Anti-Corruption Trends in Eastern Europe and Central Asia

Annex A. Regional Anti-Corruption Key Performance Indicators

Anti-corruption policy indicators

Evidence-based problem analysis and use of diagnostic tools

KPI 1. Within the last five years, an inter-institutional body has prepared and published an analytical report on public integrity risks that formulates recommendations and sets priorities for the whole public integrity system (PII Quality of Strategic Framework, Indicator 1, criteria 1).

KPI 2. The existing strategy is based on an assessment of public integrity risks, identifying, as a minimum, specific types of relevant integrity breaches, the actors likely to be involved, as well as the expected likelihood and impact if the risk materialises (PII Quality of Strategic Framework, Indicator 1, criteria 2).

KPI 3. The existing strategy refers to at least 4 out of the following 8 sources of information related to public integrity: (a) indicators from international organisations or research institutions, (b) employee surveys, (c) household surveys, (d) business surveys, other survey data, such as user surveys, or polls from local research institutions, (f) data from public registries (e.g. law enforcement, audit institutions, national statistics office), (g) published research documents from national or international organisations or academia (e.g. articles, reports, working papers, political economy analysis) and (h) commissioned research (PII Quality of Strategic Framework, Indicator 1, criteria 3).

Inclusiveness and transparency of intergovernmental and public consultations

KPI 4. A minimum duration of at least 2 weeks for inter-governmental and public consultation period is established in legislation (PII Quality of Strategic Framework, Indicator 4, criteria 1).

KPI 5. The public consultation portal contains the draft strategy, including all supporting relevant materials (PII Quality of Strategic Framework, Indicator 4, criteria 2).

KPI 6. Strategy in force has undergone mandatory inter-governmental and public consultation processes (PII Quality of Strategic Framework, Indicator 4, criteria 3).

KPI 7. Strategy has undergone an extended consultation process (PII Quality of Strategic Framework, Indicator 4, criteria 4).

KPI 8. At least one key integrity body has been consulted and provided inputs through the regular intergovernmental or public consultation procedures to the existing strategy (PII Quality of Strategic Framework, Indicator 4, criteria 5).

KPI 9. At least one non-state actor has been a member of a working group mandated to develop or amend strategy in force (PII Quality of Strategic Framework, Indicator 4, criteria 6).

KPI 10. The public consultation portal contains a summary sheet for draft strategy with responses to all submitted comments provided during the public consultation (PII Quality of Strategic Framework, Indicator 4, criteria 7).

Implementation rate

KPI 11. The implementation rate of activities in the anti-corruption action plan as presented in the monitoring reports provided by the national authorities (PII Quality of Strategic Framework, Indicator 6).

Co‑ordination, monitoring and evaluation

KPI 12. There is a central co‑ordination function responsible for co‑ordinating the implementation, monitoring, reporting, and evaluation of the action plan (PII Quality of Strategic Framework, Indicator 5, criteria 1).

KPI 13. Anti-corruption strategy has an action plan in force (PII Quality of Strategic Framework, Indicator 5, criteria 2).

KPI 14. Monitoring reports are published, at least once a year, and publicly available no later than 3 months after the defined reporting schedule (PII Quality of Strategic Framework, Indicator 5, criteria 10).

KPI 15. Monitoring reports report on progress against pre-defined indicators and targets in the action plan (PII Quality of Strategic Framework, Indicator 5, criteria 11).

KPI 16. Responsible body has initiated consultations with the general public and/or civil society organisations on its monitoring reports during the latest full calendar year or the year prior to that (PII Quality of Strategic Framework, Indicator 5, criteria 15).

KPI 17. An evaluation report exists for predecessor strategy (PII Quality of Strategic Framework, Indicator 8, criteria 1).

KPI 18. Non-state actors were involved in the evaluation of the predecessor strategy, either as evaluators or as part of a formal review/quality assurance mechanism (PII Quality of Strategic Framework, Indicator 8, criteria 3).

Business integrity indicators

Regulations for listed companies

KPI 1. Legislation requires boards of companies listed in stock exchanges to oversee corruption risk management.

KPI 2. Securities regulator, or other relevant authority, has the legal mandate to monitor how the boards of the companies listed in stock exchanges oversee corruption risk management.

Disclosure of beneficial ownership

KPI 3. The law requires companies to provide a state authority with up-to-date information about their beneficial owners, including the name of the beneficial owner, the month and year of birth of the beneficial owner, the country of residence and the nationality of the beneficial owner, the nature and extent of the beneficial interest held.

KPI 4. Beneficial ownership information is verified by public authorities.

KPI 5. Sanctions are applied in practice for violations of regulations on registration and disclosure of beneficial ownership.

Incentives and awareness raising

KPI 6. The legislation or official guidelines allow due diligence (compliance) defence to exempt legal persons from liability, mitigate, or defer sanctions, considering the case circumstances.

KPI 7. The government has implemented awareness-raising activities on corruption targeting the private sector.

KPI 8. The government has implemented activities to assist the private sector in the development of anti‑corruption compliance measures.

Designated institution (Business Ombudsman)

KPI 9. There is a designated institution - an out-of-court mechanism to address complaints of companies related to violation of their rights by public authorities

KPI 10. Designated institution has the legal mandate to receive complaints from businesses regarding violation of their rights.

KPI 11. Designated institution has the power to conduct investigations/inquiries, obtain the necessary information and issue recommendations to administrative bodies.

KPI 12. Designated institution analyses systemic problems and prepares policy recommendations to the government on improving business climate and preventing corruption.

Integrity in state-owned enterprises

KPI 13. For the five largest SOEs, regulations are in place that provide for a competitive appointment of board members, including online publication of vacancies.

KPI 14. For the five largest SOEs, regulations are in place that require that their boards include a minimum of one-third of independent members.

KPI 15. For the five largest SOEs, regulations are in place that provide for a competitive appointment of their CEOs, including online publication of vacancies.