2022 Icpc Ethics and Integrity Compliance Scorecard
2022 Icpc Ethics and Integrity Compliance Scorecard
2022 Icpc Ethics and Integrity Compliance Scorecard
1
CONTENTS
2
1. INTRODUCTION: THE PURPOSE OF THE ETHICS AND INTEGRITY COMPLIANCE SCORE CARD
The Independent Corrupt Practices and Other Related Offences Commission (ICPC), by its Establishment Act (Section 6 b-d), has the
mandate to review, on a periodic basis, the systems, procedures and operations of public and private sector institutions, in order to
determine institutional vulnerabilities that can or actually engender corruption in the organizations. The ICPC carries out this work
through the Systems Study and Review Program. Although results of the studies are shared by ICPC with the institutions reviewed,
there is no mechanism for ICPC to translate, in comparative perspective, the findings of the systems studies and to inform the Nigerian
public about the nature of corruption or institutional vulnerabilities in private and public sector institutions. Therefore, ICPC developed
an “Ethics and Compliance Score Card” (Henceforth, “The Score Card”) that will address this gap. The Score Card outlines some ethics
and integrity standards that Ministries, Departments and Agencies (MDAs) must comply with in management, performance, service,
and professional conduct settings. MDAs and their sector units shall be scored on a regular basis to determine the level, scope, extent,
and timeliness of compliance with these integrity requirements.
The Score Card contains a structured summary of values that measure a set of indicators. The card scores, tabulates and ranks indicator
items and their attributes along a range of values. Generally, in social science research, a Score Card is used to evaluate the state of
an undertaking and to inform further action or policy. Similarly, the Ethics and Compliance Score Card will create a platform for
comparing and analysing the weaknesses that make MDAs susceptible to corruption. The card will also measure MDA compliance with
institutional integrity mandates as well as accountability principles required for effective service delivery.
The assessments resulting from the application of the Score Card will be weighted into specific scores and published for the attention
of the MDAs and for consideration by the general public. The ultimate goal is to have MDAs understand the quality of their
performance and take account of their level of compliance with operational, service delivery and accountability standards, as required
by the mandates of the institutions. Furthermore, the assessments and scores will create a greater sense of urgency for the MDAs to
strengthen their accountability systems and to operate with greater efficiency and service excellence.
Where non-compliance is detected, MDAs in collaboration with ICPC shall develop measures to address the situation. Where non-
compliance is determined to result from other institutional or technical vulnerabilities or lack of capacities, MDAs shall ensure that
integrity standards are in place and are functioning successfully.
3
Each MDA must comply with (adhere to, aggressively and unconditionally pursue) the integrity standards. All employees of all grade
levels in MDAs must be provided copies of the integrity standards and compliance requirements. The standards shall also be
incorporated into recruitment and promotion procedures, as well as performance appraisals. On a regular basis, each MDA shall
conduct training sessions in ethics and compliance for employees and certify for each employee at the end of the training session, that
they have imbibed the integrity principles and are very conversant with the compliance requirements.
Designated ICPC and ACTU officers shall monitor, assess, and report compliance/non-compliance within MDAs to ICPC on a periodic
basis. These reports will be sent to ICPC for analysis and for further follow-up corrective action. The integrity compliance reporting
template shall capture the integrity principles as contained in the Ethics and Compliance Score Card.
2. METHODOLOGY OF SCORING THE MDA ETHICS AND INTEGRITY COMPLIANCE SCORE CARD:
The Ethics and Compliance Score Card evaluates MDAs based on key indicators on ethics and compliance under three broad headings,
each of which has several sub-headings and sub-indicators. The main headings are the following:
Management Culture and Structure
Financial Management Systems
Administrative Systems
In designing the Score Card, a closer scrutiny of the following was considered:
Formal procedures, i.e., what is intended to be done?
Informal procedures, i.e., what is actually done?
The management of work, i.e., how supervision is done
The scores assigned to the various indicators contained in the Ethics and Compliance Score Card carry a total of 100 points, represented
as a percentage. Each sub-indicator also carries 100 points. These are then divided by the total of all the sub-indicators and divided by
100 to get the actual score (expressed as a percentage). The real scores for the sub-indicators are assigned different weights, in terms
of the extent of variance of a sub-indicator from the main indicator. The variance refers to how closely or farther away the sub-
indicator is from the core requirements of the main indicator. That is, values are assigned from a numerical range of low to high (e.g.,
1-6). Low numbers (1) of a sub-indicator represent a variance farther away from the primary indicator in terms of importance, essence,
compliance requirements and operational viability in achieving the aims of the indicator. For example, a higher numerical value (6) of
a sub-indicator means it is very close to the primary indicator in terms of the importance, essence, compliance requirements and
4
operational viability in achieving the aims of the indicator. In sum, a major consideration for the different weights is the extent to
which the sub-indicator conveys the core elements of the primary indicator, meets the compliance requirements of the indicator, and
can actually realize the objectives of the indicator.
We should note that the weights were determined from an agreement among the programmers regarding the meaning, essence, and
level of compliance required by the indicators of the Score Card. Further, an indicator audit was done to determine conceptual
accuracy. Also, the programmers reached judgments on the weighting of the scores based on approximations, as well as drawing from
and cross-checking with expert opinion of similar indices in the public domain. The programmers also drew from general anti-
corruption experience.
Although, we consider the current scoring system to be adequate enough to guide an acceptable interpretation of the indices with
respect to their accuracy and fit, as outlined in the Score Card, we admit that the weighting process of the scores could benefit from
a more robust application of factor analysis and other statistical applications to determine the relationships among the various
indicators and sub-indicators as well as their variance, validity, etc. This can be done at a future time with the on-going implementation
and revision of the Score Card.
On the whole, the reasons for assigning the weights is to guide implementers of the Score Card on how to understand the values assigned
to the different indicators and sub-indicators and to help interpret and determine the extent to which MDAs are implementing or complying
with the requirements of Ethics and Compliance Programs. On these bases, ICPC and MDAs can know the extent to which anti-corruption
measures are effective in the MDAs and whether accountability systems are functional in preventing corrupt practices and creating high
ethical cultures, professional integrity, organizational integrity, more efficient operational systems, and better service delivery.
Selected References:
1. Corrupt Practices and Other Related Offences Act 2000 (ICPC Act 2000)
2. Earl Barbie, The Practice of Social Science Research, Belmont California: Wadsworth, 1994
3. OECD, Public Sector Integrity: A Framework for Assessment, 2005
4. OECD Corporate Governance Principles, 2012
5. Mary Hollis Johnson and Philip S. Holzman, “Scoring Manual for the Thought Disorder Index”.
(Online <http://schizophreniabulletin.oxfordjournals.org/ Accessed February 17, 2015>)
6. 3. U4, “Overview of Integrity Assessment Tools” (<www.U4.no>)
5
Undertaking
I ……………………………………………………………………………………………………………………………………………. Of
…………………………………………………………………………………………………………………………………………………….
hereby certify that all information/answers/documents supplied for the purpose of filling this
Scorecard are true and accurate to the best of my knowledge. Where any
information/answer/document is found to be false, the provisions of Sections 15 and 25 of the
Corrupt Practices and Other Related Offences Act, 2000 may be fully enforced against me.
6
ICPC
NAME OF MDA:
8
6 Are there policies regarding acceptance Scale of 1-10: 10 Proof of policy
of gifts, donations, hospitality, etc.? Yes = 10
No = 0
9
(ii) BOARD GOVERNANCE
10
3 What are the statutory functions of the Scale of 10 10 Establishment
Board? 2 marks Instrument
allotted for
a. Advisory each function
b. Regulatory
c. Policy formulation and
implementation
d. Oversight
e. Oversight of financial controls
4. Are the decisions of the Board in line Scale of 1-15 15 Board
with the conditions of service and If Yes 15; Proceedings,
operational manual of the organization? If No 0 Condition of
Service and
Operational
Manual
5. Is there any Code of Ethics for the Scale of 1-10 10 Code of Ethics for
Board? If Yes 10; Board Members,
If No 0 letters of
engagement,
establishment Act
6 Does the Organization conduct Scale of 1-5 5 Induction Training
induction courses for the newly If Yes 5; Modules, Training
appointed Board members? If No 0 Materials,
attendance list and
Reports of Training
7 Does the Organization conduct periodic Scale of 1-5 5 Capacity
capacity development training for Board If Yes 5; Development
members? If No 0 Training Modules,
Training Materials,
attendance list
and Reports of
Training
11
8. Does the organization conduct periodic Scale of 1-5 5 Report of Self-
assessment for board members? If Yes 5; Assessment
If No 0
Report of
Assessment
9. Do the Board and the Management of Scale of 1-15 15 Reports of Policy
the Organisation collaborate in policy If Yes 15; Formulation and
formulation and implementation? (for If No 0 Implementation,
Strategic Action
example, the development and
Plan
implementation of the organization’s Or any other policy
strategic plan) in collaboration
with management
10 Does Management implement Scale of 1-10 10 Reports of Policy
resolutions/recommendations from the If Yes 10; Formulation and
Board? If No 0 Implementation
12
(iii) EXECUTIVE MANAGEMENT
S/N QUESTIONS SCORE KEY TOTAL ACTUAL GUIDE REMARKS
ATTAIN SCORE PLANNING,
ABLE REVIEW AND
SCORE STATISTICS
DEPARTMENT
1a Does the Organization have a Strategic Scale of 20: 20 Strategic Action
Plan? Yes =10 Plan, Master Plan,
Departmental Blue Print, Road
plan: 5 Map etc (5 years
Operational and above)
plan: 5
No = 0
1b Is there an Operational or Work plan Scale of 1-10: 10 Work plan should
from the Strategy? Each of the include results
following framework, KPIs,
attracts 2 specific timelines,
points: responsible
Results persons, data
framework:2 collection, analysis
KPIs: 2 and reports
Timelines: 2
Responsible
persons/Dept
s: 2
Data
collection,
analysis and
reports: 2
13
2a Are the implementation of Scale of 1-5: 5 The officer should
Departmental work plans ongoing or Approved ascertain when
completed for the last year? work plan: 2 action plan was
Ongoing or approved
completed
projects: 3
2b Are the responsible staffs submitting Scale of 1-5: 5 See report of
reports on the work plan? Yes = 5 implementation of
No = 0 action plan,
quarterly report of
departmental
activities
3a Does the Organization conduct capacity Scale of 1-10: 10 See evidence of
development training for Management Yes = 10 training: schedule,
and Staff of the Organisation? No = 0 attendance sheet,
notice of training
to participants
photographs
3b Are the training consultants/firms duly Scale of 1-10: 10 Evidence of
accredited by the relevant Yes = 10 accreditation from
agencies/regulatory bodies No = 0 bid /support
documents
submitted by firm
4 Has the Organization conducted Scale of 1-10: 10 Reports of
monitoring and evaluation of its projects Monitoring: 5 assessment and
and programmes in the last six months/ Evaluation: 5 evaluation of
Year under review?
activities in the last
6 months or Year
under review?
14
5 Does the Management have fraud Scale of 1-10: 10 Autonomous Audit .
prevention strategies? Give 5 points Unit, periodic
to each of the published audited
following: accounts, stock
Periodic verification
published systems, etc.
audited
accounts: 5
Stock
Verification
Systems: 5
6 Does Management encourage Systems Scale of 1-10: 10 SSR/Risk
Studies/Corruption Risk Assessments? 2 CRAs Assessment
How often? completed Reports as MOV,
per year: ACTU SSR reports
5x2
7 Does Management use the results of Scale of 1-10: 10 Evidence of
Systems Studies/Corruption Risk Yes = 10 decisions
Assessments in decision-making? No = 0 embodying
recommendations
from SSR/CRAs
EXECUTIVE MANAGEMENT: 100
TOTAL: 10 %
15
(B) FINANCIAL MANAGEMENT SYSTEMS
Each organization should have robust and effective controls to ensure financial accountability
18
(ii) AUDIT
S/N1. QUESTIONS SCORE KEY TOTAL ACTUAL GUIDE REMARKS:
ATTAIN SCORE RESPONDENTS:
ABLE FINANCE &
SCORE ACCOUNTS,
AUDIT & STORE
1 Does Management undertake quarterly Scale of 1-10: 10 Evidence of
audit of all departments? For each completed internal
quarter of the audits, such as
year give 2.5 financial audits,
points. Stock Verification
Audits, etc.
2 Are Internal and External Audits done as Scale of 1-10 10 Attach Evidence
and when due? Internal Audit (Audit Reports)
Report= 5
External Audit
Report= 5
3a Is the Internal Audit completely Scale of 1-10 10 Organogram,
independent of Management Yes= 10 Memos and
interference in the discharge of its No=0 Reports from
Internal Audit
duties?
19
5 Are the observations and Scale of 1-20 20 Audited Reports
recommendations of the internal audit Evidence of Observations and
implemented by the Chief Executive of reports: 10 queries raised in
Actions taken: the course of
the Organization?
10 audits should be
provided. Officers
should find out
whether the issues
raised through the
audit process have
been corrected
6 Does your Organization carry out pre- Scale of 1-5 5 Sight/ Attach
payment and post-payment audit? Yes= 5 Evidence
No=0
7 Does the Organization render annual Scale of 1-10: 10 Evidence of
Audited account to the Office of the Scale of 1-10: Compliance:
Auditor General of the Federation, AUGF = 5 Acknowledged
PAC = 5 letter of
Public Accounts Committee (PAC) of the
No = 0 submission
National Assembly and other relevant
organisations within the first five
months of the previous year?
AUDIT: 100
TOTAL: 10%
(iii) PROCUREMENT
S/N QUESTIONS SCORE KEY TOTAL ACTUAL GUIDE REMARKS:
ATTAIN SCORE PRIMARY
ABLE RESPONDENT:
SCORE HOD
PROCUREMENT
1a Does the Organisation conduct an annual Scale of 1-5: 5 Consolidated
needs assessment preparatory to its Yes = 5 Needs Assessment
procurement in compliance with the No = 0 Report
provision of PPA 2007?
1b Does the Organization have an annual Scale of 1-10: 10 See Procurement
procurement plan? Yes = 10 plan
No = 0
2 Is the Organization’s procurement plan Scale of 1-5: 5 Respondent:
part of the annual budget? Yes = 5 Admin, Finance
No = 0 and Accounts,
Procurement.
Compare projects
21
on the
procurement plan
with projects listed
in the budget
5a Does the Organisation have policies that Scale of 1-10: 5 See evidence of
provide sanctions for Contractors or If Yes: 10 policy in Contract
External Partners who violate Contract If No: 0 Agreement, Award
Agreement? Letters,
Revocation of
contract or any
other means of
evidence
5b Has the Organisation received Scale of 1-5: 5 Letters of
complaints from bidders, Contractors or If Yes: 2 Complaints written
relevant Stakeholders on violation of the Evidence of to the MDA
PPA 2007 in the last three (3) years response: 3 Letters of response
If no to Stakeholder by
complaints MDA
due to
organization’s
compliance: 5
5c Does the organization comply with the Scale of 1-10: 5 Evidence of
provisions for debarment of non- If Yes=10 sanctions,
compliant companies from projects If No= 0 debarment letters,
financed by the organization? letters of revoked
contracts, etc.
6a Does the Organisation invite relevant Scale of 1-5: 5 Letters of
Professional Bodies, NGOs and If any of the invitation to
Stakeholders to be part of its evidence is Stakeholders and
procurement process in compliance available: 5 NGOs, signed
with the provisions of the PPA 2007? Attendance Sheet
23
Report of
Procurement
Proceedings
6b Does the Organisation comply with the Scale of 1-5: 5 Check Letters of
requirement to give reasonable period If Yes: 5 invitation (date
of notice for relevant Stakeholders to If No: 0 received by
attend and observe its procurement Stakeholders) vis -
process and procedure? a-vis date activity
held,
Attendance Sheet
Report of
procurement
proceedings
7a Does the Organisation undertake Scale of 1-5: 5 Monitoring Report
performance certification of ongoing If Yes: 5 Interim
(works) project before approvals for If No: 0 performance
payments? Certificates
Site verification
reports and
pictures
7b Does the Organisation verify goods Scale of 1-5: 5 Store Verification
supplied before payments are made to If Yes: 5 Reports
suppliers or contractors? If No: 0 Store Receipt
vouchers
8a Does the Organization conduct ethics Scale of 1-5: 5 See reports of
and compliance training for Training training or other
procurement officers? completed: 5 means of
If none: 0 verification
8b Does the Organisation fund attendance Scale of 1-5 5 Reports of training,
of its procurement officers at BPP Trainings Certificate of
organised trainings? attended: 5 attendance,
If None: 0 Training Materials
24
or other means of
verification
9 Did the Organization conduct market Scale of 1-5: 5 Market surveys
surveys within the year under review? Yes = 5 reports for the
No = 0 period under
review.
PROCUREMENT 100
TOTAL: 10%
28
3 Does the Ethics and Compliance training Scale of 1-20: 20 Content analysis to
identify corruption vulnerabilities and Evidence of ascertain that
mitigation mechanisms? content trainings cover
required: 20 issues bothering
on corruption
4 Does the Organization have materials on Scale of 1-20: 20 Information,
education and awareness to continuously Information: Education and
remind staff of the ethics principles and 5 Communication
compliance requirements? Education: 10 materials (IEC,
Communicati such as posters,
on: 5 handbooks,
letters, memos,
video clips. etc.)
5 Does the Organization conduct induction Scale of 1-10: 10 Trainings,
and orientation training for new staff? Evidence of induction manuals,
induction: 10 photograph,
signed attendance
lists, reports, video
clips, etc.
6 Does the Organization conduct pupillage/ Scale of 1-10 10 Pupilage/
mentorship training for staff when If yes- 10 mentorship
posted to a new department? If N0- 0 memos, reports
etc
7 Did the Organization train and retrain Scale of 1-10: 10 Training reports,
staff on Civil Service Rules and Code of Evidence of signed participant
Conduct for Public Officers and extant training: 10 list
regulations within the year under
review?
ETHICS AND COMPLIANCE EDUCATION 100
TOTAL: 5 %
29
(iii) COMPLAINTS AND WHISTLE BLOWING MECHANISMS
S/N QUESTIONS SCORE KEY TOTAL ACTUAL GUIDE: REMARKS:
ATTAIN SCORE PRIMARY
ABLE RESPONDENTS:
SCORE ACTUs
1 Does the Organisation have a Whistle- Scale of 1-10: 10 Evidence of
blower Policy? Yes =10 Whistleblowing
No= 0 Document
30
records of
complaints
31
(iv) DISCIPLINE, SANCTIONS AND REWARDS REGIME
S/N QUESTIONS SCORE KEY TOTAL ACTUAL GUIDE: REMARKS:
ATTAIN SCORE PRIMARY
ABLE RESPONDENTS:
SCORE HR AND ACTUs
1 Is the Organization guided by extant Scale of 1-10: 10 Public Service
rules? Yes = 10 Rules, Circulars,
No = 0 Conditions of
service.
2 Does the organization have Scale of 1-20: 20 Copies of
domesticated/ professional codes of If Yes=20 documents
conduct, including clearly articulated If No= 0
sanctions against violations?
3 Does the organization sanction staff for Scale of 1-10: 10 HR Records and
violation of Public Service Rules/ codes If Yes= 10 ACTU Reports
of conduct and extant Regulations? If No= 0
32
6 Is the reward system transparent and Scale of 1-20: 20 Peer reviews,
consistent with the requirements of the Give 5 to awards
core values of the organization? each of the committee,
following: evidence of
Peer reviews staff
5, Awards nominations,
committee 5, TORs for
staff awards
nomination
forms 5, TORs
for awards 5
DISCIPLINE, SANCTIONS AND 100
REWARDS REGIME
TOTAL: 5 %
ANTI=CORRUPTION AND
TRANSPARENCY UNIT
TOTAL: 10%
ADMINISTRATIVE SYSTEMS
TOTAL:30 %
33
THE SCORE CARD
Sectional Summary
TOTAL: 100%
COMPLIANCE RATING
1
91 -100 Full Compliance Green
2
70 - 90 Substantial Compliance Light Green
3 50 - 69 Partial Compliance Orange
31 - 49 Poor Compliance Brown
4
1-30 Non-Compliance Red
5
0 Non-Responsive Black
6
34
GENERAL EVALUATION OF THE ASSESSMENT
FOR THE YEAR
PERFORMANCE ANALYSIS:
DRIVERS OF PERFORMANCE
35
DATE OF ASSESSMENT:
ASSESSMENT TEAM:
NAME AND SIGNATURE
1.
2.
3.
4.
5.
36
GLOSSARY OF TERMS
1. ACCOUNTABILITY
Accountability involves the requirement to account for one’s obligations, to answer to issues raised with respect to one’s actions and
their consequences, and to take responsibility for one’s obligations.
2. ACTION PLAN
An Action Plan is a detailed sequence of steps that must be taken, or activities that must be performed well, for a strategy to succeed.
An action plan is also called action programme. It is a tool in social planning. It is also an organizational strategy to identify necessary
steps towards a goal. A written action plan serves as a token for an organization’s accountability. An action plan has four major
elements:
3. CODE OF CONDUCT
The term “Code of Conduct” refers to a written set of guidelines issued by an organization to guide its operations and interactions.
The code of conduct enables personnel within the organization and outside stakeholders to conduct their actions and affairs in
accordance with established primary values and ethical standards. For instance, the “International Federation of Accountants” defined
its code as the “principles, values, standards, or rules of behaviour that guide the decisions, procedures and systems of an organization
in a way that contributes to the welfare of its key stakeholders and respects the rights of all constituents affected by its operations”.
A common Code of Conduct protects the organization and informs the employees about the organization’s expectations. The code is
ideal for even the smallest of companies. It is a document that contains important information on operational and behavioural
37
expectations for employees. The document does not need to be complex or have elaborate policies. It should be simple enough to
convey in clear terms what the company expects from each employee.
Codes of Conduct offer an invaluable opportunity for responsible organizations to create a positive public identity for themselves. This
can lead to a more supportive political and regulatory environment. It also increases public confidence and trust among important
constituencies and stakeholders.
4. COMMUNICATION SYSTEMS
Communication systems in an organization are the various formal and informal processes by which information is transmitted between
employers and employees within the organization or between the organization itself and outsiders. Whether written, verbal,
nonverbal, visual, or electronic, communication has a significant impact on the way the organization conducts business. Managers
need to understand and eliminate the common obstacles that prevent effective communication. Some of the causes of communication
problems in organizational settings include:
5. COMPLIANCE
Generally, compliance entails adherence or conformity with the established standards (relevant laws, regulation, policies, standards,
procedures, or contractual obligations) that guide the operations of an organization. In the context of creating an effective
organizational ethical culture, ethics compliance programs focus on the following:
i. Ensure adherence to statutory standards, rules, regulations, codes, laws, procedures, timelines with respect to the
implementation of ethics and integrity regimes within the MDAs
ii. Provide monitoring and risk management mechanisms to improve a culture of ethics and organizational integrity systems
iii. Provide prevention strategies to mitigate institutional integrity vulnerabilities and ethical breaches
iv. Institute detection strategies to uncover risks, lapses, breaches and non-compliance (suggestions boxes, whistle blower
programs, freedom of information legislation, etc.)
38
v. Provide capacity development to empower and enhance ethics capabilities and ethical self-efficacy
vi. Provide ethics advisory services to educate and advise on ethical decision making, to improve ethical judgment capabilities
vii. Provide tools on how to resolve ethical dilemmas
6. CONFIDENTIALITY
Confidentiality limits access to or places restrictions on certain types of information. It ensures that information is accessible only to
those authorized to have it. Confidentiality is at the core of whistle blowing. It requires that the information and identity of the whistle
blower be kept secret to avoid victimization and recrimination. Organizations must have confidential channels for reporting non-
compliance with anti-corruption and other protocols so that employees will be encouraged to blow the whistle.
7. CORRUPTION
The understanding of corruption in the ethics and compliance score card concerns what the ICPC ACT 2000 describes as “bribery, fraud
and other related offences”. In addition, in the context of public sector institutions, corruption will be described as the misuse or abuse
of entrusted stewardship for purposes or gratifications other than as established for the conduct of that stewardship.
Corruption Risk Assessment is a diagnostic tool that seeks to identify weaknesses within a system that present opportunities for
corruption to occur. The instrument differs from many other corruption assessment tools. It focuses on uncovering the potential for
corruption, rather than the perception, existence or extent of corruption. At its core, a risk assessment tends to involve some degree
of evaluation of the likelihood of corruption occurring and the impact this would have should corruption occur. The purpose of a
corruption risk assessment is usually to supplement evidence of actual or perceived corruption in a given context, in order to inform
anti-corruption strategies and policies or for advocacy purposes. It can be applied to all systems, including government institutions,
donor support programmes, sectoral programmes, as well as individual organizations or units. Most corruption risk assessments take
an institutional approach. That is, they aim to identify weaknesses in the enforcement of rules and regulations in an institution, sector
or process.
39
The sophistication of risk assessments ranges from identification of corruption or institutional weaknesses or gaps indicating risks of
further corruption, to an analysis of the impact and estimation of the likelihood of corrupt practices. One of the key benefits of
corruption risk assessment is that it gives a better understanding of a corruption situation in a given context.
9. CORRUPTION VULNERABILITY
According to the Systems Study and Review Manual of the Independent Corrupt Practices and Other Related Offences Commission
(ICPC), a corruption vulnerability concerns all features of an organization that are weak and easily susceptible to corruption, engender
corruption or allow incidences of corruption to occur.
10. DEBARMENT
Debarment refers to officially preventing an entity from having or doing something as a result of violations of or deviance from
established standards. It is exclusion from enjoying certain possessions, rights, privileges, or practices and the act of prevention by
legal means. For example, individuals, companies, firms and other organizations can be debarred (for example, from contracts) by an
organization when convicted of fraud, mismanagement, bribery, poor performance, false statements as well as other causes. In cross-
debarment, organizations and agencies agree to mutually exclude others based on debarment by affiliates.
11. ETHICS
Ethics refers to a systematic analysis and reflection on moral principles and values. Ethics also deals with the socially established
understandings and meanings concerning core values and norms about good and bad, and right and wrong, in the life of a society or
a particular organization. Thus, organizational ethics determines what an institution holds to be the preferred convictions and ways
to achieve wellbeing (organizational purpose) through adherence to core values.
Ethics and Compliance Officers are personnel who are knowledgeable about ethical issues, organizational core values as well as
operational and service standards. The personnel coordinate, advise, guide and train members of an organization on ethical issues
relevant to the organization’s culture and operations. The officers also assist other members of the institution to understand and
implement, on a daily basis, the core values that form the foundation of the organization’s identity and service. The goal is to assist
40
and guide staff on how to work in line with a service ethic, to address ethics dilemmas that impact on professional practice and service
excellence, as well as to exercise the public stewardship with integrity, accountability and responsibility. In the Ethics and Compliance
profession, some organizations refer to the ethics officer as “Chief Ethics and Compliance Officer”, “Chief Ethics Officer” or “Chief
Compliance Officer”.
The term “ethical behaviour” refers to acting in ways consistent with what a society or organization typically understands to be in
conformity with moral values and norms. For instance, a behaviour or conduct will be considered ethical when it demonstrates
adherence to and respect for key moral principles such as honesty, fairness, equality, dignity, diversity and individual rights. In the
context of institutional operations, ethical behaviour requires organizations to act in ways that stakeholders consider to be fair and
honest. This strengthens and improves the efficiency and effectiveness of organizational life, work environments, professionalism and
the careers of employees.
The term refers to any issue that arises with respect to the pursuit of organizational core values and moral norms.
A feedback mechanism provides organizations with data from primary stakeholders about the quality and effectiveness of the
organization’s efforts. An ideal feedback process involves the gathering of information and communicating a response, which forms a
“feedback loop”. Ways of receiving feedback include monitoring and evaluation, real-time evaluation, accountability frameworks,
complaints and response mechanisms, listening exercises, perception studies, social performance management systems, social audits
through community score cards or citizen report cards, etc. Feedback is essential to the working and survival of an organization.
Information about an organization helps it to adjust its current and future activities in order to achieve desired results.
Fraud prevention strategy refers to a document that describes how ongoing fraud risk management will work in an organization. The
document outlines a high level plan on how an institution will go about implementing its fraud prevention policy. The strategy forms
41
the most important part of the fraud prevention plan. It is therefore highly advised that it be practical and not complicated. In order
to develop and implement a fraud prevention strategy, an organization needs to consider issues such as the following:
Prevention: A primary control which should lower the likelihood of fraud occurring
Detection: Use of whistle-blowing tools to assist with detecting fraud when it occurs
Investigation: To follow after the actual fraud has been committed
Resolution: Focuses on post-investigation activities which can include disciplinary actions, civil recovery, awareness and
communication, lesson learned, etc.
17. MANAGEMENT
Management can be viewed from two perspectives. First, it is the organization and coordination of the activities of a business or an
organization in order to achieve defined objectives, while using available resources efficiently and effectively. It consists of interlocking
functions of creating corporate policy and organizing, planning, controlling and directing an organization’s activities and resources in
order to achieve the objectives of that policy.
Second, management refers to the collective body of those who manage or direct the affairs of an organization. In this context,
management refers to the directors and supervisors who have power and responsibility to make decisions and oversee activities in an
organization.
42
18. MISSION
Mission refers to a declaration of an organization’s core purpose and focus that normally remain unchanged overtime. Mission
Statements communicate a sense of intended direction to the entire organization. A “mission” defines the present state or purpose
of an organization. It answers three questions about why an organization exists.
What it does
For whom it does its work
How it does its work
A “mission statement” is usually written succinctly in one or two sentences. All employees of an organization should be able to easily
articulate their organization’s mission upon request.
A “mission” is different from a “vision”. While a mission is something to be accomplished, a vision is something to be realized through
that accomplishment.
Monitoring involves the systematic and routine observation, collection and recording of information concerning projects and
programmes. This is done for three main purposes:
i. To learn from experiences in order to improve practices and activities in the future
ii. To have internal and external accountability regarding the resources used and the results obtained
iii. To take informed decisions on the future of the initiative
Monitoring is a periodically recurring task and begins from the planning stage of a project. It allows results, processes and experiences
to be documented and used as a basis to steer decision-making and learning processes. It focuses on checking progress against plans.
The data acquired through monitoring is used for evaluation.
43
The term “evaluation” refers to assessing, as systematically and objectively as possible, a completed project or programme or a phase
of an on-going or completed project or programme. Evaluation appraises data and information and is used to inform strategic
decisions, thus improving a project or programme. Evaluation helps to assess activities in terms of the following:
i. Relevance
ii. Effectiveness
iii. Efficiency
iv. Impact
v. Sustainability.
Monitoring and Evaluation (M & E) is a constitutive part of every project or programme design. During an evaluation, information from
previous monitoring processes is used to understand the ways in which the project or programme developed and stimulated change.
The evaluation process is an analysis or interpretation of the collected data which delves deeper into the relationships between the
results of the project or programme, the effects produced by the initiative as well as its overall impact.
Organizational core values refer to the fundamental beliefs of an organization in line with organizational purpose. Core values are the
guiding principles that dictate an organization’s internal conduct as well as its relationship with the external body. Core values can
help people within the organization to know what is right from what is wrong. Organizations can also determine if they are on the
right path towards fulfilling their goals. Organizational core values are usually expressed in the organization’s mission statement.
Examples include the following:
Culture can be broadly defined as the pattern of beliefs, values, arts, customs, behaviours and habits that characterize and constitute
a people’s way of life. In the context of organizations (such as schools, non-profit organizations, government agencies, business
entities, etc), organizational culture is understood to be a set of shared assumptions about a total way of life that guides the
organization and what happens within it. Organizational culture defines appropriate ways of doing things, including collective and
specific behaviours, organizational expectations, experiences, philosophy and values. These hold the organization together and are
expressed as its self-image, in its inner workings, and in interactions with the outside world. Organizational culture affects the way
people, groups and stakeholders interact with each other.
Organizational objectives refer to the overall goal, purpose and mission of an organization that management establishes and
communicates with respect to its operations. The objectives are specific measurable results that an organization aims to achieve within
a time frame and with available resources. Objectives are basic tools that underlie all planning and strategic activities of the
organization and generally lay out short and long term goals, how much of what will be accomplished and by what timeframe.
Setting organizational objectives plays a large part in developing organizational policies and determining the allocation of
organizational resources. The successful achievement of objectives helps an organization to accomplish its overall strategic goals.
Performance indicators refer to the means by which an objective can be judged to have been achieved, or not achieved. An indicator
entails a type of performance measurement which enables an organization to evaluate its success with respect to a particular activity.
Further, an indicator is a measurable value that demonstrates how effectively an organization is achieving key business objectives.
Organizations use performance indicators to evaluate their success at reaching targets. Indicators are therefore tied to goals and
objectives and serve simply as “yardsticks” for measuring the degree of success in goal achievement. Performance indicators are
quantitative tools and are usually expressed as rates, ratios or percentages. Usually, performance indicators should be formulated to
be “Specific”, “Measurable”, “Achievable”, “Relevant” and “Time bound” (SMART).
45
24. PERFORMANCE REVIEW
Performance review refers to the systematic and periodic process that assesses an employee’s job performance and productivity in
reference to certain pre-established criteria and organizational objectives. Performance review can also be referred to as performance
appraisal, performance evaluation, career development discussion, or employee appraisal. A central reason for the utilization of
performance reviews is to improve individual employee and organizational performance. Other benefits include reinforcing desired
performance expectations, with the goal to increasing organizational effectiveness.
Principal Officers are management level employees of an organization entrusted with the discretion in the exercise of some portion
of organizational powers such as making major decisions. A Principal Officer may also be called an Executive Officer. He/she is generally
responsible for running a unit in an organization. The roles of the Principal Officers vary from one organization to the next but it
generally involves leading the organization.
A “Procurement Plan” includes long-range plans for ensuring timely supply of goods or services critical to an organization’s ability to
meet its core objectives. A procurement plan defines the products and services that an entity will obtain from external suppliers.
28. STAKEHOLDERS
Stakeholders are persons, groups or organizations that have interest or concern in an organization or project. A stakeholder is anybody
who can affect or is affected by an organization’s strategy or project, actions and accomplishments. They can be internal or external
and at senior or junior levels. The primary stakeholders in a typical organization are its investors, employees, customers and suppliers,
46
a community, government or trade associations. Stakeholders are crucial to the success of any project. When neglected they can
negatively affect an organization. However, when managed, they can actively promote the organization, an enterprise or project.
A strategic plan is a broadly defined plan aimed at creating a desired future. It is an internal document that does the following:
30. VISION
The term “vision” refers to the optimal desired future state – the mental picture – of what an organization wants to achieve in the
mid-term or long term. It is intended to serve as a clear guide for choosing current and future courses of action. Thus, it provides
guidance and inspiration with respect to what an organization focuses on achieving in, for example, five, ten or more years. A vision
statement is written succinctly in an inspirational manner and in a way that makes it easy for all employees to repeat easily at any
given time. Employees understand that their work every day ultimately contributes towards accomplishing this vision over the long
term. While the vision statement is simply a description of ‘what’ the organization intends to become, the mission statement is a
description of “how” the organization intends to turn the future into a reality.
This mechanism is a communication vehicle that provides employees with a means to report known or suspected illegal, unethical or
generally unacceptable practices in the workplace.
A whistle blower is a person who exposes misconduct, alleged dishonest or illegal activity that they know to be occurring in an
organization. Alleged misconduct ranges from violation of rules and regulation, fraud and corruption. The term “whistle blower” comes
47
from the whistle a referee uses to indicate an illegal or foul play. It is generally said that the United States civil rights activist Ralph
Nader coined the phrase in the early 1970s to avoid the negative connotations found in other words such as ‘informers’ and ‘snitches’.
Whistle blowing mechanisms should be designed to allow employees to report issues of misconduct with limited risk to their own
career and financial well-being. For an effective whistle blowing mechanism, the following key components are critical:
48
DEVELOPED 2015
REVISED 2018, 2020, 2021 & 2022
49