Integrity in the business environment

Abstract

Increasing integrity, reducing vulnerabilities and corruption risks in the business environment is a strategic goal. Its achievement implies specific measures such as the exchange of good practices in the implementation of integrity programs between the private and the public sector, the organization of regular public consultations between representatives of the public sector and the business sector on the national anticorruption agenda and the public policies with impact on the activity economic development of antibribery policies and programs developed at the level of companies, including by bringing them to the attention of potential contractors and suppliers and requiring compliance with equivalent standards, initiating dialogue with regulatory authorities in areas such as energy, mineral resources, to implement legal standards integrity. The present study is dedicated to the analysis of integrity issues in the business environment, to the specific measures adopted by the Romanian state in accordance with and in the application of international reference standards, as well as to the perspectives in this essential area of business law.

Headnote

Abstract

Increasing integrity, reducing vulnerabilities and corruption risks in the business environment is a strategic goal. Its achievement implies specific measures such as the exchange of good practices in the implementation of integrity programs between the private and the public sector, the organization of regular public consultations between representatives of the public sector and the business sector on the national anticorruption agenda and the public policies with impact on the activity economic development of antibribery policies and programs developed at the level of companies, including by bringing them to the attention of potential contractors and suppliers and requiring compliance with equivalent standards, initiating dialogue with regulatory authorities in areas such as energy, mineral resources, to implement legal standards integrity. The present study is dedicated to the analysis of integrity issues in the business environment, to the specific measures adopted by the Romanian state in accordance with and in the application of international reference standards, as well as to the perspectives in this essential area of business law.

Keywords: integrity, business environment, public policies, national anti-corruption agenda.

JEL Classification: K22

1.Introduction

The word integrity comes from the Latin - „integrum" and means „totality" or „entirety". The explanatory dictionary of the Romanian language defines this term in a number of ways, including the attribute of being righteous; honest, probity; incorruptibility. The desideratum of integrity, here understood, is a general one at the level of society, both applicable and necessary to be achieved in the business environment. At both international and national levels, projects have been developed and studies have been written on integrity in the business environment and there is a wealth of legislation in the field, including specific international conventions. For example, the UN Convention against Corruption, the Civil law Convention on Corruption, the Criminal Law Convention on Corruption, the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, the Recommendation of the Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions 2.

Integrity in the business environment is closely related to the fight against corruption, but it is not confused with it, its scope being much broader. Thus, studies in the field3 identifies as areas targeted by business integrity: internal financial/administrative activities within the organization, relationship with suppliers, work relations, recruitment, customer relationship, relationship with government and public officials, partnerships. Any approach to integrity in the business environment can not ignore the political and legislative framework, so that the state's role in these components is essential to the development of a business environment characterized by fairness.

As the objective of integrity in the business environment is a strategic one, mentioned as such in public policy documents, and given its importance, the present study focuses on the measures taken by the Romanian state at strategic level to achieve integrity in the business environment, sense in which will be referred to separately from the National Anti-Corruption Strategy 2016-2020, and recent interinstitutional cooperation activities developed based on it.

2.The National Anti-Corruption Strategy (NAS) 2016-20204

2.1.General characterization

In general terms, we can characterize the NAS as a formal framework for cooperation of all public institutions representing the executive, legislative and judicial power, local public authorities, the business environment and civil society in order to prevent corruption.

The incident public policy document currently in force is Government Decision no. 583/2016 on the approval of the National Anti-Corruption Strategy for the period 2016-2020, the sets of performance indicators, the risks associated with the objectives and measures of the strategy and the sources of verification, the inventory of institutional transparency and corruption prevention measures, evaluation indicators, as well as standards for the publication of information of public interest5, a document that marks the capitalization of the results obtained through previous policy documents and the rethinking of strategic priorities at national level. The Government Decision no. 583/2016 is based on and must be corroborated with the domestic and international legislation in the field, presented on the reference page on the Ministry of Justice website 6.

The adoption of the NAS currently in progress has not come to an empty ground but to the development of the National Anti-corruption Strategy 2012-2015, in line with the Cooperation and Verification Mechanism7 established by the European Commission and sectoral policies on integrity. It is worth mentioning that Recommendation no. 11 in the CVM is "Continue to implement the National AntiCorruption Strategy, respecting the deadlines set by the government in August 2016. The Minister of Justice should put in place a reporting system on the effective implementation of the National Anti-Corruption Strategy (including statistics on integrity incidents in public administration, details of disciplinary procedures and sanctions and information on the structural measures applied in vulnerable areas) ".

Experience gained through the application of incidents until 2016 revealed the need to rethink strategic priorities through a new NAS. As specifically stated in the Government Decision no. 583/2016, it is necessary that "moreprevention, action on profound causes and not only on easily identifiable effects, more education, including legal education", of all the recipients of the Strategy.

To achieve this, precise (general and specific) objectives, performance indicators, milestones, monitoring and reporting obligations are set. The identified strategic intervention priorities include intensifying efforts to strengthen integrity in the business environment, including in public enterprises, notably by implementing an integrity plan, developing and enforcing the company's code of ethics, setting up mechanisms to protect whistleblowers in the public interest, the implementation of preventive measures for sensitive functions and mechanisms of integrity incidents.

Taking into account these priorities, the current NAS set out general and specific objectives, some of which address the business environment in a timely manner, which we will develop in what follows.

2.2.Specific NAS objectives on the integrity component in the business environment

The NAS general objective 3 is to strengthen integrity, reduce vulnerabilities and corruption risks in priority sectors and areas of activity, and reflects the commitments made by Romania internationally at the London AntiCorruption Summit8, a summit that re-launched the fight against corruption as a global priority and necessary for combating poverty and sustainable development.

On that occasion, Romania committed to9, among others, to ensure that law enforcement institutions have full and effective access to information on the real beneficiary of companies and other legal entities registered in their national jurisdiction and that they have a legal mandate for the exchange of such information at international level between networks of relevant practitioners; to further promote the transparency of the public decision-making process by establishing public disclosure requirements for interactions between dignitaries and representatives of interest groups; to implement integrity plans as mandatory requirements for stateowned companies; to further support the adoption of the necessary legislation and to provide adequate resources for the ex-ante control mechanism to be implemented by the National Integrity Agency for public procurement procedures; to work towards full implementation of the principles of open data standards on public procurement, focusing on major projects as a top priority; to develop reward mechanisms for tenders who have proven themselves to be honest in their business; to create accessible databases on companies with final decisions as well as those that fail to properly execute contracts awarded in public procurement procedures; to ensure post-employment restrictions and to regulate this issue; to strengthen the mandate and the role of ethics advisers; to pursue Romania's objective of becoming a full member of the Organization for Economic Cooperation and Development (OECD) and the relevant working groups of the organization, and in particular in the Corruption Working Group; exchange of good practices.

These commitments are specifically reflected in the specific NAS objective 3.7, and that is raising integrity, reducing vulnerability and risk of corruption in the business environment, provides the following main actions:

- the continuation of Romania's efforts to become a full member of the OECD and the relevant working groups of the organization, and in particular the Anti-Bribery Working Group. This also implies the accession to the OECD Convention and its implementation;

- identifying, deterring and sanctioning anti-competitive agreements (measure taken from NAS 2012-2015);

- implementing integrity plans as mandatory requirements for public enterprises;

- elaboration of draft normative act for transposition of the Directive 2014/95/EU amending the Directive 2013/34/EU in the presentation of non-financial information and information on diversity by certain businesses and large groups;

- the exchange of good practice in the implementation of integrity programs between the private and public sectors (measure taken from the NAS 2012-2015);

- organization of periodical public consultations between representatives of the public sector and business on the national anti-corruption agenda and public policies with impact on the economic activity (measure taken from the NAS 2012-2015).

- disseminate anti-bribery policies and programs developed at the level of companies, including by bringing them to the attention of potential contractors and suppliers and requiring compliance with equivalent standards (measure taken from the NAS 2012-2015);

- initiate dialogue with regulating authorities in areas such as energy, mineral resources, to implement legal integrity standards;

- publishing in open format the economic and performance indicators (including budgets and subsidies received from public authorities) for enterprises to which the state is a shareholder, both through central and local government structures.

To achieve these objectives and actions, all local public institutions and authorities, including subordinate, coordinated or under their authority, as well as public enterprises. We will briefly highlight concrete ways of achieving these goals and the steps taken over the period 2017-2018, as reflected also in the European Commission's Reports.

2.3.Specific activities carried out at the Ministry of Justice

2.3.1. The business environment platform

The permanent dialogue between public authorities and business is important for implementation of the NAS 2016-2020. In this respect, the role of the Ministry of Justice is to foster this dialogue through the business environment cooperation platform.

In this respect, we mention that the implementation and monitoring of NAS is carried out under the authority and coordination of the Minister of Justice, but with wide institutional involvement and civil society, because corruption prevention is and must be a goal at the level of the whole of society. Therefore, in order to have a permanent dialogue on all levels, cooperation platforms have been developed, respectively: platform of independent authorities and anti-corruption institutions; central public administration platform; business environment platform; the civil society platform. The composition of the platforms is published on the NAS portal.

In particular, these platforms are meetings of the representatives of the aforementioned sectors, convened on a quarterly basis or whenever needed, at the Ministry of Justice, to discuss the aspects of implementation of the Strategy, namely to jointly identify the progress made in the implementation of the NAS, the practical problems encountered in the application of anti-corruption policies and rules, to correct them, but also to increase the level of knowledge, understanding and implementation of measures to prevent corruption in the public and private sectors. As far as participation is concerned, it is broad, practically having representatives of all ministries, independent public authorities, business and civil society.

The list of members of the business environment platform is published on the Ministry of Justice website 10, as follows: Romanian Banking Association, Romanian Businessmen Association, Embassy of the Kingdom of the Netherlands in Romania, The US Embassy in Romania, the Embassy of the United Kingdom of Great Britain and Northern Ireland in Romania, Bayer Romania, Chamber of Commerce and Industry of Romania, American Chamber of Commerce in Romania, British-Romanian Chamber of Commerce, Romanian-German Chamber of Commerce, Dutch-Romanian Chamber of Commerce, Centre for Advanced Research in Management and Applied Ethics, Committee for the Formation of a Clean Business Coalition, Foreign Investors Council, Deloitte, Siemens Romania, Telekom, Transelectrica, Orsin Management Consulting, Romanian Business Leaders.

2.3.2. Evaluation missions

According to the NAS Monitoring Methodology11, annually, based on the proposals formulated at the level of the cooperation platforms, the themes of the evaluation missions within the public institutions are approved. In choosing the themes, the inventory of institutional transparency and corruption prevention measures are taken into account, as well as the evaluation indicators, established in the NAS. The choice of public institutions is done by lottery or on a voluntary basis.

The evaluation procedure consists of completing the thematic evaluation questionnaire, organizing the evaluation visit at the headquarters of the public institution and drafting the evaluation report. The thematic evaluation questionnaire is developed by the Ethnic Secretariat and evaluation visits are carried out by teams of experts composed of representatives of the Technical Secretariat and one representative from at least three platforms (member or expert appointed by it). Visits take place in the form of meetings between the assessment team and representatives of the institution evaluated and do not take more than 5 business days. On the basis of the findings and recommendations formulated by the evaluation team, the technical secretariat drafts the draft assessment report within a maximum of 2 months from the date of completion of the evaluation visit. The report is sent to the evaluated institution for observations and comments. They shall be sent to the Secretariat no later than 15 days after its receipt. The evaluation report is discussed in platform meetings and is published both on the site of the evaluated institution and on the NAS Portal12, and within 12 months of the publication of the assessment report on the NAS Portal, the evaluated institution shall send to the Technical Secretariat a report on the measures adopted in implementation by the selected institutions for the assessment of institutional transparency and corruption prevention measures, as well as the effectiveness of the institutional response to integrity incidents.

All reports of evaluation missions conducted so far are available on the NAS portal, and the point-based discussions in the platforms with the presentation of the Reports are relevant to the usefulness and the positive effect of the evaluation missions, especially on the awareness of specific issues and the dissemination of the correct interpretation of the applicable legislation.

The latest CVM report 13 highlights these actions - highlighting a theme of interest on the average business component as follows: "The Technical Secretariat for the national Anti-Corruption Strategy within the Ministry of Justice has continued to organise thematic evaluations of public institutions for 2018-2019. The chosen themes are conflicts of interest during and after holding a public office (including revolving-doors); transparency of public institutions (which include state-owned enterprises) and access to public information, and incompatibilities. Ten institutions within the central public administration and ten independent institutions will be evaluated in 2018-2019. The evaluations aim to check how these institutions define their corruption risks in these areas and the measures in place to prevent incidents. The peer review evaluations will be supported by EU funds. The total EU funding to the implementation of the Strategy through a variety of projects amounts to EUR 9,7 million."

2.3.3.Exchange of good practices

At the most recent meeting of the business platform in April 2018, participants were invited to share their experience of promoting integrity in the business environment, building on the premise of the usefulness of transferring good practices to the environment of public enterprises. It was mentioned that the platform is a viable mechanism for involving the business environment in the anti-corruption agenda, especially as one of its roles consists in the dissemination of good practices in the implementation of integrity programs.

An example of collaboration in this context is the series of actions organized alongside American Chamber of Commerce in Romania (AmCham), on the promotion of good practices to public enterprises and their public tutelage institutions. We mention as a remarkable initiative in this respect the preparation by AmCham of a Guidelines on Conflicts of Interest, which could strengthen the prevention of conflict of interest cases in the private environment. Present at its launch, I stressed that it is important that this guide is part of a broader business enhancing endeavor within companies14.

The guidelines explain the notion of conflict of interest, the importance of prevention activities, the consequences of ignoring the risk of conflict of interest and outlines good practices of conflict of interest management. Thus, with regard to prevention, emphasized are the promotion of the principles of ethics, the supremacy of the company's interest in the activity, integrity, impartiality, decisional transparency, everything related to the observance of the legislation in force, the use of internal instruments and mechanisms such as internal audit, internal managerial control, the whistleblower, the elaboration of internal procedures. With reference to the latter we consider very important the emphasis of the proactive character of those with attributions in the prevention of conflicts of interests within the companies, as well as the obligation of the companies to elaborate and provide employees with a model of the declaration of interests and interest register form containing the name of the employee and the position within the company, the description of the declared interest, the relevant calendar data relating to the declared interest.

AmCham proposed to the MJ to continue the continuation of interinstitutional collaboration to disseminate, as part of the National Anti-Corruption Strategy (NAS) 2016-2020 or other action, the good practices promoted by AmCham through its guidelines, to authorities and state-owned enterprises (Corporate Governance Code - 2010, Anti-Corruption Principles - 2012, Community Investment Guide - 2015, Business Partner Integrity Assessment Guide - 2016, Guidelines on Conflicts of Interest - 2017), for which a series of meetings were planned.

We believe that such collaborations as well as the transmission of identified best practices, especially in the public sector where such expertise is lacking, must be stimulated and developed.

2.3.4.Development of methodologies and projects/partnerships

A recent notable achievement within the NAS is the adoption of Government Decision no. 599/2018 for the approval of the Standard Methodology for Corruption Risk Assessment within Central Public Authorities and Institutions, together with the indicators for estimating the probability of materializing the risks of corruption, with the indicators for estimating the impact in the situation of the materialization of the corruption risks and the format of the corruption risk register, as well as for the approval of the Methodology for Integrity Incidents Assessment within the central public authorities and institutions together with the format of the annual report on integrity incidents.15

The purpose of the Methodology is to undertake intervention measures for the prevention and control of corruption risks in order to diminish the probability of corruption risks and the impact on their materialization. The methodology applies to central public authorities and institutions, including those subordinated, coordinated or under authority, whose principals are the primary, secondary or tertiary authorizing officers, but obviously through the proposed purpose, it also impacts on the business environment and on the achievement of the NAS objectives on the average business component.

The implementation of the Methodology in terms of Corruption Risk Assessment involves the establishment of a Working Group, the identification and description of corruption risks, the assessment of corruption risks, the establishment of intervention measures, the regular monitoring and review of corruption risks, the updating of the integrity plans. In the case of institutions where a work group can not be formed due to the low number of staff, the tasks related to the identification and assessment of risks, as well as the determination of the intervention measures, are fulfilled by the Working Group set up at the level of the supervisory institution, out of which a representative of that institution will also be a member. In essence, based on the results of identification, description and evaluation of corruption risks, the Working Group proposes intervention measures for their prevention and control, which may include, among other things: drafting proposals on amending legislation; development of computer systems, development of working procedures, periodic planning and development of audit and/or control activities for activities considered as vulnerable; rotation of staff. Based on these activities, the Working Group completes the Corruption Risk Register, which is the basis of the integrity plan.

Implementation of the Methodology regarding the assessment of integrity incidents16 involves designating a person responsible for the implementation of the methodology, which carries out the following activities: obtaining information about the integrity incident; integrity incident analysis; proposing prevention and/or control measures. On the basis of the information obtained, the person responsible for the implementation of the methodology draws up, for each product integrity incident, a report, proposals for measures to prevent the occurrence of a similar incident, as well as the manager and the deadline for the implementation of the proposed prevention and/or control measures. This report shall be submitted for approval to the management of the public authority or institution.

The development of the prevention component is noted, which is one of the main goals of the current NAS.

As for incidental projects, it is important to mention the project Operational Capacity Administrative Program (POCA) on Strengthening the Administrative Capacity of the Technical Secretariat of the National Anti-corruption Strategy 20162020 to support the implementation of anti-corruption measures to achieve the following activities: peer review type missions, the general model of good practice, the mid-term implementation NAS 2016-2020 audit, evaluation of legislation on the protection of integrity whistleblowers; and the migration of public sector employees to the private sector, organizing the two anti-corruption conferences, generating an Index Score of Institutional Integrity for the vulnerable sectors identified in the strategy, organizing the training session of the MJ staff and subordinate units.

3.Support in achieving NAS objectives

Preventing and combating corruption involves efforts by both authorities and civil society. An integrated and competitive business environment is a goal of the NAS, but also a prerequisite for achieving prevention and combating corruption, as it corrects and stimulates this process.

Supporting public authorities - and here we take into account the constitutional ones - is a key to success. Beyond any punctual objectives and efforts to achieve them, the fulfillment of the NAS objectives or, in particular, the business environment component requires a prompt legislative response where the need for regulation is identified, as well as a legislative and political framework characterized by stability and predictability.

As regards the first dimension, I pointed out that the implementation of the Standard Methodology for Corruption Risk Assessment within central public authorities and institutions as well as NAS monitoring in general can highlight the need for regulation - either to create a legislative framework where it does not exist or to amend the legislation in force. An example of this in the framework of the business environment platform is the one addressing the issue identified by the notion of "pantouflage", i.e. the need to regulate strict and clear rules to prevent conflicts of interest when public sector employees pass into the private sector (postemployment bans).

As far as legal certainty is concerned, this is an essential premise for the development of the business environment in general and the culture of integrity in the business environment in particular. We also emphasized on other occasions the concept of legal certainty in connection with the principle of legality and its development in the case law of the Constitutional Court. In an attempt to answer the question that if in the condition in which there are so many laws, the quality of the law is also ensured in the sense of its compliance with the principle of the rule of law and that of legal certainty in its broadest sense with the principle of the preeminence of law and with that of legal certainty, in its broadest sense, we note that the jurisprudence of the Constitutional Court and the European Court of Human Rights, marked in the last few years by the increasingly frequent invocation of requirements regarding accessibility and predictability of the law, is a signal of the necessity to take steps to remedy some deficiencies that are increasingly affecting the Romanian legal system and implicitly the existence of the rule of law. In the context, we approached constitutional control as a genuine "remedy" for sanctioning this kind of deficiencies, namely by finding a violation of the constitutional principle of legality, interpreted with reference to the rules of legislative technique17. The recent developments reflected in the numerous decisions for the admission of complaints alleging breach of the principle of legality are not encouraging in this respect and require necessary corrections.

4.Conclusions

From the NAS management experience, we can confirm how important it is to raise awareness and concerns about potential integrity incidents. The evaluation missions and the NAS implementation monitoring experience reveal the lack of specialized personnel in areas such as integrity, prevention and fight against corruption in both public administration and the business environment, with particular reference to public enterprises.

The existence of a real dialogue on the difficulties encountered both in the elaboration process and in the implementation of the integrity plans is likely to support the development of a culture of integrity within public enterprises. Both public and private institutions need to be serious about establishing integrity policies. Each entity should assess internal integrity risks to build a robust integrity policy based on them. Therefore, ongoing monitoring of the implementation of anticorruption measures is crucial to maintaining the relevance of integrity policies.

Action on the root causes and not only of the easily identifiable effects together with the promotion of a culture of transparency and integrity are likely to provide predictability and sustainability to the prevention and fight against corruption. In addition, as evidenced by the National Integrity Agency18 "there is consensus among the main international actors on how to fight corruption - it can not be defeated by repressive measures alone, but needs complementary actions as well, of awareness and prevention, as required by international standards". The development and diversification of education measures among persons working both in the central apparatus and in local public institutions, increasing the degree of anticorruption education of staff within public authorities and institutions at central level as well as public enterprises are imperatively necessary. "A systemic approach to this challenge, treated in a collaborative manner"19 is necessary, and, we add, a stabilization of the legislative framework incident not only in the matter of integrity but also of the business environment in general.

Footnote

2 https://sna.justro/Legislaţie+Intemaţională (consulted on 15.10.2018).

3 The Study "Integrity In The Business Environment. Good Practice Models", see https://www. businessintegrity.ro/content/integritatea-mediul-de-afaceri-modele-de-bune-practici-europene, consulted on 15.10.2018.

4 See also M. Safta, Interview: https://europunkt.ro/2018/01/30/interviu-marieta-safta-secretar-de-statla-ministerul-justitiei-realizarea-obiectivelor-sna-inseamna-in-esenta-promovarea-unei-culturi-aintegritatii-la-nivelul-societatii/,consulted on 15.10.2018.

5 Published in the Official Gazette of Romania no. 644 of 23 August 2016.

6 https://sna.justro/Legislaţie+Naţională; https://sna.justro/Legislaţie+Intemaţională (consulted on 15.10.2018).

7 Established by 2006/928/EC: Commission Decision of 13 December 2006 establishing a mechanism for cooperation and verification of progress in Romania to address specific benchmarks in the areas of judicial reform and the fight against corruption (notified under document number C(2006) 6569), Jurnalul Oficial al Uniunii Europene L 354/56.

8 May 16, 2016.

9 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file 522726/Romania.pdf (consulted on 15.10.2018).

10http://sna.just.ro/Mediul+de+afaceri, (consulted on 15.10.2018).

11 http://sna.just.ro/+Metodologia+de+monitorizare, (consulted on 15.10.2018).

12 http://sna.just.ro/Rapoarte+de+evaluare, (consulted on 15.10.2018).

13 https://ec.europa.eu/mfo/sites/mfo/files/technical-report-romania-2018-swd-2018-swd-2018551_ro.pdf - Report from the Commission to the European Parliament and the Council on Progress in Romania under the Cooperation and Verification Mechanism.

14 M. Safta, Strengthening Integrity in the Business Environment from the perspective of the National Anti-Corruption Strategy- https://www.amcham.ro/download?file=mediaPool/agenda_01231120 .pdf (consulted on 15.10.2018).

15Official Gazette of Romania no. 751 of 30 August 2018.

16incident of integrity, according to the Methodology: „one of the following events regarding the situation of an employee of a public authority or institution out of those specified in art. 1 or a structure within them: disciplinary termination of employment or service relationships as a result of committing a deviation from deontological rules or other similar provisions designed to protect the integrity of the public office, including those established by secondary and tertiary legislation, for which this sanction is provided; suing or convicting for a corruption offense or any act of noncompliance with the prohibitions regime, incompatibilities, conflict of interest or wealth declaration; the final stay of a report issued by the National Integrity Agency, regarding breaches of legal obligations on unjustified wealth, conflict of interest or incompatibility regime".

17M. Safta, Unconstitutional legislative solutions due to non-compliance with the legal technique norms, published in the volume of the International Law Conference, European Studies and International Relations - Legislative policy, between European, national and international regulation, Bucharest, 24-25 may 2013, pp. 622-633 or M. Safta, Valorizing the rules of legislative technique in constitutional control, in the „Legislative Information Bulletin" no.2/2016, ISSN 15833178, pp. 3-23.

18 See https://www.integritate.eu/Files/Files/Brosura%20ANI/000%20Brosura%20ANI%20%20ROMANA.pdf (consulted on 15.10. 2018).

19 Idem.

References

Bibliography

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