OECD Integrity Review of Sweden

Annex A. Sample integrity vulnerability assessment questionnaire

A. Organisational role

1. What are the core functions of the organisation (e.g. government office, public agency, their sub-units, departments, etc.)?

2. Does the organisation have a mission statement or similar description of its function/role? Are the staff aware of this? Do staff consider the mission statement accurate and appropriate?

3. Do the major organisation sub-units have mission statements or a clear definition of their function/role? Are the staff aware of these? Do staff consider them accurate and appropriate?

4. Do organisational strategic and operational plans include any integrity objectives, primary or secondary?

B. Budget

1. What is the size of the organisation’s budget?

2. What is the rough breakdown of spending between salaries, investment, purchases of goods and services and other types of spending?

3. What is the average size of a purchase/investment made by the organisation: are there a significant number of very large purchases/investments in an average year (or last year)?

4. What percentage of purchases/investment made by the organisation are put out to open tender?

5. How technically complex are the spending decisions made by the organisation? Who makes the more complex decisions and on what basis?

6. Are spending decisions on major items highly centralised (e.g. requiring the signature of one senior official) or highly decentralised?

7. Are spending decisions on minor items highly centralised (e.g. requiring the signature of one senior official) or highly decentralised?

8. Does the organisation receive income from the public, or designated clients (taxation, customs levies, payments for services or rents, etc.) What is the process for recording, banking and auditing these payments? In what form are such payments received?

C. Human resources management

1. How many staff does the organisation employ?

2. How many of these are employed centrally (e.g. in a government office), and how many indirectly (e.g. public servants such as teachers)?

3. Are there any monitoring and statistics to show the rate of staff turnover within the organisation? If so, is the turnover regarded as high, low, or about right?

4. Are there any internal recruitment guidelines in addition to the provisions in the law?

5. Do recruitment procedures for staff in positions that might be regarded as high-risk from a corruption point of view include criteria to attempt to ensure the integrity of those appointed?

6. Are applicants for staff positions questioned/screened to ensure they do not engage in external activities or hold external interests that may conflict with or impair the proper performance of their official duties?

7. Do staff have a clear understanding of what situations constitute conflicts of interest?

8. Do new staff go through any induction processes such as initial training? If so, does such training cover integrity issues? Is this repeated perhaps in more specific ways on promotion or when staff move to new roles?

9. Do staff regard their training as adequate to manage the situations that they face?

10. Who is designated as the person to whom staff should turn for advice? In cases of uncertainty would they seek advice from other colleagues on an informal basis before turning to their direct manager, or seek advice elsewhere?

11. Do staff feel that their salaries are adequate, just sufficient or insufficient to ensure a reasonable standard of living?

12. To what extent do staff feel valued by a) the organisation; b) their direct superior, in their role?

D. Procedures and decision-making processes

1. Does the organisation do any of the following?

a. issue or provide items such as licenses, permits, permissions, certificates, passports or other documents to citizens or entities:

b. allocate any financial or other benefits to citizens (for example social security benefits)

c. allocate any financial or other benefits to legal entities (for example subsidies)

d. receive payments from members of the public (such as fees, taxes, etc.).

2. Where it does so, are there clear procedures and clear criteria for the provision of such items and/or receipt of payments?

3. Where can these procedures and criteria be found?

4. Where officials have to exercise discretion in the decisions on such items, are there clear guidelines on how they should exercise that discretion (e.g. that it should serve a particular objective)?

5. If the organisation does not make a decision on items that are the subject of an application period (e.g. for a licence or permission) within the deadline defined, is the issue automatically resolved to the benefit of the citizen/entity?

6. Is the procedure for the provision of such items organised in such a way as to minimise the number of contacts citizens need to have with the organisation or other organisations (one-stop shop)?

7. Are there multiple locations at which such items may be secured (e.g. different branches of the same institution, post office, etc.) or does one office have a monopoly?

E. Record keeping

1. Does the organisation have clear rules for the management of records and files?

2. Are individual decisions of the organisation recorded and filed according to clear rules and for a clearly defined and binding minimum period?

3. Who has access to these files, and who is authorised to amend them or review them?

4. What degree of freedom of information exists with respect to the institution’s files and documentation, both in terms of which decisions/files/documents are made public automatically (and how), and which ones are available on request? To what extent is such access guaranteed in practice?

F. Transparency

1. Does the organisation have a formal policy or rules on the automatic dissemination of information? Does this include an automatic provision on the website of the following:

a. organisational structure of the organisation and contact persons

b. organisation policies and policy documents

c. laws and sub-legal acts

d. draft laws and regulations

e. procedures of relevance to citizens and legal entities

G. Access to information

1. Does the organisation have an official clearly designated process for responding to requests for information filed under the relevant legislation?

2. How many requests were filed last year?

3. How many requests were refused or are currently in dispute?

H. Ethics and integrity framework

1. Does the organisation have its own specific code of conduct or code of ethics?

2. Are staff informed about the existence of the code when assuming their position?

3. How often do staff receive training on ethics and integrity?

4. Are staff familiar with the code? What steps are taken to ensure this?

5. Are there, either in such a code or in guidelines or other regulations or staff rules, provisions that instruct staff on how to proceed in situations where they find themselves subject to a conflict of interest?

I. Accountability mechanisms

1. Do staff members have clearly defined work procedures and routines for reporting to superiors – either on a periodic basis (e.g. weekly staff meeting) and on particular decisions or activities?

2. Is there an internal inspection or control department?

3. Approximately how many inspections/controls did the department carry out last year?

4. Is there an internal audit department?

5. What were the most important findings of the department last year?

6. How often is the organisation assessed by an external inspectorate or control body?

7. How often is the organisation audited by an external audit body?

8. Were there any important findings on the organisation by such external bodies last year (or at the last assessment)?

J. Internal alerts of integrity breaches

1. Is there a formal procedure by which staff members may notify a designated official or unit of the organisation of suspected breaches of integrity or contravention of the code of conduct within the organisation?

2. Are staff informed through training of these procedures and the official/unit to whom they should file complaints?

3. Are there any mechanisms in place to protect those who file such notifications from retaliation?

4. How many cases of such notifications by staff have there been in the last 12 months, and what was the outcome of these notifications for both sides involved (the official notifying, and the subject of the notification)?

K. Complaint mechanisms

1. Is there a facilitator for integrity reporting?

2. Are there clear procedures by which citizens and public officials may file complaints against actions of the organisation or its officials? Where can these procedures be found?

3. Are decisions on complaints taken by the same person or unit in the organisation at which the complaint was directed?

4. How many complaints did the organisation receive last year?

5. How many complaints were upheld as well-founded?

L. Disciplinary procedures and sanctions

1. How many disciplinary proceedings were conducted against the organisation’s staff last year in connection with breaches of ethics rules?

2. How many of these proceedings resulted in sanctions being applied?

3. What was the breakdown in sanctions applied (number of cases for each type of sanction)?

M. Vulnerable areas

1. Can you identify which areas of the organisation or its activities are most vulnerable to misconduct?

2. Has a risk analysis been conducted on the organisation to identify areas vulnerable to misconduct?