011 MECHANISMS, REGISTER ETC) ECB WORLD BANK OSCE

4.1.2. SOURCES WITH PROPOSALS BUT WITHOUT OBLIGATIONS TRANSPARENCY INTERNATIONAL, GENERAL INSPECTOR OF PUBLIC ADMINISTRATION, PARLIAMENTARY COMMITTEE FOR INSTITUTIONS AND TRANSPARENCY, ERCAS, G20, IACA 4.1.3 . OTHER SOURCES INTERNET, PUBLICATIONS, STUDIES, SURVEYS, BOOKS

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4.2 ATTACHED DOCUMENTS A. Tax and Customs Administration's strategy to fight corruption B. MoU for an anti-corruption strategy between TFGR and the Ministries of Justice, Finance, Protection of the Citizen and of Public Administration and eGovernment. C. Anti-corruption Road Map that signed between the above parties and agreed to be included in and implemented trough the implementation of the National anti-corruption Plan.

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