OECD Integrity Review of Jordan

2. Reinforcing the evidence-informed strategic approach to public integrity in Jordan

Abstract

This chapter provides recommendations to strengthen the implementation of Jordan’s current National Integrity and Anti-Corruption Strategy (NIACS) 2020-2025. It also provides guidance to develop the next strategy and how to strengthen the evidence-base and involvement of key stakeholders through this process. The chapter follows criteria of the OECD Public Integrity Indicators and looks at the phases of strategy design, implementation and monitoring as well as evaluation and accountability.

2.1. A strategic and evidence-informed approach to public integrity

A strategy for public integrity is essential for supporting a coherent and comprehensive integrity system. However, a strategy is not an end in itself, but rather a means to an end. In particular, the process of strategy development is perhaps as important as the resulting strategy. An inclusive and rigorous process can help select relevant strategic objectives that are meaningful to citizens and businesses; prioritise and sequence actions in an open manner to address the most crucial integrity risks; and provide the necessary evidence for the interventions that are most cost-effective and likely to have the greatest impact. Strategies are also a way of demonstrating commitment and can be used to establish institutional responsibilities and resources. If, however, strategies do not lead to visible gains, for example, due to inadequate implementation, they can at best become irrelevant and at worst erode public confidence in national authorities (OECD, 2020[1]).

The OECD Recommendation on Public Integrity emphasises the relevance of an evidence-informed strategic approach to promoting public integrity. This includes (OECD, 2017[2]):

• Setting strategic objectives, and priorities for the public integrity system using a risk-based approach to violations of public integrity standards while taking into account the contributing factors for effective public integrity policies.

• Developing benchmarks, and indicators, as well as collecting credible and relevant data on the implementation level, performance, and overall effectiveness of the public integrity system.

Jordan has developed a comprehensive framework of strategic documents and guidelines that in principle has the potential to address integrity and corruption challenges within the country. In 2008, the country’s first anti-corruption strategy was developed for a four-year period. The strategy was renewed for the period from 2013 to 2017, after which, the current National Integrity and Anti-Corruption Strategy (NIACS) was adopted for the period 2017-2025. This strategy was updated in 2020 due to some internal and external developments and is now valid for 2020-2025 (JIACC, 2019[3]).

The NIACS 2020-2025 strives for a “national environment that upholds integrity and rejects corruption” and aims at promoting integrity on three levels: 1) integrity and prevention, 2) law enforcement, and 3) building organisational capabilities. Overall, 24 strategic projects, including concrete timeframes and responsibilities, are aimed at reaching five strategic objectives (JIACC, 2019[3]):

• Activating the national integrity system and assuring the public administration compliance with it

• Enhancing the efficiency of preventive action against corruption

• Enhancing and developing the efficiency of the investigation and complaints department

• Enhancing the management of local and international strategic partnerships

• Developing the organisational and human capabilities

The following recommendations aim at strengthening the implementation of Jordan’s current NIACS 2020-2025. More importantly, the chapter provides guidance to develop, implement, monitor, and evaluate the next strategy and how to strengthen the evidence-base and involvement of key stakeholders through this process. The analysis follows criteria for the assessment of the quality of public integrity and anti-corruption outlined in Principle 3 of the OECD Public Integrity Indicators as well as good international practices. It looks at the following key phases: strategy design; implementation and monitoring, and evaluation and accountability.

2.2. Ensuring a participative and evidence-informed design of integrity strategies

Given that the current NIACS ends in 2025, there is a window of opportunity in 2024 for Jordan to renew its political commitment and launch a comprehensive and nationwide consultation process on integrity and design the follow-up strategy. This new strategy can provide for continuity by building on successes of the current strategy, but also by learning from the design and the implementation challenges of the current NIACS.

2.2.1. Jordan could renew and strengthen the commitment to promote integrity at the highest levels by developing the next Anti-Corruption and Integrity Strategy in a co-ordinated way

JIACC is the ideal institution to organise, manage and co-ordinate the development of the next NIACS, including a consultation process. For that purpose, it is recommended to establish a committee or working group, steered by JIACC. The working group could involve key public entities, for example, the Ministry of Finance, the Ministry of Justice, the Audit Bureau (AB), the Service and Public Administration Commission (SPAC), which replaced the Civil Service Bureau as of January 2024, the Prime Minister’s Office as well as prosecutors and judges, while maintaining their autonomy. Other key central bodies, such as the Ministry of Education, the Ministry of Interior, the Ministry of Planning or the Department of Statistics, for example, should be involved whenever required. Civil society, private sector, academia, and other relevant stakeholders could be invited to join the working group to provide inputs. Because this process is also an opportunity to renew the commitment on a political level, it is recommended that the next NIACS should be approved by the Council of the Prime Minister.

Such a working group or committee should have a clear mandate and sufficient resources and authority to manage the process and take decisions. This exercise could also be the first step towards creating a more permanent and formal co-ordination mechanism as recommended above. Costa Rica’s recent experience could be an inspiration (Box ‎2.1).

Box ‎2.1. Costa Rica’s Working Group to steer the development of the country’s integrity and corruption prevention strategy

Costa Rica’s National Integrity and Corruption Prevention Strategy (Estrategia Nacional de Integridad y Prevención de la Corrupción, ENIPC) was launched in August 2021. Between October 2019 and December 2020, the Attorney for Public Ethics (Procuraduria de la Ética Pública, PEP) and Costa Rica Íntegra (the national chapter of Transparency International) jointly led the development of the ENIPC through a participative process involving civil society, academia and the private sector.

The ENIPC was prepared through a co-creation process, in a working group made up of 17 public, private, academic and civil society organisations. Amongst others, the working group steered a public consultation process, in which 350 responses were received from citizens and which was complemented with focus groups of selected specialists by sectors (business, academia, civil society and government).

Stakeholders of the ENIPC consider the working group as an achievement in itself, as it de facto constitutes an inter-institutional co-ordination and monitoring mechanism, with a diversity of actors and responsibilities that previously never met in such a co-ordinated and constructive way.

Source: Based on information provided by Costa Rican stakeholder and (OECD, 2022[4]).

2.2.2. JIACC can ensure the relevance of the next NIACS through a risk and evidence-informed strategy design

To develop a meaningful and realistic strategy, a comprehensive and rigorous problem analysis is essential. The analysis aims to identify and analyse the integrity risks that pose the greatest threat to public integrity. This analysis should be conducted before drafting the strategy and should involve the use of a diversity of data sources, including survey data collection, and to ensure the alignment of data with international instruments against corruption. The evidence is crucial for making informed decisions about prioritising strategic objectives, especially when addressing multiple issues simultaneously (OECD, 2020[1]). The criteria of the OECD Public Integrity Indicators can guide such an evidence-informed problem analysis (Table ‎2.1).

Table ‎2.1. OECD Public Integrity Indicator – Evidence-informed problem analysis

OECD Public integrity indicator 3.2	Criteria to fulfil
3.2.1	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.
3.2.2	Each 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.
3.2.3	Each 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, (e) 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.

Source: OECD Public Integrity Indicators

In Jordan, an analysis of the current NIACS document evidences a lack of explicit analysis and structured risk assessment that would rely upon various kinds of data. Furthermore, the strategy does not identify the areas and sectors at high risk of corruption and does not use any kind of data for a diagnostic. While an analysis was carried out internally by JIACC to prepare the NIACS, this analysis has not been communicated and can therefore not be assessed by stakeholders. As such, it is unclear and less evident to assess if the objectives proposed in the current strategy are relevant and address the most pressing issues. In particular, when looking at the scope of the current strategy, it seems that at least two areas are not covered: public procurement and public finance management, which are clearly two high-risk areas, independent of the country context. In fact, and unsurprisingly, public procurement, has been identified by an OECD-SIGMA report as vulnerable to corruption risks in Jordan (SIGMA, 2016[5]). This raises the possibility of a misalignment between the strategy and the actual corruption risks on the ground.

However, since the release of the current strategy, JIACC has been proactive in several key areas. For example, JIACC carried out research and published more than 20 studies than can provide relevant information to inform the next strategy. Furthermore, the promotion of integrity risk assessments with various entities are a significant improvement for the evidence-base of integrity policies (see more on this in Chapter 5). For example, together with the relevant entities, JIACC has been conducting risk assessment studies within the Ministry of Health and Jordan Customs as well as in eight other entities. Based on these assessments, JIACC provides recommendations to address these risks, as outlined in its annual report for 2021 (JIACC, 2021[6]). Such recommendations can be a relevant input for the design of the next strategy. Finally, the National Integrity Indicators (NII) also provide insights on gaps and opportunities to strengthen integrity across the public administration and will be analysed in more detail below. The research, the risk assessments and the NII will be of great value for the design of the next strategy.

2.2.3. Ownership and relevance of the next NIACS can be further promoted through public and inter-governmental consultations and by actively involving key stakeholders

Beyond the use of risk assessments and data, consultations and the involvement of stakeholders play a crucial role in problem identification, discussing solutions as well as enhancing ownership and practically in a country’s reform process (OECD, 2018[7]). The OECD Recommendation on Public Integrity emphasises in its principle 5 on the whole of society the relevance of engaging relevant stakeholders in the development, regular update and implementation of the public integrity system (see also Chapter 4 of this Integrity Review). This involves advanced participation, where both stakeholders and citizens provide feedback to the government (OECD, 2020[1]). The entity responsible for developing and implementing the strategy should therefore engage from the early stages of strategy formulation. Including public entities in this process can promote ownership of the strategy beyond the main integrity actors and provide insights that are valuable for setting realistic and relevant objectives. In turn, including external stakeholders allows for greater transparency, inclusivity, accountability and democratic policy-making. It fosters trust by enabling the public to follow, influence and understand the process (OECD, 2020[1]).

In addition to good international practices, JIACC could consider following the criteria stipulated in Indicator 4 of Principle 3 of OECD’s Public Integrity Indicators on the “Quality of Strategic Framework” as a guidance for designing the next consultation process. This indicator measures the extent to which public integrity strategies are consistently developed in an inclusive and transparent manner (Table ‎2.2).

Table ‎2.2. OECD Public Integrity Indicators – Inclusiveness and transparency of intergovernmental and public consultations

OECD Public integrity indicator 3.4	Criteria to fulfil
3.4.1.	A minimum duration of at least 2 weeks for inter-governmental and public consultation period is established in legislation.
3.4.2.	The public consultation portal contains the draft strategy, including all supporting relevant materials.
3.4.3.	All public integrity strategies in force have undergone inter-governmental and public consultation.
3.4.4.	At least one public integrity strategy has undergone an extended consultation process
3.4.5.	At least one key integrity body has been consulted and provided inputs through the regular intergovernmental or public consultation procedures to at least one of the existing public integrity strategies
3.4.6.	At least one non-state actor has been a member of a working group mandated to develop or amend public integrity strategies in force
3.4.7.	The public consultation portal contains a summary sheet for all draft strategies with responses to all submitted comments provided during the public consultation

Source: OECD Public Integrity Indicators

According to the current NIACS document, several debates and consultative sessions were held with partners on the national level, including from the public and private sectors, civil society organisations and the media. However, these consultations were not public, there was no open public consultation and there are no summaries of the responses or reports documenting the process. Also, according to some interviews conducted by the OECD, consultation did not systematically include the subnational level and some external stakeholders expressed doubts regarding the inclusiveness of the consultations. This view, in turn, is difficult to confirm or debunk because of the lack of transparency regarding the actual consultation process and the inputs received.

Therefore, JIACC could demonstrate its commitment to engage stakeholders both in the remainder of the implementation of the current NIACS (see next section) and for the design of the follow-up strategy in 2024. When renewing the commitment at the highest level and to ensure buy-in and ownership at all levels of the public administration and within the population, a comprehensive and tailored consultation and participatory process in the process of designing the next NIACS would be strongly recommended.

For these consultations, it is crucial to involve key actors in society meaningfully and as early as possible (see also Chapter 4). In the case of Jordan, this includes academia, think tanks, CSOs, business and professional associations. Given their societal influence in the country, religious and tribal representatives should be involved in the process as well. In particular, JIACC could do more to engage young people in the design of the next NIACS, to ensure their vision, needs and experiences are reflected in the coming strategy and to explore new ways to communicate with them to achieve a more systematic engagement on issues around public integrity (see also Chapter 4 of the (OECD[8]) Public Governance Review of Jordan).

In addition to such targeted involvement of actors across society, JIACC could consider publishing on an open website an advanced draft of the next strategy for comments for a minimum of two weeks, to allow broad and open consultations. Furthermore, the next strategy should include a summary report of the consultation process and JIACC could make publicly available the inputs received to increase transparency and promote trust in the process. The recent experience of Chile could be a relevant inspiration for such an inclusive process (Box ‎2.2).

Box ‎2.2. Stakeholder involvement in the design of Chile’s National Public Integrity Strategy

The Presidential Advisory Commission for Public Integrity and Transparency (Comisión Asesora Presidencial para la Integridad Pública y Transparencia) promoted a public consultation process to build, together with citizens, Chile’s first national integrity strategy (Estrategia Nacional de Integridad Pública, ENIP). This strategy, which sets goals for the next 10 years, aims to establish an anti-corruption culture and promote ethical values aimed at protecting the public interest and strengthening democracy. Citizens were invited to participate in a public consultation between 20 October and 10 November 2022 on a website, where the proposed objectives and components of the ENIP were available. To ensure the transparency of the process, the details and conclusions of the voluntary and anonymous public consultation were presented in aggregated form and were published on the consultation website.

In addition to the public consultation, the Presidential Advisory Commission for Public Integrity and Transparency carried out a series of targeted activities aimed at fostering the participation of specific, relevant stakeholders in the ENIP’s formulation process:

• Activity with academics and representatives of civil society organisations.

• Workshop with technical counterparts from ministries, services and other state bodies with responsibilities for public integrity.

• An event with high-level authorities, called “State Commitment for a National Strategy on Public Integrity” (Compromiso de Estado para una Estrategia Nacional de Integridad Pública), which concretised the conviction of these authorities to advance in a strategic, comprehensive and preventive approach, from the entire State.

• Five regional participatory workshops on public integrity, called “Let’s Talk about Integrity” (Hablemos de Integridad).

• Meeting with chambers of commerce from different regions.

• Working day with the gender officers of all ministries to promote the gender approach in the implementation of the ENIP.

Source: (OECD, 2024[9]).

Such a process could be used also to discuss sensitive issues (providing safe spaces and Chatham House settings) and to review and streamline core principles and values for the public sector in Jordan (see Chapter 3). It could also provide the opportunity to clearly define public integrity. Such a clear definition is the starting point for an effective integrity system (OECD, 2020[1]). While Jordan has developed both a vision (“a national environment that upholds integrity and rejects corruption”) and mission (“consolidating the national integrity system, law enforcement, prevention of corruption and limiting its effects on the national level, in accordance with the international best practice, in order the establish national environment that rejects corruption”) it has not yet defined “integrity”. It, however, would be useful to provide clarity to all actors within the public integrity system: for the public and the private sector, civil society and citizens, but also for external stakeholders such as donors, tourists or multinational companies and investors. Indeed, sometimes “integrity” is merely related to individual behaviours, while a public integrity system is broadly understood as also comprising the legislation and the institutions in place to define, support, control and enforce integrity behaviour (OECD, 2020[1]).

2.2.4. Jordan could further strengthen the connections between the NIACS, the Public Sector Modernisation Roadmap and the Open Government Action Plan

The NIACS 2020-2025 can be considered as a major achievement and an important milestone for promoting integrity and anti-corruption in Jordan. In addition, the Public Sector Roadmap 2022 and the Open Government Action Plan 2021-2025 also contribute to the establishment of a rigorous public integrity system to tackle corruption (Table ‎2.3). The Public Sector Modernisation Roadmap addresses Jordan’s current overarching reform objective to boost its economy, which, inter alia, shall be achieved via fostering “transparency and accountability” as one out of seven modernisation pillars. The explicit goal of this modernisation process is to “create a comprehensive road map to elevate public administration, enhance the institutional approach in responding efficiently to local and global developments, and contribute effectively to attain economic recovery, based on the principles of excellence, transparency and accountability”. The Open Government Action Plan aims at fostering democratic structures and participatory processes as well as consolidating the rule of law within a framework of transparency, governance, and accountability at all levels within Jordan. Enhancing integrity thereby is one of six national commitments to achieve this.

Table ‎2.3. Specific integrity-related actions included in the Jordanian Public Sector Modernisation Roadmap 2022 and the Open Government Action Plan 2021-2025

Public Sector Modernisation Roadmap 2022

Open Government Action Plan 2021-2025

Objective 3.5 Develop and amend the current system of legislation, laws and bylaws, in addition to developing the civil service system 3.5.1 Continuing to develop and re-evaluate the integrity, transparency and accountability systems (2022) 3.5.2 Identifying clear and applicable roles and responsibilities in the integrity, transparency and accountability system that enhances the discretionary and preventive role of internal control units (2023) 3.5.3 A comprehensive application of the non-conflict of interest policy to all institutions and individuals in the public administration (2024)

Commitment 5: Enhance Integrity at the National Level 5.1.1 Reviewing the general framework and work methodologies of the government compliance matrix for public integrity in the public sector. Also, reviewing the follow-up mechanism of the recommendations reached through consultations with stakeholders from the public sector, civil society, and experts based on international best practices. 5.1.2 Capacity-building of the Compliance Department on these methodologies to be utilized in the evaluations that will commence in 2023. 5.1.3 Utilize the methodology and matrix that has been developed in conducting the evaluation of the targeted ministries and institutions that will commence in 2023 and issue relevant reports. 5.1.4 Incorporating the concept of integrity into the implementation plans of the governmental institutions through the recommendations reached in the compliance reports. Therefore, these institutions are obligated to develop activities to implement these recommendations in their implementation plans and allocate the related budget. This will be regarded as part of the responsiveness to the compliance matrix, which will be followed up. 5.2.1 Developing a compliance matrix for good governance and anti-corruption, particularly for regulatory bodies, over the private sector and CSOs, to ensure their compliance with the principles of governance, transparency, and disclosure, as well as designing a mechanism to follow up with recommendations reached through consultations with stakeholders from the public sector, civil society, and experts, based on international best practices. 5.2.2 Capacity-building of the Compliance Department on these methodologies to be utilized in the evaluations that will commence in 2023. 5.2.3 Utilize the methodology and matrix that has been developed for conducting the evaluation of ministries and regulatory institutions over the private sector and CSOs that will commence in 2023 and issue relevant reports. 5.2.4 Incorporating the concept of integrity into the implementation plans of the governmental regulatory bodies over the private sector and CSOs through the recommendations reached in compliance reports. Therefore, these bodies are obligated to develop activities to implement these recommendations in their implementation plans and allocate the related budget. This will be regarded as part of the responsiveness to the compliance matrix, which will be followed upon. 5.3.1 Launching a training platform within the Innovation and Creativity Centre at the Integrity and Anti-Corruption Commission targeting the government sector, civil society, the private sector, regulatory bodies, and universities. The purpose of the platform is to enhance integrity, combat corruption, create experts in the field, disseminate information and knowledge related to the fight against corruption, and introduce some subjects into the Institute of Public Administration’s materials. 5.3.2 Incorporating the concept of public integrity in training programs for senior leadership and new officials within the Institute of Public Administration. 5.3.3 Encouraging employees from the public sector, the private sector, CSOs, and all citizens to use the “Bekhedmetkom” platform via the anti-corruption complaints window as well as the mobile application for submitting complaints to JIACC. This will be done through high-quality campaigns and meetings with various stakeholders to enhance citizens’ trust in the platform and encourage them to use it in a way that enhances accountability and combats corruption. 5.3.4 Forming a committee of Senior Management/ Secretary-Generals from various ministries and governmental bodies, where biannual and periodic meetings are organized (as the need arises) to keep them apprised of the methodologies of the compliance assessment, JIACC reports, and evaluation results. Also, to gain their support to public sector employees to enhance the integrity and act responsively to JIACC recommendations.

Source: Public Sector Roadmap and Open Government Action Plan

However, while JIACC is advancing in the implementation of the commitments in the Open Government Action Plan that are under its responsibility, there is no mention of the Open Government Action Plan in the updated NIACS 2020-2025 that would allow to make visible the connection and synergies between both documents. Furthermore, the NIACS has not been revised to consider the Public Sector Modernisation Roadmap and the activities foreseen in it. In turn, it also appears that the objectives related to integrity of the Roadmap did not take into account ongoing initiatives and are not linked logically to the NIACS. Nonetheless, these activities in the Roadmap are highly relevant and should be more explicitly communicated to the citizens and relevant stakeholders.

The other two elements of Jordan modernisation efforts, on economic and political reforms, are not explicitly making the link to integrity policies. For seeking and attracting foreign investment, an enabling and clean business environment is key. However, the role of integrity in the economic vision is not evident, and efforts with and within the private sector seem limited (see also Chapter 4). The role of integrity is also not clearly stated and elaborated in the political reform agenda, that focuses on awareness raising and electoral processes. These two dimensions contribute to strengthen an integrity system but could also be undermined by integrity risks. Indeed, the absence of an integrity dimension in those reforms could affect their impact, and the trust they should generate. For example, the trust in electoral processes is also determined by the perceived integrity of the system, the political parties and the candidates.

Therefore, the next NIACS should aim at establishing clear and explicit links to the goals set under the different modernisation efforts and the Open Government Plans. In fact, the next NIACS could be an instrument to ensure coherence and oversee the cross-cutting impact of integrity policies. This would signal co-ordination amongst these national strategies and prevent from creating confusion affecting the effective implementation of all strategies.

2.3. Promoting implementation and monitoring of integrity strategies

As mentioned, a strategy that is not effectively implemented can backfire. For an effective implementation, several elements are key. For instance, the strategic goals of a strategy need to be clarified in an action plan with clear responsibilities, timelines and resources allocated to achieving them. Of course, required resources must be available and an effective monitoring mechanism based on relevant indicators and processes needs to be in place. In turn, monitoring should inform decision-making and should not be confused with control of compliance. Monitoring should allow for honest and open discussions concerning challenges and for finding solution on how to adapt the action plan, if necessary. In addition, effective communication with stakeholders during implementation is essential. Sharing progress and results with both internal and external stakeholders, as well as the general public, not only fosters accountability but enhances the credibility of integrity initiatives and stimulates future anti-corruption and integrity actions (OECD, 2020[1]).

Again, Jordan could consider taking the OECD Public Integrity Indicators measuring the adequacy of implementation and reporting structures as a benchmark for reforms aimed at ensuring an effective implementation (Table ‎2.4).

Table ‎2.4. OECD Public Integrity Indicators – Adequacy of implementation structures and reporting

OECD Public integrity indicator 3.5	Criteria to fulfil
3.5.1	For each strategy, there is a central coordination function responsible for coordinating the implementation, monitoring, reporting, and evaluation of the action plan
3.5.2	All public integrity strategies have an action plan in force.
3.5.3	All action plans include objectives with dedicated outcome-level indicators, baseline targets, and a list of activities.
3.5.4	All action plans identify lead organisations at least for each objective.
3.5.5	All action plans contain a section specifying the monitoring, reporting, and evaluation arrangements
3.5.6	All action plans reference administrative data sources from existing public registries
3.5.7	At least one action plan includes data sources from staff, household, or business surveys
3.5.8	At least one action plan includes activities to collaborate with institutions at the subnational level.
3.5.9	All action plans are published as a minimum on the website of the responsible body during the public consultation
3.5.10	Monitoring reports are published for all action plans, at least once a year, and publicly available no later than 3 months after the defined reporting schedule.
3.5.11	All monitoring reports report on progress against pre-defined indicators and targets in the action plan
3.5.12	All monitoring reports present the rate of implementation for activities in the action plan
3.5.13	All monitoring reports draw conclusions and have a dedicated section with recommendations to management.
3.5.14	The responsible body(ies) have initiated consultations with relevant state administration bodies to discuss the monitoring report(s) during the latest full calendar year
3.5.15	At least one 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.

Source: OECD Public Integrity Indicators

2.3.1. JIACC could further promote the successful implementation of the next National Integrity and Anti-corruption Strategy by including estimates for required financial resources in the next action plan

The current NIACS (2020-2025) encompasses an action plan that undergoes annual updates, which are clearly documented in supplementary materials containing detailed operational plans for all departments and units within JIACC. JIACC’s consistent efforts to make annual and regular updates to its action plan represents a proactive approach on their part. The action plan of the NIACS consists of 24 projects, each outlining a specific set of actions designed to accomplish the project’s objectives, accompanied by a timeline and designating responsible entities.

The operational plans for each project are documented separately and demonstrate significantly more specificity and detail. They clearly define the responsibilities of each unit within JIACC and strive to achieve alignment with the strategic objectives. For each unit, the plan specifies internal and external stakeholders, includes regular updates of the timeline, assigns indicators for tracking progress and includes a resource section. This resource section, however, primarily focuses on providing information about required human and technical resources, while financial resources requirements are specified only for some projects.

When designing the next NIACS, JIACC can build on this experience of elaborating one action plan which is detailed further in operational plans. The practice of annually updating the action plan is a good practice that should be maintained. The consistent evolution and improvement in the action plan, demonstrate JIACC’s proactive approach toward addressing its strategic objectives. To further facilitate implementation and provide orientation to potential international co-operation, the action plan of the next NIACS could offer more comprehensive financial assessments for each project and actions proposed.

2.3.2. JIACC could promote evidence-informed monitoring of the NIACS using amongst others the National Integrity Indicators (NII), while reviewing and fine-tuning their methodology, their use and the communication around them to avoid misunderstandings

JIACC has been developing indicators designed to measure the progress and success of achieving the strategic objectives included in its NIACS. These indicators are still in process of refinement. Initially, JIACC’s strategy introduced five key performance indicators corresponding to the five strategic objectives. Those indicators proved to be insufficient as they lack baseline and target values, leaving their practical application unclear. Subsequently, new indicators have been developed and integrated into the operational action plans, encompassing output indicators for each phase and the implementation of corresponding actions for each project. Annual indicators with pre-defined target values have been also established for each project.

However, while these indicators are used for assessing the performance of each project, their alignment with the strategic objectives of the current NIACS is not immediately evident and the methodology for measuring these indicators within each project could be clearer. The design of the next strategy should therefore take into account the identification of a set of indicators at different levels of the theory of change that allow the monitoring of its implementation and the evaluation of its results.

Additionally, JIACC has developed a set of indicators, the National Integrity Indicators (NII), to measure the level of implementation of the National Integrity Standards (NIS) by a selected group of public institutions, which could be used to further build on an evidence-informed monitoring approach in Jordan. A first pilot measurement of the NII was carried out with support from the CSO “Al Hayat Centre” in 2022. For this first measurement exercise, the methodology of the NII stipulated to calculate an aggregate value per institution based on two complementary measurement instruments:

• Compliance matrix: Evaluates the compliance of public entities with the NIS. For the pilot exercise, it consisted of 122 questions, divided into 5 criteria: (i) rule of law, (ii) accountability, (iii) transparency, (iv) justice, equality and equal opportunities, and (v) good governance). These were measured using a total of 21 sub-criteria.

• Integrity survey: Targets public servants in the 100 public entities that participated in the pilot exercise to assess their knowledge and experience related to the application of internal integrity policies and frameworks in their institutions.

Based on these measurement instruments, JIACC conducted an assessment, calculated a result and provided recommendations to each institution. Consequently, the NII are of great value for tracking progress in the implementation of mitigation measures. They have the potential to provide a good view on the readiness of a public institution to deal with potential integrity risks (through the Compliance matrix) and to measure the level of performance with respect to preventing corruption (though the Integrity survey). The NII are a good practice that is commendable and have the potential to indirectly strengthen the preventive work of JIACC and promote cultures of integrity in the Jordanian public administration, together with additional measures of support and guidance to public entities.

Additionally, JIACC could use the criteria and the results of the NII to communicate with both internal and external stakeholders and organise workshops or training sessions. It is important to convey that the results are not a judgment but should be understood as concrete and objective guidance for continuous improvement and demonstrate the commitment of the public sector entities to integrity. Such communication, workshops and trainings also serve as valuable opportunity to enhance stakeholder’s comprehension of how to effectively apply and use the indicators and lead to more evidence-informed and co-ordinated efforts toward a national integrity system.

To further strengthen the NII, the criteria underlying the compliance matrix and the methodology to calculate the results could be reviewed and fine-tuned based on the first measurement experience. Additionally, both the criteria and the methodology should be publicly available to encourage transparency and public trust. In addition, the integrity survey could be reviewed to ensure up-to-date questions and its methodology could be revised to ensure the sustainability of this exercise in the long run.

Moreover, in the context of the next National Integrity and Anti-corruption Strategy, JIACC could consider a survey to measure public perceptions, experiences or attitudes of external stakeholders towards corruption. JIACC has been already considering such a survey, referring to this idea as an “integrity scan”. Ideally, this should be developed and implemented in co-operation with the Department of Statistics and/or potentially with a local university. JIACC, together with other stakeholders, could also continue exploring and improving the collection of data sources that could be used to collect relevant information for the NII and the monitoring activities of the NIACS without adding a burden to the public institutions.

Finally, JIACC should pay attention to the way the NII are understood by public officials. During meetings in the context of this Integrity Review some public officials seemed to view the NII as a means to measure the “level of integrity” of a public institution, that is, a means to measure whether a public entity is more or less “corrupt” or “honest”. This is of course not what the NII are measuring and JIACC should invest significant efforts in a communication strategy targeting leaders of public entities, public officials, but also civil society and citizens, in view of explaining how the NII should be interpreted, what they are telling and what they are not telling. This will improve the acceptance of the NII and promote a constructive use of this exercise.

2.3.3. While being the main responsible for monitoring the NIACS, JIACC could consider actively involving stakeholders in the exercise

JIACC holds the primary responsibility for drafting the monitoring reports. Currently, these reports are elaborated with limited engagement from stakeholders to discuss the results. As mentioned above, the implementation process and the monitoring could be improved by actively involving the responsible entities and stakeholders, moving away from a “control of compliance” focus to constructive discussions about challenges and successes. A too heavy focus on control of compliance or indicators can undermine the readiness of some entities to share data and information and to communicate challenges and ideas for improvement. In turn, actively involving stakeholders, keeping them informed, interested and inspired, will promote their commitment and their sense of “owning” the NIACS, setting incentives to jointly meet the objectives, and reducing frictions during implementation and monitoring.

JIACC could thus consider providing opportunities for stakeholder feed-back and involvement in the implementation. This could be piloted in 2024 for the remainder of the current NIACS, for example to discuss progress made and remaining challenges. These inputs would be of value for the evaluation of the current NIACS and the design of the follow-up strategy. The design for involving actively stakeholder could be inspired by good practices from Romania and the Netherlands (Box ‎2.3). The lessons learnt from this pilot could help to fine-tune the mechanism and implemented in the next NIACS.

Box ‎2.3. Involving stakeholders in the implementation of a national integrity strategy

The Netherlands

The Platform for Corruption Prevention in the Netherlands provides an example of how various stakeholders, including civil society organisations (CSOs), can be involved in implementing an anti-corruption strategy and in helping design future strategies. Beyond public institutions, representatives from business and civil society were invited. These representatives were from private integrity and investigation services; the corporate risk and security management services of multinationals; the Association of Chambers of Commerce; the Association of Business Enterprises; Transparency International Netherlands; journalists; and academia. The meetings allowed to exchange expertise and experiences with anti-corruption developments in the Netherlands, and to share contributions to policy design and implementation, identification of corruption risks, research and training.

Romania

As the co-ordinator of the implementation of the National Anticorruption Strategies (NAS), the Ministry of Justice implemented five platforms as an innovative monitoring tool to ensure the active involvement of several key stakeholder groups, including stakeholders beyond the public sector. The five platforms are: a) the platform of independent authorities and anticorruption institutions; b) the platform of the central public administration; c) the platform of the public local administration; d) the platform of the business environment; e) the platform of the civil society.

The platforms are convened biannually or whenever necessary and have decision-making powers regarding the monitoring of the NAS. For example, they decide on carrying out of peer-review missions in public institutions, adopt the evaluation reports and approve the annual monitoring report. The participating entities also discuss the progress and challenges in the implementation of the NAS and are consulted and informed about the latest developments in the anti-corruption field. Furthermore, according to the NAS monitoring methodology, the review teams assessing the compliance of public institutions must contain at least one representative of CSOs or private businesses. Outside of their regular tasks, the platforms also play a major role in the consultation phase for the drafting of a new NAS, as happened most recently to prepare the NAS 2021-2025, which replaced the NAS 2017-2020.

Source: Based on information provided by the Ministry of Justice of Romania and (OECD, 2021[10]; OECD, 2023[11]) and (OECD, 2020[1]).

2.4. Evaluation and accountability of integrity strategies

2.4.1. JIACC should initiate an evaluation of the National Integrity and Anti-corruption Strategy 2020-2025 to enable learning and accountability and to inform the design of the next strategy

The information produced by monitoring integrity policies can be used, together with adequate indicators or proxies for the desired outcomes, to evaluate the outcome and impacts of the NIACS. Evaluations ask questions beyond the implementation status of a given action and look instead into questions such as relevance, coherence, effectiveness, efficiency, impact or sustainability (inspired by the OECD DAC criteria). As such, evaluations usually use a broad spectrum of sources of both quantitative and qualitative information to answer these questions and focus on drawing lessons learnt.

Establishing evaluation mechanisms from the start is crucial for ensuring measurability, progress, reporting and accountability. Evaluation can be conducted in house or outsourced, with the choice depending on the evaluation’s purpose and available resources. In house evaluation can facilitate organisational self-reflection and learning, often at lower cost with faster execution. However, they may be perceived as less objective and staff may lack the time and necessary skills for a comprehensive evaluation (OECD, 2020[1]). Table ‎2.5 provides an overview of the advantages and disadvantages of each approach.

Table ‎2.5. Benefits and limitations of the options for evaluation setup

Options	Pros and Cons
In House evaluation	Evaluation is designed and carried out internally by the lead institution staff.  Benefits: may allow for faster evaluation, as there is no need to procure the service of an evaluator; availability of inside information; further enhancement of analytical skills and insight.  Limitations: could be less objective, due to reluctance to disclose challenges and problems.
Outsourced evaluation	Evaluation is carried out by external consultants through an outsourcing procedure.  Benefits: objective evaluation by external and independent evaluators.  Limitations: requires additional resources to procure the expertise; may require more time to procure the service of an evaluator
Mixed/combined evaluation	Only some parts of the evaluation are outsourced (e.g., data collection and some of the more sophisticated analysis), while the rest is done in-house (internally).  Benefits: objective evaluation due to the involvement of external and independent evaluators; faster evaluation process, as the more time-intensive evaluation steps can be outsourced.  Limitations: requires additional resources to procure certain services

Source: (OECD, 2020[1])

In Jordan, the current NIACS does not explicitly ask for a formal evaluation. Nevertheless, JIACC should consider evaluating the strategy in 2025 to inform the design of the next strategy. The indicators and the monitoring reports could be valuable inputs for the evaluation. Box ‎2.4 provides some suggestions for guiding questions for such an evaluation of the NIACS. To ensure an objective and fresh look at the implementation and the results of the NIACS, an outsourced or mixed/combined evaluation could be the best option, as it could provide comparisons with good practice and recommendations for keeping the strategy and Jordan’s integrity and anti-corruption work relevant and responsive. For instance, the Romanian NAS 2016-2020 was independently reviewed by the OECD (OECD, 2021[10]).

Box ‎2.4. Evaluating the Jordanian National Integrity and Anti-corruption Strategy 2020-2025

As a policy evaluation, the goal is not to assess whether every single activity of a given strategy has been implemented and to what degree, but rather to look at whether the strategy has been able to contribute to the stated goals and objectives. As such, while the level of implementation is a relevant dimension to look at, an evaluation goes beyond the implementation and achievement of outputs to investigate the change to which the strategy has contributed and to what extend the desired results have been achieved and how (OECD, 2017[12]).

As such, the methodology to evaluate the achievement of the envisaged results and the objectives of the Jordanian National Integrity and Anti-corruption Strategy (NIACS) could consider the following dimensions:

• Relevance: Was the NIACS designed to respond to country needs and priorities? To what extend are the objectives still valid? Do the stakeholders feel that they “own” the strategy, that they are an active part of it (sense of ownership)?

• Coherence: Was the NIACS coherent with other governance reforms and policies in relevant key areas (external coherence)? Were the different objectives and projects of the NIACS designed in a way to reinforce one another and create synergies and were the activities relevant to contribute to the achievement of the results and the objectives (internal coherence)?

• Effectiveness: To what degree has the NIACS achieved the envisaged goals and implemented the projects (level of implementation)? What were the major factors influencing the achievement or non-achievement of the objectives?

• Efficiency: How well were the available resources used to achieve the objectives of the NIACS? Were the objectives achieved on time?

• Impact: What differences did the NIACS make? What were the positive changes and could some unintended consequences be observed?

• Sustainability: How did the NIACS build on earlier efforts to prevent and combat corruption and how likely are the implemented changes to last over time?

Note: The criteria follow the OECD-DAC evaluation criteria.

Source: Adapted from (OECD, 2021[10]), Evaluation of the Romanian National Anti-corruption Strategy 2016-2020, OECD, Paris, https://www.oecd.org/gov/ethics/evaluation-romanian-national-anti-corruption-strategy-2016-2020.pdf

The next NIACS should provide clarity and plan for a final evaluation and perhaps a mid-term evaluation within specified timelines. This evaluation framework should include crucial tasks such as soliciting feedback from stakeholders, assessing results, formulating recommendations as well as systematically documenting lessons learned and insights. Equally essential is the inclusion of budget considerations and identification of the stakeholders to be involved in the evaluation process, along with a clear definition of their roles and responsibilities and a transparent specification of the topics to be discussed with stakeholders during the evaluation.

Finally, evaluation reports are also particularly relevant for enabling accountability and ensuring transparency. Evaluations are looking into achievements, which arguably are more interesting for citizens and stakeholders than the details of a monitoring exercise. JIACC should therefore adopt robust reporting practices focusing on results. Equally important is that the evaluation reports are readily accessible to the public and presented in plain language, as this accessibility significantly enhances both clarity and transparency.

Chapter 2: Proposals for Actions

Ensuring a participative and evidence-informed design of integrity strategies

• To develop the next anti-corruption and integrity strategy in a co-ordinated way, a committee or working group could be established, steered by JIACC. The working group could involve key public entities, for example, the Ministry of Finance, the Ministry of Justice, the Audit Bureau (AB), the Service and Public Administration Commission (SPAC), as well as prosecutors and judges. Other entities could be involved when necessary. Civil society, private sector, academia, and other relevant stakeholders could be invited to join the working group to provide inputs. Such a working group or committee should have a clear mandate and sufficient resources and authority to manage the process and take decisions.

• Because this process of developing the new NIACS is also an opportunity to renew the commitment on a political level, it is recommended that the next NIACS should be approved by the Council of the Prime Minister.

• JIACC can ensure the relevance of the next NIACS through a risk and evidence-informed strategy design. JIACC’s promotion of integrity risk assessments with various entities can be a relevant input for the design of the next strategy.

• When renewing the commitment at the highest level and to ensure buy-in and ownership at all levels of the public administration and within the population, a comprehensive and tailored consultation and participatory process in the process of designing the next NIACS would be strongly recommended. The next strategy should include a summary report of such a consultation process and JIACC could make publicly available the inputs received to increase transparency and promote trust in the process.

• The participative development process of the new strategy could be used to discuss sensitive issues by providing safe spaces, to review and streamline core principles and values for the public sector in Jordan and to clearly define public integrity.

• The next NIACS should aim at establishing clear and explicit links to the goals set under the different modernisation efforts and the Open Government Plans. The next NIACS could be an instrument to ensure coherence and oversee the cross-cutting impact of integrity policies.

Promoting implementation and monitoring of integrity strategies

• JIACC could further promote the successful implementation of the next NIACS by including estimates for required financial resources for each project and actions proposed in the next action plan.

• For the design of the next strategy, JIACC should take into account the identification of a set of indicators at different levels of the theory of change that allow the monitoring of its implementation and the evaluation of its results.

• To further strengthen the National Integrity Indicators (NII), JIACC could review and fine-tune the criteria underlying the compliance matrix and the methodology to calculate the results, based on the first measurement experience. Both the criteria and the methodology should be publicly available.

• JIACC could review the integrity survey to ensure up-to-date questions. JIACC could also review its methodology to ensure the sustainability of this exercise in the long run.

• In the context of the next National Integrity and Anti-corruption Strategy, JIACC could consider a survey to measure public perceptions, experiences or attitudes of external stakeholders towards corruption. JIACC, together with other stakeholders, could also continue exploring and improving the collection of data sources that could be used to collect relevant information for the NII and the monitoring activities of the NIACS without adding a burden to the public institutions.

• JIACC should pay attention to the way the NII are understood by public officials and invest significant efforts in a communication strategy targeting leaders of public entities, public officials, but also civil society and citizens, in view of explaining how the NII should be interpreted, what they are telling and what they are not telling. This will improve the acceptance of the NII and promote a constructive use.

• While being the main responsible for monitoring the NIACS, JIACC could consider actively providing opportunities for stakeholder’s feed-back and involvement in the implementation. This could be piloted for the remainder of the current NIACS, for example to discuss progress made and remaining challenges. These inputs would be of value for the evaluation of the current NIACS and the design of the follow-up strategy.

Evaluation and accountability of integrity strategies

• JIACC should consider evaluating the NIACS 2020-2025 to inform the design of the next strategy. To ensure an objective and fresh look at the implementation and the results of the NIACS, an outsourced or mixed/combined evaluation could be the best option, as it could provide comparisons with good practice and recommendations for keeping the strategy and Jordan’s integrity and anti-corruption work relevant and responsive.

• The next NIACS should plan for a final evaluation and perhaps a mid-term evaluation within specified timelines. This evaluation framework should include crucial tasks such as soliciting feedback from stakeholders, assessing results, formulating recommendations as well as systematically documenting lessons learned and insights. Equally essential is the inclusion of budget considerations and identification of the stakeholders to be involved in the evaluation process, along with a clear definition of their roles and responsibilities and a transparent specification of the topics to be discussed with stakeholders during the evaluation.

• JIACC should adopt robust reporting practices focusing on results, ensuring that evaluation reports are readily accessible to the public and presented in plain language, as this accessibility significantly enhances both clarity and transparency.

References

[6] JIACC (2021), Annual Report: 2021, Jordanian Integrity and Anticorruption Commission, Amman, Jordan, https://www.jiacc.gov.jo/ebv4.0/root_storage/en/eb_list_page/english_report_2021.pdf (accessed on 16 February 2024).

[3] JIACC (2019), National Strategy of Integrity and Anti-Corruption 2020-2025, https://jiacc.gov.jo/EBV4.0/Root_Storage/AR/EB_Blog/JIACC_Strategy_2020-2025_English.pdf (accessed on 16 February 2024).

[8] OECD (2024), OECD Public Governance Reviews: Jordan: Together for an Accountable and Transparent Public Administration, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/be41202d-en.

[9] OECD (2024), Promoting Public Integrity across Ecuadorian Society: Towards a National Integrity System, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/bae418f9-en.

[11] OECD (2023), Strengthening Romania’s Integrity and Anti-corruption Measures, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/ff88cfa4-en.

[4] OECD (2022), OECD Integrity Review of Costa Rica: Safeguarding Democratic Achievements, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/0031e3b3-en.

[10] OECD (2021), Evaluation of the Romanian National Anti-corruption Strategy 2016-2020, OECD, Paris, https://www.oecd.org/gov/ethics/evaluation-romanian-national-anti-corruption-strategy-2016-2020.pdf (accessed on 18 February 2022).

[1] OECD (2020), OECD Public Integrity Handbook, OECD Publishing, Paris, https://doi.org/10.1787/ac8ed8e8-en.

[7] OECD (2018), Toolkit for the preparation, implementation, monitoring, reporting and evaluation of public administration reform and sector strategies: Guidance for SIGMA partners, OECD Publishing, Paris, https://doi.org/10.1787/37e212e6-en.

[12] OECD (2017), Monitoring and Evaluating Integrity Policies, Working Party of Senior Public Integrity Officials, GOV/PGC/INT(2017)4, OECD, Paris.

[2] OECD (2017), “Recommendation of the Council on Public Integrity”, OECD legal Instruments, OECD/LEGAL/0435, OECD, Paris,, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0435.

[5] SIGMA (2016), CORRUPTION RISK ASSESSMENT OF THE PUBLIC, https://www.jiacc.gov.jo/ebv4.0/root_storage/en/eb_list_page/corruption_risk_assessment_of_public_procurement_system_in_jordan-3.pdf.