OECD Integrity Review of Kazakhstan

2. Promoting an evidence-based and strategic approach to public integrity in Kazakhstan

Abstract

This chapter provides recommendations for enhancing Kazakhstan's strategic approach to public integrity within the 2022-2026 Anti-Corruption Policy Concept and beyond. The chapter further recommends enhancing risk management by identifying evidence gaps and incorporating diverse data sources into monitoring and evaluation activities. It also highlights the importance of a participatory approach for non-governmental and sub‑national actors in designing future anti-corruption strategies.

Introduction

A strategy for public integrity is essential for supporting a coherent and comprehensive integrity system (OECD, 2017[1]). However, a strategy is not an end in itself but rather a means to an end. It serves as a roadmap to establish a robust ethical system within the public domain, fostering transparency, trust, and a long-term culture of integrity. An inclusive and rigorous deliberation and consultation process can help select relevant strategic objectives that are meaningful to citizens and businesses. It can help prioritise and sequence actions in an open manner to address the most crucial integrity risks and provide the necessary evidence for the interventions that are most cost-effective and likely to have the greatest impact. Strategies are also a way of demonstrating commitment and can be used to establish institutional responsibilities. However, if strategies do not lead to visible gains – for example, due to inadequate implementation, monitoring or reporting of progress – they can at best become irrelevant and at worst erode public confidence in the national authorities (OECD, 2020[2]). To accomplish their objectives, strategies should be ambitious yet realistic enough to be able to comprehensively address key anti‑corruption areas in a practical manner (G20, 2021[3]).

For Kazakhstan, the anti-corruption strategy is of particular relevance in the context of its international ambitions under the 2050 development strategy and against the backdrop of public frustration with the pace of progress on anti-corruption issues that came to the fore in 2022 (see Chapter 1). In Kazakhstan, the Anti-Corruption Policy Concept of the 2022-2026 Anti-Corruption Policy Concept (2022-2026 Policy Concept) constitutes the main strategic policy document on anti-corruption and public integrity. The drafting process of the 2022-2026 Policy Concept was launched following the 2021 State-of-the-Nation Address of the Head of State titled "Unity of the people and systemic reforms – a solid foundation for the prosperity of the country". The 2022-2026 Policy Concept replaces the previous 2015-2025 Anti-Corruption Strategy, which was under implementation but deemed not fit-for-purpose. The government drafted the 2022-2026 Policy Concept according to the State Planning System to provide a vision for development in the field of anti-corruption (Art. 62 of Decree 790/2017). It covers fundamental principles and approaches to implement the relevant policies and objectives in line with higher-level regulations and the United Nations Sustainable Development Goals.

The 2022-2026 Policy Concept is organised around six primary strategic objectives and is accompanied by an Action Plan containing 61 policies and measures. The target indicators and expected results are to be completed by 2026 (Government of Kazakhstan, 2022[4]). The key issues and main strategic objectives include:

1. formation of intolerance to corruption, including changing values and increasing anti-corruption culture, improving the integrity of the public administration, and promoting business integrity

2. eliminating opportunities for corruption. this includes reducing the risks of inefficient public spending and corruption in procurement, increasing the efficiency of state support provided to entrepreneurs, reduction of state participation in the economy

3. improving measures to prevent impunity

4. strengthening the role of civil society in combating corruption

5. ensuring effective monitoring of the implementation of anti-corruption measures

6. further improvement of the activities of the Anti-Corruption Authority Anti-Corruption Service.

To assess its strengths and identify areas for improvement, Kazakhstan’s strategic framework can be compared with that of OECD countries, using the OECD Public Integrity Indicators (PII) (see Box 2.1) for Principle 3 of the OECD Recommendation on Public Integrity. The principle refers to the development of a strategic approach for the public sector that is based on evidence and aimed at mitigating public integrity risks through a) setting objectives and priorities following a risk-based approach to violations of public integrity standards, and b) developing benchmarks and indicators, as well as gathering relevant data on the effectiveness of the public integrity system (OECD, 2017[1]).

Analysing Kazakhstan’s 2022-2026 Policy Concept against the criteria established under Principle 3 “quality of strategic framework” of the OECD Public Integrity Indicators suggests that the Policy Concept performs well on several indicators (Table 2.1). This includes coverage of the strategic framework, evidence-based problem analysis and adequacy of implementation structures and reporting. On the other hand, inclusiveness and transparency of the intergovernmental and public consultations on the Policy Concept, as well as its financial stability emerge as areas for improvement.

Table 2.1. OECD Public Integrity Indicators – Quality of strategic framework

Indicator
1. Coverage of strategic framework
2. Evidence-based problem analysis and use of diagnostic tools
3. Minimum contents in public integrity strategies
4. Inclusiveness and transparency of intergovernmental and public consultations
5. Adequacy of implementation structures and reporting
6. Implementation of activities
7. Financial sustainability
8. Transparency of evaluation practices and use in decision making

Source: OECD (n.d.[5]), OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/.

Box 2.1. OECD Public Integrity Indicators

The OECD Recommendation on Public Integrity provides policy makers with a vision for a public integrity strategy. It shifts the focus from ad hoc integrity policies to a context dependent, behavioural, risk-based approach with an emphasis on cultivating a culture of integrity across the whole of society.

The OECD Public Integrity Indicators (PII) combine sub-indicators establishing minimum legal, procedural and institutional safeguards for the independence, mandate and operational capability of essential actors in the integrity system with outcome-oriented sub-indicators drawing on administrative data and surveys. The PII apply a mixed methods approach, drawing on both administrative data and big data provided directly by governments and surveys.

As such, these new OECD Public Integrity Indicators:

• provide objective and credible measures of different elements of a public integrity system

• are meaningful for governments because they are co-created by the OECD with governments and do not rely on subjective expert assessments. The aim is not to provide country rankings, but a tool for learning and informing better policies

• are the first-ever comprehensive set of indicators based on an agreed international legal instrument from the OECD and beyond, adhering to the same high statistical standards as other OECD indicators and are validated by OECD member countries

• provide a better alternative to existing measures, enabling analysis of the impacts of anti-corruption efforts, linking the disaggregated data to a range of economic and social outcomes. The PII could also provide the basis for establishing cost-effectiveness and cost-benefit ratios.

To date, the OECD developed the indicators and sub-indicators for six principles of the OECD Recommendation, and a first measurement has taken place for Principles 3, 10 and 13, including the strategic framework for integrity policies. The first overall analysis of OECD integrity frameworks based on PII has been published in the OECD Integrity Outlook.

The PIIs cover 38 OECD countries and 26 non-OECD countries, including Kazakhstan.

Source: OECD (2024[6]), Anti-Corruption and Integrity Outlook 2024, https://doi.org/10.1787/968587cd-en.

Ensuring the effective implementation of the 2022-2026 Anti-Corruption Policy Concept and Action Plan

An effective integrity strategy and action plan must not only lay out a comprehensive set of substantive reforms, but also indicate the means for ensuring its implementation through proper co-ordination and monitoring, as well as evaluation and reporting (OECD, 2020[2]). For the robustness of implementation, each strategy needs a central co-ordination function responsible for implementation, monitoring, evaluation and reporting of the strategy and its action plan (OECD, 2020[2]). For the accountability of a strategy, the content of the strategy should provide for clear reporting procedures and objective indicators to evaluate the intermediate and long-term outcomes. Importantly, the evaluation should be done with involvement of external actors to avoid biased analysis.

One of the six major tasks of the 2022-2026 Policy Concept (Target 5) is dedicated to ensuring effective monitoring of the anti-corruption measures implementation. The Concept emphasises that the monitoring process builds on the principles of objectivity and publicity by applying indicators that reflect the actual situation and conditions in the field of combating corruption. To implement these goals, the Action Plan includes three tasks, two of which are relevant for this report: i) development of a system for monitoring and evaluation of the effectiveness of anti-corruption measures (Measure No. 54) and ii) development of proposals for the formation of a National Corruption Perception Index (Measure 56) (Government of Kazakhstan, 2022[4]).

The Anti-Corruption Service is responsible for the annual reporting on the implementation of the Policy Concept and its Action Plan. The state bodies involved in the implementation of the Policy Concept send a report to the Anti-Corruption Service by April each year. In turn, the Anti-Corruption Service summarises the report and sends it to the Agency for Strategic Planning and Reforms and the Ministry of National Economy. At the same time, Anti-Corruption Service publishes the project of the Report on the website of the Anti-Corruption Service with the possibility for the public to provide feedback via an e-mail. Such a draft for the 2023 report was published on 11 April 2024 with the possibility of providing feedback until 20 April 2024 (Antikor, 2024[7]). The Ministry of National Economy makes a draft conclusion on the implementation of the Policy Concept and sends it together with the report to the Office of the Prime Minister by 1^st June. The Office of the Prime Minister submits a summary report and a conclusion on the implementation of the Policy Concept to the Presidential Administration by 20 June. The Agency publishes a summary report on the implementation of the Policy Concept on its website. Currently, the National Reports on Combating Corruption for 2022 and 2023 are available on the website of Anti-Corruption Service.

The Anti-Corruption Service could improve the monitoring and evaluation framework of the 2022-2026 Anti-Corruption Policy Concept

To be effective, a strategic approach requires a robust monitoring and evaluation framework based on a results chain that sets out how an activity is expected to lead to desired results. Result chains typically have five main components: inputs, activities, outputs, outcomes, and impacts (Table 2.2).

Table 2.2. Main components of a results chain

Component	Description
Inputs	Resources that go into a project, program, or policy (funding, staffing, equipment, curriculum materials, and so forth).
Activities	What we do. Activities can be stated with a verb (“market,” “provide, “facilitate,” “deliver”).
Outputs	What we produce. Outputs are the tangible products or services produced as a result of the activities. They are usually expressed as nouns. They typically do not have modifiers. They are tangible and can be counted.
Outcomes	Why we do it. Outcomes are the behavioural changes that result from the project outputs (quit smoking, boiling water, using bed nets). Outcomes can be increased, decreased, enhanced, improved, or maintained.
Impacts	Long-term changes that result from an accumulation of outcomes. Can be similar to strategic objectives.

Source: Zall Kusek, J. and R. Rist (2004[8]), Ten Steps to a Results-Based Monitoring and Evaluation System : A Handbook for Development Practitioners, http://hdl.handle.net/10986/14926.

Along the components of a results chain, it is possible to identify indicators and establish their baselines, milestones and targets. Indicators should reflect the strategic objectives, some of which may be part of the strategy document and others part of the action plan. The goal of indicators is to support comparability over time. This allows for benchmarking that can assess the effectiveness of different interventions in the strategy and in other parts of the public integrity system. (OECD, 2020[2]). There are three types of indicators that are commonly included in a robust monitoring and evaluation framework for anti-corruption strategies, focusing on the second part of the results chain:

• Output indicators: measure the completion of an activity under the action plan in the form of a product or service (e.g. law adopted, training held).

• Outcome indicators: measure the short- to medium-term changes that result from the outputs (if any) in line with the long-term purpose of the actions.

• Impact indicators: measure the long-term change that results from the outcomes, generated after the implementation of the strategy.

The monitoring and evaluation framework for the 2022-2026 Anti-Corruption Policy Concept and its Action Plan is focused on outputs and impact, but it is lacking outcome indicators that would link these two levels in a coherent results chain. As a result, the annual reports on the implementation of the Concept show how many and which type of outputs were delivered, but do not provide an assessment of any short and medium term changes these outputs have produced. The Anti-Corruption Commission could thus strengthen its evaluation and monitoring framework by developing a set of outcome indicators to complement existing output and impact indicators.

When it comes to measuring impact, the 2022-2026 Policy Concept contains indicators to assess impact along each of the six primary objectives of the strategy. These include the level of public confidence in the Anti-Corruption Service, a reduction in the share of state participation in the economy in the country’s gross domestic product structure, the proportion of persons who had contact with officials and paid a bribe, or from whom a bribe was demanded, as well as thresholds for Kazakhstan’s performance in several international indices including the Transparency International Corruption Perceptions Index (CPI), the World Bank Government Effectiveness Index, the World Bank Voice and Accountability Index, the World Bank Control of Corruption Index and the World Justice Project Rule of Law Index. It should be noted however that the CPI is elevated in the Action Plan as the sole “strategic indicator” to measure the success of the 2022-2026 Policy Concept.

The CPI score is a well-known composite index that has a wide coverage of countries and is internationally recognised. However, several observations can be made on the limitations of using the CPI as a reference framework for integrity policies, as opposed to its original purpose as an advocacy tool (OECD, 2022[9]). First, one should bear in mind that the CPI reflects the perception of experts, not citizens. Second, the link between policy measures and perceived corruption is complex. A country may effectively implement anti-corruption measures and reduce corruption, but still suffer from a persistent high-level of perceived corruption due to other reasons, such as increased media attention because of improved detection and prosecution, or due to several highly visible cases. A country can also score better on perceived corruption, whereas corruption risks and flaws in the governance system have not successfully been addressed. The CPI does take account of these complexities, as changes in CPI scores cannot be attributed to the implementation of specific policies. Third, the confidence intervals of the CPI scores are relatively large, and as a result, it often does not make sense to make comparisons between countries with similar scores if their confidence intervals overlap. Such large confidence intervals cast doubt on the reliability of the rankings: if a country falls a few places in the ranking, it may not in fact reflect a real deterioration in the conditions on the ground. As mentioned above, Kazakhstan’s score has changed over the years, but this change is not significant. It can therefore not be used to describe any impact.

In summary, while the CPI is valuable for advocacy and cross-country econometric research at a global level, it is not suitable as a diagnostic tool for assessing the impact or effectiveness of evaluating anti-corruption and integrity policies at the national level. Considering these limitations, Kazakhstan could define additional indicators to measure impact, for example using the OECD Public Integrity Indicators (PII), in which Kazakhstan is participating. The first round of measurement can serve as baseline data against which progress could be measured in the future. As such, indicators could be defined based on a more diverse set of data sources such as those outlined in (Table 2.3). The planned National Corruption Perception Index can also complement the measurement framework and apply perception indicators disaggregated for regions and sectors, to be able to reflect regional and sectoral trends. The evidence emerging from this measurement can inform actions, but it is important to bear in mind that perception-based data are not suitable for measuring the actual progress of specific policy measures.

Table 2.3. Potential data sources for evaluating public integrity policies

Data source	Description	Quantitative	Qualitative	Examples
Administrative data	Quantitative information compiled routinely by government institutions, international organisations or civil society groups.	X		Number of complaints received in a given time frame
				Data on the use of web-based tools for interacting with citizens
				Number of sanctions issued for non-compliance with disclosure obligations, non-management or non-resolution of a conflict-of-interest situation
				Percentage of middle management who received training on conflict-of-interest management
Population surveys	Information gathered through surveys of the general public, which can be used to generate ratings for indicators based on public perceptions or experiences.	X	X	Questions asking for the perceived corruption overall or in different government institutions or public sector areas
				Percentage of population who paid a bribe to a public official, or were asked for a bribe by these public officials, during the last 12 months
Staff surveys	Information gathered through surveys of employees/civil servants, which can be used to generate ratings for indicators based on public perceptions or experiences. Staff surveys can be covering a sample from the whole civil service or be limited to samples from one or more specific public entities.	X	X	Examples of survey questions: Are you confident that if you raise a concern under the Public Ethics Law in [your organisation] it would be investigated properly? Are people who take ethical shortcuts more likely to succeed in their careers than those who do not? The organisation makes it sufficiently clear to me how I should conduct myself appropriately toward others within the organisation My supervisor sets a good example in terms of ethical behaviour
Business surveys	Information gathered through surveys of private companies. Enterprise surveys can be disaggregated by sectors, or size, for instance.	X	X	Questions asking for the perceived corruption overall or in different government institutions or services, Percentage of firms identifying corruption as a major constraint
				Percentage of businesses that paid a bribe to a public official, or were asked for a bribe by public officials, during the last 12 months

Source: OECD (2019[10]), OECD Integrity Review of Argentina: Achieving Systemic and Sustained Change, https://doi.org/10.1787/g2g98ec3-en.

To assess the 2022-2026 Policy Concept according to the pre-defined outcome indicators, the Anti‑Corruption Service could commission a comprehensive end-term evaluation that would seek to understand whether it was effective in fulfilling its objectives and achieving intended impacts, based on clear and transparent criteria, such as the OECD Development Assistance Committee (DAC) evaluation criteria (Table 2.4). The evaluation would ideally draw conclusions and provide recommendations to be discussed with relevant bodies, including non-state actors, which is helpful to ensure accountability and ownership and inform future strategies.

Table 2.4. OECD DAC Evaluation Criteria

Criterion	Question
Impact	What (intended or unintended) effects has the strategy generated?
Effectiveness	Is the strategy achieving objectives – or meeting targets?
Efficiency	How well are resources being used?
Sustainability	Will the benefits of the strategy likely last?
Coherence	How compatible is the strategy with other public policies?
Relevance	Is the strategy an appropriate response for the context?

Source: OECD (2021[11]), Applying Evaluation Criteria Thoughtfully, https://doi.org/10.1787/543e84ed-en.

Kazakhstan could ensure the overall objectivity of monitoring and evaluation by encouraging non-governmental actors beyond the Public Council, such as experts and academics to contribute. While the Action Plan aims to strengthen the role of civil society in fighting corruption through several diverse measures, it does not provide a designated role for them in the monitoring and evaluation of the 2022‑2026 Anti-Corruption Policy Concept. The website of the Anti-Corruption Service contains the possibility of providing inputs to the draft annual reports about the state of Policy Concept implementation. The Anti‑Corruption Service’s Public Council discusses the progress of implementation, which is considered in the Policy Concept implementation reports (OECD, 2024[12]). However, beyond the review of pre-drafted documents, non-governmental stakeholders in addition to the Public Council should be encouraged to generate new ideas and approaches, leading to the continual improvement of the strategy over time. A range of civil society organisations (CSOs), business sector representatives and other relevant stakeholders could be mobilised to give their views on progress and implementation gaps. This input from CSOs and other non-government actors would strengthen the effectiveness of the Action Plan and would provide opportunities to update the planning, course of action and allocation of resources.

Kazakhstan could complement the 2022-2026 Anti-Corruption Policy Concept with a budget framework

An effective integrity strategy and action plan not only lay out a comprehensive set of substantive reforms, but also indicate the means for ensuring implementation, monitoring and evaluation (OECD, 2020[2]). Having a well-defined budget ensures efficient resource allocation, enhances transparency, and facilitates strategic planning, all of which are crucial for effectively combatting corruption and implementing anti‑corruption measures. The lack of a comprehensive budget framework can be problematic for several reasons (OECD, 2022[9]):

• Budget transparency and commitment: without co-ordinated cost (and benefit) estimates of the policy measures, it is difficult to gauge what the impact will be on government resources; once adopted, a budget is also reflecting the commitment of the government to the policy.

• Competing workload: as the anti-corruption activities have to be absorbed by the budgets and existing work programme of the line ministries and agencies, they will come at the cost of other activities, creating competition and possibly conflict.

• Incentives structure: line ministries and agencies may refrain from exploring relevant integrity risks or implementing anti-corruption activities because they will need to pay for policy measures themselves.

• Monitoring: a co-ordinated budget framework can be helpful to monitor the implementation of the policy and to identify which measures are on track or not; moreover, a comparison between the cost estimates and the actual costs can provide lessons to inform future policy discussions.

The Action Plan for the 2022-2026 Anti-Corruption Policy Concept assigns tasks and responsibilities to multiple government bodies and agencies in implementation. According to the information received from officials, in line with the national financial planning system, the implementation of the strategic measures is financed from the existing budgets of the respective government bodies. The implementation of the 2022-2026 Policy Concept therefore could be accompanied by a centralised cost analysis of the various policy measures. This will provide transparency on the potential budgetary impact of the policies and measures in terms of government expenses. Additionally, the absence of concrete financial arrangements within the Action Plan framework results in significant challenges to its effective implementation. While the Action Plan assigns multiple public bodies to the implementation of each measure, their subsequent financial obligations are not settled as each responsible body should take resources from their own budget to fulfil the tasks concerned. At the same time, there is no centralised planning foreseen to allocate the estimated costs for each activity which can lead to inconsistencies in resource allocation and greater fragmentation, potentially hindering the successful execution of the measures outlined in the plan.

Therefore, providing an overview of the costing and budget allocation for each policy objective would be helpful to ascertain whether sufficient resources have been mobilised compared to the estimated costs, and whether additional funding is required. The overview of allocated budget could indicate the allocated funds from the central government, line ministries and public bodies’ respective budgets. A budget framework would also allow for monitoring of the implementation of the 2022-2026 Policy Concept in terms of budget and help identify spending gaps and/or delays. By ensuring an effective oversight mechanism, Kazakhstan would guarantee that the allocated funds are used efficiently, promote accountability among the responsible bodies, and allow for timely adjustments if additional resources are required. Examples of such good practice based on the PII assessments is provided in Box 2.2.

Box 2.2. Practices for ensuring financial sustainability of public integrity strategies

According to the Public Integrity Indicators, Lithuania is one of the good examples providing financial estimates for the activities within their anti-corruption strategy. The budget plan is published along with the Anti-Corruption Plan 2023-2025, that aims to implement the first stage of the National Anti‑Corruption Agenda 2022-2033. As the Agenda is linked to various national strategies, including Lithuania’s Progress Strategy “Lithuania 2030” and the National Security Strategy, the budget plan is also integrated with other national strategies and development programmes, ensuring a cohesive approach to anti-corruption efforts across various sectors.

The budget for Lithuania’s anti-corruption strategy is structured to support a range of targeted activities aimed at reducing corruption through education, awareness, and systemic improvements, with specific funding allocations and responsible authorities identified for each measure. The financial plan specifies funding for various activities, categorised by type, such as analytical, regulatory, investment, and communication measures. Each activity type is assigned a specific budget for the years 2023, 2024, and 2025, adjusted to the progress. For example, in 2023, a social campaign to raise awareness about the harm of nepotism is allocated 30 units of funding, which increases to 35 in 2024 and 40 in 2025. Another campaign to strengthen public anti-corruption awareness is consistently allocated 51 units of funding each year from 2023 to 2024.

The financial sustainability of Lithuania’s anti-corruption strategy is supported by a detailed implementation plan that allocates specific funding for targeted measures and includes robust monitoring and assessment mechanisms to ensure effective execution. Besides, the plan includes progress targets and outcome indicators to assess the effectiveness of the measures implemented. These indicators help monitor the achievement of anti-corruption objectives and guide future funding needs.

Sources: Government of Lithuania (2023[13]), The Plan for the Implementation of the National Anti-Corruption Agenda for 2022-2033 in 2023‑2025, https://www.stt.lt/data/public/uploads/2023/06/the-plan.pdf; analysis of OECD (n.d.[5]), OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/ (accessed on 1 December 2023).

Creating a coherent framework for prioritisation of anti-corruption measures in a future anti-corruption strategy

Experiences from OECD member countries have shown that the process of drafting a national anti-corruption strategy is equally important as the resulting strategy itself (OECD, 2020[2]). A comprehensive and carefully implemented design process should ensure that the final strategy is based on credible and relevant evidence, avoids overly rigid compliance objectives and places emphasis on promoting cultural change within organisations (OECD, 2020[2]). It is also key to ensure continued diagnostic analysis, appropriate governance, and political support. This is because a successful anti-corruption strategy and action plan must not only lay out a comprehensive set of substantive reforms but also indicate the means for ensuring co-ordinated implementation (OECD, 2022[14]).

The Anti-Corruption Service could apply a risk-based, participatory approach to designing a future anti-corruption strategy

Strategic objectives, from the general to the specific, directly link the findings of the problem analysis and align with indicators, their baselines, and targets (OECD, 2020[2]). Major integrity risks identified in the problem analysis should be addressed through primary objectives, which then cascade down to more specific secondary objectives, actions, indicators, milestones, and targets (OECD, 2020[2]). Transparently prioritising key integrity risks and actions can help ensure interventions are cost-effective and have the greatest impact (OECD, 2020[2]).

According to the Kazakh Government, the 2022-2026 Anti-Corruption Policy Concept takes a broad approach to identifying integrity risks, avoiding any sector- or agency-specific limits. Instead, the government aims to reduce corruption through universal tools with general indicators and measurements to pinpoint vulnerabilities. These tools serve as a first step on risk profiling, providing the basis for prioritising and implementing actions under a risk-based approach. However, most strategic objectives formulated in the 2022-2026 Policy Concept do not specify which integrity risks they seek to address, the actors involved, the expected likelihood and impact if the risk materialises, and information sources. While there are references to corruption risk assessments, it is not evident how the different integrity risks have been selected, assessed and prioritised for mitigation and how they have shaped strategic objectives.

Considering this, Kazakhstan could benefit from taking a more systematic approach to prioritising strategic objectives in a future anti-corruption strategy by relying on a more extensive problem analysis based on sound and transparent methodologies for risk identification and assessment. The 2022-2026 Policy Concept establishes strategic objectives for mitigating public integrity risks in internal control and risk management, in public procurement, in the private sector and quasi-public sector entities. A next strategy could be based on the assessment of integrity risks across these areas, as well as in additional areas that are typically prone to integrity risks, such as human resource management, and public financial management, including fraud and financial mismanagement.

In addition, to ensure corruption risks are effectively addressed in the most vulnerable sectors, the Anti‑Corruption Service could more systematically rely on sectoral corruption risk assessments in the strategy development. The 2023 National Report on Combating Corruption lists external corruption risk analyses conducted on use of land in Almaty, budgetary planning in education and diploma awarding in higher education (Antikor, 2024[15]). These external risk assessments can strengthen evidence-based prioritisation of the anti-corruption measures in the design of a future strategy. The problem analysis could further be expanded to other priority sectors such as infrastructure, housing, health, taxation, or customs. This is especially relevant in Kazakhstan as corruption is known to be predominant in several of these sectors, but it is unclear in which sector corruption risks are highest (GRECO, 2022[16]).

A first step towards evidence-based prioritisation would be identifying strategic sectors, for example in line with the Development Strategy 2050, and conducting sectoral risk assessments. To identify strategic sectors, a cross-governmental approach can be useful, as shown in Finland (Box 2.3).

Box 2.3. A cross-governmental approach to strategy design in Finland

The anti-corruption strategy in Finland was developed by a cross-government group, which included police, local government and civil society organisations (CSOs). Six strategic objectives were defined, and then further detailed into thirteen objectives and twenty-three specific reform measures.

Identifying and prioritising strategic objectives relied upon a large spectrum risk mapping and analysis of data and statistics from the police, the Office of the Parliamentary Ombudsman, the Finnish Competition and Consumer Authority, and the Tax Administration as well as from Transparency International Finland. High-risk sectors identified were construction, public contracting and competitive tendering, urban planning, political funding and decision making, foreign trade and sports.

Source: OECD (2020[2]), OECD Public Integrity Handbook, https://doi.org/10.1787/ac8ed8e8-en.

As a second step, the sectoral risk assessments can be triangulated with survey data to analyse citizen and businesses experience and perception of corruption in those sectors. To ensure legitimacy, the analytical processes behind prioritising measures in the Strategy - including the methodology of sectoral corruption risk assessments, survey data, administrative data and expert discussions – must be transparent and traceable. Kazakhstan used multiple data sources to analyse the situation. However, this analysis remained general, and it is not always possible to make the link between specific problems and the measures proposed to address them. The National Corruption Perception Index might contribute to more systemic work with this type of data.

Finally, as a third step, public consultations with sectoral experts could be used to define sector-specific problems, design and prioritise measures in the upcoming anti-corruption strategy. Several stakeholders were consulted in the development of the 2022-2026 Policy Concept through the Public Council of the Anti-Corruption Service. The Parliament of Kazakhstan, the public administration, academia, media, and civil society each delegated one representative to the Council. The government collected citizens’ proposals on the draft Policy Concept via a dedicated website. Additionally, the government consulted the National Chamber of Entrepreneurs “Atameken”, the Commissioner for the Protection of the Rights of Entrepreneurs and the business community throughout the country on the draft Policy Concept. Thus, a total of 59 public proposals were received: i) on the website adal.com.kz – 28 proposals, of which 11 were accepted; ii) proposals from members of the Public Council – 26, of which 17 were accepted; iii) via the WhatsApp messenger – 3 proposals, of which 1 was accepted; iv) on the "Open NPA" portal – 2 proposals, of which 1 was accepted. Official comments from the Agency were provided for proposals posted on the "Open NPA" portal. The Policy Concept itself notes that the opinion of civil society should become a “‘litmus test’ of the effectiveness of the activities of state bodies in the implementation of anti-corruption policy”. It also acknowledges the necessity of improving the processes of interaction between representatives of civil society and the state (Government of Kazakhstan, 2022[4]).

Going forward, the Anti-Corruption Service could complement public consultations with more in-depth forms of co-creation of anti-corruption measures by governmental and non-governmental stakeholders through continuous dialogue in different formats, such as public discussion, co-creation of text documents and working groups. This intense collaboration requires carefully identifying stakeholders with sectoral knowledge, as the engagement of the public at this stage is less constructive. Instead, providing feedback and responses, showing that some suggestions were accepted and justifying why others were rejected is the key for the effective co-creation. This approach will foster innovation expertise, particularly in sectoral anti-corruption policies. Ukraine serves as a good example of a risk-based and evidence-driven anti‑corruption policy, developed through an open and participatory process (see Box 2.4).

Box 2.4. Evidence-based anti-corruption policy design in Ukraine

In line with the National Anti-Corruption Strategy 2021-2025, Ukraine adopted the National Anti-Corruption Programme for 2023-2025. The Programme prioritises seven spheres for corruption counteraction. In each sphere, up to ten problems are identified that guide measures and indicators for anticipated strategic results (output level). An interactive module (https://dap.nazk.gov.ua/module/) provides an overview of entire Programme and allows associating each anti-corruption measures with the specific problem analysis that is based on corruption risk assessment in the sector or other data transparently references in the problem description attached. For example, top 30 corruption risks identified in the use of land and corruption risks analysis in the procedure of privatisation guided the problem analysis and prioritisation of measures in one of the priority spheres – “Construction, land management and infrastructure.”

In addition, the National Agency for Corruption Prevention (NACP) in Ukraine provides the full information on consultations with experts regarding each sphere, while showing who and how contributed to the design of the Anti-Corruption Programme and which proposals were considered or rejected for specific reasons (https://nazk.gov.ua/uk/antykoruptsijna-strategiya/).

Sources: OECD (n.d.[5]), OECD Public Integrity Indicators, https://oecd-public-integrity-indicators.org/ (accessed on 1 December 2023); OECD (2025[17]), OECD Integrity and Anti-Corruption Review of Ukraine, https://doi.org/10.1787/7dbe965b-en.

Finally, the Anti-Corruption Service could pilot an evidence-based, participatory approach to policy design by engaging the main stakeholders as data sources for problem analysis and prioritisation of objectives. For example, if the next strategy includes human resource management and public integrity violations as priority areas, staff surveys could serve as a core analytical tool. These surveys could assess public officials’ integrity capacities and risks, identifying values and challenges that influence their decisions (OECD, 2019[10]). In turn, policy makers would also gain insights into whether the policies resonate with public employees, influence attitudes and behaviours, and support a culture of integrity within the public sector. Staff surveys could further support the diagnostic assessment preceding the next Anti-Corruption Concept. Many OECD member countries, such as the Netherlands, use employee surveys as a key tool for monitoring integrity policies and shaping future agendas (Box 2.5).

Box 2.5. Integrity Monitor in the Dutch public administration

Since 2004, the Dutch Ministry of the Interior has been regularly observing the state of integrity in the Dutch public sector. To this end, political office holders, secretaries-general, directors, and civil servants are surveyed in central government, provinces and municipalities using mixed methods, including large‑sample online surveys and in-depth interviews.

The Integrity Monitor supports Dutch policy makers in the design, implementation, and communication of integrity policies. The results of each Monitor are reported to Parliament. The Ministry of Interior uses the Monitor to raise ethical awareness, detect implementation gaps and engage decentralised public administration in taking responsibility for integrity regulations. Insights from past Monitor waves have helped to identify priorities for anti-corruption efforts and shift integrity policies from prohibition to creating an organisational culture of integrity.

Source: OECD (2019[10]), OECD Integrity Review of Argentina: Achieving Systemic and Sustained Change, https://doi.org/10.1787/g2g98ec3-en.

The Anti-Corruption Service could encourage subnational governments to develop their own evidence-based integrity plans and involve them actively in the design of a future anti-corruption strategy

While integrity is a concern at all levels of government, opportunities for certain types of corruption can be more pronounced at subnational levels. The increased frequency and closeness of interactions between subnational government authorities with citizens and firms as compared to the national level can create opportunities, especially by facilitating subnational accountability, and risks for integrity (OECD, 2019[18]). Subnational government responsibilities for the delivery of a large share of public services (e.g. education, health, security/justice, waste management, utilities, granting licenses and permits) as well as for spending and investment, increase the frequency and directness of interactions between government authorities and citizens and firms, putting the integrity of subnational governments to the test (OECD, 2022[19]). Regional and local governments may also have higher levels of at-risk expenditure such as social spending or public procurement contracts, which require additional measures of control. For example, in 2021, 61.2 % of public procurement spending occurred at the subnational level across the OECD (OECD, n.d.[20]). Thus, to achieve impact in building a culture of integrity, reaching the territorial level, particularly municipalities is key (OECD, 2019[18]).

Given the responsibilities of local governments in service delivery and local development, integrity policies also may be able to achieve visible results for citizens, which allows to contribute to building trust in government and to increase the political buy-in from leaders to continue with reforms (OECD, 2022[19]). Regional and municipal governments are likely to be better placed to identify corruption risks and opportunities for more effective integrity and anti-corruption measures adapted to the regional context (OECD, 2022[19]). Although one-size-fits-all solutions imposed from above are not recommendable, a co‑ordinated approach and clearer guidance from the central administration would contribute to a more functional integrity system, by ensuring coherence of messages and measures across the territory.

Interviews with Kazakh officials indicate that the Anti-Corruption Service has undertaken a risk mapping exercise at the regional level and has identified several risks that are pronounced in some regions. Since 2020, the Anti-Corruption Service has been providing public information on these corruption risks at the subnational level. This includes a 2021 report that identifies corruption risks in health departments of the local executive authorities (Antikor, 2021[21]), and the corruption risk mapping conducted by the Anti‑Corruption Service Office in Astana, which identified education, roads and infrastructure, and land as the sectors most prone to corruption in the city. While all these examples can be seen as good practices, they could be expanded consistently to embrace all the territories across Kazakhstan. Based on the information provided by the Anti-Corruption Service, it the current status of public integrity in the subnational administration is unclear. Moreover, there is limited publicly available information on regional differences in public integrity risks and key trends.

Kazakhstan could work more closely with the regional and municipal decentralised administrations to have them develop their own integrity plans and contribute to the National Strategy. At a minimum, there should be a clear understanding of public integrity risks and their variation across all regions and municipalities. The Anti-Corruption Service could support these subnational administrations to map their public integrity risks and develop their own integrity polices, considering the specific local context while maintaining a coherent approach across the country. This would ensure that subnational administrations have the adequate support and gather the relevant evidence to develop public integrity policies. At the stage of designing a new national strategy, the Anti-Corruption Service could maintain sustainable communication channels to allow local level contributing to the prioritisation of sectors and spheres, problem definition, and design of solutions.

Mainstreaming integrity policies in the public and quasi-public sectors

The presence of specialised bodies responsible for anti-corruption policy or law enforcement does not absolve organisational units in the public, quasi-public and private sectors from their responsibility to uphold integrity. However, the private sector falls outside the scope of this analysis. Countries around the world are facing the challenge of ensuring a coherent and effective implementation of integrity policies throughout their public administration and quasi-public sector entities, sometimes referred to as the challenge of mainstreaming. Typically, mainstreaming integrity involves work with multiple organisational units. The main challenge is not merely formal compliance with existing regulations but fostering genuine change in organisational culture and individual behaviours. Three main obstacles on the way to organisational change, common to most OECD countries, are also present in Kazakhstan. First, the implementation of anti-corruption and integrity-related activities heavily depends on the support of organisational leadership. Second, the central authorities responsible for methodological and professional standards face challenges in co-ordinating efforts, ensuring high-quality work, and facilitating learning processes for the large number of people involved. Therefore, robust evaluation methodologies are important to monitor progress and support improvements. Finally, given the specific range of skills required for these tasks, conventional education alone is insufficient. Introducing mutual learning methods is essential to foster exchange, drive innovations, and sustain professional communities.

Kazakhstan has three key groups of actors critical to the practical implementation and co-ordination of integrity policies across the organisational units. The first group is project offices, which have been created in state bodies in line with the “Rules for the implementation of the project” approved by Government Decree in May 2021. The rules require government agencies to implement projects in six thematic groups. One of the projects is the prevention and combating of corruption thematic group 4), for which the Anti-Corruption Service is the co-ordinator and develops projects to identify and eliminate corruption risks, promote a culture of integrity, and prevent corruption in the quasi-public sector. The Anti‑Corruption Service has developed a methodology to assess the implementation of projects within the respective thematic group for anti-corruption. This methodology assesses four key tasks assigned to project offices under this thematic group: Internal corruption risk assessment, anti-corruption compliance, anti-corruption compliance in the quasi-public sector, and development of an anti-corruption culture.

The second group is Authorised Ethics Officers in public authorities, which are public officials responsible for ensuring compliance with official ethics standards and preventing violations of public service and anti-corruption legislation, as well as the Code of Ethics of Civil servants. Their role is to provide advice to public officials. The Regulations on the role and functions of Authorised Ethics Officers was approved by Presidential Decree No.153 on 29 December 2015. Typically, there is one person employed as an Authorised Ethics Officer in each public authority at the central and local level. As of 2022, there were 37 full-time officials dedicated to the role of an ethics officer – that is, one person in each state body at the central and local levels – and 731 senior officials who undertake this role in addition to other responsibilities in Kazakhstan. Since 2023, the Agency for Civil Service, responsible for guidance for Authorised Ethics Officers, has been co-ordinating their anti-corruption activities with the Anti-Corruption Service.

Third, Anti-corruption Compliance Officers in the quasi-public sector are responsible for ensuring anti‑corruption compliance by the relevant organisation and its employees.1 Some of the main responsibilities of the Compliance Officers include: the development of internal documents on Anti‑Corruption in a quasi-public sector entity; awareness raising and the development of an anti-corruption culture; taking measures to identify, monitor and resolve conflicts of interest; and monitor compliance and conducting internal analysis of corruption risks. Additionally, anti-corruption Compliance Officers have the authority to conduct official inspections in response to appeals or complaints regarding corruption or involvement in corrupt activities. In some situations, they can review civil law contracts concluded by quasi‑public sector entities (including procurement contracts) to ensure compliance with anti-corruption legislation, business ethics, integrity standards, and principles of fair competition. Anti-corruption compliance services have been established in 5 673 out of 7 000 quasi-public sector entities (IMF, 2022[22]). On average, two to three individuals perform the compliance function full-time in each public sector entity. Since 2023, the Anti-Corruption Service has been responsible for co-ordinating and providing methodological support to Compliance Officers.

The Academy of Public Administration and the Anti-Corruption Service could strengthen support for mainstreaming integrity at organisational level

Leadership at different levels is a core ingredient for establishing and reinforcing an integrity culture in public sector organisations. Leaders serve as role models in different state bodies by exemplifying and transmitting the integrity standards and values and by enhancing trust in the processes (OECD, 2022[19]). Moreover, research and empirical studies on integrity leadership suggest that leaders can have a beneficial impact not only on the ethical culture of an organisation, but also on performance: “subordinates’ perceptions of ethical leadership predict satisfaction with the leader, perceived leader effectiveness, willingness to exert extra effort on the job, and willingness to report problems to management” (Brown, Treviño and Harrison, 2005[23]).

Leaders include both high-ranking public officials and all levels of leadership within an organisation. In fact, line and middle managers play a particularly important role – often even more so than top executives – due to their closer day-to-day interactions with most public servants. The following two aspects of integrity leadership are essential:

• The leader needs to be perceived as a “moral person” who understands the values underpinning the public service and uses them to make the right decision when faced with specific ethical dilemmas.

• The leader needs to be perceived as a “moral manager” who makes open and visible ethical decisions, rewards and sanctions others based on ethical criteria, communicates openly about ethics and gives employees the tools and opportunities to make ethical decisions while encouraging them to seek advice (OECD, 2018[24]).

Thus, promoting integrity leadership incorporates two broad goals: first, ensuring that the people appointed to leadership positions have an integrity profile – moral people with the skills to be moral managers; and second, supporting these leaders as they carry out their functions as integrity leaders (OECD, 2020[2]). Support of integrity in managerial functions is critical to mainstreaming of anti-corruption in organisational units. Often the support of integrity by the leadership in the organisational work requires a shift in thinking, which can be assisted through trainings, performance incentives and awareness raising. To ensure that leaders understand and support integrity- and anti-corruption activities and related functions, Kazakhstan could undertake several measures.

First, ensuring stronger functional independence for Authorised Ethics Officers in the public sector and Anti-Corruption Compliance Officers in the quasi-public sector is essential. This requires addressing concerns related to reporting structures and enabling them to voice issues, particularly those involving leadership. Important formal steps have been taken in this regard, including provisions allowing Authorised Ethics Officers to directly report breaches in case of in-action or obstruction by their direct leadership (Government of Kazakhstan, 2015[25]). However, in practice, Authorised Ethics Officers remain vulnerable to discrimination and harassment. To address these challenges, the Anti-Corruption Service could establish a multi-stakeholder working group to analyse practical difficulties faced by officers and project managers in their daily anti-corruption and integrity efforts, particularly in organisations lacking leadership support. This group could develop context-specific mechanisms to strengthen the functional independence of Ethics and Compliance Officers. Further recommendations regarding the work of the Authorised Ethics Officers are outlined in Chapter 3.

Second, Kazakhstan can invest in cultivating integrity leadership across management functions. Concretely, the Academy of Public Administration could strengthen the curriculum for top-level civil servants with the trainings exploring the link between integrity and effectiveness of organisations, public trust and economic growth. These trainings should also cover the role and functions of Authorised Ethics Officers, as well as the importance of proper implementation of the projects in the area of preventing and combating corruption carried out by the project offices. The Anti-Corruption Service should consider developing similar curricula for the leadership of the quasi-public sector entities for them to better understand and support the work of Anti-Corruption Compliance Officers. This could include coaching and mentorship programmes as they exist in some OECD countries (Box 2.6).

Box 2.6. Leadership coaching and mentorship programmes

In Germany, the Federal Academy of Public Administration has established a coaching centre that manages an external coach pool made up of academics and private coaches and matches public leaders with appropriate coaches depending on their specific requirements. Some ministries (e.g. foreign affairs) run their own coach pool, and many also exist at the sub-national/municipal level.

In the Belgian federal administration, the Training Institute of the Federal Administration (TIFA) offers managers a programme on lean management that combines three important modes of learning: online, face to face, and more intensive coaching for specific projects.

The Flemish public service has set up a joint training programme with the Dutch Public Service, whereby top managers are trained in coaching colleagues. This enables cross-border peer coaching which has several advantages, such as allowing peers to draw on a wealth of experience from top managers of public organisations.

Source: OECD (2020[2]), OECD Public Integrity Handbook, https://doi.org/10.1787/ac8ed8e8-en.

The Anti-Corruption Service could improve evaluation methodologies for stakeholders involved in mainstreaming integrity policies to ensure coherent assessment and provide necessary guidance

The challenge of evaluating mainstreaming of anti-corruption and integrity has at least two dimensions: organisational and individual. At the organisational level, monitoring and evaluating integrity frameworks within different units should be ensured. Public bodies and agencies often overestimate their success when they assess their own progress, leading to inaccurate monitoring of programme implementation. To address this, it is recommended that the co-ordinating agency ensure independent validation of progress rather than relying solely on self-assessments. One effective approach is to have organisations conduct a preliminary self-evaluation, which is then compared with an independent audit by an external party like another government department, a civil society group, or an outside consultant. This process not only provides a more objective assessment but also helps agencies improve their own evaluation methods by revealing discrepancies and areas for improvement.

The Anti-Corruption Service could use a central monitoring system to create benchmarks that central government and local government bodies can compare each other to and promote competition among government bodies. It is also important that the results of monitoring are displayed publicly and are open for public scrutiny. The Korean Anti-Corruption and Civil Rights Commission’s integrity monitoring could be a guide for the Anti-corruption Service to evolve its corruption monitoring systems using such benchmarks (see Box 2.7).

The Anti-Corruption Service is currently in the process of developing its own methodology to evaluate state bodies along three lines: i) corruption offences, ii) effective anti-corruption measures, and iii) perception of corruption (Antikor, 2024[15]). The methodology will mix statistical data and sociological research. However, the challenge with external evaluations lies in using them as a tool to encourage public bodies to take ownership of their actions rather than as a mechanism for control.

Complementary to the external evaluation, an alternative methodology could build upon the OECD Public Integrity Maturity Models and serve the self-assessment purposes. The test, accessible for organisational self-assessment, follows the logic of the OECD Recommendation on Public Integrity, with questions clustered around its 13 Principles. However, the questionnaire should be adjusted to the context of the country. For example, the National Anti-Corruption Agency of Ukraine (NACP) adjusted the Model of Integrity Maturity in organisations. The assessment of the model foresees five levels of integrity maturity – i) beginner (ad hoc, fragmented), ii) managed, iii) defined, iv) qualitatively managed, v) optimised. NACP recommends organisations use the self-assessment test to identify gaps in their respective integrity frameworks, address them in the planning of relevant measures and trace progress through regular re‑evaluation (Antikor, n.d.[26]).

Box 2.7. Integrity Monitoring in Korea at organisational level

The Korean Anti-Corruption and Civil Rights Commission (ACRC) uses two complementary assessment frameworks to monitor and assess the quality of implementation of anti-corruption efforts as well as their results: The Integrity Assessments and the Anti-corruption Initiative Assessments.

Integrity Assessment (IA)

South Korea annually assesses integrity in all government agencies through standardised surveys. The staff of 617 organisations is asked about their experience with and perception of corruption. Furthermore, citizens who have been in contact with the respective organisations are surveyed as well as stakeholders and experts who have an interest in the respective organisation’s work. The answers are, together with other information, scored into a composite indicator – the Comprehensive Integrity Index.

Anti-Corruption Initiative Assessment (AIA)

The Anti-Corruption Initiative Assessment is a comparative assessment of integrity policies across government agencies in Korea. Agencies selected for assessment submit a performance report on their implementation of integrity policies. On-site visits verify the information, which is then scored by an external assessment team. It provides an observation of the willingness and efforts made for integrity across the public sector.

Benchmarking and competition

Underperformance in the IA or the AIA does not lead to sanctions. However, the results are public, and the direct comparison of different government entities based on integrity indicators creates healthy competition between government agencies.

Source: OECD (2020[2]), OECD Public Integrity Handbook, https://doi.org/10.1787/ac8ed8e8-en.

At the individual level, the co-ordination body must deal with thousands of dedicated officers, such as Anti-Corruption Compliance Officers or Authorised Ethics Officers. This co-ordination function is relatively new to the Anti-Corruption Service. It has developed guidance and recommendations for the work of both categories of stakeholders. Anti-Corruption Service has also developed a methodology to evaluate anti‑corruption tasks under the organisational projects. Yet, the Anti-Corruption Service could extend its project management system or develop a separate module to establish the communication channel with the Compliance and Ethics Officers. An automatised assessment system of their effectiveness, based on the reports provided can be used to provide specific feedback and guidance upon demand (see example of Ukraine in Box 2.8)

Box 2.8. Evaluation of Anti-Corruption Officers’ effectiveness in Ukraine

The National Agency for Corruption Prevention in Ukraine developed an Integrity Portal that includes a digital system to co-ordinate reporting and evaluate the effectiveness of the authorised units/persons (depending on the size of the organisation) on corruption prevention and detection. Currently, 3 462 authorised units/persons are registered at the portal and 3 177 submitted their reports. The evaluation of such a unit/person takes place in line with the 26 tasks under the responsibility of the authorised unit/person. The reports and their evaluations are publicly accessible. The feedback form is structured along the strengths and weaknesses in the work and includes recommendations to follow.

Source: Government of Ukraine (n.d.[27]), Оцінка ефективності уповноважених, https://antycorportal.nazk.gov.ua/en/efficiency-evaluation/.

The Anti-Corruption Service and the Agency for Civil Service could enhance capacities and facilitate peer-learning for integrity among professional communities supporting integrity in organisations

Further steps could be taken to ensure that all public sector entities, with a particular focus on quasi-public sector entities that face a higher risk of corruption, have the dedicated and specialised resources for mainstreaming integrity policies in the whole of the public sector. The lack of dedicated and specialised human resources in these agencies and functional units can be seen as a barrier mainstreaming integrity policies. To address the above and support the quasi-public sector bodies, Kazakhstan could expand its anti-corruption compliance services to all quasi-public sector entities, with an aim that they entities mainstream public integrity compliance programmes into core business operations incorporating an “integrity culture” perspective into their guidance. In doing so, Kazakhstan can cultivate a network of integrity advocates within these entities, fostering ethical behaviour and transparency that becomes an integral part of their day-to-day functioning.

Additionally, Kazakhstan could expand the role and increase the resources of Authorised Ethics Officers and harness these integrity actors more holistically in developing a culture of integrity in the public sector. One way in which this can be done is by dedicating more financial resources to each public sector entity for hiring specialised full-time officials for the role of an ethics officer. This would imply that the existing part-time officials no longer undertake the role of an ethics officer in addition to other job responsibilities and that full-time Authorised Ethics Officers in each unit assume those responsibilities instead. Alternatively, in the case of problematic resource allocation, Kazakhstan could consider to formally establish the position of an Authorised Ethics Officer within key units by recruiting and re-training already existing staff. This will involve appointing dedicated professionals to this position on a full-time basis, following a thorough training programme for existing staff members who will subsequently assume these new responsibilities.

To further support these Authorised Ethics Officers, Kazakhstan could consider developing specialised training for these officials and guidance to clarify their roles and responsibilities. Good practices of developing specialised training for Ethics Officers can be found in France (Box 2.9).

Another good practise would suggest Kazakhstan to consider forming an informal integrity network in which all the Authorised Ethics Officers are designated participants. These networks rarely have decision-making capacities, but they can help enhance the effectiveness of integrity systems by sharing good practices, information, and lessons learned (OECD, 2020[2]). Moreover, they can ensure that integrity remains on the agenda of public sector institutions. These informal mechanisms may however require some degree of formal support to ensure that they function appropriately (OECD, 2020[2]). Good examples can be seen in Austria and Canada (Box 2.10).

Box 2.9. Specialised training for Ethics Officers in France

New public officials are a key audience for integrity training, with induction training serving as the first opportunity to set the tone for integrity standards upon entry into the public service. This is a prime opportunity to raise awareness and build knowledge on rules and values.

In France, while there is no legal obligation for ethics officers’ training, the High Authority for Transparency in Public Life (HATVP) provides a training course specifically designed for ethics officers of the semi-public companies of the City of Paris. An ethics guide designed for them also provides guidance and tools.

Sources: HATVP (2019[28]), Ethics Guide: Handbook for Public Managers and Ethics Officers, https://www.hatvp.fr/wordpress/wp-content/uploads/2019/09/EthicsGuide_WEB.pdf.

Box 2.10. Integrity networks in Austria, Canada, Germany, and Sweden

The Austrian Network of Integrity Officers

To mainstream integrity into the public sector, Austria has established the Network of Integrity Officers, which aims to place integrity officers in various federal institutions (e.g. ministries). The tasks performed by the officers include:

• performing advisory services for employees and senior officials

• circulating information on integrity and awareness raising

• providing training

• analysing the risk of corruption

• collaboration and experience sharing

• serving as the focal point for compliance-related issues.

The Federal Bureau of Anti-Corruption is responsible for managing the network, generating, and collecting expertise on the topic of integrity, and providing basic training and training materials to the officers.

Canada’s Interdepartmental Values and Ethics Network

In Canada, the central agency, the Treasury Board Secretariat, hosts the Interdepartmental Values and Ethics Network, which is a community that meets regularly and mutually benefits from sharing good practices and lessons learned. The Network and its regular exchanges provide the Treasury Board Secretariat with an informal means of keeping up with emerging issues and evolving challenges. Their input can also help shape integrity policies as well as the Secretariat’s awareness-raising and communications activities.

The German network of contact persons for corruption prevention

In Germany, the lead federal ministry for corruption prevention and integrity is the Federal Ministry of the Interior, Building and Community. Since preventing corruption does not involve having a supervisory role over other ministries, co-operation is essential to reach a common understanding of integrity policies and comprehensive standards for their implementation. For the German federal administration, the Joint Rules of Procedure of the Federal Ministries regulates (among other issues) co-operation within the federal government. Article 19 stipulates that “in matters affecting the remits of more than one Federal Ministry, those Ministries will work together to ensure that the Federal Government speaks and acts consistently”.

In practical terms, co-operation happens through a network of contact persons for corruption prevention that meets frequently. The network also develops guidelines, handbooks, and recommendations for implementing the Federal Government Directive concerning the Prevention of Corruption in the Federal Administration.

The Network against Corruption for Swedish State Agencies

The Swedish Agency for Public Management hosts the Network against Corruption for Swedish State Agencies. Delegates participating in the network include heads of administrative departments and heads of legal departments. The network meets four times a year, and each meeting usually gathers close to 100 agencies. The purpose of the network is to share experiences, learn about good examples and take part in the production of handbooks, reports, and other publications of the Swedish Agency for Public Management on anti-corruption measures, internal control, and efficiency.

Source: OECD (2020[2]), OECD Public Integrity Handbook, https://doi.org/10.1787/ac8ed8e8-en.

Summary of recommendations

 

Issue	Recommendation
Ensuring the effective implementation of the 2022-2026 Anti-Corruption Policy Concept and Action Plan	The Anti-Corruption Service could improve the monitoring and evaluation framework of the 2022-2026 Anti-Corruption Policy Concept.
	Kazakhstan could complement the 2022-2026 Anti-Corruption Policy Concept with a budget framework.
Creating a coherent framework for prioritisation of anti-corruption measures in a future anti-corruption strategy	The Anti-Corruption Service could apply a risk-based, participatory approach to designing a future anti-corruption strategy.
	The Anti-Corruption Service could encourage subnational governments to develop their own evidence-based integrity plans and involve them actively in the design of a future anti-corruption strategy.
Mainstreaming integrity policies in the public and quasi-public sectors	The Academy of Public Administration and the Anti-Corruption Service could strengthen support for mainstreaming integrity at organisational level
	The Anti-Corruption Service could improve evaluation methodologies for stakeholders involved in mainstreaming integrity policies to ensure coherent assessment and provide necessary guidance.
	The Anti-Corruption Service and the Agency for Civil Service could enhance capacities and facilitate peer-learning for integrity among professional communities supporting integrity in organisations.

References

[7] Antikor (2024), “Draft report on the implementation of the Anti-Corruption Policy Concept for 2022-2026 for 2023”, Anti-corruption Agency of the Republic of Kazakhstan, https://www.gov.kz/memleket/entities/anticorruption/documents/details/644000?directionId=17527&lang=en.

[15] Antikor (2024), National Report on Combating Corruption for 2023, Anti-corruption Agency of the Republic of Kazakhstan, https://www.gov.kz/memleket/entities/anticorruption/documents/details/695032?lang=ru.

[21] Antikor (2021), Corruption Risks of Local Executive Authorities in the Field of Health Care, Anti-corruption Agency of the Republic of Kazakhstan, https://www.gov.kz/memleket/entities/anticorruption/documents/details/179519?lang=en.

[26] Antikor (n.d.), Integrity Maturity Model (Corruption Prevention) in Organizations, Anti-corruption Agency of the Republic of Kazakhstan, https://antycorportal.nazk.gov.ua/indeks-zrilosti/ (accessed on 4 February 2025).

[23] Brown, M., L. Treviño and D. Harrison (2005), “Ethical leadership: A social learning perspective for construct development and testing”, Organizational Behavior and Human Decision Processes, Vol. 97/2, pp. 117-134, https://doi.org/10.1016/j.obhdp.2005.03.002 (accessed on 9 December 2022).

[3] G20 (2021), High-Level Principles for the Development and Implementation of National Anti-Corruption Strategies, https://www.unodc.org/documents/corruption/G20-Anti-Corruption-Resources/Principles/2020_G20_High-Level_Principles_for_the_Development_and_Implementation_of_National_Anti-Corruption_Strategies.pdf.

[4] Government of Kazakhstan (2022), Anti-Corruption Policy Concept of the Republic of Kazakhstan for 2022-2026, https://www.gov.kz/memleket/entities/anticorruption/documents/details/412521?lang=en.

[25] Government of Kazakhstan (2015), Decree of the President of the Republic of Kazakhstan Dated December 29, 2015 No. 153 on Measures to Further Improve Ethical Norms and Rules of Conduct of Civil Servants of the Republic of Kazakhstan, http://adilet.zan.kz/rus/docs/U1500000153 (accessed on 8 December 2022).

[13] Government of Lithuania (2023), The Plan for the Implementation of the National Anti-Corruption Agenda for 2022-2033 in 2023-2025, https://www.stt.lt/data/public/uploads/2023/06/the-plan.pdf.

[27] Government of Ukraine (n.d.), Оцінка ефективності уповноважених, https://antycorportal.nazk.gov.ua/en/efficiency-evaluation/.

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[28] HATVP (2019), Ethics Guide: Handbook for Public Managers and Ethics Officers, French High Authority for Transparency in Public Life, https://www.hatvp.fr/wordpress/wp-content/uploads/2019/09/EthicsGuide_WEB.pdf.

[22] IMF (2022), Republic of Kazakhstan: Selected Issues, International Monetary Fund, https://doi.org/10.5089/9798400226540.002.

[17] OECD (2025), OECD Integrity and Anti-Corruption Review of Ukraine, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/7dbe965b-en.

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[12] OECD (2024), Baseline Report of the Fifth Round of Monitoring of Anti-Corruption Reforms in Kazakhstan: The Istanbul Anti-Corruption Action Plan, OECD Publishing, Paris, https://doi.org/10.1787/c9652173-en.

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

[18] OECD (2019), La Integridad Pública en América Latina y el Caribe 2018-2019: De Gobiernos reactivos a Estados proactivos, Estudios de la OCDE sobre Gobernanza Pública, OECD Publishing, Paris, https://doi.org/10.1787/ebd84d6d-es.

[10] OECD (2019), OECD Integrity Review of Argentina: Achieving Systemic and Sustained Change, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/g2g98ec3-en.

[24] OECD (2018), Integrity Leadership: Promoting Ethical Leaders in the Public Sector, OECD, Paris.

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[5] OECD (n.d.), OECD Public Integrity Indicators, OECD, Paris, https://oecd-public-integrity-indicators.org/ (accessed on 1 December 2023).

[20] OECD (n.d.), Public Procurement, OECD, Paris, https://www.oecd.org/en/topics/public-procurement.html (accessed on 21 January 2025).

[8] Zall Kusek, J. and R. Rist (2004), Ten Steps to a Results-Based Monitoring and Evaluation System : A Handbook for Development Practitioners, World Bank, Washington, DC, http://hdl.handle.net/10986/14926 (accessed on 30 April 2025).

Note

← 1.  The role of Anti-Corruption Compliance Officers is defined by the Law on Combating Corruption (2015) and the “Methodological recommendations on the organisation of the Institution of Anti-corruption compliance in quasi-state sector entities” (2021).