This chapter examines the fourth area of Sweden’s anti-corruption plan on promoting open cultures of integrity throughout the Swedish public administration. It provides recommendations 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 strengthen internal audit and control.
OECD Integrity Review of Sweden
Abstract
The OECD Recommendation on Public Integrity sets out the main pillars for building a culture of integrity in the public sector (OECD, 2017[1]). A holistic approach to public integrity requires going beyond laws and regulations and ensuring public values are deeply rooted in the behaviour of individuals and organisational structures (OECD, 2017[1]; OECD, 2020[2]). In particular, achieving open cultures of integrity in the public administration means that public officials at all levels of the administration are equipped with the knowledge and skills to recognise and manage integrity issues appropriately when they arise, and seek out expert advice when needed to discuss ethical dilemmas, potential conflict-of-interest situations, suspicions of integrity violations and other integrity concerns (OECD, 2020[2]).
In short, building open organisational cultures is about creating safe environments in which public officials know the rules and behave accordingly, and public organisations are able to respond to risks that threaten their integrity objectives as well as other strategic and operational objectives. The benefits of building a culture of integrity and good governance include enhanced trust in the public administration, a greater sense of ownership and pride among public employees in their work, enhanced capacities to address integrity issues before they become potentially damaging, and safeguarding the public sector’s ability to deliver services, to retain competent individuals and to protect its assets against fraud and corruption (OECD, 2020[2]).
Sweden has an established and developed framework for cultivating and maintaining a culture of integrity, with public service values embedded in governance policies and processes. However, the Swedish government has begun to reassess its framework for maintaining a culture of integrity, particularly considering the threat of unlawful influence. This chapter reviews strengths and opportunities for improvement with respect to promoting organisational cultures of integrity in the Swedish public administration. The subsequent sections provide recommendations in the following areas:
Setting clear integrity standards, including for preventing and managing conflicts of interest. Principles and values help public officials carrying out their public duties ethically. 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 fairly and visibly sanctioned in a timely way to ensure the credibility of the integrity system.
Strengthening the integrity risk management, internal control and audit framework. Applying an internal control and risk management framework and to ensure effective oversight is essential to safeguarding public integrity. A healthy internal and external control environment will set the expectation for management and personnel to take ownership of risk management and ultimately set the tone for integrity.
In Sweden, the core values guiding public administration – including impartiality, objectivity, and integrity – are anchored in several key legal texts. The foundation is laid in Chapter 1, Article 9 of the Instrument of Government, which establishes that courts of law, administrative authorities and others performing public administration functions shall shall pay regard in their work to the equality of all before the law and shall observe objectivity and impartiality (Government of Sweden, 1974[3]). These principles are reaffirmed in Section 5 of the Administrative Procedure Act (2017:900), which explicitly requires public authorities to maintain objectivity and impartiality in their operations, and are applicable to all public offices at state, regional and municipal levels. Additionally, Sections 16-18 of the Administrative Procedure Act outline procedures for managing conflicts of interest in decision-making (Government of Sweden, 2017[4]). Complementing these provisions, the Public Employment Act (1994:260) provides further regulations concerning, for instance, merit-based recruitment, employees’ responsibilities related to outside employment, disciplinary procedures or sanctions (Government of Sweden, 1994[5]). The Government Agency Ordinance (myndighetsförordningen) stipulates that heads of government agencies are responsible inter alia for operations being run efficiently and in accordance with existing laws and regulations. The heads of agencies are also responsible for ensuring a well-functioning internal control, which include e.g. preventing corruption, fraud and unauthorised influence. In addition, an ordinance on internal control is in force for all government agencies with an internal audit function (about 70 agencies). It requires these agencies to have an internal control and a “good internal environment” to foster good governance. The ordinance sets out a number of additional process requirements, such as for example risk analysis, monitoring and documentation. The Swedish National Financial Management Authority have the right under the ordinance to issue instructions. And finally, responsibilities for employment matters including, inter alia, skills development, pay and employment conditions, disciplinary sanctions and the work environment have also been delegated to the heads of central government agencies.
The principle of responsibility, whereby each ministry is in charge of handling the policies and measures in its own field and work with the relevant agencies, is another key principle of the regular working arrangements of the government. However, the government has no power to intervene on specific cases relating to the exercise of public authority vis-á-vis an individual or a local authority, or relating to the application of law as stipulated in the Instrument of Government. This system allows agency leaders to retain significant independence in their decision-making in relation to specific cases or relating to the application of law, despite being appointed by the government, operating under its overall governance and organisational framework, and being required to follow its collective directives.
Based on these principles and Sweden’s devolved public governance model (outlined further in Chapter 1), general management models and frameworks are developed to guide agency operations without undermining their autonomy. This also applies to corruption prevention and the promotion of a good administrative culture, including the training and professional development of public servants. Each agency is responsible for upholding ethical standards and bears the responsibility for promoting awareness and understanding of these standards among its personnel. Similarly, each agency holds the primary responsibility for ensuring a safe work environment, which includes systematically assessing the risks of unlawful influence and implementing preventive measures.
Within this framework, the Swedish Agency for Public Management (Statskontoret) has been mandated to support both individual agencies and the Government Offices in complementing their respective efforts to strengthen integrity and good administrative culture. For instance, the Agency has produced several reports on risk analysis, but the responsibility for implementing these tools rests with each individual agency. In 2023, a digital induction training programme was introduced to promote more consistent onboarding practices, but its use remains voluntary. The Agency has also developed a range of awareness-raising materials, including illustrative examples of ethical dilemmas, and offers capacity-building workshops upon request, covering various dimensions of public sector ethics and governance. Additionally, 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.
A number of international reports and assessments of Sweden, including from GRECO, have highlighted that public agencies are generally well-equipped to prevent and fight corruption (GRECO, 2019[6]). In addition, the main findings from the 2023 OECD Survey on Drivers of Trust in Public Institutions show that Sweden performs better than the rest of OECD countries in people’s perception of public integrity. When asked about the likelihood that a public employee would accept or refuse a bribe to speed up a service, 36% on average think that a civil servant would engage in such petty corruption, compared to 43% in OECD countries on average. In addition, 73% of Swedes are satisfied with the administrative services they use, an important driver of trust in the civil service, compared to a 66% OECD average (OECD, 2024[7]; OECD, 2024[8]).
Nevertheless, a growing awareness fueled by high-profile corruption cases, Sweden’s recent downwards trajectory in the CPI rankings, and the evolving threat of unlawful influence, has triggered a shift in mindset. Interviews conducted with national stakeholders and public officials for this report indicated that there is an increasing recognition across the public sector and civil society as a whole that earlier complacency may have bred vulnerabilities. For example, only 5-10% of the public workforce in Sweden follows a career-based trajectory, while the vast majority are hired through open competition for specific roles. This position-based approach, without a strong civil service model, has led to certain challenges, including issues related to the “revolving door” between the private and public sectors. In particular, recent corruption cases have involved individuals with prior private sector experience mishandling public responsibilities, underscoring the need to bolster ethical standards and state employee competencies.
In December 2023, the Statskontoret’s report examining agencies’ work in preventing corruption found that while many authorities have taken basic steps to combat corruption, such as establishing internal controls, assigning responsibilities, and including corruption awareness in onboarding, more advanced, integrated, and ongoing efforts remain a challenge. For example, few agencies provide targeted training for managers or systematically assess staff knowledge. Anti-corruption measures are often not embedded in daily operations, and high-quality risk analyses are lacking. Additionally, many authorities have a limited understanding of corruption, often equating it solely with bribery and interpreting it as separate from related issues like conflicts of interest or secondary employment. Some agencies have made considerable progress, offering internal training and promoting ethical awareness. However, as the Statskontoret noted, performance remains uneven, with institutions such as universities and courts reportedly lagging. The Statskontoret concluded that anti-corruption efforts must become more risk-based, operationally integrated, and aligned with broader goals of fostering a strong administrative culture (Statskontoret, 2023[9]).
International recommendations have also noted a traditionally narrow understanding of corruption in Sweden, often limited to bribery, despite growing awareness of risks related to informal relationships and personal connections within and between government and business circles, which lead to favouritism and unequal opportunities but without the stigma typically associated with bribery. As a result, Sweden’s anti-corruption policies have long been focused on developing robust compliance and enforcement regimes against bribery, but lacked a strong focus on promoting integrity, raising awareness and preventing conflicts of interest (GRECO, 2019[6]).
Overall, there is a growing push to instill a stronger administrative culture and improve preventive mechanisms across the public sector, especially in light of emerging challenges. One of the priority areas identified in the APACUI is the need to promote a good administrative culture within the public administration. In particular, the APACUI emphasises the importance of strengthening the capacity of all state employees to act objectively and impartially, in full accordance with the laws and principles that govern public administration. These principles have recently been reinforced with the amendments to the Government Agency Ordinance which came into force on the 1 July 2025. Similarly, to further reinforce the public sector’s capacity to prevent and respond to threats, harassment, and unlawful influence, the Swedish government has issued specific mandates to key institutions through new assignments. In June 2024, the Swedish Agency for Public Management and the Swedish National Council for Crime Prevention (Brå) were tasked with supporting efforts against unlawful influence within government agencies, municipalities, and regions. Their assignment includes producing and disseminating support materials and will run until 31 May 2026. In parallel, the Swedish Agency for Government Employers (Arbetsgivarverket) has been commissioned to promote knowledge-sharing among state agencies, providing guidance and training to strengthen their responses to threats, violence, and harassment directed at public officials (Government Offices of Sweden, 2024[10]). This assignment was carried out throughout 2024 and has now been completed.
Establishing clear procedures for identifying, managing, and resolving conflicts of interest is essential for public officials to maintain public integrity in their roles. Public officials must understand their obligations when it comes to recognising and disclosing potential conflict-of-interest situations (OECD, 2003[11]). When such situations are not appropriately identified and handled, they can seriously compromise the integrity of institutions and create risks of corruption in both the public and private sectors. At the same time, in many countries, conflicts of interest are frequently misunderstood and mistakenly equated with corruption. This confusion can discourage public officials from reporting conflicts of interest, fearing potential repercussions. It is therefore crucial to foster an understanding that everyone has interests; these cannot be prohibited, but they must be transparently and effectively managed. To this end, the OECD Recommendation on Public Integrity calls on adherents 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 (OECD, 2017[1]).
In addition, the Recommendation of the Council on OECD Guidelines for Managing Conflict of Interest in the Public Service provides core principles for managing conflict of interest, as well as recommendations for developing and implementing a coherent COI policy framework (OECD, 2003[11]).
In Sweden, conflicts of interest are primarily regulated by the Instrument of Government (Regeringsformen), Chapter 1 Article 9 of which establishes the foundational principles of impartiality and objectivity in public administration, and the Public Employment Act (1994:260), which applies these principles in terms of, for instance, merit-based recruitment, employees’ responsibilities related to outside employment, disciplinary procedures and sanctions. Rules on incompatibility prohibit ministers from holding positions, jobs, or engaging in activities that could compromise public trust in their integrity (Chapter 6 § 2 of the Instrument of Government). The Public Employment Act (1994:260) prohibits secondary employment that could undermine confidence in the impartiality of public employees or harm the reputation of the authority. According to Section 7 of this Act, employees must not engage in any work, assignments, or activities that could compromise trust in their own or a colleague’s impartiality or damage the authority’s credibility. The Administrative Procedure Act (Förvaltningslagen, 2017:900) further operationalises these principles through Sections 16-18, which require officials to recuse themselves in situations of disqualification (jäv) due to a conflict of interest and to notify their authority without delay:
Section 16
A person who takes part on behalf of an authority in the processing of a matter in a way that can influence the authority’s decision in the matter is disqualified if:
1. either they or a person close to them is a party in the matter or can otherwise be assumed to be affected by the decision to a not insignificant extent;
2. either they or a person close to them is or has been a representative or counsel for a party in the matter or someone else who can be assumed to be affected by the decision to a not insignificant extent;
3. they participated in the final processing of the matter at another authority and have, as a result of this, already taken a position on the questions to be examined by the authority as a superior instance; or
4. there is some other special circumstance that means that their impartiality in the matter can be questioned. If it is obvious that the question of impartiality is of no importance, the authority shall disregard the disqualification.
Section 17
A person who is disqualified must not take part in the processing of the matter and must not be present when the matter is determined either. However, they may perform tasks that no one else can perform without a considerable delay in the processing of the matter.
Section 18
A person who is aware of a circumstance that can be assumed to disqualify them must immediately notify the authority of this. An authority shall examine a question of disqualification as soon as possible. The person that the disqualification applies to may only take part in the examination of the question of disqualification if this is required for the authority to be quorate and a replacement cannot be summoned without material delay to the examination.
Within this framework, each agency or ministry is responsible for developing its own internal policies and procedures for identifying and managing conflicts-of-interest situations, providing training and support to employees, designating advisory roles or contact points (ethics or HR advisers), and documenting and following up on conflicts. Swedish officials noted in preparation for this report that this system allows for more flexibility in managing conflicts of interest, and stronger assessments of where private interests conflict with official duties. However, since there is no single, unified law or procedure that governs conflicts of interest across all ministries and agencies, specific processes and the standard of managing conflicts of interest may vary across agencies.
Sweden fulfils 44% of OECD criteria on the strength of conflicts of interest regulations, and does not fulfil any criteria on practice, compared to the OECD average of 76% and 40%, respectively (Figure 5.1). The OECD Public Integrity Indicators (PIIs) show that Sweden’s regulations define circumstances and relationships that can lead to conflict-of-interest situations for public officials, establish the obligation to manage them, and define sanctions for breaches of conflict-of-interest provisions in proportion to the severity of the offence. While members of the Government and Parliament (Riksdag) are required to declare their interests upon taking office and when their interests change, there is no equivalent requirement for public employees in high-risk positions, top-tier civil servants, or members of the highest bodies of the judiciary. In practice, there is no central authority responsible for collection and verification of interest declarations, and Sweden does not collect data on the submission of interest declarations at the central government level.
Source: Public Integrity Indicators (2024)
5.3.1. Sweden could clarify the definition of real, potential and apparent conflicts of interest through guidance which includes key concepts, non-exhaustive examples, and practical advice for managing conflicts
To enable public officials to identify and manage conflict-of-interest situations, it is advisable to adequately define a “conflict of interest” (OECD, 2003[11]). 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[2]). 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, 2003[11]).
As noted, Sweden’s rules relating to the prevention and management of conflicts of interest are elaborated across several different laws and in collective agreements between employers and trade unions. Legal provisions range from the more fundamental provisions in, for example, Chapter 1 Article 9 of the Instrument of Government, to more applied rules in, for instance, Section 16 of the Administrative Procedure Act. Indeed, the latter follows a prescriptive approach to conflict-of-interest rule-setting, defining a range of situations which may give rise to a conflict with official duties in the context of the ‘processing of matters’ at administrative authorities and courts.
Swedish public authorities are responsible for applying and adapting legal provisions relating to matters concerning staff to their own context and needs, which includes the development of rules for the prevention and management of conflicts of interest. This work draws from the provisions in the legislative framework (which are further elaborated through caselaw) and from the development of collective agreements based on workplace-level dialogue between employers and employees through trade unions.
However, while overall the legal framework contains several principles and situations related to conflicts of interest which can then be elaborated into more agency-specific policies and processes, Sweden has no single, general definition of conflict of interest which can inform and support this work. This lack of a single definition leaves the risk of inconsistency of interpretation between public authorities and confusion over the rules which apply to individuals trying to manage their interests and any conflicts. While establishing a single definition in the legal framework may not be necessary (or suited to the Swedish context), Sweden could consider producing and disseminating guidance which consolidates the existing legal provisions into one place and establishes a clearer, single definition of conflicts of interest. Such guidance could clarify the difference between real, potential and apparent conflicts of interest (Box 5.1). Other countries have developed such a single definition. The UK, for example, has no legal definition of conflicts of interest but has developed guidance for senior civil servants which establishes a single definition of real, potential and perceived conflicts (Cabinet Office, 2024[12]). In France, 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”.
Recognising that countries have different historical, legal and public service traditions, which may impact on the way conflict-of-interest situations have been understood, the OECD Guidelines developed a definition of “conflict of interest” which is intended to be simple and practical, to assist effective identification and management of conflict situations.
A “conflict of interest” involves a conflict between the public duty and private interests of a public official, in which the public official’s private-capacity interests could improperly influence the performance of their official duties and responsibilities.
On this basis, a “conflict of interest” involves a situation or relationship which can be current or may have occurred in the past. Defined in this way, “conflict of interest” has the same meaning as actual conflict of interest.
By contrast, a perceived or apparent conflict of interest exists where it appears that an official’s private interests could improperly influence the performance of their duties, but this is not in fact the case.
A potential conflict of interest occurs where a public official holds a private interest which would constitute a conflict of interest if the relevant circumstances were to change in the future.
It is important to note that this definitional approach recognises that conflicts of interest will arise and must be managed and resolved appropriately.
Source: (OECD, 2003[11])
Such guidance could also define key concepts, non-exhaustive examples, and practical advice for managing conflicts of interest. Some relevant guidance in this respect already exists in Sweden. For example, the guidelines on “Basic values of central government authorities” offer some guidance on the measures an authority could take to manage a conflict, but only specify authorities’ “responsibility to make it easy for their employees to do what is right” (Swedish Agency for Public Management, 2022[13]). In 2020, the Statskontoret produced more detailed guidance to provide managers and employees in both state and municipal administrative authorities with more knowledge about the rules on conflicts of interest (Statskontoret, 2020[14]). This guidance contained examples of conflicts of interest which have arisen in the Swedish public service and practical advice to individuals on managing their conflicts.
This existing guidance could be further developed, particularly if Sweden chooses to produce a single definition of conflicts of interest, to include, for instance, general guidelines for public agencies that include model procedures for declaring a conflict of interest and the options for resolving it. The guidelines could suggest the timeframe in which a person must declare a conflict of interest to their employer and when they can expect a response with advice on resolving the situation. They could also offer advice to authorities trying to strengthen their management of conflicts of interest based on the existing legal provisions. In time, the guidelines could provide concrete examples of how a single definition is being incorporated into agency-level policy and collective agreements, and how it is being used to prevent and manage conflicts in the public service.
5.3.2. Line managers could be trained to provide ad hoc advice to public officials on identifying and managing conflict of interest, while Ministries and agencies could be encouraged to establish a mechanism for confidential counselling on conflict of interest
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. 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. As noted in the Swedish National Audit Office’s review of the management of conflicts of interest within the Swedish Financial Supervisory Authority (Finansinspektionen), there were insufficient discussions initiated by immediate managers regarding the role of government officials and the risks of conflicts of interest, as well as inadequate documentation and follow-up on notifications and decisions related to disqualification, secondary employment, and other relevant conflicts of interest (Swedish National Audit Office, 2020[15]).
Good practice shows that dedicated integrity officers within each public entity can play a key role in providing 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 completing 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 direct superiors in charge of “taking measures” (i.e., help the direct superiors in what measures to recommend concretely to their employees).
In Swedish government agencies, while Directors-General (generaldirektörer) or their equivalents are ultimately responsible for upholding ethical standards, the practical role of providing integrity advice to staff is typically carried out by legal departments, human resources units, or specially appointed ethics officers. In some cases, such as the Swedish Migration Agency, dedicated structures like ethics councils exist to provide guidance, though these typically operate at the request of the agency leadership and are not directly accessible to individual staff for day-to-day ethical concerns. In other agencies, ethical guidance may be provided by internal legal departments, human resources units, or designated ethics officers. For example, the Swedish Research Council has a conflict-of-interest policy and guidelines that staff must follow, and potential conflicts are managed according to these internal procedures.
Similarly, in ministries, the Director-General for Administrative Affairs (expeditionschef) oversees administrative integrity and ensures adherence to rules and procedures, but does not generally serve as an ethics adviser to staff. Instead, staff may turn to legal departments or other designated officials for guidance. However, there is currently no systematic or standardised ethics advisory role clearly visible or accessible across all agencies and ministries.
As such, line managers could be trained to provide ad hoc advice on conflicts of interest to their staff, and individual agencies could also be encouraged to establish a clearly identifiable ethics function to create a “safe haven”, to provide credible advice and to build a trusted relationship with employees of the entity. 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”).
Developing clear standards of integrity, including on preventing and managing conflict of interest, is not an end in itself. Legal provisions and policies are only meaningful if they are effectively communicated and internalised. Socialisation mechanisms play a key role in this process, enabling public servants to learn and adopt ethical norms, standards of conduct and public service values (OECD, 2018[16]). Indeed, for integrity standards to translate into real behavioural change, it is essential to raise awareness, build technical knowledge and skills and provide targeted training and guidance. Raising awareness helps office holders to recognise integrity issues when they arise, while building capacities via trainings and guidance material helps them to address integrity challenges properly. Together, these efforts embed a culture of integrity and strengthen commitment among public officials (OECD, 2020[2]).
In recent years, Sweden has invested in awareness raising and training activities targeting public officials. Knowledge and awareness are, in fact, one of the four core pillars identified by the Swedish Agency for Public Management as particularly critical to the preventive efforts of public authorities in combating corruption – alongside management and organisation, risk-based approaches, and targeted anti-corruption measures (Swedish Agency for Public Management, n.d.[17]). Among the initiatives implemented in recent years for public officials, the Swedish Agency for Public Management has carried out, for example, the following activities and programmes designed to support agencies in independently implementing and adapting training and support materials to their specific needs and contexts:
An introductory e-learning course for all government employees, entitled “Your role in central government – common ground rules” was introduced in July 2023. The course provides basic knowledge of what is common to all government work in any organisation or role. It includes dedicated chapters on the six principles that make up the basic values of central government authorities: democracy, objectivity, rule of law, respect, free formation of opinion, efficacy and service. The Agency for Public Management has also provided the course in the form of a SCORM package (a communication method and data model that supports eLearning content) for central government authorities who wish to include it in their learning management platform (Swedish Agency for Public Management, n.d.[18]).
Publications and handbooks on a good administrative culture that can be used as a knowledge base for agencies and government employees, including a handbook on the “Basic values of central government authorities – common principles for a good administrative culture” (Swedish Agency for Public Management, 2022[13]).
A series of online dilemma exercises available in a “dilemma bank” and an online training course on how to lead dilemma conversations (Swedish Agency for Public Management, n.d.[19]). At the time of writing, the Agency for Public Management was also taking positive steps to develop specific dilemma exercises on unlawful influence.
Capacity-building workshops are offered upon request to support authorities in strengthening state values, promoting a sound administrative culture, and preventing corruption. These workshops are primarily designed for management teams and senior officials who hold key responsibilities in fostering ethical conduct within their agencies. Held on-site, the workshops focus on reflection and discussion, encouraging participants to consider their roles as civil servants, explore the practical application of core public sector values, and identify strategies to reinforce integrity within their operations. The content is tailored collaboratively to align with each agency’s specific context and needs, serving various purposes such as inspiration, professional development, or deepening ongoing efforts in administrative culture and anti-corruption work. According to the Agency for Public Management, approximately 40 such workshops are held annually.
Other support materials such as short videos and films explaining the six core values of the Swedish Public Administration and discussion exercises.
Several agencies have reported using the ethics and integrity guidance and training provided by the Agency for Public Management, often in combination with their own tailored training programmes to address agency-specific needs. While these efforts are a positive step, significant gaps remain in the provision and consistency of integrity training for public officials across Sweden. The need to enhance and mainstream such training throughout the public administration has been highlighted in multiple evaluations. For instance, the Swedish National Audit Office, in its review of the Financial Supervisory Authority’s efforts to address conflicts of interest (RiR 2020:18), recommended stronger training and information initiatives focused on core public sector values and the management of conflicts of interest. The report also found a lack of clarifying examples of conflicts of interest, which gives considerable scope for varying interpretation of the rules (Swedish National Audit Office, 2020[15]).
The training and awareness-raising initiatives led by the Swedish Agency for Public Management represent a significant step forward in promoting ethics and integrity within the public sector. These efforts have laid a valuable foundation, and there is considerable potential for Sweden to further build on and expand these initiatives to reinforce a culture of integrity across the entire public administration. The following sections explore concrete ways in which these efforts can be scaled up and institutionalised to strengthen capacity building on public integrity at both the national and agency levels.
5.4.1. The Agency for Public Management could develop adaptable online model training modules on public integrity, while also supporting agencies in providing of in-person integrity training sessions
Interviews conducted with institutional actors for this report found the need for more flexible and targeted integrity training approaches, particularly, in light of the developing threat of unlawful influence, for individuals working in high-risk areas such as permits and licensing. In small municipalities, where limited staff often manage critical responsibilities, there is insufficient capacity to participate in extensive in-person training. To address this, there is a clear demand for digital training modules and broader information campaigns to raise awareness of available resources. Such e-learning tools could be designed centrally and then adapted by agencies or municipalities to reflect their specific risk profiles. Additionally, there is strong interest in developing role-based integrity standards and training materials, enabling agencies to tailor integrity guidance to the distinct functions and challenges of their personnel.
For both induction and in-service training, there are several methods available to support delivery of integrity trainings, including lectures, online courses, coaching and mentoring programmes (Table 5.1). Methods should be tailored according to the training’s objectives, as some methods may not be the most effective for every circumstance. Research has shown that while online courses and lectures allow reaching a larger audience and can be used for imparting knowledge about specific integrity standards, rules and administrative procedures that exist to guide integrity in the public sector (e.g. “rules-based” training), 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 (e.g. “values-based” training). As such, it should be emphasised that online training does not replace interactive in-person training, reflection, discussions or experience.
Considering this, beyond its current offering, the Swedish Agency for Public Management could develop additional training activities and methodologies 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 – online induction training course on integrity developed by the Agency for Public Management, adaptable by individual agencies: in addition to the general induction training on common ground rules, the Agency for Public Management could consider developing a complementary model online course specifically focused on corruption prevention and integrity to help public officials familiarise themselves with relevant concepts, expected behaviours and rules derived from the regulatory framework for public integrity. Similar to the general induction training on common ground rules, the training could be provided in the form of a SCORM package for central government authorities who wish to include it in their learning management platform and adapt it to their specific realities. A special online training on identifying and managing conflict of interest could be considered (see following section).
Intermediate level – in-person ad hoc and “train-the-trainers” courses: Building on its existing ad hoc in-person trainings, the Agency for Public Management could consider expanding and formalising its offering of lectures and courses focused on key aspects of the regulatory framework for public integrity. These could include targeted modules on corruption risk management, handling ethical dilemmas, and identifying and managing conflicts of interest, with an emphasis on presenting participants with concrete, real-life scenarios. These trainings are ideally in person, go into more detail and provide concrete examples that public officials can relate to. To ensure sustainability and broader reach, a "train-the-trainers" format could also be developed, equipping agency-level trainers with the knowledge and tools needed to deliver these trainings effectively and tailor them to the specific needs and operational contexts of their respective institutions.
Advanced level – training modules for at-risk positions: to further engage specific priority groups of public officials and help them strengthen their capacities to address and manage integrity challenges, the Agency for Public Management could design specialised training modules to train public officials in at-risk positions and/or areas, such as procurement and purchasing, or human resource management, information and IT security, secondary employment, gifts and entertainment. Middle and higher management levels, particularly heads of agencies and line managers, could be trained in integrity leadership skills (see section below), as well as integrity officers recommended earlier in this chapter. As also mentioned in Chapter 6 of this report, the Agency could also work with SALAR to develop training, guidance, and capacity-building support for municipalities and regions on public integrity.
5.4.2. The Agency for Public Management could develop dedicated trainings on preventing and managing conflicts of interest and partner with the Brå to develop similar guidance on unlawful influence
Strengthening training and awareness-raising initiatives on conflicts of interest and the role of public officials has been identified as a key area for improvement in various government reviews and evaluations. This need has been further reinforced by interviews conducted with institutional stakeholders for this report, who emphasised the lack of consistent, accessible training opportunities. Specifically, there is a pressing demand for both online courses that clarify core concepts and legal obligations related to conflicts of interest, as well as structured, in-person training sessions that officials can attend on a regular basis. A common concern among stakeholders is the absence of comprehensive guidance and training that would enable public officials to apply a coherent and practical interpretation of the relevant rules on conflicts of interest.
In response to these identified gaps, the Swedish Agency for Public Management could consider developing a dedicated online training course focused on identifying and managing conflicts of interest. This course could include interactive modules, real-life ethical dilemma case studies, and practical decision-making tools. To facilitate peer learning and continuous engagement, the course could also be accompanied by an online forum where civil servants are encouraged to exchange views and discuss case-based scenarios. As an example, the Office of the Independent Commission against Corruption of South Australia provides a free conflict of interest training course that is available online. The Agency could also use the online course as a foundation to develop complementary in-person workshops, either as standalone sessions or within a “train-the-trainers” programme. This would equip designated agency trainers with the knowledge and resources to deliver tailored integrity training adapted to their agency’s specific context and risk profile.
The same type of trainings and materials could be developed as part of the ongoing efforts to address risks of unlawful influence in the Swedish public administration. The Agency for Public Management and the National Council for Crime Prevention are currently tasked with producing and disseminating support materials on unlawful influence, while the Agency for Government Employers (Arbetsgivarverket) has been tasked with supporting, facilitating, and promoting the exchange of experience among central government agencies, including with regard to threats, violence, and harassment directed at public officials. As such, the Agency for Public Management could partner with both the Council for Crime Prevention and the Agency for Government Employers to develop a dedicated online training on the prevention of unlawful influence within agencies, as well as complementary in-person workshops, either as standalone sessions or within a “train-the-trainers” programme, similar to what has been proposed above for the prevention and management of conflicts of interests.
5.4.3. The Agency for Public Management could develop targeted training and support materials for agency heads and line managers
The behaviour of both top-level and middle managers plays a critical role in fostering an open organisational culture and mitigating integrity risks. In particular, middle managers, due to their close, day-to-day interaction with staff, are uniquely positioned to model and reinforce ethical conduct within their teams. By modelling ethical behaviour, actively communicating integrity standards, and supporting employees who raise concerns, leaders build trust, raise awareness, and empower staff to uphold public integrity (OECD, 2020[2]).
The Swedish Agency for Public Management rightly underscores the importance of leadership in driving anti-corruption efforts, highlighting that agency leaders must take an active role in initiating and supporting measures that create a structured, integrity-driven working environment. For such efforts to succeed, it is essential that the structural and cultural reforms championed by senior leadership are clearly communicated to and internalised by first-line managers, who, in turn, translate these into practical behaviours and expectations among individual employees on the ground (Swedish Agency for Public Management, n.d.[20]).
Given its mandate for developing a good administrative culture, the Agency for Public Management could 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. The trainings could focus on 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.
5.4.4. Agencies could be encouraged to systematically measure and evaluate the use and impact of support materials and training activities aimed at fostering a sound administrative culture
Interviews conducted for the purpose of this report confirmed that the Swedish Agency for Public Management currently does not track the use or assess the impact of its support materials across government agencies. Nor does it have a clear understanding of how these materials are being applied in practice.
To enhance the effectiveness of integrity-related guidance, individual agencies could be encouraged to systematically report back to the Agency for Public Management on how they are using the support materials and training activities, and to provide feedback. Such a feedback loop would enable the Agency to make informed adjustments and improvements, ensuring that the materials remain relevant and impactful. Moreover, tracking usage would allow the Agency to identify which authorities and categories of public officials may require additional support, enabling more targeted assistance. Lastly, publishing online which agencies or municipalities have incorporated the materials and trainings into their own programmes would also encourage uptake, promote transparency and enable public oversight.
Agencies themselves should also be encouraged to monitor and evaluate the quality and impact of their own training and awareness-raising efforts, whether these are based on materials developed by the Statskontoret or on their own tools. This would allow agencies to learn from implementation, refine their training approaches, and focus limited resources on activities that prove to deliver the best results. While most OECD countries monitor and evaluate the quality of training activities, in general they do not measure their impact. This is largely due to the absence of established methodologies capable of capturing the long-term behavioural and organisational changes resulting from training. Additionally, the presence of numerous external and internal variables influencing the conduct of public officials makes it difficult to isolate the effects of training (OECD, 2020[2]). One of the commonly acknowledged models for assessing training is the Kirkpatrick “Four Levels Model” (Box 5.2).
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 “multirater assessments”, for instance, 360-degree assessments along a control group (McGivern and Bernthal, 2003[21]), 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[2]).
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[2]):
1. Number of cases where public officials sought integrity advice and the outcome of such cases.
2. Number of disclosures of potential conflicts of interests to relevant authorities including mitigation measures taken and implemented.
3. Perceptions about the level of integrity and openness of the organisation.
4. Number of reports from citizens and businesses outlining public officials not behaving well in the provision of public services.
5. Level of satisfaction of citizens and businesses about the quality of public services.
5.4.5. The Network against Corruption for Swedish State Agencies could serve as a platform to communicate and raise awareness on training opportunities
Co-ordination mechanisms, such as the designation of a lead organisation and the development of a centralised online platform for all public sector training materials, are essential to ensure that integrity training efforts are coherent, strategically aligned, and accessible across the public administration. Moreover, structured inter-agency collaboration can help avoid discrepancies in training implementation, foster mutual learning, and ensure that centrally-designed training initiatives are effectively communicated and tailored to the diverse needs of government agencies (OECD, 2020[2]). This is particularly relevant in the Swedish context, where, although the Agency for Public Management plays a central role in providing guidance and strengthening the capacities of public officials, the uptake and application of training initiatives are largely decentralised and left to the discretion of individual agencies. Strengthened co-ordination mechanisms would help ensure more consistent and widespread delivery of integrity-related training across the public sector.
The Network against Corruption for Swedish State Agencies could be further leveraged as a strategic platform to communicate and raise awareness of the various training opportunities and support materials offered by the Swedish Agency for Public Management. By serving as a central co-ordination hub, the Network could help to ensure that integrity-related resources reach a broader audience across the public administration. In this regard, the creation of an online platform or digital catalogue, linked to or maintained by the Network, could serve as a central repository for the Agency’s training modules, guidance documents, and tools. This would facilitate easy access for agencies and officials, encourage knowledge sharing, and contribute to a more coherent and visible approach to integrity training across the state sector.
Well-designed internal audit and internal control systems provide several levels of assurance that public funds are spent efficiently, effectively and in line with their intended purpose. To safeguard integrity in public sector organisations, the OECD Recommendation on Public Integrity calls on adherents to apply an internal control and risk management framework (OECD, 2017[1]). By ensuring that management demonstrates a commitment to integrity and public-service values, applying a strategic approach to risk management, and embedding control mechanisms with clear procedures to address violations, countries are better equipped to address risks to public integrity, including corruption, fraud, and unlawful influence (OECD, 2020[2]).
A comprehensive internal audit and internal control system puts in place three lines of assurance to protect public funds against fraud, corruption and other risks:
First line roles are assumed at the operational level, which is responsible for establishing and maintaining appropriate structures and processes for the management of operations and risk, including control measures.
As part of their second line role, management oversight functions are responsible for assisting managers in the assessment and management of risks, including by conducting compliance assessments or reviews and reporting to senior management or ministers.
Finally, the third line of assurance consists of internal auditors who provide independent and objective assurance that internal control is effective (The Institute of Internal Auditors, 2024[23]).
Sweden adheres to the three lines model and performs above the OECD average on internal control and internal audit, fulfilling 68% of OECD criteria on regulations and 53% in practice, compared to the OECD average of 67% and 33% respectively. Responsibility for mitigating integrity risks in the Swedish public sector is shared between different institutions. The framework for internal governance and control for state authorities is set out in Ordinance 2007:603 on internal governance and control. Managers in public sector authorities are responsible for owning and managing risks in their day-to-day operations as part of their first line, while functions such as financial control, quality assurance, compliance, and inspection units in public authorities provide second line assurance, and internal audit units provide independent assurance on the effectiveness of internal controls as part of the third line. State authorities are supported by the ESV in its capacity as the central harmonisation unit for financial management of Government activities and internal audit and internal control. Finally, the Supreme National Audit Office (Riksrevisionen) provides external oversight assurance as the Swedish Supreme Audit Institution under the parliament.
While Sweden therefore regulates internal control according to international standards, establishes managerial responsibility for implementation of internal control and internal audit, specifies the objectives of internal control, and establishes annual internal control and internal audit reporting activities, there is scope to independently verify the functioning of its internal control and audit framework more effectively.
5.5.1. Sweden should ensure regular external reviews of its internal control and audit system
External scrutiny and oversight are essential parts of an integrity system. While public organisations and officials should remain accountable for their decisions, actions and expenditures, oversight contributes to the public integrity system’s effectiveness through the impartial monitoring and enforcement of laws and regulations throughout the public sector. Oversight functions can also foster learning through evaluation and highlighting good and bad practices through recommendations, to which governments should be obliged to respond. In this way, oversight reporting can inform strategic planning on integrity and the wider policy cycle (OECD, 2020[2]).
A key oversight mechanism in any country is its Supreme Audit Institution (SAI). SAIs are independent from the executive with powers often entrenched by the constitution. They oversee the legality, efficiency, effectiveness, and financial and performance management in the public sector, by conducting external, independent audit of legality, regularity and performance of public bodies and policies. They also commonly issue recommendations about corrective measures, and those SAIs with jurisdictional activities can also enforce financial liabilities. SAIs are therefore an important aspect of a country’s internal control and internal audit framework. For this reason, many OECD countries’ SAIs now conduct regular reviews of the country’s internal control or audit system. Indeed, around a third of OECD countries’ SAIs have conducted a review of the internal control or audit system within the past 5 years (Figure 5.2). However, this is not the case in Sweden, with the most recent report on this subject from Sweden’s SAI, the Riksrevisionen, having been published in 2017 (Riksrevisionen, 2017[24]).
Note: Data not provided by Belgium, Colombia, France, Germany, Hungary, Iceland, Israel, Italy, New Zealand and the United Kingdom.
Source: OECD Public Integrity Indicators, 2025
In Sweden individual agencies are responsible for carrying out external quality assessments of their functions at least every five years. These external assessments are then reviewed and reported on by the ESV in an annual report to the government. According to the ESV’s latest report, 93 percent of in-scope authorities had carried out such quality assurance in 2024 (ESV, 2025[25]). There is scope, however, for Sweden’s SAI to provide an extra layer of assurance by making regular independent reviews of Sweden’s internal audit and control framework. The absence of such an external review in the past five years means independent verification of the oversight, transparency, and effectiveness of internal control in Swedish state authorities could be improved, and potentially limits opportunities for systemic improvements. Sweden could therefore ensure that more regular external reviews are conducted, either by Sweden’s Supreme Audit Institution or another qualified independent or international body. Alternatively, Sweden could conduct a self-assessment with independent external validation. By ensuring that internal control systems are externally reviewed, Sweden could be better equipped to address gaps in internal control, risk management, and internal audit, and ensure the system is taking account of and resilient to new threats such as unlawful influence.
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