This chapter provides an overview of the strengths and areas of opportunity for promoting open cultures of integrity throughout the Jordanian public administration. It provides recommendations on how to provide clear guidance with respect to expected behaviour by simplifying the principles and values, on how to strengthen the prevention and management of conflict of interest, on how to continue raising awareness and strengthening capacities of public officials, and on how to better incorporate integrity in human resource policies and management, particularly in municipalities.
OECD Integrity Review of Jordan
Together for an Accountable and Transparent Public Administration
Abstract
Achieving open cultures of integrity in the public administration requires going beyond laws and regulations and ensuring public values are deeply rooted in the behaviour of individuals and organisational structures (OECD, 2020[1]). Open organisational cultures also mean that public officials at all levels feel safe to engage in conversations with the aim of voicing their concerns and discussing integrity issues such as ethical dilemmas, potential conflict-of-interest situations, suspicions of integrity violations and other integrity concerns (OECD, 2020[1]). In short, building open organisational cultures is about creating safe environments, in which public officials know the rules, behave accordingly, and feel safe to speak up. The benefits of open organisational cultures in the public administration include enhanced trust in the organisation, an greater sense of ownership and pride among public employees in their work, and the ability to address integrity issues before they become potentially damaging.
The OECD Recommendation on Public Integrity sets out the main pillars for building a culture of integrity in the public sector (OECD, 2020[1]; OECD, 2017[2]). This chapter reviews strengths and opportunities for improvement with respect to promoting open organisational cultures of integrity in the Jordanian public administration. The subsequent sections provide recommendation in the following areas:
Setting clear integrity standards. Principles and values help public officials carrying out their public duties ethically and upholding the public interest over private interests.
Preventing and managing conflict of interest. Having clear rules and guidelines in place to prevent and manage conflicts of interest is also essential for public officials to uphold public integrity.
Raising awareness and building capacities. Providing sufficient information, training and guidance to public officials to understand and apply integrity standards and values is key. Leaders can be role models and enablers for good behaviour.
Promoting a values and merit-based civil service. Hiring people with the right skills for the job improves performance and productivity, reinforces integrity and prevents favouritism and nepotism. At the same time, even minor violations of integrity standards must be timely, fairly and visibly sanctioned to ensure the credibility of the integrity system.
In Jordan, the National Integrity Standards (NIS) are used to promote integrity inside public institutions. The Jordanian Integrity and Anticorruption Commission (JIACC) developed and implemented the National Integrity Indicators (NII) in 2020/21 to measure the level of implementation of the National Integrity Standards (NIS) by public institutions (see also Chapter 2). These NII are currently being fine-tuned to provide, in the future, coherent measurement of the level of institutional preparedness (through a Compliance Matrix) and the level of institutional implementation (through an Integrity Survey). The recommendations generated by the NII will provide concrete guidance to heads of public entities on how to improve their system of institutional preparedness and strengthen their organisational cultures of integrity.
In addition, the Prime Minister’s Project Management Implementation Office (PMIO) is currently working on developing an Institutional Culture Framework (IFC), which aims to build an institutional culture and work environment that enhances commitment and accountability as well as further develop institutional capacities to lead changes and promote commitment to institutional values. This programme is part of the implementation of the Public Sector Modernisation Roadmap for 2023. Some dimensions of the IFC are also part of the NIS and the NII. JIACC and PMIO should co-ordinate to align the IFC to the NIS and the revised NII.
This chapter informs and strengthens the implementation of key integrity dimensions aimed at promoting open cultures of integrity in the Jordanian public administration, such as providing simple and clear guidance to public officials on values and principles, strengthening the prevention and management of conflict of interest, raising awareness and strengthening the capacities of public officials on public integrity as well as integrating and mainstreaming integrity into human resource management.
Setting high standards of conduct that must be followed by all public officials and that prioritise the public interest reflects the commitment to serving the general interest and building a public service-oriented culture. Public values set out the basic principles and expectations that society deems to be of importance for public officials and provide clarity for organisations and public officials at all levels regarding expected behaviours. These standards can be out in in legal frameworks. Additionally, countries often implement guidance to public officials through codes of conduct, describing expected standards and prohibited situations, and/or through codes of ethics, identifying principles and values (OECD, 2020[1]).
Jordan has put in place a comprehensive legal and institutional integrity framework (see Chapter 1), and political leaders have expressed the necessity to promote public integrity and tackling corruption. The main legal texts providing guidance on expected behaviour of public officials are the Integrity and Anti-Corruption Law 13 of 2016 and the Civil Service Bylaw 9 of 2020, as well as their amendments. The last amendment of the Civil Service Bylaw was issued in December 2023. The Public Sector Human Resources Management Bylaw was issued in 2024 and further changes are to be expected related to the ongoing reforms of the civil service. The Civil Service Bylaw lays out values and prohibits exploiting the position of a public official to serve any personal benefit or for partisan ends.
These two legal texts are complemented by the Code of Conduct and Ethics of the Public Service (CoC). However, at the time this OECD report was drafted, it was not entirely clear which version of the CoC was the official one and different versions were found on official websites. In addition, interviews also seem to indicate that the awareness of public officials on the CoC is low and it was not possible to find publicly available information regarding formal events or communication strategies for disseminating the Code. Therefore, effective communication and dissemination of the CoC, including clarity about the current version, remains an area for potential improvement to ensure comprehensive awareness and compliance across all levels of public service.
Two actors have core responsibilities in promoting and monitoring compliance with these provisions. The Service and Public Administration Commission (SPAC) is responsible for ensuring the application and implementation of the Civil Service Bylaw and the CoC. The establishment of the SPAC marks a significant milestone in the ongoing efforts to modernise the public sector in Jordan. According to its Bylaw 80 from 2023, SPAC replaces the Civil Service Bureau (CSB) and takes up new responsibilities beyond human resource management and which are particularly relevant for public integrity, such as ensuring the delivery of public services and promoting institutional development in the public sector. In turn, JIACC is responsible for activating and ensuring the application of the set of values and rules of conduct in the public administration, for example through the NIS and NII mentioned above, and for ensuring that the public administration fairly and impartially provides high quality services (Article 4, literals a and b of the Integrity and Anti-Corruption Law).
3.2.1. To achieve one set of well-defined principles and values for public officials, the SPAC and JIACC could lead a participatory process to review and streamline the current principles and values in the Civil Service Bylaw and the Code of Conduct and Ethics
Standards and guidance for ethical conduct are often derived from a commitment to overarching values (OECD, 2018[3]). Such public values aim to guide ethical judgement when serving the public interest by becoming the reference against which public officials can evaluate their everyday choices and actions. Having such over-arching public values is particularly relevant considering that it is impossible to capture in a country’s regulatory framework all eventualities and situations that public officials could encounter in their day-to-day work. Consequently, these overarching values should be clear and simple, so they can be easily understood, recalled and applied by public officials in their everyday choices and behaviours.
In Jordan, the Civil Service Bylaw states that the civil service is based on the following set of principles and values (Article 4): Rule of law; Accountability and transparency; Welfare; Justice, equality and equal opportunities; Good governance and integrity; Excellence in performance and continuous improvement; Sound planning; Empowerment and motivation; and Effectiveness and efficiency. In one version of the CoC, the following set of principles are provided: fairness/justice, transparency, accountability, integrity, professionalism and impartiality/neutrality. The civil service human resources strategy 2023-2027 defines the following set of values: Integrity, Responsibility, Innovation, Efficiency, Respect, Excellence, Justice. As such, the values or principles included in these documents overlap and, in part, try to capture the same with different words. For example, “professionalism” in the CoC could arguably encompass the dimensions of “Excellence in performance and continuous improvement", “Sound planning” or “Effectiveness and efficiency”, for example. In turn, “Fairness” could be linked to the dimensions of “Welfare” and “Justice, equality and equal opportunities”. While all these dimensions are relevant, the use of different words and concepts adds an additional layer of complexity and could undermine the clarity of the intended messages to public officials.
Therefore, there is an opportunity for SPAC and JIACC to review and streamline the set of principles and values and ensure coherence between the CoC, the human resource strategy 2023-2027 and the Civil Service Bylaw (and its current revision). The objective would be to have one single set of principles and values. Ideally, this list should not be too long (Miller, 1955[4]). This would enhance the clarity for public officials concerning the overarching principles and values guiding the public sector. Such a review process steered by SPAC and JIACC, on the one hand, would enable defining clear and common definitions for the revised set of principles and values. On the other hand, it could allow involving public officials across the public administration and different levels of government in the revision. Involving public officials enhance their ownership and commitment and contribute to aligning expectations and promoting a common understanding. The resulting principles and values should represent what public servants themselves feel relevant for guiding their personal development, work routines, skills and organisational climate. A single set of principles and values could also help JIACC, SPAC and the Institute of Public Administration (IPA) to develop and conduct coherent trainings that are referring to this common foundation while delving into different aspects and/or targeting different groups of public officials (see section below).
“If staff members were not involved in the process of developing the code and everybody knows that the code is just a reproduction of an existing document, then this might drastically reduce staff-members‟ feelings of ownership of the code. This problem is expressed in the maxim “a code is nothing, coding is everything” (Kaptein and Wempe, 1998[5]). Although the maxim is of course exaggerated, it does catch the psychological importance of involvement in the design of a code. (OECD, 2009[6])
Successful experiences from countries such as Australia, Brazil and Colombia could be used as an inspiration for designing such a participatory process and for setting and defining common public principles and values that are easy to remember (Box 3.1). Of course, even a participatively elaborated code is likely to not have any impact on behaviour if it does not go along with measures to ensure its implementation, such as trainings and leadership but also the formal or informal sanctioning of behaviour that is not aligned with those principles and values (see also below in this chapter). A participative definition of the values is nonetheless one of the success factors evidenced by international good practice.
Defining the Australian Public Service Values
The Australian Public Service (APS) Values are set out in the Public Service Act 1999. The Values provide the philosophical underpinning of the APS, shape its organisational culture, and reflect public expectations of the relationship between public servants and government, Parliament, and the community. The APS Values complement one another and are of equal importance. The APS Values were developed following extensive public consultation, and are as follows: Impartial (The APS is apolitical and provides the government with advice that is frank, honest, timely, and based on the best available evidence); Committed to service (The APS is professional, objective, innovative and efficient, and works collaboratively to achieve the best results for the Australian community and the government); Accountable (The APS is open and accountable to the Australian community under the law and within the framework of ministerial responsibility); Respectful (The APS respects all people, including their rights and heritage); Ethical (The APS demonstrates leadership, is trustworthy, and acts with integrity, in all that it does). Moreover, commencing on 11 December 2024, Stewardship will be a new APS Value (Stewardship: The APS builds its capability and institutional knowledge, and supports the public interest now and into the future, by understanding the long-term impacts of what it does).
Defining the 7 Values of the Federal Public Service in Brazil
The Comptroller General of the Union (CGU) of Brazil, in partnership with the OECD, led a process of identifying the core Values of the Federal Public Service, launched in April 2021. The initiative was carried out by an online voting procedure, through which federal public servants throughout Brazil could choose and propose which values should guide the culture of the federal public administration. During October 2020, the CGU launched the online survey inviting all federal civil servants to participate. In this first survey, 33 407 public servants participated. The CGU, together with the OECD, cleaned the responses and grouped similar values. The top ten values were selected in a process including the participation of representatives from the private sector and civil society. A second survey, with 25 637 participants, then reduced the 10 values to the 7 final values, which are: Integrity, Professionalism, Impartiality, Justice, Engagement, Kindness and Public Vocation. Each value comes along with a brief description, which provided the opportunity to add similar values that pointed into the same direction.
Defining the Colombian Integrity Code
In 2016, the Colombian Ministry of Public Administration initiated a process to define a General Integrity Code. Through a participatory exercise involving more than 25 000 public servants through different mechanisms, five core values were selected: Honesty, Respect, Commitment, Diligence and Justice. In addition, each public entity has the possibility to integrate up to two additional values or principles to respond to organisational, regional and/or sectorial specificities.
Having one single set of principles and values could significantly contribute to facilitating the understanding of public officials in Jordan of what is expected from them. At the same time, such principles and values typically require further guidance and clarification: what concrete behaviours are related to each of the principles and values in day-to-day practice? As such, to support ongoing and future efforts in raising awareness and capacity building by JIACC and the IPA (see section below), Jordan could provide a short definition of each principle and value in the CoC and in the Civil Service Bylaw (or the new and unique set of principles as recommended above) as well as further guidance on how to translate each of these into concrete expected behaviours. This guidance could be provided in specific codes for areas or organisations (see section below), with the advantage of allowing to include concrete and relevant examples, or in a complementary guideline or manual. The example from Canada in Box 3.2 could provide an inspiration on how to frame such complementary guidance.
In Canada, the Code of Conduct of the Employment and Social Development Department includes the set of five public sector values – respect for democracy, respect for people, integrity, stewardship and excellence – that should guide public servants in everything they do. Additionally, the code includes the definition of each public sector value, along with the expected behaviours that support them. For example, the value “Respect for people” is further defined as follows:
Definition: Treating all people with respect, dignity and fairness is fundamental to our relationship with the Canadian public and contributes to a safe and healthy work environment that promotes engagement, openness and transparency. The diversity of our people and the ideas they generate are the source of our innovation.
Expected behaviours associated with the value “Respect for people” are:
Treating every person with respect and fairness.
Valuing diversity and the benefit of combining the unique qualities and strengths inherent in a diverse workforce.
Helping to create and maintain safe and healthy workplaces that are free from harassment and discrimination.
Working together in a spirit of openness, honesty and transparency that encourages engagement, collaboration and respectful communication.
These lists of expected behaviours are further elaborated into practical examples and guidance on how the civil servant should act under certain circumstances. In this way, the code not only encompasses the standards of conduct, but also presents a practical tool for reaching ethical and lawful decisions, safeguarding the integrity of the public service and employees alike.
Source: (ESDC, 2016[10]).
3.2.2. JIACC, together with the SPAC and relevant entities, could continue developing specific codes for at-risk categories of public officials and encouraging the development of organisational codes of conduct through a clear methodology and ad-hoc support
Different public entities, at different levels of government or in different sectors, face diverse risks and ethical dilemmas due to the specificity of the context and the type of work they carry out. Similarly, some at-risk positions, such as procurement officials or officials in human resources (HR) units, are confronted with very specific risks that are transversal across the public administration. Therefore, institutional or sector codes of conduct, or codes for specific positions, can allow to include relevant and concrete examples from the day-to day work to which public officials can easily relate to. Box 3.3 provides examples of countries that encourage the development of specific codes.
In Costa Rica, the Manual of Ethics for Civil Servants sets ethical norms, principles, duties and prohibitions for the 47 entities of the civil service regime, while the Ethical Principles of Civil Servants (Decree 33146 of 2006) provide the shared principles and values of the Costa Rican public sector. Additionally, the Ethics Management Model provides guidance for the development of an organisational Ethics Code or an Ethics Manual to allow public institutions to reflect their specific contexts, risks and challenges. Following this guidance, public institutions have developed institutional codes of ethics, including, for example: the Code of Ethics and Conduct of the General Directorate of the General Archive of the Nation or the Code of Ethics and Conduct of the Ministry of Housing and Human Settlements. The process typically includes a survey to employees, a diagnosis and work sessions to present and validate the proposed principles and values.
In Canada, the Values and Ethics Code for the Canadian Public Service describes the values and expected behaviours that guide public servants in all activities related to their professional duties (Respect for Democracy, Respect for People, Integrity, Stewardship and Excellence). Moreover, public institutions are expected to develop organisational codes of conduct to reflect their specific contexts, including, for example, the Code of Conduct of the Employment and Social Development Department, which describes how employees expected to behave when delivering the services that are specific to their mandate and work environment, or the Code of Values and Ethics for the Canadian Transportation Agency, which outlines the core values and expected behaviours that should guide the Agency’s employees and public servants in all activities related to their professional duties.
In the United Kingdom, the Seven Principles of Public Life (Selflessness, Integrity, Objectivity, Accountability, Openness, Honesty, and Leadership) outline the ethical standards that anyone working in the public sector is expected to adhere to. In line with these principles, there are specific codes for public officials considered to be at high-risk positions, including, for example the Ministerial Code, which sets out the standards of conduct expected of ministers, or the Code of conduct for Special Advisers, which sets out the standards of conduct expected of special advisers working in the UK government.
Source: Costa Rica: https://www.pgr.go.cr/wp-content/uploads/2019/03/Manual_etica_Funcion_Publica.pdf, (OECD, 2022[11]); Canada: https://www.tbs-sct.canada.ca/pol/doc-eng.aspx?id=25049,https://www.tbs-sct.canada.ca/pol/doc-eng.aspx?id=25049 https://otc-cta.gc.ca/sites/all/files/altformats/books/Code-VE-en-final_0.pdf, https://publications.gc.ca/collections/collection_2016/edsc-esdc/Em4-7-2016-eng.pdf; United Kingdom: https://www.gov.uk/government/publications/ministerial-code, https://assets.publishing.service.gov.uk/media/5d834869e5274a2036a24e0d/201612_Code_of_Conduct_for_Special_Advisers.pdf.
In Jordan, in addition to the CoC, JIACC requires each public entity to develop and implement a special code of conduct at entity level. Indeed, JIACC’s National Integrity Indicators (NII, see also Chapter 2) measure whether the entities have a special code of conduct that considers the specific nature of its work. These codes need to be signed by all employees and communicated actively. Through the NII, JIACC is providing incentives to public entities to comply and implement codes. According to information provided by JIACC, municipalities are starting to develop their own codes of conduct and JIACC is following-up on the progress. Jordan has also adopted specific codes of conduct for some risk areas. For example, there exists specific codes for the judiciary, including the prosecution services, for JIACC staff, for the House of Representatives and for Students and teachers (Table 3.1).
Source: Compiled by OECD
This approach of providing more detailed guidance on expected behaviour is a good practice and Jordan is encouraged to continue promoting and supporting the development of such codes. Identifying other high-risk areas where specific codes could be useful. For example, other high-risk areas in Jordan include high-level positions, such as senior public officials and ministers, or employees in municipalities not covered by the CoC, that are directly delivering key public services and therefore have a high level of direct contact with citizens and firms.
Of course, public procurement is a high-risk area in all countries given the financial resources involved and the close interaction between the public and the private sector. As such, providing clear guidance to procurement officials at all levels on their duties and responsibilities as well as on integrity policies is key. Jordan has undertaken recent reforms, modernising its procurement system. Most recently, the Government Procurement Bylaw 8 from 2022 continued to modernise Jordan’s procurement system following international practices and standards, including a centralised electronic procurement system (Jordan Online Electronic Procurement System, JONEPS). Building on this progress, the Procurement Policies Committee could task the Government Procurement Department, reporting to the Ministry of Finance, and the Government Tenders Department, reporting to the Ministry of Public Works and Housing, to develop a specific code of conduct for those involved in public procurement procedures. The code should allow procurement officials to better identify, understand and mitigate the risks and potential conflicts of interest they are facing and include concrete examples from practice. A participative process involving procurement officials of different entities and sectors could significantly enrich the process and ensure a relevant code. The Procurement Policies Committee could approve and promote the use of the code in all procuring government agencies and units.
To ensure that such institutional codes or codes for at-risk categories of public officials are coherent and based on a common set of public principles and values (for instance a new and streamlined set of values and principles as recommended above), JIACC and SPACC could jointly elaborate a simple generic manual offering methodological guidance (a “step-by-step” guide) on how to develop and implement codes. The Ethics Management Model used in Costa Rica is a good example on how such methodological guidance could look like (see Box 3.3 above). Upon request, JIACC and SPAC could provide ad-hoc assistance to entities, but the main effort should come from the entities. This way, JIACC and SPAC can ensure the quality of the resulting codes and their alignment with the overarching principles and values, while allowing enough space and flexibility to respond to the specific context or risk group.
This methodological guidance should include information on how to develop, step-by-step, a code of conduct, an include information on, for example:
How to conduct an internal diagnostic exercise (for example using an internal survey, focus groups or interviews with staff) which maps key internal processes and positions and their integrity risks. Ideally, this diagnostic exercise would be able to draw on current efforts to promote corruption risk assessments in the public administration (Chapter 5). Identifying situations of conflict of interest that can typically happen in the given context would be an essential part of this diagnostic.
How to implement exercises that invite public officials to link the generic set of principles and values that apply to the whole public sector in Jordan to relevant behaviours and situations of their specific day-to-day context (e.g., what does “fairness” or “transparency” concretely mean for a public procurement official). These concrete behaviours and situations can be used as examples in the code or in trainings and will be key to ensure that the code is relevant and reflects the reality of the entity or at-risk situation.
How to write a draft code in simple and plain language based on the inputs received from the diagnostic exercise and the exercises aimed at identifying concrete situations and examples.
How to organise an internal consultation on the draft code to raise attention, receive feed-back, continue building ownership amongst staff at all levels and elaborate the final version of the code.
How to implement the code, for example by providing a toolbox with measures aimed at integrating the code into existing processes and at communicating the code to ensure it becomes a well-know and relevant reference to public officials
How to monitor its implementation, evaluate its success and periodically revise the code.
Establishing procedures for identifying, managing and resolving conflict of interest is essential for public officials to uphold public integrity in their role. Public officials must know what is required of them in relation to identifying and declaring conflict-of-interest situations (OECD, 2004[12]). When conflict-of-interest situations are not properly identified and managed, they can seriously endanger the integrity of organisations and may lead to corruption in the public sector and private sector alike. At the same time, in many countries, conflicts of interest are typically often misunderstood and equated with corruption by public officials. This misunderstanding may imply that some public officials are reluctant to disclose a situation of conflict of interest out of fear of what might happen to them afterwards.
Therefore, having a strong and consolidated framework, where management and prevention of conflict-of-interest situations are effective, is key to safeguarding democratic achievements. Of key importance is the understanding and recognition that everybody has interests; interests cannot be prohibited, but rather must be properly managed. The OECD Recommendation on Public Integrity (OECD, 2017[2]) has called for countries to set high standards of conduct for public officials, through:
Setting clear and proportionate procedures to help prevent violations of public integrity standards and to manage actual or potential conflicts of interest.
Providing easily accessible formal and informal guidance and consultation mechanisms to help public officials apply public integrity standards in their daily work as well as to manage conflict-of interest situations.
Averting the capture of public policies by narrow interest groups through managing conflict-of interest situations.
In Jordan, conflict of interest is currently addressed in Article 69 of the Civil Service Bylaw 9 of 2020 and in the CoC. Also, the Integrity and Antti-corruption Law criminalises if public officials do not disclose their conflicts of interest. The Civil Service Bylaw 2020 lists a series of prohibited conducts, under penalty of disciplinary liability, including “exploiting his/her position to serve any personal benefit or benefit he/she has no right to”. The version of the CoC published currently on JIACC’s website includes provisions on “accepting or requesting gifts, privileges and other benefits” (Article 8) and on conflicts of interest (Article 9), covering several areas that could lead to a conflict of interest:
“Article 9. Conflict of interest for the employee
A. Refrain from carrying out any activity that would lead to the emergence of a real, apparent or potential conflict between their personal interests on the one hand, and between their responsibilities and job tasks on the other.
B. Refrain from carrying out any activity that is not compatible with the objective and impartial performance of their duties, or that could lead to preferential treatment to natural or legal persons in their dealings with the government or harms the reputation of their department or jeopardizes its relationship with the public.
C. Informing their direct superior in writing and in an urgent manner in the event of a conflict of interest taking place with any person in their dealings with the government, or if there’s a conflict between personal interest and public interest, or the employee is exposed to pressure that conflicts with or their official duties or provokes doubts with their objectivity in addition to, clarifying the nature of the relationship and the nature of the conflict. The direct manager must take necessary measures as a result. In all cases, the public interest must be considered when dealing with this type of conflict.
D. Not to use their job, directly or indirectly, to obtain financial gains or anything of value for their or their family’s benefit.
E. Not to exploit or employ the information they obtain during the performance of their official duties and after the end of their work in the department, as a means to achieve personal benefits for themselves or others, directly or indirectly, or to harm others, and not to disclose information to give an unfair or unreasonable advantage to other parties.
F. The necessary approvals and authorizations must be obtained in accordance with the relevant applicable laws and regulations, if they wish to participate in the process of collecting donations, prizes, or in-kind contributions to charitable organizations, and the direct manager may request from the employee reduces, modifies, or terminates activities when they believe that they will result in a real, apparent or potential conflict of Interests.
G. Avoid establishing close relationships with individuals or institutions whose interests depend primarily on their decisions or the decisions of their department.
H. Not accepting a job, within one year from their end date, in any institution that has important official dealings with the department in which they worked in, except with written approval from the Minister. Additionally, they are not allowed to provide advice to clients of these institutions based on information that might not be available to the public regarding the programs and policies of the department for which they worked.
I. The direct supervisor must inform the employee who intends to quit their job of the obligations listed in this article.
3.3.1. Jordan could consider amending the Civil Service Bylaw to provide a clear definition of real, potential and apparent conflict of interest, to include the procedure public officials and the superiors must follow and to strengthen the cooling-off provision
First, to enable public officials to identify and manage conflict-of-interest situations, it is advisable to adequately define a “conflict of interest” (OECD, 2004[12]). This can be done descriptively (i.e., defining a conflict of interest in general terms) or prescriptively (i.e., defining a range of situations considered as conflicting with public duties) (OECD, 2020[1]). The OECD defines a conflict of interest as “a conflict between the public duty and private interests of a public official, in which the public official has private-capacity interests which could improperly influence the performance of their official duties and responsibilities” (OECD, 2004[12]).
In Jordan, the Civil Service Bylaw currently does not provide a general definition of a conflict of interest. Rather, it follows a prescriptive approach: the legislation defines a range of situations considered as conflicting with official duties. While this has the advantage of clearly laying out key dimensions, the approach requires a comprehensive list of potential situations. Arguably however, such an exhaustive list is impossible to achieve. While jurisprudence and interpretations could adapt to emerging issues that were not explicitly considered in the legal texts, such a reactive approach would leave public officials with a certain level of uncertainty as they would depend on ex post jurisprudence and interpretation. Indirectly, it may also lead public officials to (wrongly) believe that all situations that are not listed, are fine, without carrying out an ethical reflection of whether the situation could involve conflicting interests.
Therefore, Jordan could provide a clear and simple legal definition of conflict of interest. Such a definition could be provided in the Civil Service Bylaw, for example, by aligning it with Article 9 of the CoC as cited above. In addition, the legal text could be complemented by a guideline (see next section). The amendment could be the opportunity to clarify the difference between real, potential and apparent conflict of interest, as introduced in the version of the CoC as published on JIACC’s website, as each one is relevant to safeguard the public interest. In France, for example, the Law of 11 October 2013 on transparency in public life defined a conflict of interest as “a situation in which a private or public interest interferes with a public interest in such a way that it influences or appears to influence the independent, impartial and objective performance of a duty”. State the procedure for the management for conflict of interest, including its reporting (to whom) and management (recusal).
Second, in addition to a clear definition, public officials need clarity concerning procedures they are expected to follow to prevent and to manage conflicts of interest. Public officials need to know the concrete steps of what is expected from them. Clarity of what follows a declaration of conflict of interest is therefore key as it can contribute to mitigating such fear and reduce the uncertainty of the consequence of disclosure.
In Jordan, the version of the CoC published on JIACC’s website stipulates that public officials shall inform their superiors in writing, but it is not clear if an informal statement would be sufficient or whether the public officials must follow a certain procedure. This absence of a clear procedure was emphasised by stakeholders in Jordan during interviews carried out by the OECD. In addition, the CoC currently requires the direct manager to take “necessary measures” when an employee declares a conflict of interest. However, there are no clear guidance on what measures exactly a superior could take. It is important that Jordan clearly set out and communicate the procedure for managing a conflict of interest. Public officials need clarity on how and to whom to declare a conflict of interest and superiors need to know what to do when receiving such declarations.
Therefore, in addition to considering to include a clear definition in the Civil Service Bylaw, Jordan could add a standalone provision that includes the procedure for declaring a conflict of interest and the avenues for resolving it. It should also specify in which timeframe a conflict of interest shall be declared and in which timeframe the public official can expect a response from its superior on how to resolve the situation. Jordan could also reflect on elaborating a template form that public officials could use to proactively declare a conflict-of-interest situation, including several relevant elements (Box 3.4).
Description of the private interest, pecuniary or non-pecuniary, impacting the official duties.
Description of the official duties the public official is expected to perform.
Identification of whether this is an apparent, potential or real conflict of interest.
Signed employee declaration committing to manage the conflict of interest.
Description by the manager of the proposed action to resolve the conflict of interest.
Signature of both manager and employee that has been discussed.
Source: (OECD, 2019[13])
Third, one of the main risks and concerns related to conflict of interest is the so-called “revolving door”. Movements between the private and public sectors result in many positive outcomes, notably the transfer of knowledge and experience. However, it can also be a vehicle for undue or unfair advantage and to influence government policies and decisions if not properly regulated. Time limits, or “cooling off” periods, are a useful tool to prevent abuses of the revolving door. When considering the length of cooling-off periods, these time lengths should be fair, proportionate and reasonable considering the seriousness of the potential offence and be tailored to the risk, e.g., depending on the type of problem area and level of seniority. Similarly, many countries have decided to include compensation for former high-level officials whose decision-making powers covered a wide range of issues which would make finding a job difficult (OECD, 2020[1]).
In Jordan, the version of the CoC cited above contains a “cooling-off-period” provision in Article 9.H. It prohibits accepting job offers within one year after leaving public functions, in any institution with which the department in which they worked had “important official dealings”. Exceptions to this rule can be granted by the Minister. The CoC does not provide sanctions for individuals and companies that do not comply with the “cooling-off-period”.
To strengthen its legal provision, Jordan should amend the Civil Service Bylaw in line with the CoC and clarify what “important official dealings” would entail as well as the criteria under which exceptions to this provision could be granted by the respective Minister. It should further require that such exceptions should be documented, clearly justified and archived. Lastly, for the sake of clarity and legal certainty, Jordan could establish a communication channel with the private sector to advise on potential questions regarding former public employees and the scope of coverage of the law. Similarly, the Civil Service Bylaw could establish concrete sanctions (primarily fines) for non-compliance with the cooling-off periods for both individuals and private companies who disregard these provisions and hire a public official during a cooling-off period.
Finally, when amending the Civil Service Bylaw, Jordan could consider including a standalone article which states the purposes and procedures of asset declarations. This would allow a clearer separation between asset declarations, focusing on preventing and detecting illicit enrichment, and the prevention and management of conflict of interest. However, Jordan’s asset declaration system has not been analysed in the scope of this OECD Integrity Review.
3.3.2. JIACC, together with the SPAC, should elaborate complementary guidance on the definition and on key concepts, which should include non-exhaustive examples, and on the expected procedures for managing conflict of interest
In addition to amending the legal framework to clearly lay out the definition of conflict of interest and the expected procedure to prevent and manage them, public officials typically will require additional, complementary guidance in non-legal documents, such as guidelines or manuals. Such complementary material should be drafted in simple and plain language.
First, considering that the concept of “conflict of interest” can be difficult to comprehend, such a complementary guideline could further clarify what a conflict of interest is. For example, the French High Authority for Transparency in Public Life (Haute Autorité pour la transparence de la vie publique, HATVP) published a comprehensive guide on conflicts of interests for public officials (HATVP, 2021[14]). A further example is a website provided by the Canadian Treasury Board in Canada which provides information, material and a section on frequently asked questions about the different types of conflict of interest and how public servants can prevent, manage and resolve them. Furthermore, it could be an inspiration for Jordan on why and how to clearly define real, potential and apparent conflict of interest (Box 3.5).
The Treasury Board in Canada provides concrete definitions and guidance on real, potential and apparent conflict of interest as part of the Values and Ethics Code for the Public Service. It is emphasised that “preserving the appearance of integrity in government is as important as actual integrity” and that public servants therefore are required to avoid apparent conflicts of interests as much as actual or potential ones.
The guidance provides the following definitions:
A "real" conflict of interest is where a public servant's private interests are sufficient to influence the exercise of his or her public duties. A "potential" conflict of interest is where such a situation could arise in the future. An "apparent" conflict of interest, however, is where it appears to members of the public that a public servant's private interests could improperly influence the performance of his or her duties. "Private interests" are not limited to financial interests.
As apparent conflicts of interests can be particularly difficult to understand and identify, further guidance is provided, emphasising for example:
In determining apparent conflicts of interest, the appearance of a public servant's actions to the public is the key, not the public servant's integrity or good faith. Public servants can be found to be in apparent conflict of interest even if they are not aware that their actions create an apparent conflict of interest. Public servants - and their managers – are required to think beyond the scope of their own perceptions and motives, and to consider how the public may perceive their actions.
An apparent conflict of interest is determined by the perception of "a reasonable person" (a hypothetical member of the public) who is "reasonably well-informed".
Such a person is to have a "reasonable perception" that a conflict of interest exists, even if the conflict of interest is not a major one.
The onus is on public servants to anticipate apparent conflicts of interest arising from their actions, and to take steps to comply with the rules.
This onus on public servants is ongoing, as apparent conflicts of interest may arise at any time, if their personal affairs or official duties change. This onus extends to disclosing items about which there is doubt, and continues after filing a disclosure report.
Whether a conflict of interest is apparent or potential or real, the consequences are the same. The conflict must be remedied. Efforts should therefore focus on determining appropriate methods of compliance, rather than making definitive classifications on the type of conflict of interest.
Second, the concept of a conflict of interest entails several related concepts that can be difficult to understand as well. In Jordan, for instance, the CoC outlines that civil servants shall refrain to use public authority for private or financial interests or refrain from directly or indirectly accepting or requesting any gift or other benefits, but it does not define what private interests, gifts or other benefits entail.
Therefore, to further strengthen its conflict-of-interest management practices, Jordan could consider clarifying through complementary guidance key terms such as “private interests” (Box 3.6), “gift”, “benefit”, “nepotism” and “favouritism”. These clarifications could include descriptions of circumstances as well as concrete examples. In any case, the guidance should emphasise that it does not provide an exhaustive list of situations. This way, public officials are nudged towards reflecting on conflict of interest and not just checking boxes. These examples could include benefits that could impact officials’ impartiality such as invitations for lunch/dinner or to events.
As established by OECD standards, private interests include financial or pecuniary interests, interests which generate a direct personal benefit to the public official and/or their family, legitimate private-capacity activity, personal affiliations and associations, family interests and other interests that could reasonably be considered likely to influence improperly the official’s performance of their duties (OECD, 2004[12]).
In this sense, private interests that could lead to a conflict of interest may include, for example, personal relationships, family and community relationships, business interests, external activities and positions, as well as gifts, benefits, favours and hospitality.
Source: Based on (OECD, 2004[12]).
Third, besides establishing the procedures for the reporting and managing in the legal framework by the Civil Service Bylaw as recommended above, JIACC could consider providing additional guidance on concretely how public officials are expected to manage situations of conflicts of interest. Such complementary guidance could also include laying out potential solutions for conflict-of-interest situations and would also provide concrete guidance for the superiors expected to guide their employees after receiving a declaration of conflict of interest, as mentioned above (Box 3.7).
When a public official has a potential or real conflict of interest, there are several measures that can be taken to manage the conflict and reduce the risk of biased decisions. These measures be categorised into “strategies that focus on the private interest” and “strategies that focus on the public official”.
Strategies that focus on the private interest aim to eliminate or mitigate the influence a private interest can exert on a public official and include:
Divestiture: the public official relinquishes their external interest entirely – for example, by selling shares or stocks. Transferring the private interest to a family member does not equal divestiture.
Resignation: the public official resigns from their external employment position that is causing the conflict of interest
Waiver: the public official waives their involvement in particular activities of their external employment that could lead to a conflict of interest
Establishing a bind management trust to manage the financial interests (e.g., stocks, shares, other investments) of the public official while holding public office: the interests are transferred to a third party, who manages them independently. The official remains the beneficiary, but cannot interfere in the management of the assets, issue instructions, or know how the assets are being invested/used.
Strategies that focus on limiting the influence of the public official on the decision-making process include:
Recusal or restriction: where a particular conflict is not likely to recur frequently, it may be appropriate for the public official concerned to maintain their current position but not participate in decision making on the affected matters, for example by having an affected decision made by an independent third party, or by abstaining from voting on decisions. Care must be taken to protect the integrity of the decision-making process where recusal is adopted. Likewise, an option to restrict access by the affected public official to particular information, by prohibiting them from receiving relevant documents and other information relating to their private interest, could be adopted.
Reassignment: The public official is reassigned to a different set of functions, tasks or portfolios.
Resignation: in some cases, the conflict of interest may be so difficult to manage and the potential negative consequences may be so serious, that resignation or termination may be the only feasible strategy to uphold the public trust. In the event of resignation of the public official from their public office, the conflict-of-interest policy (together with the relevant employment law and/or employment contract provisions) should provide the possibility that the official can be terminated in accordance with a defined procedure in such circumstances.
Source: Adapted from (OECD, 2004[12]) and (World Bank/OECD/UNODC, 2018[15]).
3.3.3. Line managers and Integrity Officials as recommended in Chapter 1 should be trained to provide ad hoc advice to public officials on identifying and managing conflict of interest, while an online platform could be implemented to provide initial directions to employees
The legal framework and written complementary guidance materials must be supported by ad hoc support to public officials. Conflicts of interest can arise at any moment and public officials need to know and feel safe to seek advice and guidance on how to manage such situations correctly. In turn, superiors need to know what and how to provide guidance to their employees in such situations.
Currently, the CoC requires public officials to inform their direct superiors of a conflict-of-interest situation. Ad hoc guidance to public officials should be provided, therefore, primarily by line managers. However, public officials may not always feel comfortable to reach out to them. Therefore, line managers should encourage an environment of confidence so that their teams can formulate questions and reveal situations that may place them in a potential conflict of interest. In addition, good practice shows that dedicated Integrity Officers within each public entity as recommended in Chapter 1 can play a key role to really provide public officials a place to go in their organisation in case of questions and doubts on how to behave. They can also support officials in filling the conflict-of-interest template form, raise awareness on conflicts of interest more generally, emphasising in particular the difference between corruption and a conflict of interest (a situation of risk that needs to be managed correctly) and provide guidance and support to the direct superiors in charge of “taking measures” (i.e., help the direct superiors in what measures to recommend concretely to their employees). In any case, the persons who provide ad hoc support should be specifically trained to be able to respond to questions and concerns (see section below on “advanced trainings”).
Finally, technological tools can help relieve the burden of line managers and integrity officials alike and allow them to focus their in-person ad hoc support to the most complex situations. The SPAC, together with JIACC, could design and implement an online tool, in simple and plain language, which guides public officials through the process of correctly identifying conflict-of-interest situations and which can provide initial directions on how to manage these. The online simulator implemented by the Anti-corruption Office of Argentina could inspire such a platform in Jordan (Box 3.8).
To provide specific guidance and orientation on conflict-of-interest situations, the Anti-corruption Office of Argentina (Oficina Anticorrupción, OA) implemented an online conflict-of-interest simulator. Through the selection of answers to certain questions, public officials receive an assessment of whether they are in a situation of current or potential conflict of interest and orientation about what to do. The simulator is available for future, current and past public officials. By asking the public official various questions throughout the simulation, the simulator determines if the official is in a conflict-of-interest situation based on the legal framework. If a potential conflict of interest is detected, the simulator informs the official of the violated norm of the Public Ethics Law and advises the public official to seek more specific guidance of the OA. The simulator is a useful tool to enable officials to clarify any doubts they might have over a situation.
Source: (OECD, 2019[13]).
Developing clear standards of integrity, including on preventing and managing conflict of interest, is not an end in itself. Legal provisions and policies remain words on paper if they are not adequately communicated and trained. Socialisation mechanisms are the processes by which public servants learn and adopt ethical norms, standards of conduct and public service values (OECD, 2018[3]). Indeed, effective implementation and behavioural change require raising awareness about integrity standards and values, building technical knowledge and skills. Raising awareness helps to recognise integrity issues when they arise, while building capacities via trainings and guidance material help to address integrity challenges properly. Both, in turn, contribute to cultivating commitment among public officials (OECD, 2020[1]).
Countries can use several tools and mechanisms to raise awareness and build capacities relevant for public integrity to public officials. To be effective, awareness-raising and capacity building activities should be clear, provide up-to-date information, be tailored to the specific needs and be designed and implemented by considering the following elements: content, timing, targeted audience and delivery methods. Capacity building activities can include induction, regular and special trainings and should include monitoring and evaluation on the quality and impact of the trainings (OECD, 2020[1]).
3.4.1. JIACC and SPAC, if required in co-operating with the PMIO, IPA and MOLA, should further invest in raising awareness and developing capacities for integrity, especially at the municipal level and for integrity officers as recommended in Chapter 1
Jordan has invested in raising awareness through broader campaigns and specific activities as well as in building capacities on integrity and anti-corruption on different levels and for different audiences. Several initiatives from JIACC target citizens, civil society organisation and businesses, which are discussed in Chapter 4 of this OECD Integrity Review. JIACC, as well as the Institute of Public Administration (IPA), have also designed and implemented awareness raising and training activities targeting public officials.
Amongst these initiatives directed to public officials carried out of the past years, JIACC and the IPA have been implementing, for example, the following activities and programmes:
JIACC has created courses on integrity standards and corruption crimes and has developed and conducted specialised trainings on integrity and countering terrorism via its Innovation and Training Centre, amongst others. For example, JIACC offers a 20-hour training for general managers. Also, the trainings related to the National Integrity Indicators provided by JIACC are particularly key in promoting change, raising awareness and promoting knowledge on issues such as the code of ethics, role models and values and integrity standards.
JIACC is delivering awareness raising lectures for public officials in senior, supervisory and leadership management positions, executive staff and new staff in different ministries and in the Greater Amman Municipality.
JIACC has partnered with different institutions to design and implement capacity building activities. For instance, JIACC and the University of Jordan offer a master’s programme on anti-corruption and integrity.
The IPA developed a leadership programme, which is compulsory for (i) managers under the umbrella of the SPAC, (ii) public officials that will or might become managers, (iii) supervisors that are heads of division, (iv) supervisors, and v) public officials that will or might become supervisors. The leadership programme includes, for example, components on integrity and anti-corruption, merit-based hiring, performance-based evaluations and on developing soft skills for leaders.
Together with JIACC, the IPA has also developed and implemented training programmes on “compliance with national integrity standards” and on “enhancing governance practices”, as well as training modules for all public officials, which include anti-corruption and integrity issues. Some of these modules are mandatory and are based on a competency dictionary that had been developed by the Civil Service Bureau (CSB), the precursor of the SPAC, while others are voluntary and are based on actual needs of the respective institutions.
Regarding the trainings and awareness raising activities by JIACC and the IPA, these represent an important improvement and Jordan can build on these initiatives in several ways.
First, there is room for strengthening capacity building on integrity and anti-corruption among employees at the local and municipal levels. Given the challenges and known integrity and corruption risks at subnational levels (see Chapter 1), increasing efforts to raise awareness and build capacities of employees at municipal and governorate levels is key. To that end, JIACC could co-operate with the IPA, the Ministry of Local Administration (MOLA) and selected municipalities to develop specific trainings on integrity and anti-corruption for local employees. Trainings could focus on high-risk areas, such as procurement or the delivery of public services with frequent and direct interactions with citizens and business, and on sensitive topics such as favouritism/wasta, conflicts of interest in the context of recruitments or integrity in election processes and other areas considered as relevant. As such, it is commendable that JIACC has analysed training needs in municipalities and integrated the local level into training plans for 2024, amongst others, on procurement. The National Integrity Indicators will also be able to inform the trainings and the topics to be covered. Additionally, the trainings can provide additional guidance on developing and implementing the codes of conduct at municipal level mentioned above.
Second, there are several methods available to support delivery of integrity trainings, including lectures, online courses, coaching and mentoring programmes (OECD, 2020[1]). Research has shown that while online courses and lectures allow reaching a larger audience, interactive components, where participants are confronted with realistic situations, are more likely to generate a personal mental commitment to integrity than mere presentations by trainers (Bazerman and Tenbrunsel, 2011[16]). Considering this, JIACC could partner with the IPA and the SPAC to develop complementary training activities on anti-corruption and integrity that use different delivery methods tailored to the target audience, the training’s objectives and the available resources.
For instance, the following multilevel approach could be considered:
General level: JIACC, the IPA and the SPAC could consider developing an online course on anti-corruption and integrity to help public officials familiarise themselves with relevant concepts, expected behaviours and rules derived from the regulatory framework for public integrity. Such a training method could be prioritised in the case of induction training to new employees and specific training derived from changes to the regulatory framework. A special online training on identifying and managing conflict of interest could be considered. For example, the Office of the Independent Commissioner against Corruption of the Northern Territory in Australia provides a free conflict of interest training course that is available online.
Intermediate level: Building on already existing in person trainings, JIACC, the IPA and the SPAC could consider further developing lectures and courses on specific areas of the regulatory framework for public integrity, in particular also on corruption risk management, on dealing with ethical dilemmas or on identifying and managing conflict of interest, where participants are presented with concrete situations (Box 3.9). These trainings are ideally in person, go into more details and provide concrete examples that public officials can relate to.
Advanced level: To further engage specific priority groups of public officials and help them strengthening their capacities to address and manage integrity challenges, JIACC, the IPA and the SPAC could design and implement in-depth practical trainings and encourage participants to discuss and connect with their peers. Specialised trainings modules could be developed, for example, to train public officials in at-risk positions (e.g., procurement or human resource management). Middle and higher management levels, particularly secretary generals and director generals, could be trained in integrity leadership skills (see section below on promoting integrity leadership).
To raise awareness and capacities on public integrity, the Agency for Government Personnel of the Flemish Region developed a series of guidelines for integrity actors to discuss ethical dilemmas. Ethical dilemma training provides participants with practical situations in which they face an ethical choice with no clear path to resolving the situation in a good, moral way. In such training, the facilitator encourages discussion between the participants about how to resolve the situation and helps them explore the different choices. The focus of the ethical dilemma training is the debate rather than possible solutions, as the objective is to help participants identify how different values might act in opposition to one other.
Examples of ethical dilemma situations include the following:
Situation 1: “I am a policy officer. The Minister needs a briefing within the next hour. I have been working on this matter for the last two weeks and should have already been finished. However, the information is not complete. I am still waiting for a contribution from another department to verify the data. My boss asks me to submit the briefing urgently as the Chief of Cabinet has already called. What should I do?
I send the briefing and do not mention the missing information.
I send the briefing but mention that no decisions should be made based on it.
I do not send the briefing. If anyone asks about it, I will blame the other department.
I do not send the information and come up with a pretext and promise to send the briefing tomorrow.”
Situation 2: “I am head of a department. My senior official asks me to carry out an interesting assignment that will help my department score well. We need that after the recent blunders of my department. The content of that assignment actually belongs to another department. What am I doing?
After I have notified the other department of the assignment, my department will carry out the job.
I inform the other department that I have received the assignment and ask them for input.
I refuse the assignment because I don’t think I can do it in front of the other department.
I carry out the assignment and do not inform the other department myself: after all, this is the task of my senior official.”
Source: (Flemish government, n.d.[17]).
Finally, although integrity is ultimately the responsibility of all organisational members and in particular the leaders, dedicated “integrity actors” play a key role in stimulating integrity and shaping ethical behaviour. Considering this, Chapter 1 of this Integrity Review recommended to create permanent and dedicated integrity officers in every public entity at national and at subnational level. Such integrity officers should have the mandate and be empowered to become a “safe haven” to provide guidance, advice and counsel to public officials within their institution. As such, these integrity officers could play a key role in promoting open organisational cultures of integrity. To do so, they require specific capabilities and skills.
Therefore, to ensure some level of coherence across public entities and levels of government and to prepare integrity officers for the situations that they may encounter while carrying out their activities, the SPAC, together with JIACC and IPA, should create a specific training programme for integrity officers in public institutions and municipalities. Trainings provided to integrity officials could include train-the-trainer activities to turn these actors into multipliers of information and should include the development of soft skills and capacities needed to create trust and to build a “safe haven” in their entity.
Jordan should continue implementing measures to monitor and evaluate the quality and impact of their training activities, to learn from the implementation, introduce relevant changes to the trainings and/or focus limited resources in those activities that prove to deliver the best results. For example, a multi-level model for measuring their training activities could be adopted (Box 3.10).
One of the commonly acknowledged models for assessing training is the Kirkpatrick “Four Levels Model” outlined as follows:
Level 1: Reaction, the immediate impressions of the participants and trainers, what they thought and felt about the training.
Level 2: Learning, the development of knowledge, skills and attitudes resulting from the training.
Level 3: Behaviour, the extent of behaviour and capability improvement, and demonstrated application of the new learning within the work setting.
Level 4: Results, the impact on work results; the return on the training investment.
While most assessments focus on level 1, pre- and post-trainings assessments in the form of “multi-rater assessments”, for instance, 360-degree assessments along a control group (McGivern and Bernthal, 2002[18]), could help to measure behaviour change. This would allow gathering useful data on whether the training really serves the purposes of the organisation and whether costs are justified (OECD, 2020[1]).
To measure level 4, public organisations require a baseline established prior to the beginning of the trainings against which potential changes are measured. Potential indicators in this respect could be (OECD, 2020[1]):
Number of cases where public officials sought integrity advice and the outcome of such cases.
Number of disclosures of potential conflicts of interests to relevant authorities including mitigation measures taken and implemented.
Perceptions about the level of integrity and openness of the organisation.
Number of reports from citizens and businesses outlining public officials not behaving integer in providing public services.
Level of satisfaction of citizens and businesses about the quality of public services.
3.4.2. JIACC could design and rigorously test different messages to be used in awareness raising campaigns before implementing them at scale
Making sufficient and relevant information available for public officials is key to raising awareness about integrity standards and triggering behavioural change. Public entities may use different means for raising awareness about integrity standards, including posters, computer screen savers, employee boards, banners, bookmarks, among others, as well as different messages depending on the targeting audience (OECD, 2020[1]). As mentioned before, awareness must be raised not only in the public sector, but also amongst citizens, civil society organisations and businesses, which will be discussed in Chapter 4.
Interviews and focus groups conducted in Jordan by the OECD with public officials highlighted that, as in many countries, corruption prevention is often more associated with concepts of control and enforcement rather than promoting integrity. Also, these same interviews and focus groups noted that there is often resistance from institutions and public officials to change. As such, communication activities aimed at raising awareness, both in form of broader campaigns targeting the public sector or more specific activities targeting specific groups or entities, could be key to achieve organisational cultures of integrity throughout the public sector as they can ensure a general understanding of integrity standards and encourage specific behaviours.
However, when designing such communication activities, countries should be aware of sometimes unintended consequences. For instance, reminding people about the scope and costs of corruption could simply reinforce that corruption is the norm and thus facilitate the justification of own unethical behaviour (“everybody is doing it”). Corruption can then become a self-fulfilling prophecy and such messages can reinforce existing perceptions (Corbacho et al., 2016[20]; Peiffer, 2018[21]; Cheeseman and Peiffer, 2021[22]). Therefore, JIACC could build on recent available research and consider designing and implementing awareness-raising campaigns or activities that explicitly focus on making visible and salient desired behaviours, thereby contributing to reinforcing such behaviours as the social norm.
In that sense, it is commendable that JIACC already started to shift the narrative in its communications away from corruption and towards integrity. Additional efforts could, for example, link to the recommendation above to review and streamline the values and principles in the Civil Service Bylaw, the civil service human resources strategy 2023-2027 and the COC and develop messages focusing on behaviours related to these values and principles, making them visible and tangible to promote public officials understanding and making them see that these values and principles are applied in day-to-day practice and are not just wishful thinking.
To counteract unethical behaviour, so-called “moral reminders” have proven to be effective tools (OECD, 2018[3]). Moral reminders are specific, short messages that help remind public officials about the moral norms that they are expected to follow in the moment of decision making or when confronted to ethical choices (OECD, 2018[3]; Bursztyn et al., 2016[23]). Indeed, inconspicuous messages such as “Thank you for your honesty” can have striking impact on compliance with integrity standards (Pruckner and Sausgruber, 2013[24]). Similarly, short messages reminding public officials of specific tasks can be helpful in promoting the desired behaviour. JIACC could therefore assess, together with other relevant entities such as procurement authorities or human resource management, processes and procedures to identify opportunities for inserting timely reminders that could “nudge” public officials into taking desired behaviours or reminding them to consider ethical implications of the task that they are about to carry out. For example, officials should be timely reminded of filling out a conflict-of-interest declaration before starting a tender procedure (in a procurement unit) or a hiring process (in a human resource management unit).
To fine tune such messages or moral reminders and to ensure that they unfold the desired impact and do not backfire, JIACC should consider testing the impact of such interventions in a pilot before implementing them at scale. Lessons from the pilot could then lead to improvements and help fine-tuning the messages. Jordan could follow, for example, the OECD BASIC methodology for applying behavioural insights systematically (BASIC stands for Behaviour, Analysis, Strategy, Intervention, Change) (OECD, 2019[25]; OECD, 2018[3]). The example from Mexico described in Box 3.11 can serve as an inspiration for such kind of interventions. As the new CoC 2024 requires departments to “open a special register for gifts (…), in which the gifts (…) shall be recorded”, this experience from Mexico could be relevant to inspire ways to “nudge” public officials to actually declare the gifts they have received.
In Mexico, the Ministry of Public Administration in co-operation with the research centre CIDE sent out reminder e-mails to public employees required to register their received gifts. They randomly varied the text of the message to see which message had the strongest impact.
Five different types of reminder messages were sent:
Legal: It is your legal obligation to register received gifts.
Honesty: We recognise your honesty as a public official. You are required to register gifts. Show your honesty.
Impartiality: Receiving gifts can compromise your impartiality. When you receive a gift, register it.
Social: More than 1,000 registrations per year are made by your colleagues. Do the same!
Sanction: If you receive a gift and you do not inform us, someone else might. Don’t get yourself punished. Register your gifts.
The Ministry of Public Administration and CIDE then observed the number of gifts registered around the Christmas period (peak season for gifts) and compared this with previous years and against a control group who did not receive any of the messages.
The study demonstrated that receiving a reminder email increased the number of gifts registered. However, some messages were more effective than others: reminding public officials of their legal obligations and appealing to their impartiality and honesty encouraged more people to register gifts than referring to sanctions or registrations made by colleagues.
Source: (OECD, 2018[3])
3.4.3. The SPAC could partner with JIACC and the IPA to further invest in integrity leadership via specialised trainings for managers and senior civil servants and by including an integrity dimension into their performance assessments
An open organisational culture requires empowerment and courage of public official to raise ideas or concerns while knowing they will not be punished for their initiative. Again, trusted integrity officers, as recommended in Chapter 1, can help to provide such an environment where employees feel safe.
Leaders also play a key role, however. The behaviours of both top and middle level managers are instrumental in promoting open organisational cultures and mitigating integrity risks. Leaders, especially middle managers because of their day-to-day proximity to most public servants, can enable ethical behaviour by all employees and, in particular, by their direct teams (OECD, 2023[26]). First, by setting the right example from the top, leaders ensure credibility and trust in integrity standards. Public employees see that values and principles are not only aspirations but are lived in practice. Second, by communicating about values and standards and engaging employees in discussions on integrity norms, leaders raise awareness and promote engagement. Third, by advising employees on integrity concerns and listening and acting upon employees’ suggestions and reports of misbehaviour without punishing them, senior officials promote empowerment and courage (OECD, 2023[26]).
In Jordan, as mentioned above, both JIACC and the IPA have designed and implemented specific awareness raising and capacity building activities (voluntary and mandatory) for senior public officials and managers. Moreover, there are mandatory integrity modules that public officials must pass for career advancements. However, Jordan could further invest in strengthening integrity leadership behaviour to effectively promote a culture of openness and integrity in the public sector. This is particularly important as discussions with key stakeholders highlighted, as already mentioned, the existence of a strong culture of control within the public administration, low levels of trust amongst public officials, the existence of cases of wasta (close personal connections between employees and managers) in public institutions, and resistance to change both from organisations and individuals.
Given the mandate for developing institutional cultures and human resource policies, the SPAC could partner with JIACC and the IPA to develop advanced-level training for senior public officials and managers aimed at further developing capacities and skills that are needed to promote integrity and openness in their organisations. Such trainings should target not only high-level managers, but also middle-levels managers as they experience larger day-to-day proximity to most public servants and can enable ethical behaviour by their direct teams. These trainings could be developed under a gender-responsive approach that considers specific learning needs, dynamics, roles and expectations of female and male participants, and ensures both men and women are equally encouraged to participate.
Moreover, these trainings could consider several relevant dimensions to foster open organisational cultures and focus on developing key leadership skills leading to enhanced ethics in the public service (Box 3.12). For instance, trainings for Jordanian managers could consider the following dimensions aimed at supporting managers in becoming models of integrity and active promoters of an open environment for their employees:
Training on relevant integrity standards and the new principles and values of the public sector, learn how to use these principles and values in their daily activities and how to foster their use by their employees.
Training on how to manage ethical dilemmas and conflict of interest themselves as well as how to raise awareness within their teams through ethical dilemma case studies and discussions.
Training on how to build and maintain a “safe space” within their direct teams to discuss integrity openly and sincerely in professional spheres.
Five leadership skills can enhance individual and organisational integrity standards:
Technical: Responsiveness, Rule of law, Accountability, Transparency
Conceptual: Ethical Decision Making, Reliability, Resolve Ethical Dilemmas
Interpersonal: Diffuse and Establish Ethical Values
Emotional intelligence: Impartiality, Protection of Public Interest, Integrity
Social intelligence: Compassion, Fairness
Source: (Haq, 2011[27])
Finally, the SPAC could include integrity more explicitly into the performance management system for public managers. Indeed, to ensure that performance systems promote and reward integrity leadership, these should not only focus on what leaders achieve, but also on how they achieve it (OECD, 2020[1]). By integrating values-based assessments into performance evaluations, organisations can reinforce a culture of integrity and ensure that ethical behaviour is prioritised and rewarded at all levels. As a guide for such performance assessments, the SPAC could for example seek inspiration in the Canadian Key Leadership Competencies (KLCs), which define the behaviours expected of leaders in the Public Service (Government of Canada, 2016[28]), or the competency framework of the New South Wales Government in Australia, which identifies five levels of integrity and the behaviours associated with each (Table 3.2).
Source: (OECD, 2020[1]) , from New South Wales Government Public Service Commission, The NSW Public Sector Capability Framework, www.psc.nsw.gov.au/workforce-management/capability-framework/access-the-capability-framework/the-capability-framework, (accessed 22 February 2020).
A civil service selected and managed based on merit presents many benefits. First, a merit-based system reduces opportunities for clientelism, patronage and nepotism, which can be forms of corruption when they result in the use of public funds to enrich people based on their family ties, political affiliations or social status. Second, hiring people with the right skills for the job generally improves performance and productivity, which translates into better policies and services for citizens. Third, a merit-based system contributes to creating the necessary foundations to develop a culture of integrity in the public sector by providing the right type of incentives and accountabilities that underpin professionalism and public sector values (OECD, 2020[1]).
Integrity measures in merit-based systems should cover the selection, appointment and recruitment, but also be integrated throughout the whole career of public servants, including performance management, trainings and development opportunities, pay systems, discipline and dismissal. In general, the following principles should be applied to all processes: transparency (e.g., open and documented processes), objectivity (e.g., clear criteria and standardised processes), and consensus (e.g., involving multiple people in HR decision making) (OECD, 2020[1]).
To ensure consistent and fair application of the existing human resources policies, institutions and processes need to be in place. International good practices suggest that three interrelated mechanisms (institutions and processes) are key: assigning authority for the oversight and protection of the merit-based system to an independent body with investigative powers and authority to intervene in human resources processes when breaches are deemed to have happened or to be imminent; having recourse mechanisms available to candidates who feel they have been treated unfairly; and ensuring that all managers have a clear and consistent understanding of the system and their discretion within it (OECD, 2020[1]).
3.5.1. Jordan has strengthened the institutions and processes needed to ensure consistent and fair application of the existing human resources policies
In Jordan, the public sector is the largest employer and amounts to around 40% of total employment as registered for social security purposes (PEFA, 2022[29]). As such, promoting integrity in public employment is even more important. Article 22 of the Jordanian Constitution grants every Jordanian the right to be appointed to public office under the conditions as prescribed by law or regulations. It also states that appointments to any government office or to establishment attached to the government or municipal offices, whether permanent or temporary, shall be made based on merit and qualifications.
Over the past years, Jordan has made progress in modernising human resource management in the public sector. Jordan’s public employment system is governed by several laws and regulations, including the Civil Service Bylaw and the Social Security Law 1 of 2014, amongst others. Reforms are ongoing. As mentioned above, since 2024, the main responsible institution for developing human resource policies and standards and overseeing their implementation is now the SPAC. The SPAC is reporting to the Prime Minister’s Office and is an important step towards ensuring consistent and fair application of human resource policies and towards promoting merit-based recruitment. The reform reflects the transformation of the civil service system from a centralised model to a more decentralised one, as government entities have the responsibility to implement the human resource policies and procedures.
To effectively manage human resources and ensure that laws and policies are adequately implemented, SPAC became responsible for monitoring the departments’ commitment and compliance to implementing legislation, policies, standards, indicators and targets related to human resources management in all ministries. There are also several tools available to ensure that selection and recruitment processes are equal, objective and transparent. SPAC’s Assessment Centre is responsible for providing an integrated assessment centre to conduct tests for government entities if they wish to conduct them at the commission. Transparency is promoted, for example, by granting access to the electronic database where all candidates can see their rankings. JIACC is currently in the process of preparing job competencies for its positions, such as the investigators and researchers, which will include a commitment to national integrity standards.
Moreover, the recent reform in Jordan also considers recourse mechanisms available for candidates that feel unfairly treated. Article 14.c of the Public Sector Human Resources Management Bylaw from 2024 states that the if a candidate feels that its rights have been affected, the candidate can submit a complaint to the hiring entity. There, the organisational unit concerned with human resources and institutional performance development shall consider the submitted complaint and respond to them within one week after reception. By the time this report was finalised, SPAC has worked on instructions that will detail all the articles of the reform and plans to carry out control activities. It is key that these instructions are being endorsed by the prime ministry as soon as possible. Additionally, the Audit Bureau and JIACC have put in place complaints mechanisms for violations of integrity standards and allegedly cases of corruption, which can include, for example cases of nepotism and favouritism.
At the local level, the Ministry of Local Administration (MOLA) follows the Civil Service Bylaw and SPAC and MOLA are jointly responsible for supervising recruitment processes. Finally, according to the Civil Service Bylaw, the Prime Minister’s Office is responsible for hiring directly senior public officials such as Secretary Generals or Directors. Exceptionally, the Prime Minister’s Office can also hire directly through employment contracts or service outsourcing contracts. These appointments are outside the civil service system and are not undergoing the SPAC process.
3.5.2. To mitigate risks of favouritism in recruitments, SPAC should continue ongoing efforts in clarifying job categories and selection criteria, introducing more transparency as well as ensuring timely and broad advertising and communicating openings
The current reform of the SPAC offers an opportunity to continue strengthening the independence of the authority responsible for overseeing and protecting the merit-based system and ensuring its powers to oversee, investigate and intervene in human resources processes when breaches are deemed to have happened or to be imminent. While improvements have been achieved with respect to access to public services, for which wasta rates are lower than in Lebanon and Palestinian Authority (Figure 3.1), interviews conducted by the OECD confirm that interference in recruitment and selection processes remains an issue, and wasta and nepotism are still considered a widespread in Jordan’s recruitment processes, as highlighted in several reports (Rasheed, 2016[30]; Jackson, Tobin and Egger, 2019[31]; Baranik, Gorman and Wright, 2023[32]; Queen Rania Center for Jordanian Studies Community Service, 2020[33]). In fact, key stakeholders emphasised during interviews conducted by the OECD that these issues are amongst the most important integrity challenges. Concrete actions addressing this with visible results would therefore be important to restore trust of citizens. Indeed, a survey shows that 81% of respondents in Jordan perceive wasta as an unacceptable practice (Queen Rania Center for Jordanian Studies Community Service, 2020[33]).
Note: The original question: In the past 12 months have you had contact with any of the following services? How often, if ever, did you have to use wasta in order to get the assistance or services you needed?
Note: Average calculated with the data from Jordan, Lebanon and Palestinian Authority.
Source: Global Corruption Barometer 2019, Transparency International
Despite the advances in the recruitment systems, there seem to be loopholes that allows for nepotism and favouritism to happen. A lack of effective implementation of existing laws and regulations seems to be the main reason for this. Indeed, a report from Rasheed (Rasheed, 2016[30]), the national chapter of Transparency International, emphasises that while vacancies, administrative and technical needs are determined in accordance to staffing procedures by the end of each year, in practice, selection criteria or methods were often not disclosed and appointments were de facto often made outside of existing procedures. Furthermore, the report states that often exceptions were made for not openly publishing job offers to bypass formal structures without having clear criteria for such exceptions. Even for lower ranking public servant positions, exceptional recruitment processes and special employment contracts were rather frequently used and allow for circumventing existing processes and criteria (Rasheed, 2016[30]). While this report is relatively old, interviews conducted by the OECD with key stakeholders for this Integrity Review emphasised that the findings, overall, still hold: While rules and procedures exist, a lack of effective implementation continues to allow for favouritism in recruitments. The problem is particularly acute at the local level, where such practices reportedly lead to overstaffing, people being hired for positions that are not needed or people being hired without having the required skills to perform the functions of the position.
To contribute to overcoming these challenges, the SPAC should continue working towards ensuring that all positions at lower, middle, and higher levels of government are clearly identified and the role to be performed is described. Such information should be publicly available. This ensures that positions are created based on functional needs (OECD, 2020[1]). Moreover, it is advisable to publish the full organisational charts of all public entities for public scrutiny. Jordan could do so, for instance, by requiring that all public entities to publish the organisational chart on their websites. Furthermore, Jordan could consider implementing job-profiling, which helps not only to describe the tasks of positions, but also to focus on the outcomes of the job and the skills and competencies needed to achieve them (Box 3.13). SPAC could focus efforts on timely and broadly advertising and communicating job openings. Vacancies should be public and define the profile and the selection procedures. Clear and transparent criteria need to be defined for allowing exceptional, alternative hiring processes. Monitoring of these practices could fall under the responsibility of JIACC liaison officers, while the internal audit units and the Audit Bureau could continue auditing the compliance with HR regulations and procedures. Finally, JIACC and MOLA could be entitled to revise and evaluate the HR system at the municipal level from an integrity perspective.
Job profiling is a way of combining a statement about what is expected from a job with a view of what the job holder must bring in terms of the skills, experience, behaviours and other attributes needed to do the job well. It is an approach that helps organisations think about the outputs and results they want as well as what they are looking for in terms of the person who will perform the corresponding duties.
Job profiles differ from traditional job descriptions in two important respects:
They focus on the outputs or results expected from the job rather than, as in the case of traditional job descriptions, the tasks or functions to be carried out.
They include a statement about the skills and personal attributes needed for the job.
Job profiles help to determine the criteria for both selection and performance in a post. Job profiles are best when based on objective job analysis methods, which ideally include expert input and engagement with people who do those jobs. Job profiles usually include some combination of the following:
Job title
Purpose of the post (oriented towards objectives and goals of the organisation)
Scope of the post (some sense of the range of responsibility, relationships internal and external to the organisation)
Principal duties and responsibilities (what this post will be accountable for achieving)
Skills and knowledge (can include behavioural and cognitive competencies, often oriented toward a competency framework)
Experience
Personal attributes (e.g., personal values, including integrity).
Source: (OECD, 2011[34]).
3.5.3. The SPAC and JIACC could jointly increase efforts in raising awareness on disciplinary violations and sanctions and consider operating a common website to display key statistics on the disciplinary system
People orient their actions in accordance with their perception of acceptable behaviour within their social context (Bicchieri, 2005[35]; Bicchieri and Xiao, 2009[36]). The key to organisational cultures of integrity is therefore to continuously strengthen and renew efforts to establish integrity as a social norm and to integrate integrity into professional identities as discussed in the previous sections of this chapter. However, if a public employee behaves unethically without facing consequences, this behaviour can spread among or colleagues. Gradual divergences from an ethical norm tend to be more accepted by others, creating a slippery slope towards generalised dishonesty (Gino and Bazerman, 2009[37]; Robert and Arnab, 2013[38]).
While good behaviour needs to be made visible to become the reference behaviour, it is equally important to sanction undesired behaviour timely, fairly and visibly. The OECD Recommendation on Public Integrity emphasises that this requires a mix of disciplinary/administrative (e.g., warnings, dismissal), civil (e.g., compensation, appeal) and criminal (convictions) proceedings and sanctions (OECD, 2020[1]). While criminal enforcement is typically at the centre of debates around corruption (see Chapter 6), disciplinary enforcement plays an important, albeit sometimes underappreciated, role in public integrity systems. It can increase the credibility of the standards, ensure trust in the system and contribute to the creation of open organisational cultures in which integrity is a lived and practiced value.
In Jordan, the most important disciplinary regulations are codified in the Civil Service Bylaw, in the Public Sector Human Resources Management Bylaw, the CoC as well as in specialised codes of conduct for certain areas and institutions. In principle, there are two categories of violations: First, major violations, where it is not clear whether the breach might qualify as well as a criminal offence. These cases are referred to JIACC or directly to the public prosecution services (see Chapter 6). Second, for other violations, an internal investigation must be conducted by the concerned public entity. Within ministries, investigation committees can be formed consisting of representatives of different units as well as a representative from the Audit Bureau and/or JIACC liaison officer. Disciplinary sanctions can start with a warning and can include dismissal. Decisions can be appealed in front of the Administrative Court. The decision goes to the respective minister, who will sign and commission the execution of the decision. After the decision is issued, it can be stopped through a judicial appeal or by filing a grievance and issuing a decision in favour of the appellant or the complainant. However, this procedure will potentially be reviewed in the context of the ongoing reform of the civil service.
While a detailed analysis of the disciplinary process is out of the scope of this Integrity Review, interviews carried out by the OECD in Jordan indicate, however, that there is a perceived lack of enforcement of disciplinary matters. The ongoing reforms therefore are an opportunity to continue strengthening disciplinary enforcement. Also, considering that there is no statistical data publicly available, this perception is difficult to debunk, and efforts could be made to publish data on the disciplinary system. While there are different approaches in countries with respect to the statutory (and thus legally binding) character of codes of conduct, Jordan has chosen to adopt a legally binding document (Art. 11 of the CoC). Therefore, on the one hand, the SPAC, together with JIACC and the IPA, could increase their efforts in raising awareness and building capacities on this legally binding character of the CoC and the disciplinary consequences derived from violations this may entail. On the other hand, to ascertain and communicate that violations of integrity standards are not tolerated, statistical data on disciplinary enforcement should be rigorously collected and published. While individual cases of course should remain confidential, statistics play a key role in demonstrating the overall effectiveness and thus credibility of the system. A common portal operated by SPAC and JIACC could be considered to increase transparency and accountability of the disciplinary system. Korea, for example, has developed the Corrupt Public Official Disciplinary Index (Anti-Corruption and Civil Rights Commission, 2016[39]). Other good practices in terms of availability and visibility of data on disciplinary processes and sanctions can be found, for example, in Brazil and Colombia (Box 3.14).
The federal executive branch’s disciplinary system in Brazil
In Brazil, the Office of the Comptroller General of the Union (Controladoria-Geral da União, CGU) is responsible for overseeing the federal executive branch’s disciplinary system (Sistemas Correcionais, SisCor). Through a dedicated website (https://centralpaineis.cgu.gov.br/visualizar/corregedorias), users can access data on disciplinary sanctions imposed on public officials from the Federal Executive Power. The information is reported and updated monthly, and it can be filtered according to different criteria (e.g., by year, month, entity, state or underlying conduct). Tables and graphs are generated to highlight trends and enable comparisons.
The Information System Register for Sanctions and Inability Causes in Colombia
In Colombia, the Transparency and Anti-corruption Observatory publishes statistics on criminal, disciplinary and fiscal sanctions related to corruption (http://anticorrupcion.gov.co/medir/indicador-de-sanciones-disciplinarias). Data on disciplinary sanctions, data are taken from the Information System Register for Sanctions and Inability Causes (Sistema de Información de Registro de Sanciones y Causas de Inhabilidad, or SIRI) which keeps record of the decisions executed and notified to Inspector General (Procuraduría General de la Nación) by the competent authorities. In turn, the Transparency and Anti-corruption Observatory elaborates this information not only providing a map and details of sanctions but also analysing the data and providing graphs breaking the data according to several criteria such as entity, breach, department, sanction, typology of official on its website:
Source: Updated based on (OECD, 2019[13]).
Provide simple and clear guidance on overarching principles and values
Fine-tune the National Integrity Indicators (NII) to provide a coherent measuring of the National Integrity Standards (NIS) through the level of institutional preparedness (through a Compliance Matrix) and the level of institutional implementation (through an Integrity Survey). In addition, JIACC and PMIO should co-ordinate to ensure that the Institutional Culture Framework (IFC) considers and is aligned to the NIS and the revised NII.
Ensure effective communication and dissemination of the Jordanian Code of Conduct and Ethics, including clarity about the current version, to ensure comprehensive awareness and compliance across all levels of public service.
To achieve one single set of well-defined principles and values for Jordanian public officials, the SPAC and JIACC could lead a participatory process to review and streamline the current principles and values in the Civil Service Bylaw, the Code of Conduct and Ethics and the civil service human resources strategy 2023-2027.
To support ongoing and future efforts in raising awareness and capacity building by JIACC and the IPA, Jordan could provide a short definition of each principle and value as well as further guidance on how to translate each of these into concrete expected behaviours (e.g., through specific codes for areas or organisations or in a complementary guideline or manual).
JIACC, together with the SPAC and relevant entities, could continue developing specific codes for at-risk categories of public officials (e.g., procurement officials and municipal employees) and encouraging the development of organisational codes of conduct through a clear methodology and ad-hoc support.
Strengthen the prevention and management of conflict of interest
Jordan could consider amending the Civil Service Bylaw to provide a clear definition of real, potential and apparent conflict of interest, to include the procedure public officials must follow and to strengthen the cooling-off provision.
JIACC, together with the SPAC, should elaborate complementary guidance (i) on the definition and on key concepts, which should include non-exhaustive examples, and (ii) on the expected procedures for managing conflict of interest.
Line managers and Integrity Officials as recommended in Chapter 1 should be trained to provide ad hoc advice to public officials on identifying and managing conflict of interest, while an online platform could be implemented to provide initial directions to employees.
Raise awareness on integrity and strengthen the capacities of public officials
JIACC could co-operate with IPA, SPAC and MOLA to further invest in raising awareness and developing capacities for integrity, including and especially at the municipal level.
JIACC could expand its partnership with the IPA and the SPAC to develop complementary training activities on anti-corruption and integrity that use different delivery methods tailored to the target audience, the training’s objectives and the available resources, differentiating between a general level (online, for all public employees), an intermediate level (in person, on specific dimensions of integrity policies) and an advanced level (in person, for leaders, officials working on integrity and anti-corruption and at-risk positions).
The SPAC, together with JIACC and IPA, should create a specific training programme for integrity officers in public institutions and municipalities, which should include train-the-trainer activities to turn these actors into multipliers of information and the development of soft skills and capacities needed to create trust and to build a “safe haven” in their entity.
Jordan should continue implementing measures to monitor and evaluate the quality and impact of their training activities, to learn from the implementation, introduce relevant changes to the trainings and/or focus limited resources in those activities that prove to deliver the best results.
JIACC could design and rigorously test different messages to be used in awareness raising campaigns or for nudging public officials towards integrity before implementing them at scale.
The SPAC could partner with JIACC and IPA to develop advanced-level training for senior public officials aimed at further developing capacities and skills that are needed to support them in becoming models of integrity and active promoters of an open environment for their employees. Such trainings should target not only high-level managers, but also middle-levels managers as they experience larger day-to-day proximity to most public servants and can enable ethical behaviour by their direct teams.
The SPAC could include more explicitly an integrity dimension into the performance management system for public managers to ensure that performance systems promote and reward integrity leadership.
Integrate and mainstream integrity in human resources management
To ensure that positions are created based on functional needs, SPAC should continue working towards ensuring that all positions at lower, middle, and higher levels of government are clearly identified and the role to be performed described.
Public entities could be required to publish their organisational charts for public scrutiny on their websites.
Jordan could consider implementing job-profiling, which helps not only to describe the tasks of positions, but also to focus on the outcomes of the job and the skills and competencies needed to achieve them.
JIACC and MOLA could be entitled to revise and evaluate the HR system at the municipal level from an integrity perspective.
SPAC could focus efforts on timely and broadly advertising and communicating job openings. Vacancies should be public and define the profile and the selection procedures. Clear and transparent criteria need to be defined for allowing exceptional, alternative hiring processes.
Monitoring of HR practices could fall under the responsibility of JIACC liaison officers, while the internal audit units and the Audit Bureau could continue auditing the compliance with HR regulations and procedures.
The SPAC, together with JIACC and the IPA, could increase their efforts in raising awareness and building capacities on this legally binding character of the CoC and the disciplinary consequences derived from violations this may entail.
The ongoing reforms of related to human resource management are an opportunity to continue strengthening disciplinary enforcement. To ascertain and communicate that violations of integrity standards are not tolerated, data on disciplinary enforcement should be rigorously collected and published. A common portal operated by SPAC and JIACC could be considered to increase transparency and accountability of the disciplinary system.
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