Review of Lithuania’s National Agenda on the Prevention of Corruption

Executive summary

Lithuania has strengthened its public integrity system over the past decades. The National Agenda on the Prevention of Corruption (NAPC) 2022-2033 is at the backbone of these efforts. Supporting the Government’s vision to reduce corruption and increase transparency and openness in the public and private sectors, the NAPC promotes a whole-of society and whole-of-government approach to anti-corruption, while addressing at-risk priority areas. Nonetheless, there is a need to continue and build on its strategic approach. This includes ensuring that the National Agenda on the Prevention of Corruption (NAPC) 2022-2033 is underpinned by a coherent theory of change articulating a clear vision, explaining envisaged outcomes, objectives and how planned activities will contribute to the achievement of that vision. In this context, this Report assesses the 2015-2025 National Agenda on the Prevention of Corruption (NAPC) in several priority areas and provides key recommendations for the next implementation period.

Key findings

In line with the 2017 OECD Recommendation on Public Integrity, the 2015-2025 NAPC identified and consolidated integrity policies using a risk-based approach. Most notably, it set out eight at-risk priority areas in which corruption was thought to be most likely to occur. Distilling the lessons from the previous NAPC, the 2022-2033 NAPC was developed to anchor Lithuania’s anti-corruption and integrity efforts following international best practices.

The OECD assessment of the 2015-2025 NAPC and the development process of the 2022-2033 NAPC revealed both challenges and opportunities for future agendas:

• The NAPC lacked support from leadership to implement some reforms. As a result, ethics officers have limited capacity to promote integrity policies throughout the public administration.

• Several legislative changes were intended to compel public bodies to strengthen their internal integrity management systems introducing general anti-corruption preventive measures. However, implementation remains low and there is a lack of publicly available information about steps taken by public entities to prevent corruption.

• Despite recent efforts to increase transparency in political finance, data indicates that Lithuanians are among the Europeans most likely to perceive that links between businesses and politicians generate corruption.

• There is no centralised and up-to-date guidance for ethics officers on the prevention and management of conflict-of-interest situations. While the Chief Official Ethics Commission (COEC) provides guidance to ethics officers, these communications are rather dispersed and sporadic.

• Although progress has been made to improve the framework conditions to encourage whistleblowing, the application of whistleblower protection is considered to be “still at an early stage”. More efforts are needed to instill a culture of integrity, where public sector employees, the private sector and citizens trust the existing reporting channels.

• The inconsistent application of integrity measures at the subnational level has resulted in weak accountability mechanisms and control and audit systems that lack independence.

• The development of the 2022-2033 NAPC lacked a stringent “theory of change” supported by a robust diagnosis in thematic areas that could help explain how planned activities will contribute to the NAPC’s strategic objectives.

• Despite recent efforts to improve and systematise the consultation process for the development of the 2022-2033 NAPC, private sector, civil society and local government organisation stressed that their participation was merely formal and that many of their inputs were not taken into consideration.

Key recommendations

To address the challenges identified, the report provides the following concrete recommendations to support the government of Lithuania in developing and improving integrity measures in key strategic sectors.

• Public institutions and their leadership must increase ownership of integrity measures and mainstream these across their sectors and entities.

• Increase communication and feedback to ethics officers in key agencies and line ministries to mainstream integrity strategies.

• Strengthen corruption risk analysis and the measurement of resilience to corruption to inform integrity management systems.

• Increase data availability on political finance to promote openness and enable the analysis by citizens, journalists and CSOs. Furthermore, consider developing training programmes for journalists, businesses and civil society groups on the use of the “Political Parties and Political Campaign Financing Control Subsystem”, a digital platform developed by Lithuania’s Central Electoral Commission for the electronic reporting of financial information on the funding of political campaigns.

• Provide public servants, including parliamentarians, with further guidance on conflict-of-interest definitions, regulations and their applicability. This includes establishing internal channels of consultation that provide an alternative to a public servant’s direct superior. Similarly, work with ethics officers on emerging challenges and ways to address and manage them.

• Strengthen whistleblower protection by measuring the effectiveness of recently passed measures, providing training on the evaluation of reports, and raising awareness about the use of internal reporting channels.

• Consider measures to increase the independence of subnational enforcement and oversight systems to address corruption and improve access to information at the local level.

• Identify targets and envisaged outcomes in the 2022-2033 Action Plans, all aligned with the desired results of a previously established “theory of change”.

• Widen the group of stakeholders consulted for the 2022-2033 Action Plans and provide feedback on the inclusion of their suggestions.