Examples of Best Practices: Anti- corruption Strategy of the TCA Musa KAYRAK Senior Auditor, CISA

Best Practices : Preventive 1. A strategic approach to the fight against corruption: Anti- corruption strategy and action plan of the TCA ( ) 2. Improving audit capacity through the use of information technologies: Developing our own audit management system 3. The internal element of integrity: Regulation on the professional code of ethics for the TCA auditors

Best Practices: Detective 1. Physical observation and site visits 2. General risk assessment methodology of the TCA

Best Practices : Reporting Reporting suspected cases of corruption in accordance with the steps clearly defined in the law on the TCA and relevant regulations

Background Information The Anti-corruption Strategy of the TCA has four main references: 0 The regulatory framework 0 The National Strategy of Turkey for Improving Transparency and Strengthening Anti-corruption 0 The Strategic Plan of TCA and its Action Plan 0 International indexes on corruption, integrity, and transparency

1. National Strategy for Improving Transparency and Strengthening Anti-corruption  Adopted in February 2010 and published in Official Gazette  Issued by the decision of Council of Ministers and covers 2010 – 2014  Coordinated by the Prime Ministry Inspection Board  The main components of the Strategy: Prevention, enforcement of sanctions, and raising awareness in the society.  Aiming at  removing the factors that prevent transparency and feed corruption and  developing an understanding of governance that is fair, accountable, transparent and credible.

TCA on the National Strategy for Improving Transparency and Strengthening Anti- corruption TCA is mentioned in following actions: 1. Action 1.5: Adoption of the new TCA Law 2. Action 1.9: Reviewing public procurement system 3. Action 1.13: Strengthening the capacity of auditing public sector 4. Action 1.14: Focusing on high risk areas by going through audit reports and taking the necessary actions

According to the Action Plan of the Strategic Plan of the TCA, there are three main actions decided: ACTIVITY RESPONSIBLE UNITS TIMEFRAME PERFROMANS INDICATORS/OUTPUTS Activity : Preparing and implementing the strategy for the fight against corruption. Commission for the Fight Against Corruption March 2014Strategy paper for the fight against corruption Activity : Detecting risk-prone areas on the basis of the audit reports and prioritizing such areas in the annual audit programs Under the coordination of the Head of Sector Annual Audit Program -Completing the risk-prone area/sector report -Decrease in the number of corrupt activities detected in the Audit Reports by the end of 2018 Activity : Organizing conferences, panels, trainings etc. to raise awareness concerning TCA’s role in the fight against corruption -Under the coordination of the Head of Sector -Training Department Number of conferences/panels organized 2. Strategic Plan of TCA

3. International Indexes Main issues raised by Transparency International Corruption Perception Index, Global Integrity Report, Open Budget Index:  Follow-up of reports  Communication with public  Figuring audit expectations out and providing feedbacks

Methodology and Scope-1 The Anti-corruption Strategy of the TCA includes followings:  1 Strategic GOAL  7 Strategic OBJECTIVES in seven areas: Strategy, methodology development and implementation, training, use of information technologies, follow-up, cooperation, self-integrity control framework  25 ACTIONS to be taken  Mapping of 25 actions to the survey questions/criteria in indexes on corruption, integrity and transparency  Bibliography of referred ISSAIs, academic studies, reports of national or international organizations, laws and regulations in force

Methodology and Scope-2 Each action is analyzed according to:  Scope of the action: WHAT  Detailed steps to realize the action: HOW  Expected benefits: WHY  Responsible units and their responsibilities: WHO  Timeframe: WHEN  Prioritization  Outputs and performance indicators  Reference to standards and academic/professional studies

Expected Benefits and Outcomes  Focusing on high risk areas by referring to them in audit strategic plans/ annual audit programs  Better use of information technologies in the fight against corruption (e.g. complaint sys, surveys, use of social media)  Highlighting vulnerable areas when giving opinion on certain regulations  Better understanding and meeting the expectations of citizens  Improving the competence of auditors concerning fraud and corruption  Contribution to the ranking of Turkey in indexes on corruption, integrity and transparency  Improving the self-integrity of the TCA  Promoting cooperation and collaboration with other public institutions with responsibilities in anti-corruption efforts and international organizations

STRATEGIC GOAL STRATEGIC OBJECTIVES ACTIONS

STRATEGIC GOAL «To strengthen role of the TCA in the fight against corruption and fraud by promoting transparency and accountability in the public sector and improving the efficiency of the TCA audit in accordance with international standards»

STRATEGIC OBJECTIVE 1: To determine audit strategies which pay attention to areas open to fraud and corruption and contribute to the strengthening of public financial management and control systems. ACTION NO 1: Preparing the audit strategic plans and annual audit programs by considering the areas with high risk of fraud and corruption ACTION NO 2: Launching questionnaires regarding audit expectations of public on our webpage and considering the results in the processes of audit planning and reporting in accordance with Article 31 of the TCA Law ACTION NO 3: Evaluating the news regarding fraud and corruption that appear in the press

STRATEGIC OBJECTIVE 2: To develop audit methodologies in the light of institutional knowledge and generally accepted standards on auditing and accounting so as to improve efficiency of TCA audit. ACTION NO 4: Preparing the «Manual on the Fight against Fraud and Corruption» ACTION NO 5: Reviewing the audit guidelines of the TCA within the framework of principles of international audit standards relating to anti-fraud and anti-corruption ACTION NO 6: Creating a database of the audit procedures regarding anti-fraud and anti-corruption” and including them in the audit pool of SAYCAP ACTION NO 7: Implementing the IT audits ACTION NO 8: Providing input on areas open to fraud and corruption when giving opinion of the TCA on draft laws and regulations

STRATEGIC OBJECTIVE 3: To analyze institutional training needs of the TCA on the basis of international standards on auditing and accounting and to carry out necessary trainings determined. ACTION NO 9: Conducting regular trainings on the subject of accounting errors and fraud ACTION NO 10: Conducting regular trainings on the subject of fighting against fraud and corruption ACTION NO 11: Training a group of expert auditors specialized on the subject of fight against fraud and corruption ACTION NO 12: Promoting the attendance to the certification programs related to forensic accounting and auditing ACTION NO 13: Compiling the national legislation, international agreement and other documents related to fighting against fraud and corruption, translating the basic documents to Turkish, and publishing them on our webpage

STRATEGIC OBJECTIVE 4: To use the information technologies for increasing the efficiency of the TCA in the fight against fraud and corruption. ACTION NO 14: Developing a web-based complaint system ACTION NO 15: Sharing the TCA reports via e- mail and social media ACTION NO 16: Publishing judicial decisions of the TCA on our webpage on timely basis ACTION NO 17: Developing a web-based application for the responsible parties to keep track of trial stages

STRATEGIC OBJECTIVE 5: To strengthen the preventive and deterring role of the TCA in the fight against fraud and corruption by means of effectively monitoring the results of audit and judicial activities ACTION NO 18: Making the process of follow- up of findings operational ACTION NO 19: Following the results of cases sent to the Office of Public Prosecutor and including them in annual activity reports ACTION NO 20: Monitoring and reporting on the results of the execution of writs

STRATEGIC OBJECTIVE 6: To develop collaboration with the national and international actors in the field of anti- fraud and anti-corruption ACTION NO 21: Organizing collaboration activities for ensuring an exchange of ideas between the auditors and members of the TCA and the judiciary (judges and public prosecutors)on the subject of fraud and corruption in order to increase the effectiveness of denunciation mechanism ACTION NO 22: Developing communication and collaboration with the international organizations working in the field of fighting against fraud and corruption ACTION NO 23: Organizing conferences together with the Prime Ministry Inspection Board, the Ethics Committee, the Financial Crimes Investigation Board, the General Directorate of Security, inspection boards and internal audit units on the subject matter and discovering other opportunities of collaboration

STRATEGIC OBJECTIVE 7: To develop the accountability culture and transparency understanding within the TCA itself ACTION NO 24: Implementing an INTOSAINT workshop to improve the internal aspect of transparency and accountability ACTION NO 25: Establishing the Ethics Committee

Musa KAYRAK Senior Auditor, CISA