© OECD

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

The role of the Court of Accounts in preventing and fighting fraud and corruption

Intosaint Selmi Nesrine, Court of Accounts, Tunisia

Algiers, 8-9 April 2015

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

Concept of integrity has a wide scope,

beyond fraud and corruption

Self Assessment helps to promote

integrity awareness =>

SAINT

SAIs can lead by example and

learn from each other =>

IntoSAINT

1

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

Integrity?

2

- Integrity is defined by time, place and

function

- Integrity is also about values, norms and

decency

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

3

Personal integrity

Individual characteristics of honesty, trustworthiness and uprightness

Behaviour that complies with defined standards and rules

Acting in the public interest / not private interest

Civil servants act with integrity if

they observe the values and

standards of good

administration

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

4

Organisational integrity

Behaviour of personnel defines integrity of organisation

Every organisation runs integrity-risks

Management responsibility to control these risks / remove temptations

It also refers to virtue, incorruptibility and the state of being unimpaired

An organisation must also

do all it can to ensure that

its personnel cannot

succumb to temptation

Integrity policy calls for a combination of

repression and prevention.

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

Precondition for government authority and public confidence

Integrity is a precondition for the effective and continuous performance of the public sector.

5

Integrity in the public sector

Integrity: not only laws and rules but also

moral responsibility

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

6

Two approaches of Integrity

Negative approach of Integrity Positive approach of Integrity

Rule based: Imposed Norms (law

and regulation)

Principle based: shared norms and

values (decency)

Hard controls Soft controls

Opinion: people are bad Opinion: people are good

Focus on preventing integrity

violations

Focus on facilitating good behavior

Legal focus Managerial focus

Repression/Reactive Prevention/Pro-active

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

7

Self Assessment

Integrity

Tool developed in co-operation with the Dutch Ministry of the interior and city of Amsterdam

Promotes integrity

awareness and prevention of

integrity breaches

Assess integrity

vulnerabilities (risks) and

maturity level of integrity controls

Workshop with cross section of

employees / utilising

knowledge and experience of

employees about risks and controls

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

8

Integrity public sector:

SAIs lead by example

Objectives

Strengthen role of SAIs as watchdogs of the integrity of the public sector;

exchange of experiences

between SAIs about enhancing

integrity.

Expected impact

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

9

Aim of the workshop

Using your combined knowledge

and experience, we aim to assess:

Vulnerability of processes

What do we need to worry

about?

What risks / temptations do we spot?

Maturity level of ‘integrity control

system’

What is already in

place?

How well is this

implemented?

Is it effective?

Recommendations for follow up

action

What more/else should we

do?

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

10

SAINT methodology

Object definition

- organisation

- processes

Assessment

vulnerabilities

Assessment Maturity level

Integrity Control System

Gap analysis

Recommendations

- Reducing vulnerability

- Strengthening controls

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

11

Assessment of vulnerabilities

Inherent vulnerabilities

Vulnerability enhancing factors

Vulnerability profile

Object definition

- organisation

- processes

Assessment

vulnerabilities

Assessment

Maturity level Integrity Control System

Gap analysis

Recommendations

- Reducing vulnerability - Strengthening controls

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

12

0.00

0.50

1.00

1.50

2.00

2.50

3.00

Contr

acting

Paym

ent

Gra

nting /

issuance

Regula

ting

Inspection /

audit

Enfo

rcem

ent

Info

rmation

Money

Goods

Real Esta

te

1 2 3 4 5 6 7 8 9 10

Score

Inherent vulnerabilities: medium

Average

StDev

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

13

0.00

0.50

1.00

1.50

2.00

2.50

3.00

Com

ple

xity

Change/d

ynam

ics

Managem

ent

Pers

onnel

Pro

ble

m h

isto

ry

1 2 3 4 5

Sco

re

Vulnerability enhancing factors: medium

Average

StDev

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

14

Vulnerability profile

Vulnerability

Enhancing

factors

Inherent

vulnerability

Low Medium High

Low

low low Medium

Medium

Medium Medium HIGH

High

High HIGH HIGH

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

15

Assessment maturity level Integrity Control System

The maturity level of the integrity

control system covers:

Existence of controls

Operation of controls

Effectiveness of controls

Object definition

- organisation

- processes

Assessment

vulnerabilities

Assessment

Maturity level Integrity Control System

Gap analysis

Recommendations

- Reducing vulnerability - Strengthening controls

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

16

Integrity Control System

General controls

1. Integrity policy framework

Hard controls 2. Vulnerability / risk analysis Soft controls

3. Responsibilities 8. Values and standards

4. SAI legal framework 13. Recruitment and selection 9. Professional SAI

standards

5. Integrity legislation and

regulations

10. Integrity awareness

6. Administrative

organisation / internal

control

14. Response to integrity

violations

11. Management attitude

7. Security 12. Organisational culture

15. Accountability and

transparency

16. Audit and monitoring

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

17

Gap analysis

Matching the integrity control system with

established vulnerabilities

What is the vulnerability

profile?

Does the integrity control system

protect the organisation against these

integrity vulnerabilities?

What are the remaining

vulnerabilities?

Object definition

- organisation

- processes

Assessment

vulnerabilities

Assessment

Maturity level Integrity Control System

Gap analysis

Recommendations

- Reducing vulnerability - Strengthening controls

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

18

Gap analysis

• Vulnerabilities is determined by the total vulnerability score and profile

• Resilience is determined by the maturity level of integrity controls

• Balance may be achieved by reducing vulnerability or enhancing controls

Remaining

Vulnerability

M L

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

Tunisian Into SAINT workshop

When? Why and With whom?

• The self assessment took place within the context of a the Twinning project between CdC and NCA to identify the integrity self assessment of the Supreme Audit Institution of Tunisia.

• The self assessment was performed on 3 and 4 April 2012 by a carefully selected group of employees from strategic positions in the organisation (Prosecutor Chamber, Head of IT team, 5 Councillors, Training officer, Head computer department, 2 members from the Financial and Administrative Department)

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

Tunisian Into SAINT workshop

During the workshop the participants conducted an assessment on the general level of vulnerabilities and resilience. For CdC the workshop established an imbalance between the vulnerability profile (level: Medium) and the maturity level of the integrity control system (maturity level:Low).

From the Gap analysis it may be concluded that there are two important issues that challenge the integrity of the CdC: fairness and trust within the organisation and independence of the organisation.

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

21

Recommendations

Disseminate results

IntoSAINT

Appoint integrity co-

ordinator

Start integrity policy

development

Integrate integrity in strategy

© OECD

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

Recommendations

Establish career criteria

Awareness training program

Three months

time

Appointment 1st president by Parliament and President of Republic

Financial & administrative independence from executive

Publication of reports by CdC

Work on establishing a

legal framework

that assures independence

(ISSAI 10)

A j

oin

t i

nit

iati

ve o

f th

e O

EC

D a

nd

th

e E

uro

pe

an

Un

ion

,

pri

nc

ipall

y f

ina

nced

by t

he

EU

Thank you

23