The Integrity Offices in the Public Integrity Model

Since the National Policy on Integrity and Fight against Corruption was approved by D.S. N° 027-2017-PCM, it has sought to incorporate prevention as a strategy to be considered in the public sphere through the Integrity Model; however, the guidelines and actions provided are still in the process of implementation with incomprehension from those who should firmly sustain this process that aims to address the country's main problem: corruption.

Progress in the field of prevention requires political decision to improve the culture of integrity which, although it has a legal framework that has been promoted for some time on the recommendation of the OECD, we are still halfway there, being necessary to have a better regulation for the deployment of the integrity function, as well as to specify competencies and effectively assume the responsibilities of internal control by the head and management bodies of public entities in accordance with Law No. 28716 of 2006.

Bill 5635/2023-PE, which proposes to strengthen the integrity function in the public sector through the implementation of the integrity model in all entities to prevent acts of corruption, contributes to this objective. However, more than a year has passed since its presentation to the Congress of the Republic without even having an opinion, questioning that the legislative initiative maintains integrity as a Function (Integrity Function), renouncing the creation of a Functional System, as proposed by the OECD and as it should be in order to have greater strength.

Let us remember that Article 45 of the Executive Branch Law (Law No. 29158) establishes that the purpose of the functional systems is to ensure compliance with public policies that require the participation of all State entities, so that converting this Function into a System would be a huge step towards aligning the Public Sector in the integrity policy, for which having a governing body would be decisive to advance in strengthening the capacity to prevent and combat corruption.

Naturally, it is essential to consider the implementation of Institutional Integrity Offices within the organizational structure of public entities as proposed in the prevention model, considering all the elements required for effective work: direct line to senior management, political support, stability in positions and sufficient resources to promote a culture of integrity in the entity. At present, progress in this area is limited, since not all public administrations have incorporated integrity offices, nor have they done so to the same standard, since in some cases they have been inserted into the structure of the organization, but in other cases the integrity function has been entrusted to some body, which weakens its performance.

According to the last National Report on the implementation of the Integrity Model of 2023, in the Executive Branch there is an important group of entities (29) that have already incorporated the Integrity function through an Organic Unit (Office of Institutional Integrity), which gives greater weight to the function. However, most entities have chosen to incorporate these offices as Functional Units (45 entities), which implies an administrative decision with a lower degree of organizational intensity.

Other assumptions at the Executive Branch level for the integration function have been to assign it to a permanent work team (9 entities), delegation to a server (18 entities) and delegation to the Human Resources Office (34 entities). All this implies that out of 135 entities that are applying the Public Integrity Model in the Executive Branch, only 21% have a formula for integrating these offices organically within the ROF. At the level of regional and local governments this is even weaker.

Naturally, the attributions of these officials are of primary importance, since they lead the units responsible for exercising the integrity function in public entities for a series of tasks such as the implementation of the integrity model, the promotion of integrity, strengthening the culture of integrity, among others. The members of these offices are usually young and committed public servants who already make up a specialist group that in the near future should become visible within the families of positions to ensure career lines. We are sure that this critical mass, which is accumulating casuistry and good practices, will develop a positive work that will permeate the entire administration to introduce the integrity culture.

If integrity officers are uncomfortable, it is almost certain that they are doing their job well. It is already known that in some entities there are arbitrary dismissals, which should lead us to other discussions to seek alternatives to the precariousness of the appointments of these officials.

Finally, we must highlight the implementation of the Index of Preventive Capacity against Corruption designed by the Integrity Secretariat of the PCM (Resolution No. 002-2021-PCM-SIP), which is an innovative instrument to evaluate the administration in a sensitive aspect, which has been generating a movement in many entities to improve their performance, which still remains at a technical level, without political empowerment. Let us hope that this will gradually change.