National Anti-Corruption Strategy Discussion Document · Anti-Corruption Initiatives in South...
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National Anti-Corruption StrategyDiscussion Document
DISCUSSION DOCUMENTTowards a National Anti-Corruption Strategy
for South Africa
This document re�ects the inclusion of some of the comments and recommendations made during the initial consultations in
September and October 2016
December 2016
National Anti-Corruption Strategy Discussion Document
Published in the Republic of South Africa, 2016
This discussion document was commissioned by the Steering Committee responsible for the development of
a National Anti-Corruption Strategy (NACS), as part of the South African Government’s anti-corruption
programmes. The work towards the development of a resilient anti-corruption system, as envisioned by the
National Development Plan, was done under the guidance of the Anti-Corruption Inter-Ministerial
Committee (ACIMC).
NACS Steering Committee members : Department of Cooperative Governance (DCoG)
Department of Public Service and Administration (DPSA)
Department of Planning, Monitoring and Evaluation (DPME)
Government Communication and Information System (GCIS)
O�ce of the Public Service Commission (PSC)
National Intelligence Coordinating Committee (NICOC)
South African Local Government Association (SALGA)
State Security Agency (SSA)
Technical assistance : Deutsche Gesellschaft für Internationale
Zusammenarbeit (GIZ1)
Researched and compiled by : Public A�airs Research Institute
Distributed by : Government Communications (GCIS)
Private Bag X745, Pretoria, 0001
Street address: Tshedimosetso House
1035 cnr Frances Baard and Festival streets
Hat�eld
PRETORIA
Tel: (012) 473 0000
Fax: (012) 325 2030
E-mail: [email protected]
Design & layout : SSA Reprographic Unit
1 The GIZ is a federal enterprise specialising in the �eld of international cooperation for sustainable development, with the German Federal Ministry for Economic Cooperation and Development (BMZ) as its main commissioning party. The GIZ has provided ongoing support to the South African government through bilateral cooperation since 1993. The Governance Support Programme (GSP) was established through a bilateral agreement between South Africa and Germany. The GSP aims, among other things, to strengthen the capacity of state institutions and their cooperation with the private sector and civil society.
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ContentsGlossary of key terms used in the document List of abbreviations and acronyms
Introduction 1
PART A : Background 21. Process for developing proposals for the strategy 22. Next steps: roadmap for developing a �nal strategy 23. Policy context 24. Role players and stakeholders 55. Challenge 8
PART B : Proposals for a national anti-corruption strategy 171. Rationale for a national anti-corruption strategy 172. Vision 173. Objectives 184. Conceptual framework 185. Strategic pillars and programmes 19
Pillar 1 : Support citizen empowerment in the �ght against corruption 21Pillar 2 : Develop sustainable partnerships with stakeholders 22Pillar 3 : Improve transparency 23Pillar 4 : Improve the integrity of the public procurement system 24Pillar 5 : Professionalisation 25Pillar 6 : Improve adherence to integrity management and anti-corruption mechanisms and improved consequence management for non-compliance 26Pillar 7 : Strengthen oversight mechanisms 27Pillar 8 : Strengthen the resourcing, cooperation and independence of dedicated anti-corruption agencies 28Pillar 9 : Vulnerable sector management 29
6. Institutional mechanisms to implement the strategy 30
Appendices 31Appendix A : Roadmap for developing a �nal national anti-corruption strategy 31
Purpose 31Proposed Process 31Phase 1 : Research, Initial Consultation And Drafting 32Phase 2 : Public Consultations 33Phase 3 : Finalisation of the NACS 35
Appendix B : Summary of Programme Elements under each Strategic Pillar 36Appendix C : United Nations Guidelines On Developing National Anti-Corruption Strategies 37
National Anti-Corruption StrategyDiscussion Document
GLOSSARY OF KEY TERMS USED IN THE DOCUMENT
Accountability: is understood as the acknowledgment and assumption of responsibility for actions and decisions, and being answerable to a person or group of people (such as Government being answerable to citizens, a �rm being answerable to a regulator, a non-governmental organisation being answerable to donors).
Business sector: refers to private sector �rms in the formal and informal sector, as well as organised business, including their employees and members of the Board.
Civil society sector: refers to non-governmental organisations outside the business sector, inclusive of organised labour, community-based organisations, religious bodies, social movements, the media, academia, professional bodies and non-pro�t organisations (NPOs).
Corruption: According to South Africa’s Prevention and Combating of Corrupt Activities Act (PRECCA), Act 12 of 2004 corruption occurs when any person directly or indirectly accepts or o�ers (or agrees to o�er or accept) any form of grati�cation (i.e. not necessarily monetary) that will either bene�t themselves or another person. In terms of this legislation, corruption is de�ned as acts that involve an improper/corrupt exchange between two or more parties. In South Africa, as in many other countries, there is some debate about the de�nition of corruption. For the purposes of this document, the de�nition of corruption includes the acts de�ned as corrupt under the PRECCA, and is broadened slightly to include the concept of “abuse of entrusted power or authority for private gain” that does not have to involve more than one party (for example, theft of public monies where there is only one witting party to this theft).
Government or public sector: includes employees and elected and nominated o�cials in all three spheres of government (including those of state-owned and state-controlled entities).
Local government: includes employees of local municipalities, local government agencies and councillors.
Professionalise: refers to the orientation and skills set of employees. A professionalised sector is one in which its employees see their commitment �rst and foremost to the citizens of the country, according to the values and requirements of the Constitution of the Republic of South Africa and to implementing policies/services/products in the interest of social and economic transformation,
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and not to private or party interests where these deviate from formal policy. Further, it incorporates a vision in which employees have the necessary skills and experience to undertake their work.
Provincial and national government: covers employees and executive authorities of national and provincial departments and entities.
Public service: refers to employees of national and provincial departments and entities as de�ned in the Public Service Act.
Transparency: refers to an organisation or individual operating and providing information in such a way that it is easy for others to see what actions are performed and to enable relevant groups of people to hold the organisation/sector/leader accountable for their actions, including whether due process has been followed.
Vulnerable sector or high-risk sector: refers to an area, sector and/or institution with a high risk or speci�c vulnerability to the manifestation of corrupt practices or activities. This extends to business/private industries or sectors (e.g. mining or construction), or institutions inclusive oforgans of state (e.g. departments, institutions, state-owned entities or municipalities) or large-scale projects (e.g. infrastructure development) at risk of being targeted by actors or facilitators (both domestic or foreign) of corrupt practices, or that could be at risk due to their position or involvement in procurement or decision-making processes (e.g. regulatory or compliance monitoring functions, procurement, investigative, judicial) and/or that could place the development of the country or functioning of government systems at risk or make it vulnerable to exploitation.
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LIST OF ABBREVIATIONS AND ACRONYMS
ACIMC Anti-Corruption Inter-Ministerial CommitteeACTT Anti-Corruption Task TeamAEPF Anti-Intimidation and Ethical Practices ForumAFU Asset Forfeiture UnitAGSA Auditor-General of South AfricaANC African National CongressAU African UnionBAC Business against CrimeB-BBEE Broad-Based Black Economic EmpowermentBEE Black Economic EmpowermentBUSA Business Unity South AfricaCEO Chief Executive O�cerCPI Corruption Perceptions IndexDBE Department of Basic EducationDCoG Department of Cooperative GovernanceDPCI Directorate of Priority Crime InvestigationDPLG Department of Provincial and Local GovernmentDPME Department of Planning, Monitoring and EvaluationDPSA Department of Public Service and AdministrationDTI Department of Trade and IndustryEA Executive AuthorityEthicsSA Ethics Institute of South AfricaFATF Financial Action Task ForceFIC Financial Intelligence CentreGCIS Government Communication and Information SystemGIZ Deutsche Gesellschaft für Internationale ZusammenarbeitHR Human Resource ManagementHSRC Human Sciences Research Council IGI Inspector-General of IntelligenceIPID Independent Police Investigative DirectorateJCPS Justice Crime Prevention and Security ClusterMEC Member of the Executive CommitteeMFMA Municipal Finance Management ActMPAT Management Performance Assessment ToolMPS Municipal Police ServicesMTSF Medium Term Strategic Framework
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NACF National Anti-Corruption ForumNACS National Anti-Corruption Strategy NDP National Development PlanNEOF National Ethics O�cers Forum NICOC National Intelligence Coordinating CommitteeNPA National Prosecuting AuthorityNPC National Planning CommissionNGO Non-governmental organisationOCPO O�ce of the Chief Procurement O�cerOECD Organisation for Economic Cooperation and DevelopmentPAIA Promotion of Access to Information ActPAJA Promotion of Administrative Justice ActPARI Public A�airs Research InstitutePFMA Public Finance Management ActPRECCA Prevention and Combating of Corrupt Activities ActPSC Public Service CommissionRSA Republic of South AfricaSADC Southern African Development CommunitySALGA South African Local Government AssociationSANDF South African National Defence ForceSAPS South African Police ServiceSARS South African Revenue ServiceSCM Supply chain managementSCOPA Parliament’s Standing Committee on Public AccountsSIU Special Investigating UnitSMS Senior Management ServiceSOE State-owned enterprise / state-owned entitySSA State Security AgencyTAU Technical Assistance Unit (of the National Treasury)UNCAC United Nations Convention against CorruptionTAU Technical Assistance Unit (of the National Treasury)UNCAC United Nations Convention against Corruption
National Anti-Corruption Strategy Discussion Document1
INTRODUCTIONThe Government’s commitment to reduce corruption in South Africa is articulated in the Medium Term Strategic Framework (MTSF) 2014–2019, the National Development Plan (NDP), and the National Security Strategy (NSS). The MTSF 2014-2019 requires the development of a National Anti-Corruption Strategy (NACS) and a supporting implementation plan.
This document outlines proposals for a National Anti-Corruption Strategy. As noted in the National Development Plan, tackling corruption involves commitments from all members and sectors of society. A national strategy should serve as a guide for developing a set of shared commitments across sectors, to support collaboration within and between sectors, and to direct renewed energy towards the goal of reducing corruption and building an ethical society.
The document is divided into two parts:
• Part A provides background to the development of the strategy: it outlines the process followed up until now to develop proposals for a national strategy. It details a roadmap that will ensure that the process for developing the �nal strategy is inclusive and transparent, and developed with substantial contributions of leaders from government, business and civil society. Part A concludes with a summary of the challenges facing the country: the current manifestations of corruption in South Africa; the foundations on which further anti-corruption e�orts can be built; and the issues the strategy should aim to tackle.• Part B outlines proposals for inclusion in a strategy: outlining a vision, objectives, strategic pillars and programmes for the strategy.
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2 A summary of the review is contained in this document. The full review is covered in the document, ‘Diagnostic Review and Situational Analysis: Corruption and Anti-Corruption Initiatives in South Africa’, May 2016.
PART A: Background
1. Process for developing proposals for the strategyThe proposals for a National Anti-Corruption Strategy contained in this document are based on:
• A thorough situational review of corruption and anti-corruption initiatives to date2. • Consultations undertaken with stakeholders in government, business, civil society and academia.• The scrutiny of relevant national policy that articulates government commitments and plans for reducing corruption, such as the National Development Plan; the Medium Term Strategic Framework (2014-2019); and documents outlining the programmes of the Anti-Corruption Task Team (ACTT) and the National Anti-Corruption Forum (NACF).• Readings of international guides for developing anticorruption strategies, including the United Nations document, ‘National Anti-Corruption Strategies: A Practical Guide for Development and Implementation’ (2014).• Academic literature in the area of institutional change, corruption and related fields.
2. Next steps: Roadmap for developing a �nal strategyA roadmap outlining the process for developing a �nal National Anti-Corruption Strategy is proposed. Appendix A of this document contains more details in this regard.
The roadmap was developed to meet the following goals:
• Achieve a “whole of government and society” approach in the fight against corruption.• Be open, transparent and inclusive of all sectors of South African society.• Arrive at a robust National Anti-Corruption Strategy that has buy-in from Government, business and civil society.• Foster ownership of the process and the resulting National Anti-Corruption Strategy by all sectors.
3. Policy contextThe Constitution of the Republic of South Africa, Act 108 of 1996 (the Constitution) and a range of statutory provisions and speci�c legislation provide the broad framework and founding principles for anti-corruption work in South Africa.
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3 The King Committee on Corporate Governance has already issued four King Reports that provide guidelines for the governance structures and operation of companies in South Africa, setting out what ethical and e�ective leadership entails. The reports are referred to as: King I (issued in 1994), King II (issued in 2002), King III (issued in 2009) and the most recent revision King IV (issued in 2016).
Recognition of the rule of law, and the accountability and transparency of Government, are founding principles of the Constitution, which also provides for the establishment of oversight bodies that play a role in supporting accountability and transparency of the public and private sectors. Various pieces of legislation have been developed to give greater legal e�ect to the principles of accountability and transparency contained in the Constitution.
The King Code3 of Governance Principles in South Africa has relevance for reducing corrupt practices by members of the private sector and state-owned as well as state-controlled entities, as does Business Unity South Africa’s Code of Good Corporate Citizenship.
Recommendations for reducing corruption in the private sector, as provided by the Organisation for Economic Cooperation and Development, have been incorporated into Regulation 43 of the South African Companies Act, Act 71 of 2008.
South Africa is a signatory to various international conventions and treaties that commit the country to implementing a range of interventions aimed at reducing corruption. These conventions include the United National Convention Against Corruption (2003), the Organisation for Economic Cooperation and Development Convention on Combating Bribery of Foreign Public O�cials in International Business Transactions (1997), the African Union Convention on Preventing and Combating Corruption (2003), the Southern African Development Community Protocol against Corruption (2001), and the United Nations Convention against Transnational Organised Crime (2000) and its associated Protocols. Further, South Africa is an active participant in relevant intergovernmental bodies and forums, such as the Group of 20’s (G20’s) Anti-Corruption Working Group and the Financial Action Task Force (FATF), and is implementing various FATF recommendations.
Policy proposals for reducing corruption and improving accountability and transparency of the public and private sectors are articulated in the National Development Plan. The National Development Plan contains proposals for building a resilient anti-corruption system through strengthening the protection of whistle-blowers; developing greater central oversight over the awarding of large tenders or tenders with long duration; and empowering the tender compliance monitoring o�ce (now the Chief Procurement O�cer) to investigate corruption and the monetary value of tenders. It also outlines proposals for strengthening the accountability and responsibility of public servants as well as judicial governance and the rule of law.
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Improved resources for a revitalised National Anti-Corruption Forum are also recommended, as well as calls for commitments by the various sectors to ensure that the Forum is e�ective. Several National Development Plan recommendations on building the capacity of the State are also relevant for anti-corruption initiatives, including proposals regarding the professionalisation of the public service; strengthening delegation, accountability and oversight in the public sector; and improving governance of state-owned and state-controlled entities.
Government outlined several goals and indicators with relevance to reducing corruption in the latest Medium Term Strategic Framework (2014-2019). A number of these priorities are drawn directly from the National Development Plan:
• Under the outcome, “All South Africans are, and feel, safe” the strategy targets “an improvement in South Africa’s ranking on the Transparency International Corruption Perception Index”; and notes that Government will prioritise “coordinated initiatives to make the criminal justice system more efficient and effective”. Government further commits to improving conviction rates for serious corruption cases. The strategy also noted that revisions are needed for legislation “to provide for more stringent penalties [for corruption-related crimes], to protect whistle-blowers including those in the private sector, and to strengthen the independence of anti-corruption agencies to insulate them from political pressure”.• Under the outcome, “Responsive, accountable, effective and efficient local government”, the strategy notes a decline in public trust in municipalities owing to “weak leadership or political interference in operations, vacancies in critical posts, poor �nancial management, lack of transparency and accountability, and weak and ine�ective platforms for public participation and communication with communities”. It aims to promote citizen participation in local government processes and to improve skills development and capacity building, focusing on improving “the quality of municipal administrative and management practices including human resources and recruitment practices, supply chain and �nancial management, and anti-corruption initiatives”.• Under the outcome, “An efficient, effective and development-oriented public service”, the strategy sets goals for “institutionalising long-term planning, forging a disciplined, people-centred and professional public service, [and] empowering citizens to play a greater role in development and building an ethical public service”. The document outlines a central role for the Chief Procurement Officer in strengthening oversight of procurement processes and pricing to ensure “cost-effectiveness and transparency, better value for money, and adherence to procedures and fairness”. It also notes that, “as part of steps to promote an
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4 In July 2010 the Justice, Crime Prevention and Security Cluster was tasked with the establishment of a task team to fast-track investigations and prosecution. The Anti- Corruption Task Team was formed in October 2010 to give e�ect to this, aimed at a multi-disciplinary and integrated operational approach based on the mandate of the South African Police Service Directorate for Priority Crime Investigation.
ethical public service, measures will be introduced to prevent public servants from doing business with the state, as set out in the election manifesto. These will be supported by improved implementation of the Financial Disclosure Framework, strengthened protection of whistle-blowers, and the provision of technical assistance to departments for the e�ective management of discipline.”
4. Role players and stakeholdersPoliticians are elected representatives to champion the interests of the public. They are obliged to uphold the Constitution, especially the principles of transparency and accountability. Their contribution towards the development of a National Anti-Corruption Strategy is therefore both necessary and critical.
The Anti-Corruption Inter-Ministerial Committee (ACIMC) was established in June 2014 and is mandated to coordinate and oversee the work of state organs aimed at combating corruption in the public and private sectors. The Committee is convened and chaired by the Minister for Planning, Monitoring and Evaluation in the Presidency, and comprises the Ministers of Justice and Correctional Services, State Security, Police, Cooperative Governance and Traditional A�airs, Public Service and Administration, Finance, Home A�airs and Social Development. The Committee also provides strategic direction for the operational activities of the multi-agency Anti-Corruption Task Team.4
In 2014 the Anti-Corruption Inter-Ministerial Committee expanded the role of the Anti-Corruption Task Team, which is the central body mandated to give e�ect to Government’s anti-corruption agenda. Guided by the Anti-Corruption Inter-Ministerial Committee and Anti-Corruption Task Team Executive Committee, this collective of government stakeholders is mandated to implement Government’s anti-corruption agenda and programmes. The task team currently consists of representatives from the National Prosecuting Authority, the Asset Forfeiture Unit, the Directorate for Priority Crime Investigation (“Hawks”) in the South African Police Service, the Special Investigating Unit, the South African Revenue Service, the O�ce of the Accountant-General and the Chief Procurement O�cer in the National Treasury, the Financial Intelligence Centre, the National Intelligence Coordinating Committee, the State Security Agency, the Presidency, the Department of Justice and Constitutional Development, the Department of Public Service and Administration, and the Government Communication and Information System.
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Other government organisations playing a role in the anti-corruption landscape include the Auditor-General of South Africa (Auditor-General) and the Department of Cooperative Governance, in the case of local government. These departments work with the Anti-Corruption Task Team on speci�c programmes.
Important oversight bodies include the Public Service Commission (mandated to provide oversight of the public service); the Public Protector (investigating and redressing maladministration and abuse of power in state a�airs); the Independent Police Investigative Directorate (mandated to provide oversight of policing); the Inspector-General of Intelligence (oversight of intelligence services); and committees tasked with executive and government oversight in Parliament, the provincial legislatures and local government councils.
The Competition Commission plays a role in combating corruption through its work in investigating and regulating against private sector collusion: certain collusive practices are de�ned as corrupt in terms of the Prevention and Combating of Corrupt Activities Act.
The National Anti-Corruption Forum, a coalition formed by the public, business and civil society sectors, was established in 2001 with the aim of driving the national anti-corruption campaign. Its mandate is to contribute towards the establishment of a national consensus through the coordination of sectoral strategies against corruption, to advise Government on the implementation of strategies to combat corruption, to share information and good practice on sectoral anti-corruption work and to advise sectors on the improvement of sectoral anti-corruption strategies. It comprises various representatives of Government, the civil society sector, including trade unions, and the business sector.
Several bodies in the business sector have been active in anti-corruption work. These include those representing organised business, professional associations, and networks and forums set up to undertake anti-corruption work in the sector, or in partnership with Government to address corruption as it manifests more broadly in society.
A number of other civil society organisations play a role in monitoring the use or abuse of state resources, transparency and access to information, governance of organisations and instances of possible illegal activity. Some of these organisations also run campaigns to raise awareness of the damaging e�ects of engaging in corrupt activity. Corruption Watch was established in 2012 with the sole purpose of �ghting corruption and is the accredited chapter of Transparency Internation
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al in South Africa. Corruption Watch �ghts corruption through public mobilisation, litigation, investigations and research. The media are also important players in exposing corruption, and potential partners in anti-corruption campaigns. Trade unions are well placed to monitor and report corruption in the organisations and business sectors in which they are active. The members of trade unions have an especially important role in blowing the whistle on corruption, both in organisations in which they represent workers, as well as in the respective workplaces, and the unions have a crucial role in supporting e�orts to build whistle-blower protection programmes. The unions are potentially valuable partners in national e�orts to prevent corruption and in future anti-corruption campaigns.
Civil society and non-governmental organisations feature prominently in the detection of, and reporting on corruption as it manifests in the broader society. They also play a key role in educating and representing particular constituents and remain a powerful mechanism to promote positive behaviour. Some of these organisations and emerging social movements are vital in mobilising people around rights (such as access to information) and demanding transparency and accountability for organs of state. Corruption however also manifests within this sector, given that many people who work in the sector are economically vulnerable, making it di�cult for them to blow the whistle on corruption in their own sectors. In addition to the promotion of general reporting of corruption by citizens and their empowerment to do this, leaders in the civil society sector can play a key role to support greater integrity within the sector itself by subjecting themselves to the same stringent standards demanded from both business and the public sector.
Lastly, the individual South African citizen’s awareness and participation, either through joining public campaigns or blowing the whistle on suspected cases of corruption, are crucial in national anti-corruption e�orts. To play this role, ordinary members of the public should be able to recognise corrupt behaviour and feel empowered to take a stand against it, for example, by bringing it to the attention of the relevant authorities. Whistle-blowing should be promoted and encouraged by publicising stories of successful prosecutions as a result of information provided by whistle-blowers, as well as reporting on the e�ective protection of such persons from any form of harm or victimisation. Further, the citizenry can provide pressure for improved accountability and transparency in various sectors in South Africa. The proposed National Anti-Corruption Strategy should empower more citizens to play an active role in reducing corruption.
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5 Van Vuuren, H. 2006. ‘Apartheid grand corruption: assessing the scale of crimes of pro�t in South Africa from 1976 to 1994’. Institute of Security Studies, Pretoria, commissioned by the civil society representatives of the Second National Anti-Corruption Summit.6 Patronage is generally accepted to mean the power to control appointments to o�ce or the right to privileges, but is also used in this context as synonymous with favouritism, nepotism, partisanship, partiality, preferential treatment and “the old boy network”.7 Posel, D. 1999. ‘Whiteness and Power in the South African Civil Service: Paradoxes of the Apartheid State.’ In Journal of Southern African Studies 25 (1): 99–119.8 O’Meara, D. 1996. Forty Lost Years: The Apartheid State and the Politics of the National Party, 1948-1994. Randburg: Ravan Press.9 Peires, J.B. 1992. ‘The Implosion of the Transkei and Ciskei.’ In African A�airs, 91: 365–87’.10 Hyslop, J. 2005. ‘Political Corruption: Before and after Apartheid’. In Journal of Southern African Studies, 31(4): 773–789.11 Van Vuuren, ‘Apartheid grand corruption: assessing the scale of crimes of pro�t in South Africa from 1976 to 1994’.
5. ChallengeCorruption undermines the values of the Constitution and progress towards greater social and economic transformation as well as democratic processes. It not only results in the loss of state revenue for economic and social development and service delivery, but also erodes the capacity and legitimacy of the State.
Under National Party rule, a form of capitalism developed that blurred the boundaries between party, private capital and the State. A report commissioned by the National Anti-Corruption Forum details examples of entrenched corruption that was observed and prevalent under the previous dispensation.5 Academics have described patronage6 in the appointment of people to the public sector7 and in the development of white, and in particular Afrikaner, capital.8 Furthermore, parts of the homeland administrations were ruled through patrimonial networks that extended from the central apartheid state to local chiefs and public servants.9 By the late 1970s and 1980s, as the apartheid state unravelled, fraud, theft and other corrupt activity appear to have grown in the top echelons of the State.10 The state security agencies and police were particularly implicated in corruption, and the climate was ideal for these abuses given the levels of secrecy under which they operated.11 Some of the institutional legacies of this past have interacted with contemporary politics and changes to the structure of society and the state bureaucracy to shape the nature of corruption in South Africa today.
Corruption is usually a hidden phenomenon and attempts to determine its current prevalence are therefore di�cult. However, research on perceptions of corruption, experiences of corruption and related crimes, and compliance with legislation aimed at improving accountability and reducing corruption can provide an indication of the nature of the problem to be tackled.
Assessments of public perceptions over the last 15 years show that citizens feel that corruption has increased. Although a rough indicator of corruption in the country, these perceptions are important pointers in terms of the level of trust between the State and citizens. A report issued by the Human Sciences Research Council that used data from the South African Social Attitudes Survey indicated that the vast majority of those surveyed in 2011 (91%) believe that corruption is a serious problem in South Africa.
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12 Human Sciences Research Council (HSRC). 2012. ‘Business Unusual: Perceptions of Corruption in South Africa’ In HSRC Review, Vol 10 (2), Human Sciences Research Council, Pretoria.13 Afrobarometer. 2016. ‘Summary of Results. Round 6 Survey in South Africa.’ Available at www.afrobarometer.org14 “The Corruption Perceptions Index (CPI) ranks countries and territories based on how corrupt their public sector is perceived to be. It is a composite index – a combination of polls – drawing on corruption-related data collected by a variety of reputable institutions. The CPI re�ects the views of observers from around the world, including experts living and working in the countries and territories evaluated.” Source: http://www.transparency.org/cpi2013/in_detail#myAnchor2 (accessed May 2016).15 See Transparency International. 2015. ‘Exporting Corruption: Assessing Enforcement of the OECD Convention on Combating Foreign Bribery’, results per country posted on the Transparency International website: http://www.transparency.org/exporting_corruption (accessed April 2016); HSRC, ‘Business Unusual: Perceptions of Corruption in South Africa.’; Afrobarometer, ‘Summary of Results. Round 6 Survey in South Africa.’; National Victims of Crime Survey, cited in Bruce, D. 2014. ‘Counting the covert: Using data to understand corruption in South Africa’. ISS Monograph No. 198, Institute of Security Studies, Pretoria.16 Newham, G. and Faull, A. 2011. ‘Protector or predator? Tackling police corruption in South Africa.’ ISS Monograph, Institute of Security Studies, Pretoria.
In 2003, 9% of respondents put corruption in the top three most serious national challenges, which increased to 26% in 2011.12 In the latest Afrobarometer survey, undertaken in 2015, 64% of the respondents stated that they felt that corruption had increased signi�cantly over the last year, and 19% felt that it had increased slightly.13
Transparency International’s 2015 global Corruptions Perception Index currently scores South Africa at 44, down from the past high of 51 in 2007. (A score of 0 means a country is considered “very corrupt”, and a score of 100 means a country is considered “very clean”.) South Africa’s ranking compared to other countries in terms of the Corruption Perception Index has also deteriorated, dropping 29 places in the global perceptions ranking since 2001. (The higher the ranking of a country, the “cleaner” it is considered to be.)14
A range of surveys, among others the National Victims of Crime Survey, Human Sciences Research Council’s Quality of Life Survey (2012), the Afrobarometer and Transparency International’s research, suggest that instances of bribery are fairly common in some services in which the public interfaces with government o�cials. This is the case in tra�c policing and, to a lesser extent, in home a�airs, local government and policing.15
In policing, corruption more generally, i.e. not just bribery but also theft, fraud and other forms of corruption, has been described as systemic16, limiting the State’s ability to tackle it and other forms of crime. Immigration and border control are also particularly vulnerable to corruption. Citizens’ experience of these services or sectors is of central importance in shaping public perceptions of corruption in South African society more generally.
The South African Government has developed several strategies, campaigns and frameworks to speci�cally reduce corruption and support ethical practice in the public sector. These include the National Crime Prevention Strategy, 1996; the Batho Pele programme, aimed at supporting an ethical and citizen-orientated public service that was �rst developed in 1997 and relaunched under a dedicated campaign in 2004; the Public Service Anti-Corruption Strategy, 2002, and mechanisms resulting from the strategy, such as the development of guidelines for minimum
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17 See Auditor-General of South Africa (AGSA) consolidated reports on the PFMA and MFMA for the years 2012-2015; and PSC reports in the case of the public service: 2011. ‘Report on Financial Misconduct for the 2009/2010 Financial Year’ (2011); ‘Fact Sheet on Actions Taken by the Executive Authorities with regard to Identi�ed Cases of Potential Con�icts of Interests and Compliance with the Financial Disclosure Framework.’ (2013); ‘Factsheet on Financial Misconduct and the Recovery of Money Lost through Financial Misconduct for the 2013/2014 Financial Year.’ (2015); ‘Assessment of the Handling of Disciplinary Cases in the Public Service.’ (2016).
anti-corruption capacity in public service departments and entities; the development of the Financial Disclosure Framework for managers in the public service; the development of a Public Service Integrity Management Framework; and the Local Government Anti-Corruption Strategy, which was approved in May 2016. Further, some provinces, municipalities and public sector organisations have developed their own anti-corruption strategies.
The Public Service Anti-Corruption Strategy (PSACS) was particularly important for bolstering the legislative framework to �ght corruption, and establishing policies, norms and guidelines for supporting anti-corruption and integrity management work in the public service. The PSACS proposed a review of the legislative framework surrounding corruption, and the consolidation of this framework into a new corruption act. The PSACS also suggested that departments foster a minimum capacity to �ght corruption, and pointed to the need for mechanisms to coordinate the numerous government entities involved in anti-corruption initiatives. The PSACS called for the improvement of management policies and practices related to areas such as the management of employment, discipline, procurement, risk, information and �nances; the establishment of a comprehensive system of professional ethics; as well as greater stakeholder participation. It also suggested that these initiatives should all be underpinned by training and education programmes.
South Africa has developed a fairly comprehensive legislative framework for combating corruption, ranging from the Prevention and Combating of Corrupt Activities Act, through other legislation dealing with �nancial and organised crime, public �nance management and procurement legislation, to legislation promoting the public’s access to information held by the public and private sectors. As mentioned previously, South Africa is also a signatory to several international conventions and treaties. However, the implementation or enforcement of some of these obligations and aligned legislation remains uneven and, in some cases, weak.
A generally clear set of rules and values has been articled for guiding the conduct of public servants and members of the executive. Despite many public servants and politicians being committed to serving the public, compliance with these regulations and codes has been generally weak. This is especially the case in supply chain, human resource management and in compliance with frameworks for disclosing business and other �nancial interests.17 An environment of non-compliance enables corruption and makes it hard to detect.
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18 See Auditor-General of South Africa (AGSA) consolidated reports on the PFMA and MFMA for the years 2012 to 2015.19 Based on Auditor-General reports 2009 to 2013, in Brunette, R. et al. 2014. ‘The Contract State: Outsourcing and Decentralisation in Contemporary South Africa’. Public A�airs Research Institute, Johannesburg.20 Presidential Review Committee on State-Owned Enterprises. 2012. Presidential Review Committee on State-Owned Enterprises: Main Report, Volume 2.’ The Presidency, Pretoria.21 Public Service Commission (PSC). 2013. ‘Fact Sheet on Actions Taken by the Executive Authorities with regard to Identi�ed Cases of Potential Con�icts of Interests and Compliance with the Financial Disclosure Framework.’ PSC, Pretoria.
In national, provincial and local government, the Auditor-General �ndings show rising irregular expenditure (despite an improvement in the number of clean audits) in local government and the public service.18 Between 2009 and 2013, 75% of the total irregular and wasteful expenditure was attributed to the contravention of supply chain management regulations.19 Public procurement is a signi�cant area of potential risk for corruption by public and private sector players in South Africa.
Private sector involvement in corruption remains a concern with many companies still failing to report corrupt activity as a result of the stigma attached to admitting control and governance failures. Corruption in state procurement usually implicates both public and business sector players. Private sector involvement in corruption has taken the form of bribery, locally and in business dealings with other African countries, and fraud in procuring with the State. In addition, the Competition Commission has uncovered practices of collusion in tendering with the State. Another business practice that remains particularly problematic is “fronting” or the deliberate or attempted circumvention of the B-BBEE Act, Act 53 of 2003 and the related codes.
Data on the integrity and compliance with relevant legislation in state-owned entities remains scanty. Scandals in several large state-owned entities around board and management instability, and procurement and appointment irregularities, are however a cause for concern, especially in view of the substantial procurement budget of these entities. The Presidential Review Committee on state-owned entities cited the African National Congress’s Committee on Schedule 2 state-owned entities that rising corruption is a problem facing these companies.20
Regulations and codes preventing elected o�cials from doing business with the State, and regulating the conditions under which family members of elected o�cials can do business with the State, are not being adhered to in many cases. Further, public servants and local government employees are not facing appropriate (legislated) sanction for non-compliance. On average, the executive has not ensured compliance with these frameworks and regulations in the public, 21 and oversight structures in municipal councils are not always working e�ectively. Further, monitoring of compliance in the government sector has relied heavily on self-reporting, but has not su�ciently included citizens. Self-reporting has thus far not led to improved compliance, and consideration should be given to improving processes for feedback on corruption to the public, for example interaction and feedback to the community and other interested groups as proposed in the revised Local Government Anti-Corruption Strategy.
National Anti-Corruption StrategyDiscussion Document 12
22 See African Union and the United Nations Economic Commission for Africa. 2015. ‘Illicit Financial Flow: Report of the High Level Panel on Illicit Financial Flows from Africa.’ African Union and the United Nations Economic Commission for Africa Conference of Ministers of Finance, Planning and Economic Development; and the Panama Papers website. The Panama Papers refers to the analysis and presentation of leaked data from the Panama-based law �rm Mossack Fonseca. See: https://panamapapers. icij.org/video/ (accessed April 2016).23 Illegal movement of money or capital from one country to another. 24 Global Financial Integrity. 2016. Data on the Global Financial Integrity website: http://www.g�ntegrty.org/report/illicit-�nancial-�ows-from-developing-countries-2004- 2013/ (accessed April 2016).25 African Union et al, ‘Illicit Financial Flow: Report of the High Level Panel on Illicit Financial Flows from Africa.’26 Economic Justice Network, Financial Transparency Coalition, and the Tax Justice Network. 2016. ‘A month after Panama Papers, South Africa commits to end anonymous companies.’ Joint press release, 6 May 2016.27 Archival Platform. 2015. State of the Archives: An Analysis of South Africa’s National Archival System. Archival Platform, Cape Town.
The recent release of the African Union and the United Nations Economic Commission for Africa report on illicit �nancial �ows from Africa, and the release of the “Panama Papers” by the International Consortium of Investigative Journalists, provide some insight into the extent of monies �owing illegally across borders linked to tax evasion, bribery, illegal arms dealing and �nancial fraud involving politicians, state o�cials, business people and corporates.22 South Africa is ranked seventh in the world in terms of the volume of illicit �nancial �ows from developing and middle-income countries. This �gure is based on the highest average illicit �nancial �ows23 between 2003 and 2014, which was $20,922 billion.24 The African Union report notes that, "Transparency of ownership and control of companies, partnerships, trusts and other legal entities that can hold assets and open bank accounts is critical to the ability to determine where illicit funds are moving and who is moving them.”25 In this regard, at the recent Open Government Partnership Africa Regional Meeting in Cape Town, the South African Government announced an action plan that includes commitments to compile a register of bene�cial ownership of all companies in the country.26
The National Development Plan has noted that the implementation of the Promotion of Access to Information Act 2 of 2000 and the Promotion of Administrative Justice Act 3 of 2000 needs to be improved. Currently, the state of recordkeeping in several government departments and municipalities is poor27, which a�ects citizens’ right to access information and departments’ capacity to support the Promotion of Access to Information Act, Act 2 of 2000 and Administrative Justice Act, Act 3 of 2000.
Improved institutional mechanisms to support whistle-blowers are also needed. As outlined by various reports produced under the United National Convention Against Corruption, providing this protection requires a range of interventions, such as improved systems to provide for appropriate legal aid for whistle-blowers, ensuring that whistle-blowers can report anonymously to the extent possible and that their identities and the information they provide are recorded, stored and used in such a way that this does not unnecessarily increase the risk of harm to the whistle-blower and so forth.
Further e�orts are also required to engage and empower more citizens in the �ght against corruption, through for example awareness-raising campaigns, national debates on the nature of
National Anti-Corruption Strategy Discussion Document13
28 Newham, G. 2016. Interview with Gareth Newham, Institute of Security Studies, 7 April 2016.
corruption, its e�ects on society and the kinds of pressures and institutional factors that enable corruption. Campaigns which provide people with information on their rights in terms of accessing services are also needed: if citizens have good information about the functioning of a particular administrative process, and the rights they have in terms of the expected conduct of a public servant or private sector service provider, they are in a better position to resist requests for bribes, and in a better position to blow the whistle on possible cases of corruption.
Regarding enforcement of legislation regulating the business sector, large companies follow the King Code. The �rst two iterations of the code applied to listed companies and government departments at national, provincial and local levels; the third has been developed so that civil society can incorporate these governance codes into the management of their organisations. King IV was launched in 2016. The King Code is not adequately enforced through domestic legislation, though legislation such as the Companies Act now incorporates some of the aspects covered in the Code.
This has to some degree assisted in improving the transparency of private sector activity. However, notwithstanding the obligation to report corruption and various other o�ences in terms of the Prevention and Combating of Corrupt Activities Act, many companies still fail to report corrupt activity as a result of the stigma attached to admitting control and governance failures. Furthermore, initiatives are needed to bring unlisted and smaller companies into the national dialogue on corruption.
The Prevention and Combating of Corrupt Activities Act has thus far been insu�ciently used to prosecute cases of corruption. Law-enforcement agencies prefer to investigate and prosecute potentially corrupt activities through the use of legislation pertaining to other �nancial crimes or common law o�ences such as fraud, than to investigate or prepare cases based on o�ences listed under the Corrupt Activities Act.28 This appears to be due to the lack of police training on how to develop cases for prosecution under the Act, and the need for training on the Act in the courts, and due to di�culties in proving that bribery took place. Signi�cantly, the enforcement of the Act, and other acts dealing with �nancial and organised crime, are a�ected by the capacity of the criminal justice system and relevant oversight bodies.
Some oversight bodies have developed a public reputation of independence, integrity and capacity, including the Auditor-General, the Financial Intelligence Centre, and the Public Protector.
National Anti-Corruption StrategyDiscussion Document 14
29 National Planning Commission. 2016. ‘The National Development Plan’; Tamukamoyo, H, and Mofana, R. 2013. ‘Is South Africa really complying with the anti-corruption protocols it has rati�ed?’. In ISS Today, 9 July 2013, Institute for Security Studies, Pretoria; Corruption Watch. 2015. ‘Hawks saga: the feather continue to �y’, published on Corruption Watch’s website on the 15 January 2015: http://www.corruptionwatch.org.za/hawks-saga-feathers-continue-to-�y/ (accessed April 2016); Newham, G. 2016. Interview with Gareth Newham, Institute of Security Studies, 7 April 2016; De Vos, P. 2015. ‘Turmoil at the Hawks: A birds eye view of the legalities’, published online on the Daily Maverick, 8 January 2015: http://www.dailymaverick.co.za/opinionista/2015-01-08-turmoil-at-the-hawks-a-birds-eye-view-of-the-legalities/#.Vw0Mc-mKh68 (accessed April 2016).30 Constitutional Court of South Africa. 2011. ‘Case CCT 48/10 [2011] ZACC 6.’ Constitutional Court of South Africa, Johannesburg.31 Constitutional Court of South Africa. 2014. Press release in respect of case CCT 07/14 and CCT 09/14, posted on the Southern African Legal Information Institute: http:// ww.sa�ii.org/za/cases/ZACC/2014/32media.pdf (accessed May 2016).
The Specialised Commercial Crimes Courts have achieved success in prosecuting corruption, the Asset Forfeiture Unit has been successful in seizing assets, and the Special Investigating Unit has successfully pursued cases of corruption.
A central issue of concern raised by civil society organisations and the National Development Plan is that the independence of the criminal justice agencies tasked with investigating and prosecuting corruption has not been e�ectively maintained.29 A 2011 Constitutional Court ruling found that the State has a constitutional obligation to establish and maintain an independent body to combat corruption and organised crime, and that the Directorate for Priority Crime Investigation lacked this structural and operational independence.30 This was rea�rmed in a Constitutional Court ruling in 2014.31 E�ective independence is needed to improve the appetite for pursuing senior politicians, o�cials and business people, and to build public con�dence in Government’s commitment to reduce corruption, as well as to strengthen the rule of law in the country.
South Africa’s anti-corruption system requires adequate safeguards of independence, and adequate resourcing in the form of su�cient budget and the appropriately trained and experienced sta�. Furthermore, improved coordination between the various government agencies tasked with reducing corruption and supporting ethical practice is needed. Speci�cally, mechanisms are required to ensure that representatives of the various bodies on the Anti-Corruption Task Team do not prioritise their own agency work over cross-agency collaboration.
There are also real challenges to collaboration and information-sharing across the government, business and civil society sectors. The National Anti-Corruption Forum (NACF) is no longer meaningfully active, limiting cross-sectoral collaboration in developing anti-corruption mechanisms. Intersectoral collaboration is crucial and proper planning to revitalise this or to constitute a similar intersectoral platform should ensure su�cient institutional capacity and resources (permanent sta� and adequate budget / sectoral contributions) are available to enable meaningful implementation of intersectoral anti-corruption programmes. Given the intersectoral nature of such an organisation, it can play a signi�cant role in the promotion and implementation of a national strategy.
National Anti-Corruption Strategy Discussion Document15
Outside of the conduct of o�cials and employees in their organisational settings across various sectors, improved adherence to certain laws by the public would reduce the room for corruption. For example, greater compliance with tra�c laws by the public potentially provides fewer opportunities for tra�c o�cers to solicit bribes. Conversely, ensuring that the rules of the road are appropriately enforced by tra�c o�cers could increase compliance by road users and reduce the incentives to o�er bribes.
Better data is needed to improve anti-corruption e�orts in South Africa. The data already captured by the State and private sector could be better reported. Data on investigations and convictions of cases involving corruption is inconsistently reported by various crime-�ghting agencies; data on compliance with regulations relevant to corruption is inconsistently collected and reported by government agencies, and not su�ciently consolidated and used to inform risk pro�ling, etc. Further, private sector reporting of corruption remains too low. Improving the collection, reporting and analysis of these kinds of statistics are important for monitoring the State and other sectors’ impact on reducing corruption, and identifying areas of potential or current risk for corruption.
National Anti-Corruption StrategyDiscussion Document 16
In summary, the following major issues should be given consideration in a National Anti-Corruption Strategy:
• The need for efforts to empower citizens in the fight against corruption through awareness-raising campaigns, campaigns on citizens’ rights in terms of administrative process and improved whistle-blower protection.• Building ethical leadership across government, business and civil society sectors.• Building a professional public sector orientated towards serving citizens and implementing policy.• Improving adherence to anti-corruption and integrity management regulations and other regulations with relevance for anti-corruption, and ensuring improved consequence management for non-compliance with these regulations and codes of conduct across sectors.• Improving transparency of activity and use of resources in the government, business and civil society sectors.• Improving the transparency and accountability of the public procurement system to ensure fair, effective and efficient use of public resources.• Improving the collection, reporting, analysis and use of data relevant to anti-corruption work.• Developing or strengthening programmes aimed at tackling corruption in sectors particularly vulnerable to corruption.• Strengthening the capacity of government organisations tasked with combating corruption and providing oversight of government’s work through adequate resourcing and strengthened independence.• Ensuring personnel in organisations tasked with anti-corruption and integrity management work have the necessary training and organisational support to undertake their work.• Improving platforms for cooperation between the various anti-corruption bodies.• Strengthening stakeholder partnerships to support anti-corruption work across sectors.
South Africa can build on progress already made. This includes generally robust legislation for �ghting corruption; some very strong investigative skills in senior police ranks in South Africa; Chapter 9 and 10 institutions committed to promoting integrity in public and private sectors; a generally clear set of rules and values for guiding the conduct of government employees and members of the executive in the government sector; organised business and civil society having shown earlier commitments to collaborating on anti-corruption e�orts which can be revived; and South Africa having a free media and active civil society to support e�orts to build accountability.
At this point there is a need to develop a comprehensive strategy that can establish an integrated approach to support improved coordination between the numerous role players in the �ght against corruption, and to tackle the systemic causes of corruption in the country.
National Anti-Corruption Strategy Discussion Document17
Part B: Proposals for a national anti-corruption strategy
1. Rationale for a national anti-corruption strategyThe National Anti-Corruption Strategy is intended to serve as a guide for Government, the business sector and civil society organisations, to help coordinate and support their e�orts to reduce corruption. The strategy therefore provides a set of strategic pillars and programmes around which sectors, organisations and other forums within these sectors can direct and attempt to align their work. It also provides a tool for citizens and others to monitor South Africa’s progress in achieving a substantial reduction in corruption in the country.
Several state organisations and spheres of government, and organisations or representative bodies in the business and civil society sectors, have already developed anti-corruption and integrity management strategies of their own. Where these are bearing fruit they should clearly be continued. The proposals for a National Anti-Corruption Strategy outlined below include nine strategic themes or pillars under which organisations and sectors can develop new programmes as well as a common set of concepts and commitments for reducing corruption.In summary, the rationale of an overarching National Anti-Corruption Strategy is to:
• Rejuvenate a national dialogue and direct energy towards practical mechanisms to reduce corruption and improve ethical practices across sectors and among citizens in South Africa.• Support coordination of government, business and civil society efforts to reduce corruption and improve accountability and ethical practice.• Provide a robust conceptual framework and strategic pillars to guide anti-corruption approaches across relevant sectors in the country.• Provide a tool for monitoring progress towards a less corrupt society.
2. VisionThe vision of the National Anti-Corruption Strategy is a South Africa that has:
• An ethical and accountable state, business and civil society sectors in which those in positions of power and authority act with integrity.• Citizens who respect the rule of law and are empowered to hold those in power to account.• Zero tolerance of corruption in any sphere of activity and substantially reduced levels of corruption.
National Anti-Corruption StrategyDiscussion Document 18
In line with the National Development Plan, the vision of the National Anti-Corruption Strategy further entails a society in which police o�cers and others involved in enforcement do not wield power inappropriately over the vulnerable; one in which principals manage school funds in the best interests of learners; small business owners and corporates seek to provide value for money to customers; leaders of corporates seek to ensure their actions do not undermine the environmental or economic sustainability of communities and regions; traditional leaders serve the interests of their communities; citizens respect the rule of law; the judiciary acts with integrity and impartiality; trade union leaders are motivated by service to workers; members of parliament, legislatures and councillors hold o�cials and members of the executive to account; and public servants and politicians see their commitment �rst towards the citizens of the country, according to the values and requirements of the Constitution, and to implementing policy in the service of social and economic transformation, and not towards private or other interests. In order to achieve this vision, South Africa requires leaders across all sectors to set an example in acting with integrity and accepting accountability to their constituencies and stakeholders.
3. ObjectivesThe objectives of the National Anti-Corruption Strategy are to:
1. Improve citizens’ awareness of their rights and responsibilities relevant to the �ght against corruption.2. Improve whistle-blower protection and active participation in anti-corruption e�orts by members of the public.3. Improve transparency across sectors.4. Improve compliance with anti-corruption and integrity management obligations and mechanisms across sectors.5. Improve the structures for detection and enforcement (an independent, resourced, skilled and coordinated anti-corruption system).6. Improve structures of oversight and accountability.7. Improve domestic and international partnerships in and across sectors for reducing corruption and building accountability.
4. Conceptual frameworkCorruption a�ects and involves the actions of people in the government, business and civil socie-ty sectors. Tackling it will require commitment from all sectors, and interventions to empower citizens to support e�orts aimed at reducing corruption. Substantially reducing corruption in South Africa therefore requires “a whole of government and society approach”, as called for in the National Development Plan and Government’s Medium Term Strategic Framework (2014-2019).Furthermore, corruption is not simply caused by a few “bad apples”. In order to deal with the systemic factors enabling corruption it is important to recognise that corruption and, conversely, ethical practice are shaped by particular organisational, social and political contexts.
National Anti-Corruption Strategy Discussion Document19
Behavioural change is supported through changes to the institutions that govern or shape behaviour. Institutions are those structures, processes and mechanisms that shape people’s behaviour in a particular context or community. Examples of relevant institutions are the organisations that govern training, such as schools or universities, workplace or organisational cultures and religions. Therefore, ensuring people have knowledge about anti-corruption regulations, ethics frameworks, etc, is a �rst important step towards reducing corruption and supporting ethical practice. It is however not su�cient. The aim of programmes initiated under the National Anti-Corruption Strategy should be to provide guidance on how to shift the incentives and constraints under which people and organisations operate, and build institutions that provide public servants, private sector professionals, citizens and others with a blueprint for ethical practice.
5. Strategic pillars and programmesThe National Anti-Corruption Strategy is built around nine strategic pillars, which are mutually supportive:
1. Support citizen empowerment in the �ght against corruption, including increased support for whistle-blowers.2. Develop sustainable partnerships with stakeholders to reduce corruption and improve integrity management.3. Improve transparency by government, business and civil society sectors.4. Improve the integrity of the public procurement system to ensure fair, e�ective and efficient use of public resources.5. Support the professionalisation of employees.6. Improve adherence to integrity management and anti-corruption mechanisms and improve consequence management for non-compliance of these across government, business and civil society sectors.7. Strengthen oversight and governance mechanisms in the government sector.8. Strengthen the resourcing, cooperation and independence of dedicated anti-corruption agencies.9. Build specific programmes to reduce corruption and improve integrity in sectors particularly vulnerable to corruption (vulnerable sector management), with an initial focus on the Justice, Crime Prevention and Security Cluster.
Some of the programmes undertaken under the strategic pillars will be cross-cutting, i.e. supporting more than one of the strategic pillars. For example, professionalising supply chain management can support the integrity of the public procurement system; strengthening the capacity of anti-corruption agencies can support improved whistle-blower protection; etc.
National Anti-Corruption StrategyDiscussion Document 20
These strategic pillars will be supported by the following programme elements and actions:
• Awareness-raising and public dialogues.• Integrity pacts and public commitment campaigns.• Research and analysis.• Development of guidelines and systems to support compliance with regulations.• Education and training interventions.• Improvement or development of platforms for enhanced coordination across and within sectors.• Improvement or development of institutionalised platforms for detection, investigation and prosecution.• Improvement of mechanisms to support increased reporting of corruption and whistle- blowing, including the protection of whistle-blowers.• Development, review or amendments to legislation and policy frameworks.
Monitoring and evaluation should be a built-in component of all programmes. The United Nations O�ce on Drugs and Crime has developed a high-level guide for developing anti-corruption strategies. It dedicates a chapter to the monitoring and evaluation of anti-corruption strategies and highlights the importance of a strong monitoring and evaluation component to support implementation of the strategy and institutional learning. The indicators should be very carefully developed to ensure that they refer to actions that can meaningfully contribute to reducing corruption or improving ethical practice.
A number of constructive recommendations for the reorganisation and reduction of some of the proposed pillars and strengthening of possible programmes were made during the initial sectoral consultations with select government, business and civil society stakeholders in September and October 2016.
• These recommendations and comments were not included in this version of the Discussion Document, as the discussion of these should form part of the public consultation phase.• Comments related to the roadmap and consultation process were, where feasible, included in the Roadmap (Appendix A).
National Anti-Corruption Strategy Discussion Document21
Pilla
r 1: S
uppo
rt c
itiz
en e
mpo
wer
men
t in
the
�ght
aga
inst
Cor
rupt
ion
(incl
udin
g im
prov
ed w
hist
le-b
low
er p
rote
ctio
n)
Th
roug
h pa
ying
a b
ribe
to a
gov
ernm
ent
o�ci
al, o
rdin
ary
mem
bers
of
the
publ
ic c
an p
erpe
tuat
e co
rrup
t ac
tivity
. Con
vers
ely,
thr
ough
join
ing
publ
ic c
ampa
igns
, or
blow
ing
the
whi
stle
on
susp
ecte
d ca
ses
of c
orru
ptio
n, o
rdin
ary
mem
bers
of
the
publ
ic, c
ivil
soci
ety
and
med
ia p
lay
a ro
le in
ant
i-cor
rupt
ion
wor
k, a
nd c
an p
rovi
de
pres
sure
for
im
prov
ed a
ccou
ntab
ility
in
vario
us s
ecto
rs i
n So
uth
Afr
ica.
The
Uni
ted
Nat
ions
Con
vent
ion
Aga
inst
Cor
rupt
ion
and
othe
r in
tern
atio
nal
trea
ties
urge
si
gnat
ory
coun
trie
s to
est
ablis
h m
echa
nism
s th
at e
ncou
rage
par
ticip
atio
n in
the
�ght
aga
inst
cor
rupt
ion
by th
e m
edia
, civ
il so
ciet
y an
d or
dina
ry c
itize
ns.
Stra
tegi
c pr
ogra
mm
es u
nder
pill
ar1:
Stra
tegi
c Pr
ogra
mm
e Ra
tion
ale
1.1
Deve
lop an
d im
plem
ent a
ware
ness-
raisi
ng ca
mpa
igns o
n the
natu
re an
d e�e
cts of
co
rrupt
ion, a
nd th
e mec
hanis
ms a
vaila
ble to
redu
ce co
rrupt
ion, in
cludin
g cor
rupt
ion-
re
porti
ng ho
tline
s, in
partn
ersh
ip wi
th ci
vil so
ciety.
Impr
oved
awar
enes
s of t
he im
pact
of co
rrupt
ion in
parti
cular
serv
ices o
r sec
tors
can p
lay a
role
in in�
uenc
ing po
sitive
be
havio
ur ch
ange
away
from
corru
ption
, and
enco
urag
e peo
ple to
repo
rt ins
tanc
es of
corru
ption
, if ca
mpa
igns h
ave a
cle
ar th
emat
ic fo
cus t
hat a
llow
peop
le to
iden
tify i
n quit
e spe
ci�c w
ays w
ith th
e issu
es be
ing ra
ised.
Furth
erm
ore,
thes
e ca
n help
build
shar
ed un
derst
andin
g of w
hat c
onsti
tute
s cor
rupt
ion.
1.2
Deve
lop an
d im
plem
ent i
nfor
mat
ion ca
mpa
igns o
n citi
zens
’ righ
ts an
d how
adm
inistr
ative
pr
oces
ses s
hould
func
tion t
o ser
vice c
itize
ns in
:
• Fro
ntlin
e ser
vices
and i
n sec
tors
offer
ing se
rvice
s tha
t give
effec
t to s
ocio-
econ
omic
right
s in t
he Co
nstit
ution
, suc
h as i
n the
healt
h and
educ
ation
secto
rs (p
ublic
and
priva
te).
•
On ci
tizen
s’ righ
ts as
they
parti
cular
ly aff
ect p
eople
living
in ru
ral a
reas
, on i
ssues
such
as
acce
ssing
land
and o
ther
serv
ices.
Whe
re ci
tizen
s hav
e goo
d inf
orm
ation
abou
t how
a pa
rticu
lar ad
mini
strat
ive pr
oces
s wor
ks, a
nd w
hat t
hey h
ave a
rig
ht to
expe
ct fro
m th
e con
duct
of a
publi
c ser
vant
or pr
ivate
secto
r ser
vice p
rovid
er, th
ey ar
e in a
bette
r pos
ition
to
resis
t req
uests
for b
ribes
, and
in a
bette
r pos
ition
to bl
ow th
e whis
tle on
possi
ble ca
ses o
f cor
rupt
ion. T
his st
rate
gic
prog
ram
me a
lso co
ntrib
utes
to th
e im
plem
enta
tion o
f the
Prom
otion
of Ad
mini
strat
ive Ju
stice
Act.
1.3
Ensu
re st
reng
then
ed w
histle
-blow
er pr
otec
tion t
hrou
gh m
echa
nism
s suc
h as:
•
Deve
loping
appr
opria
te sy
stem
s for
the p
rote
ction
of th
e ide
ntity
of w
histle
-blow
ers
and f
or th
e pro
vision
of le
gal a
id to
them
.
• De
velop
impr
oved
inve
stiga
tive/
refer
ral c
apac
ity to
supp
ort s
ucce
ssful
pros
ecut
ion
ba
sed o
n inf
orm
ation
prov
ided t
o hot
lines
.
• Re
port
posit
ive su
ccess
storie
s in r
educ
ing co
rrupt
ion du
e to i
nfor
mat
ion fr
om
wh
istle-
blowe
rs.
The O
rgan
isatio
n for
Econ
omic
Deve
lopm
ent W
orkin
g Gro
up as
sessi
ng co
mpli
ance
with
prov
ision
on co
mba
ting
bribe
ry no
tes t
hat e
�orts
are n
eede
d in S
outh
Afric
a to e
nsur
e tha
t in p
racti
ce w
histle
-blow
ers a
re pr
ovide
d with
the
prot
ectio
n out
lined
in la
w. 32
To be
e�ec
tive,
the p
ublic
shou
ld se
e exa
mple
s of c
ases
of co
rrupt
ion be
ing pr
osec
uted
as
a re
sult
of th
ese h
otlin
es.
32 O
rgan
isatio
n for
Econ
omic
Coop
erat
ion an
d Dev
elopm
ent (
OECD
). 20
16. ‘S
outh
Afric
a Pha
se 3
Writ
ten F
ollow
-up R
epor
t.’ OE
CD, P
aris.
National Anti-Corruption StrategyDiscussion Document 22
Pilla
r 2: D
evel
op s
usta
inab
le p
artn
ersh
ips
wit
h st
akeh
olde
rs
Pa
rtne
rshi
ps a
nd c
olla
bora
tive
foru
ms
are
need
ed t
o st
reng
then
and
sus
tain
the
�gh
t ag
ains
t co
rrup
tion.
The
se p
artn
ersh
ips
and
foru
ms
can
impr
ove
coor
dina
tion
arou
nd a
nti-c
orru
ptio
n e�
orts
, bui
ld g
reat
er c
onse
nsus
aro
und
the
need
for
inte
rven
tions
to
redu
ce c
orru
ptio
n, d
evel
op c
onse
nsus
abo
ut a
ppro
pria
te a
nti-c
orru
ptio
n e�
orts
and
bui
ld s
ocia
l cap
ital b
etw
een
sect
ors
in th
e co
untr
y.
Stra
tegi
c pr
ogra
mm
es u
nder
pill
ar 2
:
Stra
tegi
c Pr
ogra
mm
e Ra
tion
ale
2.1
Rejuv
enat
e the
Nat
ional
Anti-
Corru
ption
Foru
m as
a pla
tform
to co
ordin
ate a
nd st
reng
then
anti-
co
rrupt
ion an
d int
egrit
y e�o
rts ac
ross
busin
ess,
civil s
ociet
y and
gove
rnm
ent s
ecto
rs; en
surin
g the
foru
m
has t
he ne
cessa
ry le
ader
ship
supp
ort,
reso
urcin
g and
appr
opria
te st
ructu
re to
be e�
ectiv
e.
Ther
e are
chall
enge
s to c
ollab
orat
ion an
d inf
orm
ation
on an
ti-co
rrupt
ion m
easu
res,
and t
o obt
aining
secto
r inp
ut on
how
corru
ption
and a
nti-c
orru
ption
a�ec
ts va
rious
secto
rs an
d ind
ustri
es. T
he N
ation
al An
ti-Co
rrupt
ion Fo
rum
was
a po
sitive
deve
lopm
ent i
n the
anti-
corru
ption
land
scap
e. Ho
weve
r, the
foru
m ha
s not
be
en ve
ry ac
tive s
ince t
he Fo
urth
Sum
mit
in 20
11. T
his bo
dy sh
ould
be re
vived
, as e
ncou
rage
d in t
he N
ation
al De
velop
men
t Plan
and b
y pub
lic st
atem
ents
of th
e Mini
ster in
the P
resid
ency
: Plan
ning,
Mon
itorin
g and
Ev
aluat
ion, M
r Rad
ebe.
33 To
be e�
ectiv
e it w
ill re
quire
the a
ctive
parti
cipat
ion of
very
senio
r lea
ders
from
all
secto
rs; ap
prop
riate
insti
tutio
nal d
esign
; ade
quat
e res
ourci
ng, e
spec
ially
from
gove
rnm
ent;
and a
supp
ortin
g ad
mini
strat
ion/se
creta
riat.
Long
- ter
m pa
rtner
ships
betw
een e
duca
tion i
nstit
ution
s, pr
ofes
siona
l bod
ies an
d gov
ernm
ent s
take
holde
rs ca
n bu
ild st
rong
capa
city f
or tr
aining
and d
evelo
pmen
t in t
he ar
ea of
anti-
corru
ption
.
Awar
enes
s-rais
ing ab
out c
orru
ption
and d
iscus
sions
of et
hical
prac
tice i
n a ra
nge o
f set
tings
are a
part
of th
e sch
ool c
urric
ulum
. Inte
rven
tions
are n
eede
d to b
ring s
ome o
f the
issu
es ra
ised i
n the
curri
culum
to lif
e for
lea
rner
s and
to ex
pand
the d
iscus
sion t
o sup
port
spec
i�c a
nti-c
orru
ption
cam
paign
s bein
g im
plem
ente
d und
er
the N
ation
al An
ti-Co
rrupt
ion St
rate
gy.
Guide
lines
are n
eede
d for
deve
loping
syste
ms t
o ens
ure t
hat w
histle
-blow
ers c
an re
port
anon
ymou
sly to
the
exte
nt po
ssible
, tha
t the
ir ide
ntiti
es an
d the
info
rmat
ion th
ey pr
ovide
are r
ecor
ded,
store
d and
used
in su
ch a
way t
hat t
his do
es no
t unn
eces
saril
y inc
reas
e the
risk o
f har
m to
the w
histle
-blow
er.
2.2
Deve
lop pa
rtner
ships
betw
een t
he N
ation
al Sc
hool
of G
over
nmen
t and
othe
r gov
ernm
ent t
raini
ng
acad
emies
, cen
tral g
over
nmen
t dep
artm
ents
such
as th
e Dep
artm
ent o
f Pub
lic Se
rvice
and
Ad
mini
strat
ion an
d Nat
ional
Treas
ury,
educ
ation
al ins
titut
ions a
nd pr
ofes
siona
l bod
ies to
ensu
re
impr
oved
insti
tutio
nal c
apac
ity to
unde
rtake
e�ec
tive e
duca
tion,
train
ing an
d qua
lity c
ontro
l in su
ppor
t
of an
ti-co
rrupt
ion, in
tegr
ity m
anag
emen
t and
prof
essio
nalis
ation
of th
e pub
lic se
ctor.
2.3
Deve
lop pa
rtner
ships
betw
een G
over
nmen
t, civ
il soc
iety a
nd sc
hools
in th
e pub
lic an
d priv
ate s
yste
ms t
o
unde
rtake
awar
enes
s-rais
ing pr
ogra
mm
es ar
ound
corru
ption
and a
nti-c
orru
ption
, and
in su
ppor
t of t
he
relev
ant s
ectio
ns of
the s
choo
l cur
riculu
m. T
hese
could
inclu
de dr
ama a
nd m
usic
even
ts, an
d oth
er
creat
ive in
terv
entio
ns.
2.4
Secto
ral in
put i
nto s
treng
then
ed w
histle
-blow
er pr
otec
tion:
gove
rnm
ent,
busin
ess a
nd ci
vil so
ciety
to
deve
lop gu
idelin
es an
d pro
cedu
res f
or ho
w or
ganis
ation
s in t
heir s
ecto
rs ca
n sup
port
and p
rom
ote
wh
istle-
blowi
ng, a
nd th
e dev
elopm
ent o
f guid
eline
s for
coor
dinat
ing in
form
ation
colle
cted f
rom
re
porti
ng ho
tline
s.
33 Ra
debe
, J. 2
014.
Mini
ster R
adeb
e’s sp
eech
at In
tern
ation
al An
ti-Co
rrupt
ion D
ay, 9
Dec
embe
r 201
4.
National Anti-Corruption Strategy Discussion Document23
esen
tativ
es. G
over
nmen
t acc
ount
abili
ty
is s
ubst
Nat
iona
l D
evel
opm
ent
Plan
. re
leva
nt s
take
hold
ers
in t
heir
sect
ors:
from
cus
tom
ers
and
St
rate
gic
prog
ram
mes
und
er p
illar
3:
Pilla
r 3: I
mpr
ove
tran
spar
ency
(by
gove
rnm
ent,
busi
ness
and
civ
il so
ciet
y se
ctor
s)
The
Cons
titut
ion
incl
udes
var
ious
cla
uses
requ
iring
tran
spar
ency
in th
e op
erat
ions
of g
over
nmen
t dep
artm
ents
and
ele
cted
repr
antia
lly e
nabl
ed b
y tr
ansp
aren
cy i
n de
cisi
on-m
akin
g an
d th
e m
anag
emen
t of
pub
lic r
esou
rces
. Th
is i
s a
key
them
e of
the
Fu
rthe
rmor
e, t
he b
usin
ess
and
civi
l soc
iety
sec
tors
als
o ha
ve a
dut
y to
ens
ure
appr
opria
te t
rans
pare
ncy
to
othe
r citi
zens
a�e
cted
by
busi
ness
act
ivity
, to
dono
rs, b
ene�
ciar
ies
and
othe
r gro
ups
a�ec
ted
by c
ivil
soci
ety
activ
ity.
Stra
tegi
c Pr
ogra
mm
e Ra
tion
ale
3.1
Deve
lop an
d im
plem
ent a
ware
ness-
raisi
ng ca
mpa
igns a
nd tr
aining
inte
rven
tions
on le
gislat
ion th
at gi
ve co
ncre
te e�
ect t
o
trans
pare
ncy,
with
a fo
cus o
n the
Prom
otion
of Ac
cess
to In
form
ation
Act a
nd th
e Pro
mot
ion of
Adm
inistr
ative
Justi
ce Ac
t, in
pa
rtner
ship
with
civil
socie
ty an
d med
ia.
3.2
Impr
ove s
yste
ms f
or re
cord
keep
ing in
orga
ns of
stat
e to s
uppo
rt ov
ersig
ht of
gove
rnm
ent a
ctivit
y and
the i
mple
men
tatio
n of t
he
Prom
otion
of Ac
cess
to In
form
ation
Act a
nd th
e Pro
mot
ion of
Adm
inistr
ative
Justi
ce Ac
t in p
artic
ular, t
hrou
gh:
•
The d
evelo
pmen
t of a
ppro
priat
e pro
fessio
nal re
cord
keep
ing st
anda
rds a
cross
all sp
here
s of G
over
nmen
t.
• Pr
ovidi
ng eff
ectiv
e tra
ining
for r
ecor
d man
ager
s and
arch
ivists
.
• M
aking
avail
able
small
gran
ts fo
r app
licat
ion by
gove
rnm
ent d
epar
tmen
ts an
d mun
icipa
lities
in de
velop
ing ap
prop
riate
reco
rd
ke
eping
syste
ms.
•
Prov
iding
tech
nical
supp
ort b
y Gov
ernm
ent f
or th
is pu
rpos
e.
3.3
Impr
ove t
he av
ailab
ility a
nd qu
ality
of go
vern
men
t dat
a rele
vant
to co
rrupt
ion an
d ant
i-cor
rupt
ion e�
orts
thro
ugh:
•
The d
evelo
pmen
t of s
tand
ardis
ed gu
idelin
es an
d oth
er m
echa
nism
s for
reco
rding
and r
epor
ting o
n cor
rupt
ion-re
lated
inves
tigat
ions a
nd pr
osec
ution
s for
vario
us se
ctors.
•
Alloc
ating
resp
onsib
ility t
o a go
vern
men
t bod
y to c
ollec
t, an
alyse
and r
epor
t on d
ata r
eleva
nt to
corru
ption
and a
nti-c
orru
ption
e�or
ts.
• M
appin
g and
rese
arch
ing th
e pot
entia
l futu
re ar
eas o
f risk
for c
orru
ption
.
3.4
Esta
blish
appr
opria
te in
strum
ents
and m
echa
nism
s to p
rovid
e for
info
rmat
ion on
bene
�cial
owne
rship
thro
ugh:
•
Amen
dmen
ts to
or de
velop
men
t of le
gislat
ion.
•
Appr
opria
te sy
stem
s to c
aptu
re an
d rep
ort o
n ben
eficia
l own
ersh
ip.
• In
form
ation
and a
ware
ness-
raisi
ng ca
mpa
igns o
n the
natu
re of
bene
ficial
owne
rship
and t
he pu
rpos
e of t
rans
pare
ncy i
n this
area
, in pa
rtner
ship
with
civil
socie
ty an
d med
ia.
3.5
Esta
blish
mec
hanis
ms f
or im
prov
ing tr
ansp
aren
cy of
gove
rnan
ce in
civil
socie
ty or
ganis
ation
s and
priva
te se
ctor �
rms,
in pa
rtner
ship
wi
th th
ese s
ecto
rs, fo
r exa
mple
thro
ugh:
•
The d
evelo
pmen
t of g
uideli
nes f
or in
form
ation
to be
prov
ided t
o the
publi
c.
• Aw
aren
ess-r
aising
cam
paign
s and
dialo
gues
on tr
ansp
aren
cy.
•
Othe
r mec
hanis
ms.
3.6
Deve
lop m
echa
nism
s to i
mpr
ove b
usine
ss se
ctor c
ompli
ance
with
repo
rting
requ
irem
ents
on co
rrupt
ion as
outli
ned i
n the
Prev
entio
n
and C
omba
ting o
f Cor
rupt
Activ
ities
Act,
thro
ugh m
echa
nism
s suc
h as:
•
Awar
enes
s-rais
ing ca
mpa
igns.
•
The d
evelo
pmen
t of g
uideli
nes r
egar
ding h
ow an
d wha
t to r
epor
t.
The P
rom
otion
of Ac
cess
to In
form
ation
Act g
ives g
reat
er le
gal e
�ect
to pr
ovisi
ons i
n the
Cons
titut
ion an
d the
Bill o
f Righ
ts pr
ovidi
ng
for a
ccess
to in
form
ation
in th
e pub
lic an
d priv
ate s
ecto
rs. Th
e Pro
mot
ion of
Adm
inistr
ative
Justi
ce Ac
t sta
tes t
hat m
embe
rs of
the
publi
c hav
e the
right
to ad
mini
strat
ive ac
tion b
y the
Stat
e tha
t is l
awfu
l, rea
sona
ble an
d pro
cedu
rally
fair,
and t
o be p
rovid
ed w
ith
reas
ons i
n circ
umsta
nces
whe
re on
e’s rig
hts a
re ad
verse
ly a�
ecte
d by a
dmini
strat
ive ac
tion.
The N
ation
al De
velop
men
t Plan
has
highl
ighte
d the
need
to gi
ve gr
eate
r e�e
ct to
thes
e Acts
by go
vern
men
t dep
artm
ents
and a
genc
ies.
The s
tate
of re
cord
keep
ing in
a nu
mbe
r of g
over
nmen
t dep
artm
ents
and m
unici
palit
ies is
poor.
This
creat
es ro
om fo
r cor
rupt
ion by
re
ducin
g the
Stat
e’s ab
ility t
o ide
ntify
and p
rose
cute
case
s of c
orru
ption
. Fur
ther,
poor
reco
rdke
eping
mak
es it
di�
cult
or ti
me-
cons
um-
ing fo
r dep
artm
ents
to co
mply
with
requ
ests
for in
form
ation
unde
r the
Prom
otion
of Ac
cess
to In
form
ation
Act a
nd Pr
omot
ion of
Ad
mini
strat
ive Ju
stice
Act.
Data
on in
vesti
gatio
ns an
d con
victio
ns of
case
s inv
olving
corru
ption
are i
ncon
siste
ntly
repo
rted b
y gov
ernm
ent a
genc
ies, a
nd da
ta on
co
mpli
ance
with
regu
lation
s rele
vant
to co
rrupt
ion is
inco
nsist
ently
colle
cted a
nd re
porte
d by p
ublic
secto
r dep
artm
ents.
Furth
er, th
is da
ta is
not p
rope
rly co
nsoli
date
d. Im
prov
ing th
e coll
ectio
n and
repo
rting
of th
ese k
inds o
f sta
tistic
s in G
over
nmen
t is i
mpo
rtant
for
mon
itorin
g ant
i-cor
rupt
ion w
ork,
and i
dent
ifying
area
s of p
oten
tial a
nd cu
rrent
risk f
or co
rrupt
ion.
At th
e Ope
n Gov
ernm
ent P
artn
ersh
ip Af
rica R
egion
al M
eetin
g in C
ape T
own i
n May
2016
, the
Sout
h Afri
can G
over
nmen
t ann
ounc
ed an
ac
tion p
lan th
at in
clude
s com
mitm
ents
to co
llecti
ng in
form
ation
on be
ne�c
ial ow
nersh
ip of
all c
ompa
nies i
n the
coun
try an
d mak
ing
this
publi
cally
avail
able.
This
will r
equir
e am
endm
ent t
o exis
ting l
egisl
ation
or th
e dev
elopm
ent o
f new
legis
lation
, and
the
deve
lopm
ent o
f sup
porti
ng re
gulat
ions a
nd in
stitu
tions
.
Whil
e som
e org
anisa
tions
in ci
vil so
ciety
and t
he bu
sines
s sec
tor h
ave t
aken
the l
ead i
n ens
uring
their
proc
esse
s are
tran
spar
ent a
nd
acco
unta
ble to
their
stak
ehold
ers,
ther
e is s
till a
need
to im
prov
e the
tran
spar
ency
of op
erat
ions o
f som
e civi
l soc
iety o
rgan
isatio
ns an
d pr
ivate
secto
r �rm
s, an
d to i
mpr
ove r
epor
ting o
n how
orga
nisat
ions a
re ta
cklin
g cor
rupt
ion in
their
own o
rgan
isatio
ns. T
he dr
aft K
ing IV
ou
tline
s pro
posa
ls fo
r pro
mot
ing go
od co
rpor
ate g
over
nanc
e in a
ll sec
tors
– inc
luding
prop
osals
for im
prov
ed tr
ansp
aren
cy.
Regu
lation
s on r
epor
ting c
orru
pt ac
tivity
in th
e bus
iness
secto
r by b
usine
sses i
s writ
ten i
nto l
aw, b
ut co
mpli
ance
with
thes
e pro
vision
s is
not w
hat i
t sho
uld be
, in pa
rt du
e to t
he st
igma a
ttach
ed to
adm
itting
cont
rol a
nd go
vern
ance
failu
res.
National Anti-Corruption StrategyDiscussion Document 24
Pilla
r 4: I
mpr
ove
the
inte
grity
of t
he p
ublic
pro
cure
men
t sys
tem
The
Med
ium
Ter
m S
trat
egic
Fra
mew
ork
and
the
Nat
iona
l Dev
elop
men
t Pla
n in
clud
e st
reng
then
ing
over
sigh
t of t
he p
ublic
pro
cure
men
t sys
tem
as
a st
rate
gy fo
r red
ucin
gco
rrup
tion.
The
inte
rfac
e be
twee
n pu
blic
and
priv
ate
sect
ors
in th
e pr
ocur
emen
t pro
cess
is w
here
a g
ood
deal
of c
orru
pt a
ctiv
ity ta
kes
plac
e. S
uppo
rtin
g im
prov
ed
over
sigh
t of c
ompl
ianc
e by
ele
cted
o�
cial
s, p
ublic
sec
tor e
mpl
oyee
s an
d th
e bu
sine
ss s
ecto
r with
regu
latio
ns a
nd c
odes
inte
nded
to e
nsur
e ac
coun
tabi
lity
in th
e us
e of
pu
blic
reso
urce
s is
vita
l to
redu
cing
cor
rupt
ion
and
ensu
ring
that
pub
lic m
onie
s ar
e sp
ent o
n de
velo
pmen
t and
ser
vice
del
iver
y. T
he O
�ce
of t
he C
hief
Pro
cure
men
t O�
cer
was
est
ablis
hed
to s
uppo
rt a
mor
e tr
ansp
aren
t, fa
ir an
d e�
ectiv
e pu
blic
pro
cure
men
t sys
tem
. Im
port
ant r
efor
ms
of th
e pr
ocur
emen
t sys
tem
are
und
erta
ken
and
led
by th
is
o�ce
, whi
ch s
houl
d be
sup
port
ed b
y th
e N
atio
nal A
nti-C
orru
ptio
n St
rate
gy.
St
rate
gic
prog
ram
mes
und
er p
illar
4:
Stra
tegi
c Pr
ogra
mm
e Ra
tion
ale
4.1
Impr
ovem
ents
in pu
blicly
avail
able
data
on st
ate p
rocu
rem
ent i
n org
ans o
f sta
te th
at en
able
citize
ns, c
ivil
so
ciety
and c
once
rned
busin
ess t
o mon
itor t
he in
tegr
ity of
the p
ublic
proc
urem
ent s
yste
m. T
his
prog
ram
me s
hould
inclu
de a
majo
r foc
us on
ensu
ring t
he av
ailab
ility o
f suc
h dat
a on p
rocu
rem
ent b
y
state
-own
ed en
tities
.
4.2
Unde
rtake
annu
al fo
rens
ic re
views
of a
small
sam
ple of
proc
uring
entit
ies an
d lar
ge pr
ocur
emen
t
cont
racts
acro
ss all
leve
ls of
Gov
ernm
ent. T
he sa
mple
met
hod s
hould
vary
depe
nding
on th
e sph
ere o
f
Gove
rnm
ent.
For e
xam
ple:
•
In lo
cal g
over
nmen
t, a s
mall
rand
om sa
mple
of m
unici
palit
ies co
uld be
iden
tified
annu
ally.
•
In th
e cas
e of s
tate
-own
ed en
tities
, a ra
ndom
sam
ple of
cont
racts
abov
e a ce
rtain
value
could
be
ide
nti�
ed.
Thes
e inv
estig
ation
s wou
ld ne
ed to
be fo
llowe
d up w
ith ap
prop
riate
crim
inal o
r disc
iplina
ry ac
tion.
4.3
Deve
lop an
d im
plem
ent e
duca
tion a
nd aw
aren
ess c
ampa
igns t
o im
prov
e bus
iness,
civil
socie
ty an
d
med
ia ov
ersig
ht of
proc
urem
ent,
includ
ing:
•
Orga
nised
busin
ess p
artn
ering
with
Gov
ernm
ent t
o und
erta
ke tr
aining
for fi
rms,
civil s
ociet
y and
m
edia
rega
rding
the p
rocu
rem
ent p
roce
ss (h
ow th
e pro
cess
work
s, wh
ere t
o �nd
relev
ant
infor
mat
ion on
tend
ers,
wher
e to r
epor
t sus
pecte
d cas
es of
corru
ption
, etc.
).
• Th
e dev
elopm
ent o
f a su
ppor
ting h
andb
ook o
n how
proc
urem
ent i
s reg
ulate
d cou
ld be
deve
loped
.
Su
ch m
ater
ial ha
s alre
ady b
een d
evelo
ped i
n som
e sec
tors,
by or
ganis
ed bu
sines
s, th
e Eth
ics
In
stitu
te of
Sout
h Afri
ca an
d oth
ers. T
hese
could
be up
date
d and
mor
e wide
ly dis
tribu
ted.
Deve
loping
cons
olida
ted p
ublic
ly av
ailab
le da
ta on
stat
e pro
cure
men
t cou
ld aid
in bu
ilding
grea
ter t
rans
pare
n-cy
and a
ccoun
tabil
ity of
the g
over
nmen
t and
busin
ess s
ecto
rs in
the c
ount
ry.
Inte
rven
tions
are n
eede
d to c
reat
e a hi
gher
leve
l of r
isk of
dete
ction
of co
rrupt
activ
ity by
impr
oved
enfo
rce-
men
t of r
eleva
nt le
gislat
ion ar
ound
proc
urem
ent;
and t
o im
prov
e con
sequ
ence
man
agem
ent f
or tr
ansg
ressi
ons
of la
w re
gulat
ing pr
ocur
emen
t.
Civil s
ociet
y, or
ganis
ed bu
sines
s and
med
ia ca
n sup
port
impr
oved
mon
itorin
g of t
he pu
blic p
rocu
rem
ent
syste
m. O
rgan
isatio
ns th
at ar
e tra
ined o
n the
natu
re of
the r
eform
s to t
he pr
ocur
emen
t sys
tem
and t
he
com
plian
ce ex
pecte
d fro
m go
vern
men
t ins
titut
ions a
nd pr
ivate
secto
r com
panie
s in c
ontra
cting
with
the s
tate
ca
n assi
st Go
vern
men
t in p
rovid
ing pr
essu
re fo
r com
plian
ce.
National Anti-Corruption Strategy Discussion Document25
Pilla
r 5: P
rofe
ssio
nalis
atio
n (o
f pub
lic s
ervi
ce e
mpl
oyee
s)
Prof
essi
onal
isat
ion
of t
he p
ublic
sec
tor
is a
key
the
me
of t
he N
atio
nal
Dev
elop
men
t Pl
an,
as o
utlin
ed i
n Ch
apte
r 13
, an
d is
not
onl
y in
clud
ed i
n th
e ch
apte
r on
co
mba
ting
corr
uptio
n bu
t al
so a
n ou
tcom
e of
the
Med
ium
Ter
m S
trat
egic
Fra
mew
ork
2014
2019
. A p
rofe
ssio
nalis
ed p
ublic
sec
tor
is o
ne in
whi
ch it
s em
ploy
ees
see
thei
r com
mitm
ent �
rst a
nd fo
rem
ost t
o th
e ci
tizen
s of
the
coun
try
and
to im
plem
entin
g po
licy
in th
e se
rvic
e of
soc
ial a
nd e
cono
mic
tran
sfor
mat
ion,
and
not
to p
rivat
e or
par
ty in
tere
sts
whe
re th
ese
devi
ate
from
form
al p
olic
y. F
urth
er, i
t inc
orpo
rate
s a
visi
on o
f a p
ublic
sec
tor i
n w
hich
em
ploy
ees
have
the
nece
ssar
y sk
ills
and
expe
rienc
e to
und
erta
ke t
heir
wor
k. P
rofe
ssio
nalis
atio
n re
quire
s an
app
roac
h to
tra
inin
g an
d re
crui
ting
civi
l ser
vant
s th
at c
an h
elp
shap
e a
sens
e of
com
mitm
ent
to s
ervi
ng t
he
publ
ic. I
nitia
tives
to
supp
ort t
he p
roce
ss o
f pro
fess
iona
lisat
ion
are
alre
ady
unde
rtak
en b
y th
e D
epar
tmen
t of P
ublic
Ser
vice
and
Adm
inis
trat
ion
, the
Nat
iona
l Sch
ool o
f G
over
nmen
t, th
e So
uth
Afr
ican
Loc
al G
over
nmen
t A
ssoc
iatio
n, a
nd o
ther
s. F
urth
er s
take
hold
ers
in t
his
proc
ess
incl
ude
othe
r tr
aini
ng b
odie
s an
d pr
ofes
sion
al
asso
ciat
ions
.
The
deve
lopm
ent
of a
wel
l-ski
lled
publ
ic s
ervi
ce f
eatu
res
prom
inen
tly i
n co
mpa
rativ
e po
litic
al s
cien
ce l
itera
ture
as
a ke
y fe
atur
e of
les
s co
rrup
t so
ciet
ies,
and
st
reng
then
ing
this
in
Sout
h A
fric
a w
ill r
equi
re d
edic
ated
res
ourc
es a
nd a
tten
tion
and
shou
ld o
btai
n pr
omin
ence
in
the
natio
nal
disc
ours
e on
cor
rupt
ion.
Hum
an
reso
urce
s, s
uppl
y ch
ain
man
agem
ent
and
�nan
ce s
houl
d be
par
ticul
arly
targ
eted
und
er th
is s
trat
egic
pill
ar. A
n im
prov
ed h
uman
reso
urce
func
tion
is v
ital f
or e
nsur
ing
bett
er c
onse
quen
ce m
anag
emen
t and
dis
cipl
ine
for n
on-c
ompl
ianc
e in
dep
artm
ents
, for
sup
port
ing
trai
ning
and
impr
oved
recr
uitm
ent i
n th
e pu
blic
sec
tor.
Impr
oved
�n
anci
al m
anag
emen
t an
d su
pply
cha
in m
anag
emen
t is
vita
l to
ensu
re m
ore
e�ci
ent
use
of p
ublic
res
ourc
es a
nd t
o re
duce
the
roo
m f
or c
orru
pt a
ctiv
ity
in p
ublic
pr
ocur
emen
t. O
ther
occ
upat
iona
l gro
ups
that
requ
ire in
terv
entio
ns re
late
to th
e pr
ofes
sion
s th
at d
etec
t and
inve
stig
ate
unet
hica
l or c
orru
pt b
ehav
iour
suc
h as
inte
rnal
au
dit a
nd fo
rens
ic in
vest
igat
ions
.
Stra
tegi
c pr
ogra
mm
es u
nder
pill
ar 5
:
Stra
tegi
c Pr
ogra
mm
e Ra
tion
ale
5.1
Deve
lop co
re cu
rricu
lum fo
r sup
ply ch
ain m
anag
emen
t, �n
ance
and h
uman
reso
urce
s; to
be de
velop
ed by
the
Na
tiona
l Sch
ool o
f Gov
ernm
ent,
in pa
rtner
ship
with
senio
r pra
ctitio
ners
in th
ese o
ccup
ation
s in t
he pu
blic s
ecto
r,
relev
ant p
rofes
siona
l asso
ciatio
ns an
d univ
ersit
ies. T
he cu
rricu
lum sh
ould
be ca
refu
lly de
velop
ed to
supp
ort
pr
actic
al tra
ining
that
re�e
cts th
e wor
king e
nviro
nmen
t of p
ublic
secto
r em
ploye
es.
5.2
Deve
lop a
coho
rt of
expe
rt tra
iners
and l
ectu
rers
in th
e Nat
ional
Scho
ol of
Gov
ernm
ent,
prov
incial
acad
emies
and
tra
ining
for l
ocal
gove
rnm
ent. T
his co
hort
shou
ld inc
lude t
raine
rs wh
o hav
e had
leng
thy p
eriod
s of e
xper
ience
at a
se
nior l
evel
in th
e pub
lic se
rvice
.
5.3
Phas
ed-in
exam
inatio
ns an
d tra
ining
requ
irem
ents
for s
ta�
at Se
nior M
anag
emen
t Ser
vice l
evel
in su
pply
chain
m
anag
emen
t, �n
ance
and h
uman
reso
urce
s. En
tranc
e exa
ms f
or po
sition
s in t
he Se
nior M
anag
emen
t Ser
vice o
r
anot
her a
ppro
priat
e lev
el in
thes
e occ
upat
ions c
ould
be ph
ased
in ov
er a
perio
d of t
ime,
begin
ning w
ith
know
ledge
testi
ng of
relev
ant l
egisl
ation
and c
odes
, the
n mov
ing sl
owly
towa
rds s
tand
ardis
ed co
mpe
tenc
y-ba
sed
ex
amina
tions
as tr
aining
insti
tutio
ns an
d cou
rses f
or pu
blic s
erva
nts m
atur
e.
5.4
Deve
lop or
stre
ngth
en pr
ofes
siona
l asso
ciatio
ns to
supp
ort t
he pr
ofes
siona
lisat
ion of
supp
ly ch
ain m
anag
emen
t,
�nan
ce an
d hum
an re
sour
ces i
n the
publi
c sec
tor.
5.5
Deve
lop a
grad
uate
recru
itmen
t pro
gram
me f
or su
pply
chain
man
agem
ent,
�nan
ce an
d hum
an re
sour
ces,
which
inc
ludes
a ce
ntra
l stra
tegy
for p
rovid
ing tr
aining
, men
torin
g and
supp
ort t
hrou
ghou
t the
�rst
year
s on t
he sc
hem
e,
as ca
lled f
or in
the N
ation
al De
velop
men
t Plan
.
The d
evelo
pmen
t of c
ore c
urric
ula fo
r the
se oc
cupa
tions
can s
uppo
rt im
prov
ed an
d sta
ndar
dised
train
ing, s
uppo
rt th
e de
velop
men
t of s
tand
ardis
ed cr
iteria
for a
ppoin
ting p
erso
nnel
in th
ese o
ccup
ation
s and
deve
lop a
com
mun
ity of
prac
tition
ers
in th
ese o
ccup
ation
s.
Traini
ng to
supp
ort p
rofes
siona
lisat
ion sh
ould
ideall
y tak
e the
form
of sp
ecial
ised,
long-
term
coho
rt tra
ining
, to d
evelo
p stro
ng
skills
and t
o dev
elop a
shar
ed et
hos.
Entra
nce e
xam
inatio
ns an
d tra
ining
requ
irem
ents,
if ap
prop
riate
ly ph
ased
in, c
an im
prov
e the
skills
leve
ls of
perso
nnel
in th
ese
posit
ions a
nd th
e sta
tus o
f the
se oc
cupa
tions
in th
e pub
lic se
ctor.
In a
num
ber o
f pro
fessio
ns, re
gistra
tion w
ith a
prof
essio
nal a
ssocia
tion o
r bod
y is s
tand
ard.
The p
rofes
siona
l asso
ciatio
ns (f
or
exam
ple th
e Sou
th Af
rican
Insti
tute
of Ch
arte
red A
ccoun
tant
s) ac
credit
mem
bers
of a
prof
essio
n, of
ten t
hrou
gh re
quiri
ng of
ap
plica
nts a
mini
mum
leve
l of q
uali�
catio
n or r
equir
ing th
at ap
plica
nts p
ass a
stan
dard
ised e
xam
inatio
n. Th
roug
h par
tner
ing
with
exist
ing pr
ofes
siona
l bod
ies, t
hese
form
s of a
ccre
ditat
ion co
uld be
built
up ov
er ti
me a
nd sh
ould
includ
e mem
bers
signin
g a c
ode o
f con
duct
for a
ccre
dited
entry
into
the p
rofes
sion.
The N
ation
al De
velop
men
t Plan
prop
oses
the d
evelo
pmen
t of a
grad
uate
recru
itmen
t pro
gram
me.
This
could
assis
t in
deve
loping
a co
mm
unity
of su
ppor
t and
prac
tice a
mon
g gra
duat
es in
thes
e occ
upat
ions a
nd in
impr
oving
the r
ecru
itmen
t of
skille
d gra
duat
es in
to th
e pub
lic se
ctor in
thes
e occ
upat
ions.
National Anti-Corruption StrategyDiscussion Document 26
Pilla
r 6: I
mpr
ove
adhe
renc
e to
inte
grit
y m
anag
emen
t an
d an
ti-co
rrup
tion
mec
hani
sms
and
impr
oved
con
sequ
ence
man
agem
ent f
or n
on-c
ompl
ianc
e
St
rate
gic
prog
ram
mes
und
er p
illar
6:
Stra
tegi
c Pr
ogra
mm
e Ra
tion
ale
6.1
Deve
lop re
gulat
ions a
nd gu
idelin
es to
supp
ort t
he im
plem
enta
tion o
f the
Publi
c Adm
inistr
ation
Man
agem
ent A
ct, Ac
t 11 o
f 201
4 in t
he
publi
c ser
vice a
nd m
unici
palit
ies.
6.2
Deve
lop su
ppor
ting g
uideli
nes a
nd tr
aining
for t
he im
plem
enta
tion o
f the
Loca
l Gov
ernm
ent A
nti-C
orru
ption
Stra
tegy
.
6.3
Inve
stiga
te an
d ins
titut
e app
ropr
iate d
iscipl
inary
proc
edur
es ag
ainst
non-
com
plian
ce by
an ap
prop
riate
ly pla
ced a
nd ca
pacit
ated
unit
in
Gove
rnm
ent,
such
as th
e Pub
lic Ad
mini
strat
ion Et
hics,
Inte
grity
and D
iscipl
inary
Tech
nical
Assis
tanc
e Unit
in th
e Dep
artm
ent o
f Pub
lic
Serv
ice an
d Adm
inistr
ation
(esta
blish
ed by
the P
ublic
Adm
inistr
ation
Man
agem
ent A
ct). T
his ne
wly c
reat
ed un
it, or
anot
her
ap
prop
riate
ly pla
ced b
ody,
shou
ld be
give
n the
man
date
to en
sure
that
disci
plina
ry ac
tion i
s tak
en ag
ainst
emplo
yees
foun
d guil
ty of
o�
ence
s, an
d tha
t whe
re th
ere i
s rea
sona
ble su
spici
on of
illeg
al ac
tivity
this
is ha
nded
over
to la
w en
force
men
t. Fu
rther,
it sh
ould
be
prov
ided w
ith th
e res
ourci
ng to
unde
rtake
this
work
e�ec
tively
.
6.4
Imple
men
t tra
ining
for e
thics
o�ce
rs an
d per
sonn
el re
spon
sible
for d
etec
ting a
nd re
porti
ng on
corru
ption
in go
vern
men
t dep
artm
ents
an
d mun
icipa
lities
. The
train
ing sh
ould
be pr
actic
al in
cont
ent:
helpi
ng pe
rsonn
el de
al wi
th th
e situ
ation
s the
y are
likely
to fa
ce in
the
wo
rkpla
ce.
6.5
Stre
ngth
en go
vern
men
t em
ploye
e well
ness
prog
ram
mes
in th
e are
a of p
erso
nal �
nanc
ial m
anag
emen
t, th
roug
h im
prov
ed tr
aining
,
awar
enes
s rais
ing an
d deb
t cou
nsell
ing se
rvice
s.
6.6
Imple
men
t awa
rene
ss-ra
ising
prog
ram
mes
on th
e ant
i-cor
rupt
ion re
quire
men
ts fo
r priv
ate �
rms a
nd st
ate-
owne
d ent
ities
cont
ained
in
the C
ompa
nies A
ct, th
e Pre
vent
ion an
d Com
batin
g of C
orru
pt Ac
tiviti
es Ac
t and
othe
r rele
vant
piec
es of
legis
lation
, in pa
rtner
ship
with
or
ganis
ed bu
sines
s and
prof
essio
nal a
ssocia
tions
.
6.7
Deve
lop gu
idelin
es to
supp
ort c
ompli
ance
with
anti-
corru
ption
legis
lation
by pr
ivate
com
panie
s and
SOEs
. The
se gu
idelin
es co
uld be
de
velop
ed th
roug
h a pa
rtner
ship
betw
een g
over
nmen
t and
orga
nised
busin
ess.
6.8
Deve
lop an
anti-
corru
ption
com
plian
ce cu
lture
in pr
ivate
com
panie
s and
stat
e-ow
ned e
ntiti
es th
roug
h the
deve
lopm
ent o
f a ne
w
o�en
ce, i.
e. fai
lure b
y a co
mm
ercia
l org
anisa
tion t
o pre
vent
bribe
ry an
d pos
sibly
othe
r for
ms o
f cor
rupt
ion, w
hich r
equir
es co
mpa
nies t
o
proa
ctive
ly pu
t mea
sure
s in p
lace t
o man
age t
he ris
k of c
orru
ption
and t
o ens
ure t
hat t
hey h
ave a
defen
ce ag
ainst
the o
�enc
e of f
ailur
e
to pr
even
t brib
ery a
nd ot
her f
orm
s of c
orru
ption
.
The A
ct es
tabli
shes
a Pu
blic A
dmini
strat
ion Et
hics,
Inte
grity
and D
iscipl
inary
Tech
nical
Assis
tanc
e Unit
in th
e DPS
A; re
gulat
es pu
blic
serv
ants
cond
uctin
g bus
iness
with
the S
tate
; pro
vides
for t
he es
tabli
shm
ent o
f the
Nat
ional
Scho
ol of
Gov
ernm
ent;
prov
ides f
or th
e M
iniste
r of P
ublic
Serv
ice an
d Adm
inistr
ation
to se
t mini
mum
norm
s and
stan
dard
s for
publi
c adm
inistr
ation
; and
esta
blish
es an
O�
ce of
Stan
dard
s and
Com
plian
ce to
ensu
re co
mpli
ance
with
mini
mum
norm
s and
stan
dard
s.
The L
ocal
Gove
rnm
ent A
nti-C
orru
ption
Stra
tegy
was
laun
ched
this
year,
and o
utlin
es sp
eci�
c pro
gram
mes
for r
educ
ing co
rrupt
ion
and i
mpr
oving
acco
unta
bility
in lo
cal g
over
nmen
t.
Audit
or-G
ener
al an
d Acco
unta
nt-G
ener
al �n
dings
rega
rding
case
s of p
ossib
le or
actu
al co
rrupt
ion an
d non
-com
plian
ce w
ith
regu
lation
s and
code
s gov
ernin
g pub
lic se
ctor e
mplo
yees
’ cond
uct a
re no
t bein
g su�
cient
ly ac
ted u
pon b
y Acco
untin
g O�
cers
and
Exec
utive
Auth
oriti
es in
Gov
ernm
ent,
nor a
re th
e rec
omm
enda
tions
of th
e Pub
lic Se
rvice
Com
miss
ion be
ing ac
ted o
n with
rega
rd to
co
n�ict
s of in
tere
st as
discl
osed
in Fi
nanc
ial D
isclos
ure f
orm
s.
Traini
ng is
need
ed in
the a
rea o
f enf
orce
men
t and
inte
grity
man
agem
ent i
n gov
ernm
ent d
epar
tmen
ts an
d mun
icipa
lities
. Per
sonn
el as
signe
d to r
eleva
nt po
sts in
gove
rnm
ent o
rgan
isatio
ns of
ten d
o not
have
spec
ialise
d tra
ining
to su
ppor
t the
m in
helpi
ng to
prev
ent,
dete
ct an
d act
on po
ssible
case
s of c
orru
ption
.
The l
evel
of in
debt
edne
ss of
som
e pub
lic se
rvan
ts an
d the
risk t
hat t
his m
ight s
ee em
ploye
es m
ore l
ikely
to en
gage
in th
eft o
r oth
er
form
s of �
nanc
ial m
iscon
duct
requ
ires a
meli
orat
ion th
roug
h im
prov
ed tr
aining
and c
ouns
elling
supp
ort o
n man
aging
perso
nal
�nan
ces.
The a
nti-c
orru
ption
com
plian
ce re
quire
men
ts fo
r �rm
s are
not w
idely
know
n in t
he bu
sines
s sec
tor.
The r
egula
tions
of th
e Com
panie
s Act
do no
t spe
cify i
n det
ail w
hat k
inds o
f ant
i-cor
rupt
ion co
mpli
ance
mea
sure
s sho
uld be
un
derta
ken b
y �rm
s.
Som
e com
panie
s hav
e bee
n ver
y pro
activ
e in p
uttin
g in p
lace m
echa
nism
s to r
educ
e the
ir exp
osur
e to b
riber
y and
othe
r for
ms o
f co
rrupt
ion in
Sout
h Afri
ca an
d oth
er co
untri
es. H
owev
er, co
mpa
nies f
ace a
repu
tatio
nal r
isk fo
r rep
ortin
g on c
orru
ption
, and
putti
ng
in pla
ce an
ti-co
rrupt
ion co
mpli
ance
mea
sure
s can
be se
en as
yet a
noth
er co
mpli
ance
burd
en or
cost.
Awar
enes
s-rais
ing ca
mpa
igns
are n
ot su
�cie
nt: a
n app
ropr
iate s
et of
pres
sure
s or in
cent
ives i
s nee
ded t
o im
prov
e rep
ortin
g on b
riber
y and
to im
prov
e com
plian
ce
with
anti-
corru
ption
regu
lation
s by c
ompa
nies. T
here
are s
ucce
ssful
inter
natio
nal m
odels
that
Sout
h Afri
ca ca
n dra
w fro
m. T
he
Unite
d King
dom
, for e
xam
ple, h
as cr
eate
d a co
rpor
ate o
�enc
e kno
wn as
“the
failu
re by
a co
mm
ercia
l org
anisa
tion t
o pre
vent
br
ibery
”. This
oblig
es co
mpa
nies a
ssocia
ted w
ith th
e Unit
ed Ki
ngdo
m to
proa
ctive
ly pu
t mea
sure
s in p
lace t
o man
age t
he br
ibery
risk
to en
sure
that
they
have
a de
fence
again
st th
is ne
w “co
rpor
ate o
�enc
e”. Th
e Unit
ed Ki
ngdo
m G
over
nmen
t has
also
issu
ed ve
ry cl
ear
guide
lines
to co
rpor
ates
abou
t wha
t the
y reg
ard a
s “ad
equa
te pr
oced
ures
” to p
reve
nt br
ibery,
whic
h, if
prop
erly
put i
n plac
e, wi
ll co
nstit
ute a
defen
ce ag
ainst
a cha
rge o
f fail
ing to
prev
ent b
riber
y. Th
e UK R
egula
tor u
tilise
s defe
rred p
rose
cutio
n agr
eem
ents
as an
inc
entiv
e for
com
panie
s to e
nter
nego
tiatio
ns w
here
bribe
ry vi
olatio
ns ar
e alle
ged.
Whe
re ve
ry cl
ear e
viden
ce of
corru
ption
is
obta
ined,
law en
force
men
t stil
l inve
stiga
tes a
nd ca
n pro
secu
te cr
imina
l acti
vity.
Thes
e init
iative
s are
havin
g a dr
amat
ic e�
ect o
n m
ultina
tiona
l priv
ate s
ecto
r com
panie
s.
A ra
nge
of la
ws i
n So
uth
Afr
ica
requ
ire o
rgan
isat
ions
in G
over
nmen
t and
bus
ines
s to
impl
emen
t mec
hani
sms a
imed
at r
educ
ing
corr
uptio
n an
d su
ppor
ting
inte
grity
man
agem
ent i
n th
eir
orga
nisa
tions
. For
exa
mpl
e, in
the
cas
e of
the
bus
ines
s se
ctor
and
sta
te-o
wne
d en
titie
s, th
e Pr
even
tion
and
Com
batin
g of
Cor
rupt
Act
iviti
es A
ct o
utlin
es r
epor
ting
requ
irem
ents
on
corr
uptio
n, a
nd t
he C
ompa
nies
Act
req
uire
s co
mpa
nies
to
esta
blis
h So
cial
and
Eth
ics
Com
mitt
ees
whi
ch a
re t
o ov
erse
e, a
mon
g ot
her
thin
gs, t
he d
evel
opm
ent
of a
nti-c
orru
ptio
n co
mpl
ianc
e m
echa
nism
s to
redu
ce c
ompa
nies
’ exp
osur
e to
brib
ery
and
othe
r cor
rupt
ion-
rela
ted
risks
. The
dia
gnos
tics d
evel
oped
in p
repa
ratio
n fo
r thi
s str
ateg
y sh
owed
that
com
plia
nce
with
the
se r
egul
atio
ns is
stil
l too
low
. In
the
gove
rnm
ent
sect
or, c
lear
reg
ulat
ions
, pol
icy
guid
elin
es a
nd c
odes
of
cond
uct
have
bee
n de
velo
ped
to s
uppo
rt in
tegr
ity m
anag
emen
t, in
clud
ing
the
Fina
ncia
l D
iscl
osur
e Fr
amew
ork,
gui
delin
es a
roun
d re
port
ing
on s
uspe
cted
cas
es o
f co
rrup
tion,
on
inve
stig
atio
ns w
ithin
dep
artm
ents
, etc
. How
ever
, Pub
lic S
ervi
ce
Com
mis
sion
and
Aud
itor-
Gen
eral
rep
orts
and
the
�nd
ings
of
the
Acco
unta
nt-G
ener
al h
ave
note
d th
e lo
w le
vels
of
appr
opria
te s
anct
ion
appl
ied
to e
mpl
oyee
s an
d m
embe
rs o
f th
e ex
ecut
ive
in G
over
nmen
t who
do
not a
dher
e to
thes
e co
des
and
regu
latio
ns, a
nd th
ose
susp
ecte
d of
ille
gal a
ctiv
ity. E
�ort
s ar
e ne
eded
to e
nsur
e gr
eate
r com
plia
nce
and
cons
eque
nce
man
agem
ent i
n or
gani
satio
ns in
the
gove
rnm
ent a
nd b
usin
ess
sect
ors
thro
ugh
both
enf
orce
men
t and
pre
vent
ativ
e m
easu
res.
National Anti-Corruption Strategy Discussion Document27
Pilla
r 7: S
tren
gthe
n ov
ersi
ght m
echa
nism
s (in
the
gove
rnm
ent s
ecto
r)
The
Cons
titut
ion
of th
e Re
publ
ic o
f Sou
th A
fric
a es
tabl
ishe
d a
num
ber o
f ove
rsig
ht b
odie
s w
ith re
leva
nce
to a
nti-c
orru
ptio
n e�
orts
. The
se in
clud
e th
e Pu
blic
Pro
tect
or,
the
Aud
itor-
Gen
eral
, and
the
Pub
lic S
ervi
ce C
omm
issi
on.
The
natio
nal
and
prov
inci
al p
arlia
men
ts (
legi
slat
ures
), an
d th
e lo
cal
gove
rnm
ent
coun
cils
are
to
prov
ide
gene
ral o
vers
ight
ove
r the
act
iviti
es o
f gov
ernm
ent d
epar
tmen
ts a
nd a
genc
ies.
In a
dditi
on, b
odie
s ha
ve b
een
esta
blis
hed
in le
gisl
atio
n to
pro
vide
ove
rsig
ht o
f par
ticul
ar
sect
ors,
suc
h as
pol
icin
g an
d th
e in
telli
genc
e se
rvic
es. T
he in
tegr
ity a
nd e
�ect
iven
ess
of th
ese
bodi
es is
cen
tral
ly im
port
ant i
n th
e �g
ht a
gain
st c
orru
ptio
n.
Stra
tegi
c pr
ogra
mm
es u
nder
pill
ar 7
:
Stra
tegi
c Pr
ogra
mm
e Ra
tion
ale
1.1
Ensu
re ap
prop
riate
reso
urcin
g and
ethic
al lea
dersh
ip of
Chap
ter 9
and 1
0 Con
stitu
tiona
l ove
rsigh
t
bodie
s, an
d of o
versi
ght b
odies
of th
e poli
ce an
d int
ellige
nce s
ervic
es so
as to
build
publi
c con
�den
ce
in th
eir ov
ersig
ht ro
le an
d stre
ngth
en th
eir e�
ectiv
enes
s.
1.2
Deve
lop an
d im
plem
ent p
ublic
awar
enes
s-rais
ing ca
mpa
igns a
bout
the r
ole an
d im
porta
nce o
f
Chap
ter 9
and 1
0 ove
rsigh
t bod
ies in
stre
ngth
ening
dem
ocra
cy an
d im
prov
ing go
vern
men
t
acco
unta
bility
.
1.3
Initi
ate p
ublic
conv
ersa
tion a
bout
the r
ole an
d man
date
of th
e Pub
lic Se
rvice
Com
miss
ion in
str
engt
henin
g dem
ocra
cy, im
prov
ing ov
ersig
ht of
gove
rnm
ent e
mplo
yees
and b
uildin
g a pr
ofes
siona
l
publi
c sec
tor, a
nd de
velop
prop
osals
for h
ow to
stre
ngth
en th
e aut
horit
y of t
he Co
mm
ission
’s
reco
mm
enda
tions
in lin
e with
reco
mm
enda
tions
mad
e in t
he N
ation
al De
velop
men
t Plan
.
1.4
Impr
ove t
he ca
pacit
y of m
unici
pal o
versi
ght f
uncti
ons t
hrou
gh:
•
Traini
ng in
terv
entio
ns fo
r cou
ncillo
rs an
d mun
icipa
l man
ager
s.
• Tra
ining
for c
ivil s
ociet
y org
anisa
tions
to pl
ay a
stron
ger r
ole in
publi
c par
ticipa
tion p
roce
sses.
•
Natio
nal a
nd re
giona
l dial
ogue
s on t
he na
ture
and p
urpo
se of
acco
unta
bility
and o
versi
ght
mec
hanis
m in
loca
l gov
ernm
ent.
Thes
e ove
rsigh
t bod
ies sh
ould
be ap
prop
riate
ly re
sour
ced a
nd in
depe
nden
t of p
ressu
re fr
om th
e exe
cutiv
e or
othe
r sec
tors
to pl
ay th
eir ro
le in
actin
g aga
inst a
buse
s of p
ower
and o
ther
form
s of c
orru
ption
.
Thes
e bod
ies ar
e vita
lly im
porta
nt in
ensu
ring i
mpr
oved
gove
rnm
ent a
ccoun
tabil
ity an
d req
uire t
he ac
tive
supp
ort o
f mem
bers
of th
e pub
lic.
Over
the l
ast 2
0 yea
rs, th
e Pub
lic Se
rvice
Com
miss
ion ha
s play
ed a
valua
ble ro
le in
mon
itorin
g the
cond
uct o
f pu
blic s
erva
nts a
nd m
embe
rs of
the e
xecu
tive.
Howe
ver, t
he Co
mm
ission
does
not h
ave t
he m
anda
te to
en
sure
com
plian
ce by
depa
rtmen
ts an
d poli
tician
s with
its �
nding
s. A p
ublic
deba
te on
the p
ossib
le str
engt
hene
d role
of th
e Com
miss
ion w
ould
be va
luable
.
At lo
cal g
over
nmen
t lev
el, st
ructu
res e
stabli
shed
to im
prov
e ove
rsigh
t of m
unici
pal d
ecisi
on-m
aking
and
spen
ding,
such
as th
e Mun
icipa
l Pub
lic Ac
coun
ts Co
mm
ittee
s, ar
e not
wor
king a
s e�e
ctive
ly as
they
shou
ld.
National Anti-Corruption StrategyDiscussion Document 28
Pilla
r 8: S
tren
gthe
n th
e re
sour
cing
, coo
pera
tion
and
inde
pend
ence
of d
edic
ated
ant
i-cor
rupt
ion
agen
cies
Sout
h A
fric
a fo
llow
s a
mul
ti-ag
ency
app
roac
h to
com
batin
g co
rrup
tion:
it d
oes
not
have
one
ent
ity s
olel
y fo
cuse
d on
enf
orce
men
t an
d an
ti-co
rrup
tion
mea
sure
s.
Irres
pect
ive
of w
heth
er c
ount
ries
follo
w a
sin
gle
or m
ulti
-age
ncy
mod
el, t
hose
tha
t ha
ve b
een
succ
essf
ul i
n re
duci
ng c
orru
ptio
n ha
ve d
emon
stra
ted
a nu
mbe
r of
im
port
ant c
hara
cter
istic
s.
Sout
h A
fric
a m
ust e
nsur
e th
at it
s an
ti-co
rrup
tion
syst
em d
emon
stra
tes
the
follo
win
g ch
arac
teris
tics:
•
Inde
pend
ence
from
the
exec
utiv
e, a
nd fr
om s
ecto
ral i
nter
ests
. •
Acc
ount
abili
ty, t
hrou
gh c
ivili
an a
nd/o
r par
liam
enta
ry o
vers
ight
. •
A tr
ansp
aren
t pro
cess
for a
ppoi
ntin
g le
ader
s an
d se
nior
man
ager
s on
the
basi
s of
thei
r int
egrit
y, c
ompe
tenc
y an
d sk
ills.
•
Job
secu
rity
thro
ugh
fair
and
tran
spar
ency
pro
cess
es fo
r dis
mis
sing
sta
�.
• A
dequ
ate
reso
urce
s in
the
form
of b
udge
t and
infr
astr
uctu
re.
• A
ppro
pria
tely
ski
lled
sta�
that
are
spe
cial
ised
and
hav
e be
en a
ppro
pria
tely
trai
ned.
St
rate
gic
prog
ram
mes
und
er p
illar
8:
Stra
tegi
c Pr
ogra
mm
e Ra
tion
ale
8.1
Ensu
re th
e stru
ctura
l and
oper
ation
al ind
epen
denc
e of k
ey ag
encie
s inv
olved
in in
vesti
gatin
g and
pros
ecut
ing co
rrupt
ion (c
urre
ntly
the
Di
recto
rate
for P
riorit
y Crim
e Inv
estig
ation
; the
Spec
ial In
vesti
gatin
g Unit
; and
the N
ation
al Pr
osec
uting
Auth
ority
) thr
ough
:
• Im
prov
ing th
e tra
nspa
renc
y and
rigou
r of t
he pr
oces
ses f
or se
lectin
g and
dism
issing
senio
r lea
ders
in th
ese o
rgan
isatio
ns.
•
Ensu
ring o
versi
ght o
f the
se ag
encie
s wor
k thr
ough
dire
ct re
porti
ng to
parli
amen
t or s
ome c
ivil o
versi
ght b
ody.
8.2
Revie
w an
d im
prov
e the
desig
n of a
coor
dinat
ing bo
dy fo
r ant
i-cor
rupt
ion w
ork,
ensu
ring t
hat t
he bo
dy ha
s:
• su
fficie
nt le
gal s
tatu
re
• is
appr
opria
tely
struc
ture
d
• is
appr
opria
tely
reso
urce
d to b
e effe
ctive
in co
ordin
ating
anti-
corru
ption
dete
ction
, inve
stiga
tion a
nd pr
osec
ution
.
Th
is sh
ould
includ
e im
prov
ed m
echa
nism
s for
supp
ortin
g:
• Pr
osec
ution
-guid
ed in
vesti
gatio
ns, a
nd fo
r
• Tra
cking
case
s of c
orru
ption
in G
over
nmen
t whe
re re
levan
t par
ties a
re no
t crim
inally
char
ged,
but w
here
disci
plina
ry ac
tion i
s
re
com
men
ded b
y the
inve
stiga
ting u
nit, i.
e. m
onito
ring c
onse
quen
ce m
anag
emen
t of s
uch c
ases
by or
ganis
ation
s in g
over
nmen
t.
8.3
Unde
rtake
capa
city b
uildin
g, inc
luding
train
ing, fo
r impr
oved
enfo
rcem
ent,
amon
g oth
ers:
•
Impr
oved
syste
ms f
or ca
ptur
ing an
d ana
lysing
inte
lligen
ce an
d dat
a on r
epor
ted o
r sus
pecte
d cas
es of
corru
ption
in su
ppor
t of
inves
tigat
ions,
risk a
ssessm
ents,
etc
•
Traini
ng fo
r inve
stiga
tors
on bu
ilding
succe
ssful
case
s und
er th
e Pre
vent
ion an
d Com
batin
g of C
orru
pt Ac
tiviti
es Ac
t
• Tra
ining
on de
aling
with
soph
istica
ted f
orm
s of fi
nanc
ial cr
ime a
nd cy
bercr
ime.
8.4
Impr
ove b
ilate
ral c
oope
ratio
n with
othe
r cou
ntrie
s in t
he �g
ht ag
ainst
corru
ption
(and
�nan
cial c
rimes
in pa
rticu
lar) e
nsur
ing m
utua
l
legal
assis
tanc
e in i
nves
tigat
ions,
pros
ecut
ions a
nd ju
dicial
proc
eedin
gs in
relat
ion to
corru
ption
.
8.5
Stre
ngth
en en
gage
men
t bet
ween
Sout
h Afri
ca an
d the
relev
ant i
nter
natio
nal c
usto
dians
of th
e agr
eem
ents
to w
hich S
outh
Afric
a is a
sig
nato
ry.
Furth
er e�
orts
are r
equir
ed in
Sout
h Afri
ca to
build
the i
ndep
ende
nce o
f the
crim
inal ju
stice
agen
cies t
o sup
port
anti-
corru
ption
wor
k esp
ecial
ly in
pursu
ing se
nior p
olitic
ians,
gove
rnm
ent o
�cia
ls, bu
sines
s peo
ple an
d oth
er
leade
rs, an
d buil
ding p
ublic
con�
denc
e in g
over
nmen
t’s co
mm
itmen
t to r
educ
ing co
rrupt
ion. T
he N
ation
al De
velop
men
t Plan
high
light
s the
impo
rtanc
e of in
sulat
ing cr
imina
l justi
ce ag
encie
s fro
m po
litica
l pre
ssure.
Ther
e is a
need
for im
prov
ed co
ordin
ation
betw
een t
he va
rious
crim
inal ju
stice
agen
cies (
and o
ther
s in G
over
nmen
t ta
sked
with
com
batin
g cor
rupt
ion) i
n Sou
th Af
rica.
The P
reve
ntion
and C
omba
ting o
f Cor
rupt
Activ
ities
Act h
as th
us fa
r rar
ely be
en us
ed to
pros
ecut
e cas
es of
corru
ption
. Po
lice a
re m
ore l
ikely
to us
e leg
islat
ion pe
rtaini
ng to
frau
d and
othe
r �na
ncial
crim
es th
an th
is Ac
t. Tra
ining
on
build
ing ca
ses u
nder
the A
ct co
uld as
sist w
ith im
prov
ing pr
osec
ution
rate
s.
The c
halle
nges
with
data
on co
rrupt
ion an
d ant
i-cor
rupt
ion ha
ve al
read
y bee
n men
tione
d.
Sout
h Afri
ca is
a sig
nato
ry to
a nu
mbe
r of in
tern
ation
al co
nven
tions
and t
reat
ies th
at co
mm
it th
e cou
ntry
to
imple
men
ting p
artic
ular in
terv
entio
ns ai
med
at re
ducin
g cor
rupt
ion. Im
prov
ed m
echa
nism
s are
need
ed to
incre
ase
the c
ount
ry’s c
ompli
ance
with
the v
ariou
s con
vent
ions a
nd ag
reem
ents,
impr
ove c
oope
ratio
n bet
ween
Sout
h Afri
ca
and o
ther
coun
tries
in th
e �gh
t aga
inst c
orru
ption
, esp
ecial
ly �n
ancia
l crim
es, a
nd to
stre
ngth
en en
gage
men
t with
th
e rele
vant
inte
rnat
ional
custo
dians
of th
ese a
gree
men
ts.
National Anti-Corruption Strategy Discussion Document29
Pilla
r 9: V
ulne
rabl
e se
ctor
man
agem
ent:
build
spe
ci�c
pro
gram
mes
to re
duce
corr
upti
on a
nd im
prov
e in
tegr
ity
in s
ecto
rs p
arti
cula
rly
vuln
erab
le to
cor
rupt
ion
Ce
rtai
n se
rvic
es o
r sec
tors
are
mor
e vu
lner
able
to c
orru
ptio
n th
an o
ther
s. T
he W
orld
Ban
k an
d th
e G
roup
of 2
0 su
ppor
t and
hav
e in
tern
atio
nally
prio
ritis
ed a
num
ber o
f in
dust
ry s
ecto
rs in
whi
ch g
over
nmen
ts a
nd b
usin
esse
s pl
ay im
port
ant
role
s fo
r pr
iorit
ised
focu
s re
gard
ing
anti-
corr
uptio
n m
easu
res.
In m
any
coun
trie
s, t
hese
sec
tors
in
clud
e th
ose
serv
ices
in w
hich
pub
lic s
ecto
r pe
rson
nel h
ave
a gr
eat
deal
of p
ower
ove
r th
e fa
te o
f mem
bers
of t
he p
ublic
suc
h as
pol
icin
g, im
mig
ratio
n an
d bo
rder
co
ntro
l, co
rrec
tiona
l ser
vice
s, s
ocia
l ser
vice
s, th
e al
loca
tion
of li
cenc
es o
r cer
ti�ca
tes,
e.g
. min
ing
or e
nviro
nmen
tal e
xplo
ratio
n/ex
ploi
tatio
n, o
r are
as th
at a
re o
f nat
iona
l or
str
ateg
ic in
tere
st t
o th
e de
velo
pmen
t or
eco
nom
ic s
tabi
lity
of t
hat
coun
try,
e.g
. ene
rgy
prov
isio
n or
infr
astr
uctu
re d
evel
opm
ent.
Impr
ovin
g th
e in
tegr
ity o
f th
ese
sect
ors
in a
n in
tegr
ated
man
ner m
ust t
here
fore
be
an im
port
ant c
ompo
nent
of t
he N
atio
nal A
nti-C
orru
ptio
n St
rate
gy.
In li
ne w
ith c
urre
nt g
over
nmen
t pro
gram
mes
, the
em
phas
is o
n sp
eci�
c at
tent
ion
to v
ulne
rabl
e se
ctor
s al
read
y ex
ists
. In
keep
ing
with
this
app
roac
h it
is p
ropo
sed
that
th
e se
ctor
s in
the
Just
ice,
Crim
e Pr
even
tion
and
Secu
rity
Clus
ter a
re p
riorit
ised
�rs
t und
er th
is s
trat
egic
pill
ar, p
artic
ular
ly p
olic
ing,
imm
igra
tion
and
bord
er c
ontr
ol, a
nd
corr
ectio
nal s
ervi
ces.
Per
sonn
el in
the
se s
ecto
rs a
re in
clo
se p
roxi
mity
to
crim
e ne
twor
ks, a
nd in
Sou
th A
fric
a, t
here
are
a n
umbe
r of
add
ition
al c
onte
xt-s
peci
�c a
nd
hist
oric
al f
acto
rs t
hat
have
sha
ped
the
Just
ice,
Crim
e Pr
even
tion
and
Secu
rity
Clus
ter’s
vul
nera
bilit
y to
cor
rupt
ion.
Whi
le t
hese
ser
vice
s ar
e pa
rtic
ular
ly v
ulne
rabl
e to
co
rrup
tion,
they
are
als
o vi
tal t
o th
e �g
ht a
gain
st c
orru
ptio
n.
Stra
tegi
c pr
ogra
mm
es u
nder
pill
ar 9
:St
rate
gic
Prog
ram
me
Rati
onal
e
9.1
Deve
lopm
ent o
f spe
ci�c i
ndus
try, s
ecto
r or d
epar
tmen
tal a
nti-c
orru
ption
stra
tegie
s for
prior
itise
d
area
s (as
appli
cable
).
9.2
Deve
lopm
ent o
f app
ropr
iately
reso
urce
d pro
ject p
lans t
o im
plem
ent f
ocus
ed, p
arall
el, m
ulti-l
evel
int
erve
ntion
s to m
itiga
te ve
ry sp
eci�
c risk
s in a
secto
r.
9.3
Cent
rally
mon
itor a
nd ev
aluat
e pro
gres
s on i
mple
men
tatio
n of t
hese
indu
stry/
depa
rtmen
tal
an
ti-co
rrupt
ion st
rate
gies a
nd/o
r pro
jects
with
in a s
ecto
r.
Dedic
ated
indu
stry,
secto
r or d
epar
tmen
t-spe
ci�c a
nti-c
orru
ption
stra
tegie
s are
need
ed to
guide
and
impr
ove a
nti-c
orru
ption
e�or
ts in
prior
itise
d are
as, c
urre
ntly
in pa
rticu
lar in
the J
ustic
e, Cr
ime P
reve
ntion
an
d Sec
urity
clus
ter. T
hese
shou
ld inc
lude:
•
Each
of th
e dep
artm
ents
unde
r a sp
ecifi
c sec
tor/i
ndus
try de
velop
ing (o
r rev
iewing
, whe
re th
ese
have
been
deve
loped
) det
ailed
and a
ppro
priat
ely co
sted a
nti-c
orru
ption
stra
tegie
s and
proje
cts.
•
Thes
e sho
uld al
locat
e tim
efram
es an
d role
s as w
ell as
resp
onsib
ilities
for im
plem
enta
tion o
f the
va
rious
com
pone
nts o
f the
stra
tegy
/pro
ject (
includ
ing bu
sines
s sec
tor p
artic
ipatio
n).
•
The i
nten
tion i
s tha
t a st
rate
gy sh
ould
targ
et a
perio
d of 5
�10 y
ears,
and r
elate
d pro
jects
targ
et
pe
riods
of 3-
5 yea
rs un
til ris
ks in
thes
e sec
tors,
indu
stries
or de
partm
ents
are s
igni�
cant
ly
re
duce
d or s
yste
ms r
egula
rised
.
• Th
ese s
hould
be au
gmen
ted w
ith an
d sup
port
the r
egula
r/ins
titut
ionali
sed m
echa
nism
s to
impr
ove i
nteg
rity m
anag
emen
t pro
fessio
nalis
ation
and d
iscipl
inary
actio
n or in
itiat
e
inv
estig
ation
s aga
inst c
orru
pt pa
rties
in th
e prio
ritise
d clus
ter.
National Anti-Corruption StrategyDiscussion Document 30
6. In
stit
utio
nal m
echa
nism
s to
impl
emen
t the
str
ateg
y
6.1
Key
depe
nden
cies
for t
he N
ACS
will
be
de�n
ed a
s pa
rt o
f the
con
sulta
tion
proc
ess.
6.2
Impl
emen
tatio
n m
echa
nism
s
A l
ead
orga
nisa
tion
shou
ld b
e id
enti�
ed t
o su
ppor
t the
impl
emen
tatio
n, c
oord
inat
ion
and
mon
itorin
g of
the
Nat
iona
l A
nti-
Corr
uptio
n St
rate
gy,
and
to a
ct a
s a
secr
etar
iat t
o or
gani
satio
nal p
latf
orm
s th
at a
re im
port
ant f
or it
s de
liver
y, s
uch
as th
e N
atio
nal A
nti -
Cor
rupt
ion
Foru
m. I
t is
prop
osed
that
suc
h a
unit
is e
stab
lishe
d in
the
Pres
iden
cy. A
pro
pose
d st
ruct
ure
is o
utlin
ed
in th
e di
agra
m b
elow
.
MIN
ISTE
RIA
L O
VERS
IGH
TW
ith d
esig
nate
d as
pol
itica
l cha
mpi
on o
f the
�gh
tag
ains
t cor
rupt
ion
Body
to c
oord
inat
e an
ti-co
rrup
tion
agen
cies
Func
tions
:O
pera
tiona
l coo
pera
tion
on la
w e
nfor
cem
ent
and
inte
llige
nce
gath
erin
g
Nat
iona
l Ant
i-cor
rput
ion
Foru
m o
r oth
erin
ter-
sect
oral
coo
rdin
atin
g bo
dyCh
air:
Min
iste
r (po
litic
al c
ham
pion
)
Opt
ion
1: C
ompo
sitio
n, o
pera
tiona
l and
fund
ing
mod
aliti
es to
be
dete
rmin
ed th
roug
h a
polit
ical
cons
ulta
tion
proc
ess,
star
ting
imm
edia
tely
.
Opt
ion
2: C
ompo
sitio
n, o
pera
tiona
l and
fund
ing
mod
aliti
es to
be
dete
rmin
ed th
roug
h co
nsul
tatio
npr
oces
s (ro
ad m
ap) a
nd in
ter-
sect
oral
bod
yes
tabl
ishe
d at
end
of t
he p
roce
ss.
Prop
osed
func
tions
:•
Prom
ote
cohe
sion
and
com
mon
pur
pose
in
so
ciet
y on
�gh
ting
corr
uptio
n•
Alig
n an
d co
ordi
nate
sec
tora
l ant
i-cor
rupt
ion
pr
ogra
mm
es•
Esta
blis
h, c
oord
inat
e an
d m
onito
r int
er-
se
ctor
al w
orki
ng g
roup
s on
them
atic
s/sp
eci�
c
area
s•
Out
com
e m
onito
ring
of th
e N
atio
nal A
nti-
co
rrup
tion
Stra
tegy
O�
ce fo
r the
pro
mot
ion
of in
tegr
ity
and
�ght
ing
corr
uptio
nPe
rman
ent O
�ce
with
per
man
ent h
ead
and
sta�
and
prog
ram
mic
bud
get
Func
tion
• Po
licy-
mak
ing
on fi
ghtin
g co
rrpu
tion
• Co
ordi
natio
n of
impl
emen
tatio
n of
the
Nat
iona
l
Ant
i-cor
rupt
ion
Stra
tegy
• M
onito
ring
the
effica
cy o
f the
ant
i-cor
rupt
ion
sy
stem
• M
onito
ring
the
impl
emen
tatio
n of
the
Nat
iona
l
Ant
i-cor
rupt
ion
Stra
tegy
• Re
port
ing
(dom
estic
and
inte
rnat
iona
l ins
trum
ents
/
foru
ms)
• Ev
alut
ion
• Co
mm
unic
atio
n, a
war
enes
s an
d ed
ucat
ion
• Se
cret
aria
t sup
port
to th
e in
ter-
sect
oral
co
ordi
natin
g bo
dy
National Anti-Corruption Strategy Discussion Document31
App
endi
x A
: Roa
dmap
for d
evel
opin
g a
�nal
Nat
iona
l Ant
i-Cor
rupt
ion
stra
tegy
Purp
ose
The
purp
ose
of th
is ro
adm
ap is
to o
utlin
e th
e pr
oces
s to
be
follo
wed
in th
e de
velo
pmen
t of t
he N
atio
nal A
nti-c
orru
ptio
n St
rate
gy.
The
goal
s of
the
prop
osed
pro
cess
are
to:
•
Achi
eve
a “w
hole
of g
over
nmen
t and
soc
iety
” app
roac
h to
the
fight
aga
inst
cor
rupt
ion.
•
Be o
pen,
tran
spar
ent a
nd in
clus
ive
of a
ll se
ctor
s of
Sou
th A
fric
an s
ocie
ty.
•
Arr
ive
at a
robu
st N
atio
nal A
nti-C
orru
ptio
n St
rate
gy th
at h
as b
uy-in
from
the
stat
e, b
usin
ess
and
civi
l soc
iety
.
• Fo
ster
ow
ners
hip
of th
e pr
oces
s an
d th
e re
sulti
ng N
atio
nal A
nti-C
orru
ptio
n St
rate
gy b
y al
l the
sec
tors
.
Prop
osed
pro
cess
Belo
w is
the
cons
ulta
tion
proc
ess
to b
e fo
llow
ed, f
rom
the
appr
oval
of t
he c
onso
lidat
ed c
onsu
ltatio
n do
cum
ent t
o th
e ap
prov
al o
f the
�na
l na
tiona
l ant
i-cor
rupt
ion
stra
tegy
and
its
impl
emen
tatio
n pl
an.
This
com
preh
ensi
ve p
roce
ss is
aim
ed a
t ach
ievi
ng w
ide
cons
ulta
tion,
giv
ing
the
stra
tegy
max
imum
pub
licity
and
ach
ievi
ng h
igh
leve
ls o
f cr
edib
ility
and
thus
buy
-in fr
om a
ll or
gani
sed
sect
ors
of S
outh
Afr
ican
soc
iety
as
wel
l as
ordi
nary
citi
zens
. Thi
s pr
oces
s is
pro
pose
d as
the
rout
e fo
r bui
ldin
g pu
blic
con
�den
ce in
Gov
ernm
ent a
nd o
ther
sec
tors
’ com
mitm
ent t
o �g
htin
g co
rrup
tion.
National Anti-Corruption StrategyDiscussion Document 32
Phas
e 1:
Res
earc
h, in
itia
l con
sult
atio
n an
d dr
afti
ng
A
ctio
ns
Resp
onsi
bilit
y Ti
mel
ine
1 D
raft
con
sult
atio
n do
cum
ent d
evel
oped
•
Dia
gnos
tic a
sses
smen
t and
dra
ft p
ropo
sals
for a
n an
ti-c
orru
ptio
n st
rate
gy d
evel
oped
(in
the
form
of a
dr
aft c
onsu
ltatio
n do
cum
ent)
. •
Dev
elop
ed b
y th
e Pu
blic
A�a
irs R
esea
rch
Inst
itute
(WIT
S), s
uppo
rted
by
a St
eerin
g Co
mm
ittee
(cha
ired
by th
e D
epar
tmen
t of P
ublic
Ser
vice
and
Adm
inis
trat
ion)
.
Stee
ring
Com
mitt
ee a
nd
Publ
ic A
�airs
Res
earc
h In
stitu
te
May
to A
ugus
t 201
6
2 Si
gn-o
� b
y A
CTT:
•
Cons
ulta
tion
docu
men
t sig
ned
o� b
y A
nti-C
orru
ptio
n Ta
sk T
eam
A
nti-C
orru
ptio
n Ta
sk
Team
Ju
ly 2
016
3 Su
ppor
ting
org
anis
atio
ns a
nd s
truc
ture
s id
enti
�ed
•
Stee
ring
Com
mitt
ee re
mai
ns a
refe
renc
e gr
oup
until
the
end
of th
e pr
oces
s.
• A
dep
artm
ent i
s ap
poin
ted
to a
ssum
e re
spon
sibi
lity
for d
rivin
g th
e pr
oces
s.
• A
gree
d-up
on a
ppro
ach
to re
vive
a re
conc
eptu
alis
ed a
nd re
desi
gned
cro
ss-s
ecto
ral A
nti-C
orru
ptio
n Fo
rum
(pre
viou
sly
the
Nat
iona
l Ant
i-Cor
rupt
ion
Foru
m)
Ant
i-Cor
rupt
ion
Inte
r-M
inis
teria
l Com
mitt
ee
July
201
6
4 In
tern
al g
over
nmen
t aw
aren
ess
rais
ing
• A
war
enes
s ra
isin
g of
the
proc
ess
with
oth
er g
over
nmen
t dep
artm
ents
thro
ugh
the
clus
ter s
yste
m.
Lead
dep
artm
ent
End
July
201
6
5 In
itia
l con
sult
atio
n w
orks
hops
•
Initi
al c
onsu
ltatio
n do
cum
ents
with
civ
il so
ciet
y, b
usin
ess
and
wid
er g
over
nmen
t.
• A
imed
at r
aisi
ng a
war
enes
s an
d ge
t buy
-in fo
r a th
orou
gh p
ublic
con
sulta
tion
proc
ess
that
will
follo
w
afte
r the
9 D
ecem
ber 2
016
laun
ch o
f the
con
sulta
tion
docu
men
t.
Stee
ring
Com
mitt
ee
Sept
embe
r 201
6
6 U
pdat
e th
e N
ACS
dis
cuss
ion
docu
men
t •
Prep
are
�nal
con
sulta
tion
docu
men
t, in
corp
orat
ing
inpu
t fro
m th
e th
ree
cons
ulta
tion
wor
ksho
ps.
• Pr
epar
e sh
ort s
umm
ary
of d
ocum
ent a
nd tr
ansl
ate
sum
mar
ies
into
all
o�ci
al la
ngua
ges.
Stee
ring
Com
mitt
ee a
nd
Publ
ic A
�airs
Res
earc
h In
stitu
te
Oct
ober
201
6
7 Fi
nalis
e an
ti-c
orru
ptio
n co
nsul
tati
on d
ocum
ent
• Pr
esen
t con
sulta
tion
docu
men
t to
Ant
i-Cor
rupt
ion
Inte
r-M
inis
teria
l Com
mitt
ee fo
r �na
l app
rova
l. Le
ad D
epar
tmen
t su
ppor
ted
by S
teer
ing
Com
mitt
ee
End
Oct
ober
201
6
8 In
form
Par
liam
ent,
the
Legi
slat
ures
and
Jud
icia
ry o
f the
pro
cess
•
Parli
amen
t, pr
ovin
cial
legi
slat
ures
, and
the
o�ce
of t
he C
hief
Just
ice
info
rmed
of t
he p
roce
ss.
• En
gage
with
the
Hou
se o
f Tra
ditio
nal L
eade
rs.
Stee
ring
Com
mitt
ee
Oct
ober
201
6
9 Pl
anni
ng fo
r the
laun
ch o
f the
con
sult
atio
n do
cum
ent
• Pl
anni
ng fo
r an
even
t whi
ch w
ill la
unch
the
wid
er c
onsu
ltatio
n pr
oces
s fo
r dev
elop
ing
a N
atio
nal A
nti-
Corr
uptio
n St
rate
gy fo
r Sou
th A
fric
a.
• In
volv
e bu
sine
ss a
nd c
ivil
soci
ety
in p
lann
ing
for t
he la
unch
.
Lead
Dep
artm
ent w
ith
supp
ort f
rom
Ant
i-Co
rrup
tion
Inte
r-M
inis
teria
l Com
mitt
ee
End
Nov
embe
r 201
6
National Anti-Corruption Strategy Discussion Document33
• Re
activ
atio
n of
NA
CF o
r est
ablis
hmen
t of a
cro
ss-s
ecto
ral A
nti-C
orru
ptio
n Fo
rum
. •
Dev
elop
a d
etai
led
proc
ess
map
to s
uppo
rt p
lann
ing
(map
the
activ
ities
ass
ocia
ted
with
the
step
s ou
tline
d in
the
Road
map
for P
hase
s 2
and
3, p
rovi
ding
as
prec
ise
an e
stim
ate
as p
ossi
ble
of th
e tim
e ne
eded
to u
nder
take
thes
e ac
tiviti
es, a
nd p
reci
sely
how
they
sho
uld
be s
eque
nced
). 10
Re
leas
e of
the
Publ
ic C
onsu
ltat
ion
Doc
umen
t and
laun
ch o
f Pub
lic C
onsu
ltat
ion
Phas
e •
Expr
essi
ons
of s
uppo
rt b
y se
nior
bus
ines
s an
d ci
vil s
ocie
ty le
ader
s at
a p
ress
con
fere
nce
alon
gsid
e th
e M
inis
ter.
• St
atem
ent o
f int
entio
n to
revi
ve a
rest
ruct
ured
cro
ss-s
ecto
ral A
nti-C
orru
ptio
n Fo
rum
(pre
viou
sly
the
Nat
iona
l Ant
i-Cor
rupt
ion
Foru
m).
• G
CIS
to la
unch
maj
or c
oord
inat
ed c
omm
unic
atio
n ca
mpa
igns
nat
iona
lly a
nd in
pro
vinc
es, i
nclu
ding
a
web
pla
tfor
m.
• Co
ncur
rent
pro
vinc
ial l
aunc
hes
of P
ublic
Dis
cuss
ion
Doc
umen
t.
Iden
ti�ed
Cha
mpi
on
9 D
ecem
ber 2
016
Phas
e 2:
Pub
lic C
onsu
ltat
ions
Act
ivit
ies
Resp
onsi
bilit
y Ti
mel
ine
11
Pr
ovin
cial
info
rmat
ion
and
awar
enes
s se
ssio
ns
Hos
ted
by th
e O
�ce
of t
he P
rem
ier a
nd/o
r Pro
vinc
ial T
reas
ury
at p
rovi
ncia
l ant
i-cor
rupt
ion
or s
imila
r fo
rum
mee
tings
. CO
MM
ENT:
The
pro
vinc
ial w
orks
hop
(201
6-10
-13)
pro
pose
d th
at th
is c
ould
be
join
tly fa
cilit
ated
by
a Pr
ovin
cial
Ste
erin
g Co
mm
ittee
(OTP
, DPM
E D
CoG
, etc
.) or
the
Inte
grity
Man
agem
ent U
nits
. Ta
rget
aud
ienc
e:
• SA
LGA
gov
erna
nce
grou
p •
Busi
ness
cha
mbe
rs
• N
GO
um
brel
la b
odie
s/si
gni�
cant
NG
Os
• EC
OSO
C pr
ovin
cial
repr
esen
tativ
es
• Pr
ovin
cial
and
Loc
al G
over
nmen
t com
mun
icat
ion
stru
ctur
es
• Pr
ovin
cial
legi
slat
ure:
Cha
irper
sons
of a
ppro
pria
te c
omm
ittee
(s)
• O
ther
pro
vinc
ial d
epar
tmen
ts
• Pr
ovin
cial
gov
ernm
ent a
nti-c
orru
ptio
n co
ordi
natin
g fo
rum
s/st
ruct
ures
, whe
re th
ey e
xist
.
Lead
dep
artm
ent w
ith
the
supp
ort o
f the
NA
CS
Stee
ring
Com
mitt
ee
Janu
ary
2017
12G
ener
al a
war
enes
s-ra
isin
g ac
tivi
ties
/eng
agem
ents
• Br
oad-
base
d m
edia
cam
paig
n to
enc
oura
ge e
very
one
to p
rovi
de in
put.
• En
gage
men
ts a
t dis
tric
t and
loca
l lev
el.
• In
clus
ion
in e
xist
ing
depa
rtm
enta
l pla
ns/a
ctiv
ities
.
Janu
ary
to M
arch
201
7
National Anti-Corruption StrategyDiscussion Document 34
• Co
nven
e a
wor
ksho
p w
ith o
vers
ight
and
regu
lato
ry b
odie
s on
mon
itorin
g an
d im
plem
enta
tion
of
the
stra
tegy
. M
inis
teria
l Com
mitt
ee
Nat
iona
l Ant
i-Cor
rupt
ion
Foru
m
16
Cons
olid
atio
n of
inpu
t and
dra
ftin
g of
NA
CS
• Te
chni
cal p
roce
ss.
• Po
ssib
ly in
clud
e pu
blic
feed
back
ses
sion
(or p
ublic
hea
ring)
to c
omm
ent o
n th
e co
nsol
idat
ed
docu
men
t.
Dra
ftin
g Te
am s
uppo
rted
by
NA
CS S
teer
ing
Com
mitt
ee
NA
CF/m
ulti-
sect
oral
team
June
201
7
13
Invi
tati
on fo
r sec
tor a
nd in
dust
ry s
peci
�c e
ngag
emen
ts (n
atio
nal a
nd p
rovi
ncia
l) Th
e �n
al n
umbe
r of e
ngag
emen
ts a
nd fo
rmat
s ar
e st
ill to
be
dete
rmin
ed. T
his
is to
be
base
d on
two
cons
ider
atio
ns:
1) C
ritic
al s
ecto
rs/in
dust
ries
that
mus
t be
cons
ulte
d, a
nd
2) E
xpre
ssio
ns o
f int
eres
t and
em
erge
nce
of s
take
hold
ers
base
d on
the
resp
onse
s to
the
med
ia/m
ass
com
mun
icat
ion
cam
paig
ns.
Targ
et a
udie
nce(
s):
• N
atio
nal d
epar
tmen
ts (x
1)
• G
over
nmen
t dep
artm
ents
in p
rovi
nces
(x9)
•
Prov
inci
al A
nti-C
orru
ptio
n/Et
hics
For
ums
(mul
ti-se
ctor
al) (
x9)
• Ke
y Se
ctor
s/In
dust
ries:
–
Loca
l gov
ernm
ent s
truc
ture
s an
d m
unic
ipal
ities
–
Trad
ition
al le
ader
s (C
ON
TRA
LESA
) –
Min
ing
– Co
nstr
uctio
n –
Educ
atio
n –
Labo
ur o
rgan
isat
ions
/ Tr
ade
unio
ns
– Pr
ofes
sion
al b
odie
s –
Busi
ness
sec
tor (
orga
nise
d an
d in
form
al)
– Ci
vil s
ocie
ty o
rgan
isat
ions
.
Lead
dep
artm
ent
Febr
uary
to A
pril
2017
PA
RI
Reco
mm
enda
tion
: Th
e tim
ing
allo
cate
d fo
r th
e se
ctor
al
cons
ulta
tions
nee
ds to
be
ext
ende
d to
at l
east
3
mon
ths,
and
in a
dditi
on
to th
is, a
mon
th sh
ould
be
incl
uded
(Jan
uary
20
17) t
o or
gani
satio
ns
logi
stic
s in
supp
ort o
f th
e co
nsul
tatio
ns n
ext
year
.
14
Subm
issi
ons
of w
ritt
en in
put t
hrou
gh e
lect
roni
c m
eans
/pla
tfor
m
• Po
litic
al p
arty
inpu
ts
Cons
olid
ated
doc
umen
t sen
t to
polit
ical
par
ties
and
rece
ive
writ
ten
inpu
t. •
Citi
zen
inpu
t (ad
ded
step
) To
be
sent
thro
ugh
to le
ad d
epar
tmen
t.
Lead
dep
artm
ent a
nd
Ant
i-Cor
rupt
ion
Inte
r-M
inis
teria
l Com
mitt
ee
Apr
il / M
ay 2
017
15
Cros
s-se
ctor
al c
onsu
ltat
ion
wor
ksho
ps
• Co
nven
e a
wor
ksho
p w
ith M
inis
ter a
nd h
igh-
leve
l gov
ernm
ent d
eleg
atio
n, b
usin
ess
and
civi
l soc
iety
le
ader
s to
ach
ieve
con
sens
us o
n w
hat t
he �
nal s
trat
egy
need
s to
incl
ude.
Lead
dep
artm
ent (
DPM
E),
NA
CS S
teer
ing
Com
mitt
ee,
Ant
i-Cor
rupt
ion
Inte
r-
May
201
7
National Anti-Corruption Strategy Discussion Document35
Phas
e 3:
Fin
alis
atio
n of
the
NA
CS
A
ctiv
itie
s Re
spon
sibi
lity
Tim
elin
e 17
Fi
nalis
e a
Nat
iona
l Ant
i-Cor
rupt
ion
Stra
tegy
•
Dra
ft im
plem
enta
tion
plan
ass
igni
ng c
lear
role
s an
d re
spon
sibi
litie
s to
line
func
tion
depa
rtm
ents
, bu
sine
ss a
nd c
ivil
soci
ety.
•
Dra
ft a
mon
itorin
g an
d ev
alua
tion
plan
. •
Begi
n pr
oces
s of
ent
erin
g N
atio
nal A
nti-C
orru
ptio
n St
rate
gy in
to th
e ag
enda
in ti
me
for t
he n
ext
Cabi
net m
eetin
g af
ter A
nti-C
orru
ptio
n Ta
sk T
eam
or A
CIM
C ap
prov
al.
Dra
ftin
g te
am
Lead
dep
artm
ent
June
/Jul
y 20
17
18
Ant
i-Cor
rupt
ion
Inte
r-m
inis
teri
al C
omm
itte
e ap
prov
al o
f Nat
iona
l Ant
i-Cor
rupt
ion
Stra
tegy
•
App
rova
l of t
he �
nal d
ocum
ent b
efor
e be
ing
tabl
ed a
t the
nex
t Cab
inet
mee
ting
for �
nal a
ppro
val.
Lead
dep
artm
ent
end
July
201
7
19
Cabi
net a
ppro
val o
f Nat
iona
l Ant
i-Co
rrup
tion
Str
ateg
y •
App
rova
l of �
nal N
atio
nal A
nti-C
orru
ptio
n St
rate
gy.
Cham
pion
Fi
rst C
abin
et
mee
ting
afte
r Ant
i-Co
rrup
tion
Task
Te
am a
ppro
val
20
Dis
trib
ute
Nat
iona
l Ant
i-Cor
rupt
ion
Stra
tegy
•
Prin
t cop
ies
of �
nal n
atio
nal s
trat
egy
docu
men
t. •
Dis
trib
ute
the
docu
men
t acr
oss
the
coun
try
via
vario
us m
edia
.
Lead
dep
artm
ent
Imm
edia
tely
aft
er
Cabi
net a
ppro
val
21
LAU
NCH
of t
he �
nal N
atio
nal A
nti-
Corr
upti
on S
trat
egy
• La
unch
of t
he N
atio
nal A
nti-C
orru
ptio
n St
rate
gy.
• Be
ginn
ing
of im
plem
enta
tion.
Lead
dep
artm
ent
Cham
pion
20
17
National Anti-Corruption StrategyDiscussion Document 36
Appendix B: Summary of programme elements under each strategic pillar
Anti-corruption interventions are commonly organised or reported under the themes of prevention, detection and enforcement. The table below shows which of these forms of intervention are incorporated under each pillar.
Strategic pillar Prevention Detection Enforcement Monitoring, evaluation and response1. Support citizen empowerment in the x x x �ght against corruption, including increased support for whistle-blowers. 2. Develop sustainable partnerships with x x x stakeholders to reduce corruption and improve integrity management. 3. Improve transparency of activity by the x x x government, business and civil society sectors. 4. Improve the integrity of the public x x x procurement system to ensure fair, e�ective and e�cient use of public resources. 5. Support the professionalisation of x x public sector employees in organs of state. 6. Improve adherence to integrity x x x x management mechanisms and consequence management in organisations across government, business and civil society sectors. 7. Strengthen oversight and x x governance mechanisms in the government sector. 8. Strengthen the structures for x x x enforcement: an independent, resourced, skilled, and coordinated multi-agency anti-corruption system. 9. Vulnerable sector management: build x x x x speci�c programmes to reduce corruption and improve integrity in sectors particularly vulnerable to corruption, with a focus on the JCPS Cluster.
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Appendix C: United Nations guidelines on developing national anti-corruption strategies
The United Nations O�ce on Drugs and Crime has developed a high-level guide for developing anti-
corruption strategies. The UNODC notes that it is “important that the strategy contains a set of concrete
recommendations, rather than simply stating objectives in broad, abstract terms without connecting
them to any speci�c reforms or policy changes”. It also stresses that the programmes or actions proposed
should be linked to evidence that the approach adopted could plausibly impact on the nature of
corruption it seeks to address.
The UN report dedicates a chapter to monitoring and evaluating the strategy. It highlights the
importance of a strong monitoring and evaluation component to the strategy to support
implementation and institutional learning. The indicators should be very carefully developed to ensure
against indicator gaming in which organisations choose indicators that are easy to achieve, but do not
necessarily show substantive reform or progress on anti-corruption.
The United Nations Convention against Corruption calls for a range of actions against corruption that can
act as a (broad) guide for developing national anti-corruption strategies. These are:
(a) Strengthening anti-corruption law and law enforcement […].
(b) Implementing more e�ective measures to prevent corruption measures while reducing the
incentives and/or the opportunities for corruption. Such reforms might include:
(i) Measures to prevent corruption in the public sector, including through promotion of
integrity in public administration, strengthening public sector ethics, addressing
corruption risks in procurement and in the budgeting process and promoting
transparency and civic participation (articles 7 to 10 and 13); and
(ii) Measures to prevent corruption in the private sector, including transparency and
reporting measures, accounting controls and auditing (article 12).
(c) Establishing education programmes, publicity campaigns and awareness-raising initiatives
intended to change attitudes towards corruption, shift cultural norms and encourage reporting
(article 13).
(d) Bolstering institutional capacity, providing adequate training and ensuring the e�ectiveness,
autonomy and integrity of the government bodies that implement anti- corruption policy
(articles 6, 11, 36, 58 and 60).
(e) Improving both domestic and international coordination between law enforcement authorities
and other agencies responsible for combating corruption, as well as between the public and
private sectors (articles 37 to 39 and 43 to 50).
(f ) Enhancing the collection and analysis of data and other information on corruption, in order to
address uncertainties and knowledge gaps (article 61).
Reproduced from: United Nations O�ce on Drugs and Crime. 2015. ‘National Anti-Corruption Strategies: A Practical Guide for Development and Implementation.’ United Nations O�ce on Drugs and Crime, Vienna
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