Introduction
Good evening and welcome at the Flemish government administration. My name is Kristien
Verbraeken and I work for the Flemish government administration, here in this builing at the
Public Governance Department and I am the Integrity Officer of the Flemish government
administration since October 2010.
In other organisations my function may be named compliance officer but compliance is narrower
than integrity and our organisation has a very broad definition of integrity.
Our definition of integrity covers the whole range from correct and proper interaction and
relations with people (colleagues, citizens, suppliers and business partners…) to correct and
proper use of means (not only means such as office supplies, company cars, funds but also
business information, work time …)
So integrity at the Flemish government administration covers a very wide field of different
aspects of values and ethics. How did we arrive at such a broad concept of integrity and how is it
reflected in our integrity policy? I will try to answers these questions by giving you an overview of
the start of our policy, its development and the plans and challenges for the near future.
Wat is integriteit (bij de Vlaamse overheid? (het ruime begrip schetsen)
Wat is de Vlaamse overheid of wat is het toepassingsgebied van het integriteitsbeleid (aantal
entiteiten, aantal personeelsleden (bijna 41.000 personeelsleden – hoeveel entiteiten?,
afhankelijk van wat je als vertrekbasis neemt, onduidelijkheid over het precieze
toepassingsgebeid)
Genesis
The start of our integrity policy was in part caused by a fraud scandal in Antwerp in 2003. A
number of public officials such as council members had used/abused the credits cards which
were meant for professional expenses, for a number of personal, sometimes very personal or
rather excessive purchases. This caused quite a stir and led to several council members stepping
down. The scandal also had a big impact on the public opinion and resulted in a change in
political climate: governments had to be more transparent and account for what they spend the
tax payers’ money on, governments have to earn the trust of the citizens. Transparency,
accountability are key words in what became the policy of ‘good governance’ or ‘government
governance’.
In this changed political environment the Flemish government decided in 2005 to start working
on an official integrity policy as one of the main pillars of good governance and to appoint an
integrity officer to manage the process toward an integrated and co-ordinated integrity policy.
This brings me to the 1st phase of the development of our organisations’ integrity policy: 20052010
The first five years were mainly dedicated to building structures and developping instruments to
construct 3 pillars of the integrity policy: prevention, detection and reaction.
In 2006 the first Integrity officer was appointed and IAVA, the internal auditing division was
founded
In the same year a new version of the code of conduct was introduced and the circular on high
risk functions or as we call it ‘vulnerable functions’ and regulations for former employees who
start working for private companies, and are therefore excluded from government procurement
two years after leaving the public service.
Between 2004 and 2006 The Flemish government was the first government in Belgium to have a
whistleblower protection act, which still is named as a good practice on a European scale. To
implement the whistleblower protection act the cabinet office and IAVA drew up protocols with
the office of the ombudsperson.
Following these major initiatives a number of instruments were developped by different
colleagues who all contribute to the integrity policy (overzicht matrix) and correspond to one or
several of the 3 pillars of our policy.
e.g dilemma trainings, manual for the identification of ‘vulnarable functions’, guidelines for the
implementation of an integrity policy for the seperate departments and divisions, the training of
trusted intermediaries, a strategy for crisis communication in case of integrity calamities.
As you can see from this matrix there are al lot of entities and colleagues involved with the
building of the integrity policy and bringing it into practice. This resulted in not only a very broad
work area – because of our broad definition of integrity – but also in a multitude of initiatives
and instruments that were not geared to oneanother, there was no integration or co-ordination
to speak of.
In 2009 the Integrity officer changed jobs and there was almost a year of a stand still, in the
midst of the making of a new code of conduct. This obviously led to some confusion on what
course the code of conduct and the integrity policy would take. But looking back on this periode I
believe that this period of stand still also opened the eyes of some entitities that integrity policy
is something that has to be worked on. This became even more apparent because of the
screening that IAVA did: IAVA screened all entities on their level of maturity and scored them on
11 criteria: one of which the level of maturity of their integrity policy and its implementation.
This confronted many entities with the need to invest in their integrity policy.
It was about this time I started working as Integrity Officer: October 2010. The first year I tried to
make up for the year of stand still and gave priority to the new and third version of the code of
conduct and making it known to our employees with a communications campaign. In the past the
code of conduct had been implemented simply by the publication of a circular but no other
communication efforts had been made to make it known to the employees. So it created quite a
buzz when we launched the new code of conduct with posters in all the buildings of the Flemish
government administration and started to flyer fake film tickets to draw attention the
regulations on how to deal with gifts and invitations as a civil servant, as one of the regulations
that are included in the new code of conduct.
Together with the campaign the integrity website was completely renewed with many cases, tips
and of course the instruments and links to the services of the partners.
This campaign also triggered many entitities to start working on their integrity policy and made
the integrity website one of the most visited sites of the Flemish government administration.
Where do we stand today?
The seconde phase 2010-2011: we are on a tipping point for the integrity policy to evolve
from this multitude of structures, partners an instruments to a more coherent policy with
more co-ordination and fine tuning between partners and their initiatives.
Key element in this change is communication: to bring these partners together but also to
inform entitites and employees about integrity policy and the services we offer
communication plays a vital role.
The 3rd version of the code of conduct has been drawn up together with representatives of
the 13 departments of the Flemish government administration. This involvement of the 13
departments obviously contributed to the support it received from the different entities. This
collaboration also led to having an integrity point of contact in almost all entities of the
Flemish government administration.
The new code of conduct is explicitedly based on the values of the Flemish government
administration which are well known by the employees for these are the values they are also
appraised/assessed upon as part of the yearly appraisal. This way integrity becomes a part of
the appraisal criteria of all employees.
Next to the introduction of a new code of conduct, the virtual Integrity office was founded in
2011. In this ‘virtual’ office all the partners of the Flemish government administration are
brought together to work on a mutual integrity policy and where all the relevant domains
(integrity, welfare and saftey at work, social services, IAVA , diversity and equal opportunities
and training and support) are linked to achieve more integration and co-ordination.
Why is called virtual? Because it is not an actual office but it is this collaboration of different
experts and domains of expertise who join forces but who also stay active on their own
domain of expertise.
The road ahead
The 3rd phase 2012-2014 has just started and focuses on the multidisciplinary approach of
the integrity policy.
Three elements are key in this multidisciplinary approach: the virtual office of integrity, the
‘unique’ centre of complaints and the integrity network group.
The virtual office of integrity consists of three groups: a centre group that deals with cases
that have both important integrity aspects and welfare and safety aspects.
The second group consists of 6 members, representatives of the central partners of the
Flemish government administration who from their own perspective and goals work on the
integrity policy. This group will determine parameters to measure the results of the integrity
policy and will make policy proposals to improve the policy. It will also give advice to
entitities with regards to the implementation of the integrity policy and work on mutual
initiatives e.g communication initiatives.
The third group gathers representatives of colleagues who work on the implementation of
the policy in the different departments e.g. the complaints managers, the trusted
intermediaries, the integrity points of contact and colleagues who have a specific field of
expertise that offers an important value to the integrity policy e.g the crisis manager, the
reputation manager, the manager coach, representatievs of the legislation devision…
This third group acts as a sounding board for the policy proposals of the sencond group and
will be able to give important feedback on the practicality of the proposals to make them
actually work in practice.
The unique centre of complaints is an improvement of the current centre, named Spreekbuis.
Employees can call a free number if they have questions about or complaints on welfare and
safety and integrity at work. Today this service is available to approximately 15.000 eployees,
who work in entities that are a member of the central division for welfare and safety. We
want this service to be available to as many employees as possible to make it a true ‘unique’
meaning, uniform centre of complaints. With regards to integrity complaints the centre will
also be expanded with a point of contact for citizens and private firms who have complaints
about integrity at the Flemish government administration. This unique centre of complaints
will gather the information, cases and data for the virtual integrity office to work with and
will play a vital role in improving the whistleblower protection act. By using the unique
complaits centre as thé channel to register complaints, we can give better protection to
whistleblowers as the identity of the wistleblower is kept a secret. Today whistleblowers
often voice their complaints in their own entity which makes them vulnerable to
repercussions.
The third element for the multidisciplinary approach is the integrity network group. The
network group gathers all integrity contact persons of the entities of the Flemish government
administration to share knowledge and information. They keep the integrity officer informed
on what is important for their entity, what issues and topics they are dealing with, which is
essential input for the overall policy. The Integrity officer can share first hand information
about the policy and give advice on policy implementation via the network. The network will
also organise one yearly event on integrity which keeps integrity on the agenda.
Although we have only recently started working together on this multidisciplinary approach
we have already discoverd that an extra pillar needs to be added to our policy, namely the
aftercare or follow- up pillar. When there has been a serious breach of integrity, the entity
involved really needs support to get back on the right track: all trust between employees,
between employees and management is gone and employees are not motivated anymore to
work for their organisation. With different experts the entity can be helped to rebuild its
mutual trust, its activities and reputation.
Other initiatives in 2012-2014 include the renewal of the ICT code of conduct, work group
integrity risk analysis, integrity training for managers and benchmarking with other
governments.
Challenges
On the other hand the multidisciplinary approach also confronts us with a number of issues
and challenges:
- Delineation of work field: integrity is so broad that almost everything has a link with
integrity – workload has to be kept manageable
- Clarity in scope (range of application): which entities have to comply with the integrity
policy? Because of the organisational structure some entities are very autonomous and
have power of self regulation also in personnel matters, such as integrity. This difference
in scope does not beneficial for transparency and uniformity.
- Range of application of the different integrity partners: the different partners have all
different ranges of application which proves a challenge to ensure a uniform service to
the entities
- Professional secrecy versus obligation of discretion: some integrity partners are bound by
professional secrecy while other partners are not, to share knowledge and information
between partners we have to tread carefully not to make any professional errors while
striving for an optimal service to the employees and organisation.
- 4th pillar: aftercare still has to be completely built
- Communication: is an important element for success of our policy and to show our
stakeholders that our organisation values integrity very highly. But it is a constant
balance exercise for one can never boast a perfect integrity policy because one can never
rule out breaches.
This brings me to the conclusion of my talk on our integrity policy: it is a neverending
story. Why?
Working on an integrity policy is a continuous process that evolves parallel with the
evolution of the organisation and society. To keep pace with this evolution co-operation
and communication are essential to gain support, involvement, awareness and to make it
part of the identity and DNA of the organisations and its reputation. Integrity is not a nice
to have policy theme but an absolute neccesity, not only for private companies but most
certainly for governments who have to account for how they spend the tax payers’
money. It is a non stop task that has to make leaps in periods when it does not have to
deal with serious integrity breaches to improve its policy and its implementation to try to
make to risk of breaches a small as possible without ever forgetting that a complete risk
free organisation cannot be achieved.
Hence it is a neverending story.
Thank you for listening to my story.