In line with the Recommendation for Development Co‑operation Actors on Managing the Risk of Corruption [OECD/LEGAL/0431], both the MFEA and SAIDC have developed a Code of Ethics, establishing requirements for integrity and rules of conduct for civil servants and employees. The MFEA provides training for diplomats on anti-corruption measures, reporting misconduct and protecting whistleblowers – a practice that could be expanded to SAIDC staff and implementing partners. The advisor for ethical behaviour within the MFEA, active since April 2021, promotes an ethical culture and assesses compliance with the Code of Ethics. To effectively fulfil their role, it will be important to ensure that staff providing such advisory services are trained and prepared to discuss sensitive matters.
The MFEA’s 2019 Anti-Corruption Programme identifies project grants for development co‑operation as a risk area for corruption and outlines measures to mitigate these risks. In 2022, the MFEA revised guidance on the provision of project grants, mandating impartial evaluation by SAIDC, the selection commission, Slovak embassies and external experts. While maintaining impartiality in project grants is key, it constitutes only part of broader corruption risk management. Development actors are encouraged to map corruption risks across project cycles (e.g. from project design and selection to implementation and monitoring) as well as across modalities (e.g. including concessional loans and procurements, once these become operational). Specific guidance on corruption risk management in development co‑operation is still lacking. SAIDC publishes annual action plans for combating corruption, identifying potential corruption areas and measures to prevent corrupt behaviour.
Applications for SAIDC grants must include a risk analysis and proposed mitigation measures. However, the recommendation encourages ODA providers to conduct their own diagnostics – such as political economy analyses and risk assessments – to identify corruption risks and develop mitigation strategies, rather than placing the full responsibility for risk assessment on local partners applying for grants. Local partners may not always have the capacity to undertake such diagnostics effectively. For a lasting anti-corruption impact, providers should therefore invest in building local capacity through training, technical support and the development of meaningful partnerships.
In terms of due diligence, SAIDC grant agreements require adherence to the OECD Convention on Combating Bribery and, as such, include anti-corruption clauses. In addition, applicants must register in the Register of Public Sector Partners to enhance transparency. Each grant agreement includes monitoring provisions through reports and on-site missions – although, in practice, the latter do not happen systematically due to capacity constraints (see section entitled Institutional arrangements and management systems). Beyond ex ante monitoring, it is key to continually monitor projects and course correct as needed.
SAIDC grants are audited externally and internally to ensure compliance with financial regulations and project documentation. In 2023, building on existing internal regulations, the MFEA adopted a directive to protect whistleblowers which outlined procedures for reporting anti-social activities while ensuring confidentiality. SAIDC provides an online form where any individual can report suspicions of criminal offenses related to its activities, and it requires grant beneficiaries to report conflicts of interest. Violations can also be reported to the Whistleblower Protection Office, which safeguards whistleblowers' rights. Tracking the volume of complaints, who these are processed by and if follow-up action was taken, will be an important next step.
Violations of anti-corruption in SAIDC grants lead to contract termination or other remedial actions. Corruption is prosecuted as a criminal offence under Slovak law, with specific penalties outlined in the Criminal Code. Civil servants and SAIDC employees who violate Codes of Ethics may face disciplinary action.
Following recent legislative developments, the European Commission expressed concerns regarding the effectiveness of the anti-corruption framework, including the dismantling of the Special Prosecutor’s Office, amendments to the public procurement framework and attempts to amend the whistleblower protection framework and for a criminal law reform (European Commission, 2024[13]). This is a worrying development to the overall anti-corruption ecosystem and points towards the weakening of oversight and accountability institutions.