Oecd Public Governance Reviews: Oecd Integrity Review of Argentina Achieving Systemic and Sustained Change

Foreword
Acknowledgements
Abbreviations and acronyms
Executive summary
	Key findings and recommendations
Chapter 1.  Towards a coherent and co-ordinated public integrity system in Argentina
	1.1. Introduction
	1.2. Ensuring integrity policies across branches and levels of government in Argentina
		1.2.1. The implementation of the Public Ethics Laws is heterogeneous across branches and there is little dialogue between branches
		1.2.2. The majority of provinces do not have an integrity system in place
	1.3. Improving co-ordination and mainstreaming of integrity policies in the National Executive Branch
		1.3.1. A National Commission for Integrity and Transparency could strengthen the co-ordination amongst key integrity actors of the national executive branch
		1.3.2. Establish an integrity contact point dedicated to preventing corruption and promoting integrity policies in each public entity
	1.4. Developing a strategic approach to public integrity in the National Executive Branch
		1.4.1. The Anti-corruption Office could develop a National Integrity Strategy, with concrete and achievable goals and strategic objectives
		1.4.2. All public entities could elaborate own objectives and activities that are aligned with the National Integrity Strategy
	1.5. Strengthening the focus and the organisation of the Anti-corruption Office
		1.5.1. The Anticorruption Office could reinforce and make more visible its preventive work as a policy adviser
		1.5.2. The Anti-Corruption Office could be strengthened by increasing its financial and administrative autonomy
	Proposals for action
		Ensuring integrity policies across branches and levels of government in Argentina
		Improving co-ordination and mainstreaming of integrity policies in the National Executive Branch
		Developing a strategic approach to public integrity in the National Executive Branch
		Strengthening the focus and the organisation of the Anti-corruption Office
	References
Chapter 2.  Towards strengthening the evidence-base for integrity policies in Argentina
	2.1. Introduction
	2.2. Implementing a system for monitoring and evaluating Argentinian integrity policies
		2.2.1. The monitoring and evaluation of integrity policies requires relevant indicators measuring different levels and that are based on different data sources
		2.2.2. A central integrity monitoring system, which produces regular reports on the advances of the implementation of the National Integrity Strategy, could help to manage and communicate progress towards integrity goals
		2.2.3. Objective integrity policy evaluations could enable evidence-based learning, improve the design of future integrity policies and credibly reflect the government’s political will
		2.2.4. Rigorous impact evaluations could be used to test innovative integrity measures before considering implementing them at larger scale
	2.3. Gathering relevant data for integrity policies
		2.3.1. Expanding and adapting the use of staff surveys could provide data on how integrity policies contribute to a culture of integrity in Argentina’s public sector
		2.3.2. Data from citizen interactions with government and citizens surveys could help to understand how integrity policies affect awareness for integrity in the whole of society and encourage social accountability
	Proposals for action
		Implementing a system for monitoring and evaluating Argentinian integrity policies
		Gathering relevant data for integrity policies
	References
Chapter 3.  Building a culture of integrity in the public sector in Argentina
	3.1. Introduction
	3.2. Building a strong normative framework for public ethics and conflict of interest by reforming the Public Ethics Law
		3.2.1. Inconsistencies between the various legislations on integrity could be overcome during the current reform process of the Public Ethics Law
		3.2.2. A clear and realistic description of circumstances and relationships leading to a conflict of interest is needed A clear and realistic description of circumstances and relationships leading to a conflict of interest is needed
		3.2.3. Argentina could reform the Public Ethics Law to design a comprehensive system for managing conflict of interest
		3.2.4. The Anti-corruption Office could develop specific guidelines for at-risk categories of public officials such as senior civil servants, auditors, tax officials, political advisors, and procurement officials.
		3.2.5. Argentina needs to introduce additional measures to implement the cooling-off period for pre- and post-public employment
	3.3. Implementing integrity to support public officials to apply ethics in their daily work life
		3.3.1. The Code of Ethics should be simplified
		3.3.2. Entities could develop their own codes of ethics to respond to entity-specific corruption risks
		3.3.3. Argentina could reinforce the Code of Ethics with guiding and orientation material for ethical dilemmas and conflict-of-interest situations
	3.4. Mainstreaming integrity in Human Resources Management
		3.4.1. The merit principle could be reinforced by limiting the use of short-term contracts and using the same qualification and performance criteria for these positions as for permanent positions
		3.4.2. To ensure that senior management acts as role models, integrity could be included as a performance indicator
	3.5. Developing capacities and raising awareness for integrity to promote a change of behaviour
		3.5.1. The impact of the ethics training could be strengthened by designing more practical training elements and follow-up
		3.5.2. The Secretary of Public Employment could develop a mentoring programme for public officials at the junior level to build a pool of ethical leaders for the future
		3.5.3. The Anti-Corruption Office could design and test different behavioural reminders
		3.5.4. On an annual basis, Argentina could award an Integrity in the Public Service Award to public officials showcasing ethical behaviour
	3.6. Creating an open organisational culture
		3.6.1. The Ministry of Modernisation could engage senior public officials to provide guidance, advice and counsel
		3.6.2. To empower and engage employees, staff champions for openness could be nominated who would consult with staff on measures to improve employee well-being, work processes and openness
		3.6.3. Argentina has no whistleblower protection scheme
		3.6.4. Whistleblower protection goes beyond witness protection
		3.6.5. A communication strategy within the different entities as well as externally could encourage staff to raise concerns and improve the perception of whistleblowers
	Proposals for action
		Building a strong normative framework for public ethics and conflict of interest by reforming the Public Ethics Law
		Implementing integrity to support public officials to apply ethics in their daily work life throughout the public service
		Mainstreaming integrity in Human Resources Management
		Developing capacities and raising awareness for integrity to promote a change of behaviour
		Creating an open organisational culture
	References
Chapter 4.  Promoting transparency and integrity through a targeted and effective Financial and Interest Disclosure System in Argentina
	4.1. Introduction
	4.2. Strengthening the submission process: Adapting the form and processes to better fit the system’s objectives
		4.2.1. As most OECD countries, Argentina applies a risk based approach
		4.2.2. The prevention and identification of conflict of interest requires more information
		4.2.3. Beneficial ownership could be explicitly defined and included as one of the form of possession of assets for politically exposed persons
		4.2.4. The electronic filing system could be by using the digital signature for the authentication of disclosures.
		4.2.5. Using behavioural science to incentivise public officials to comply with their duty to declare their assets
	4.3. Ensuring effective verification of the submitted information
		4.3.1. To ensure effective verification, the Anti-Corruption Office needs to be granted access to confidential information
		4.3.2. The disclosure system has a well-developed system for verification
		4.3.3. Argentina could increase the availability of information to the public
		4.3.4. The user friendliness of the on-line interface could be improved
	4.4. Administrating appropriate and effective sanctions that create a deterrent effect
		4.4.1. Given the high burden of proof for declaring false information, Argentina could introduce civil sanctions for false and missing information
	Proposals for action
		Strengthening the submission process: Adapting the form and processes to better fit the system’s objectives
		Ensuring effective verification of the submitted information
		Administrating appropriate and effective sanctions that create a deterrent effect
	References
Chapter 5.  Applying an internal control and risk management framework that safeguards public integrity in Argentina
	5.1. Introduction
	5.2. Establishing a control environment with clear objectives
		5.2.1. SIGEN could ensure that clear objectives for the control environment are communicated to staff across the national public sector
		5.2.2.  SIGEN could assist government entities to more consistently apply the principles of the three-lines-of-defence model to give greater responsibility for internal control and risk management to operational management
	5.3. Developing a strategic approach to risk management
		5.3.1. SIGEN could improve its risk management approach to ensure it is consistent and clearly separated from the internal audit function
		5.3.2. SIGEN could promote the incorporation of risk management into the culture of government entities by providing clear guidance for operational staff and including risk management requirements in mandatory training
		5.3.3. Argentinian government entities could operationalise the risk management framework by assigning clear responsibility for risk management to senior managers
	5.4. Implementing coherent internal control mechanisms
		5.4.1. SIGEN could assist government entities to strengthen their internal control mechanisms to ensure that they are implemented and effective and that reasonable assurance is provided
	5.5. Improving the internal audit function
		5.5.1. SIGEN could ensure that its central coordination of internal audit leverages the available resources in order to strengthen oversight and enable a cohesive response to integrity risks
		5.5.2. All Argentinian government entities could implement control committees to better monitor the implementation of audit recommendations
	5.6. Strengthening the supreme audit institution
		5.6.1. Argentina’s National Congress could strengthen the functional independence of the AGN by increasing the AGN’s power to select its own audit topics and by clearly outlining the AGN’s independence and mandate in a specific organic law
		5.6.2. The AGN could strengthen its processes for the follow-up and monitoring of audit recommendations
		5.6.3. The AGN could increase its influence by setting an example of transparency
	Proposals for action
		Establishing a control environment with clear objectives
		Developing a strategic approach to risk management
		Implementing coherent internal control mechanisms
		Improving the internal audit function
		Strengthening the supreme audit institution
	References
Chapter 6.  Strengthening Argentina’s disciplinary regime for greater accountability
	6.1. Introduction
	6.2. Creating a more comprehensive and effective disciplinary framework
		6.2.1. The application of the disciplinary regime should be formally extended to all categories of public officials in Argentina.
		6.2.2. Temporary staff working in disciplinary offices should be allowed to prepare cases.
		6.2.3. The ongoing revision of the Public Ethics Law could improve consistency between the existing fragmented integrity framework and the disciplinary system.
		6.2.4. Argentina could introduce economic sanctions for public officials as well as administrative sanctions for private entities.
	6.3. Promoting cooperation and exchange of information
		6.3.1. The Treasury Attorney General Office could introduce mechanisms to further support coordination and communication with disciplinary offices.
		6.3.2. All the institutions participating in disciplinary proceedings could create a formal working group to enhance coordination among them.
	6.4. Improving understanding of the disciplinary regime
		6.4.1. The collection and use of data on the disciplinary system could be further developed in order to improve monitoring and evaluation of policies, performance assessment and communication.
		6.4.2. The Treasury Attorney General Office could ensure regular training and provide further guidance to staff working on disciplinary matters.
	Proposals for action
		Creating a more comprehensive and effective disciplinary framework
		Promoting co-operation and exchange of information
		Improving the understanding of the disciplinary regime
	References
Chapter 7.  Ensuring transparency and integrity in Argentina’s public decision-making processes and political financing
	7.1. Introduction
	7.2. Fostering integrity and transparency in lobbying
		7.2.1. Argentina could strengthen the existing framework on lobbying by extending its subjective scope beyond the executive branch, and ensuring the transparency of any kind of lobbying activity that may take place in practice.
		7.2.2. The Roundtable for Institutional Coordination on Access to Public Information could also ensure co-ordination of the implementation of lobbying regulation and manage a single online platform
		7.2.3. In order to improve the perception of lobbying among citizens and address concerns, Argentina could further promote stakeholder participation in the discussion and implementation of the regulations.
		7.2.4. Argentina could increase the responsibility of the private sector and promote complementary self-regulation
		7.2.5. Argentina should introduce effective sanctions for breaches of lobbying rules and make this information public
	7.3. Enhancing integrity in election processes
		7.3.1. Improving regulation of public funds and subsidies for campaign financing could strengthen the party system and level the field of competition by reducing incumbents’ advantages
		7.3.2. The scope for informal campaign financing should be reduced by closing existing loopholes in the law, especially by prohibiting contributions in cash and allowing donations by legal entities
		7.3.3. Transparency and audit capacities need to be strengthened in order to enable or facilitate better enforcement
		7.3.4. Credible and effective sanctions are key to ensure accountability in the political financing system
		7.3.5. Closing the gap between the national and subnational level is essential for the integrity of the political financing system
		7.3.6. Legislators in Argentina should take a clear stance against patronage and vote-buying by implementing the Australian ballot system, prohibiting vote buying and introducing sanctions
	7.4. Promoting transparency and stakeholder engagement
		7.4.1. All public entities across powers and levels of government need to ensure an effective implementation and enforcement of the Access to Information Law
		7.4.2. Argentina could improve the effectiveness of tools for stakeholder engagement and participation, as well as their awareness among citizens
	Proposals for action
		Fostering integrity and transparency in lobbying
		Enhancing integrity in electoral processes
		Promoting transparency and stakeholder engagement
	References
Chapter 8.  Cultivating a culture of integrity across society in Argentina
	8.1. Introduction
	8.2. Raising awareness in society of the benefits of integrity and reducing tolerance of violations of public integrity
		8.2.1. The Anti-Corruption Office could take an active role in communicating to citizens their roles and responsibilities for respecting public integrity.
	8.3. Engaging with the private sector to uphold integrity in business activities
		8.3.1. The guidance prepared by the Anti-Corruption Office could emphasise how to go beyond cosmetic compliance programmes.
		8.3.2. The Anti-Corruption Office could consider developing guidance for independent verification of the quality of companies’ business integrity programmes
	8.4. Carrying out civic education on public integrity in schools
		8.4.1. The Ministry of Education and the Anti-Corruption Office could incorporate integrity and anti-corruption concepts into the curricula
		8.4.2. The National Teacher Trainer Institute could incorporate training on public integrity into the Jurisdictional Curriculum Designs
		8.4.3. The Ministry of Education and the Anti-Corruption Office could partner with universities to mainstream integrity and anti-corruption throughout their degree programmes.
	Proposals for action
		Raising awareness in society of the benefits of integrity and reducing tolerance of violations of public integrity
		Engaging with the private sector to uphold integrity in business activities
		Carrying out civic education on public integrity in schools
	References
Chapter 9.  Proposals for Actions
	Chapter 1. Towards a coherent and co-ordinated public integrity system in Argentina
	Chapter 2. Towards strengthening the evidence-base for integrity policies in Argentina
	Chapter 3. Building a culture of integrity in the public sector in Argentina
	Chapter 4. Promoting transparency and integrity through a targeted and effective Financial and Interest Disclosure System in Argentina
	Chapter 5. Applying an internal control and risk management framework that safeguards public integrity in Argentina
	Chapter 6. Strengthening Argentina’s disciplinary regime for greater accountability
	Chapter 7. Ensuring transparency and integrity in Argentina’s public decision-making processes and political financing
	Chapter 8. Cultivating a culture of integrity across society in Argentina
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