9 december 2010Auditing integrity1 Experiences in Auditing Integrity in The Netherlands Ina de Haan Netherlands Court of Audit

9 december 2010Auditing integrity EU Twinning project: Risk mapping How does the NCA approach integrity? How did we continue? What opportunities?

9 december 2010Auditing integrity3 Role and approach NCA Prevention Repression People Opportunity/system

9 december 2010Auditing integrity4 Integrity in NCA strategy Good governance both requires and enhances integrity of the public sector Performance audits: Policies Organizations Regularity audits: Financial Compliance Audits of Integrity Care Systems Operational management

9 december 2010Auditing integrity5 Integrity in NCA strategy Integrity is a positive concept and has a wide scope, beyond fraud and corruption

9 december 2010Auditing integrity6 Integrity in NCA strategy Integrity of organisation is responsibility of management

9 december 2010Auditing integrity7 Integrity in NCA strategy All organisations in the public sector should have a risk based integrity policy

9 december 2010Auditing integrity8 Integrity in NCA strategy Approach should be a mix of repressive and stimulating measures

9 december 2010Auditing integrity9 Activities Three Tiers: 1. Embedding Integrity within Financial, Regularity and Performance Audits 2. Monitoring the Integrity Care Systems of the Public Sector 3. Sharing knowledge and working together with strategic allies =>

9 december 2010Auditing integrity10 Self Assessment INTegrity Tool developed in co-operation with the Dutch Ministry of the interior and city of Amsterdam

9 december 2010Auditing integrity11 What is SAINT? Self Assessment INTegrity vulnerabilities Integrity controls

9 december 2010Auditing integrity12 Two day workshop With cross section of employees

9 december 2010Auditing integrity13 Utilises knowledge and experience of employees Promotes integrity awareness !

9 december 2010Auditing integrity14 Quick results Practical and applicable recommendations

9 december 2010Auditing integrity15 Ownership Integrity

9 december 2010Auditing integrity16 methodology Object definition - organisation - processes Assessment vulnerabilities Assessment Maturity level Integrity Control System Gap analysis Recommendations - Reducing vulnerability - Strengthening controls

9 december 2010Auditing integrity17 Good experiences in The Netherlands –Prevention –Involvement and ownership –Quick results Good experience with similar approach in Hungary EU Twinning project on corruption risk analysis Into-SAINT project: Adapt methodology for other SAIs to use.

9 december 2010Auditing integrity18 Into- Presentation at INCOSAI Johannesburg November SAIs interested in moderator training.

9 december 2010Auditing integrity19 Monitoring integrity policy Integrity management: a base line measurement in 2004 (2005) State of integrity management in central government in 2009 (2010)

9 december 2010Auditing integrity20 Results

9 december 2010Auditing integrity21 Employee perception survey Enrichment of documental evidence Insight in effects and maturity of instruments; especially soft controls Internet survey amongst civil servants (a-select) Integrity module validated emloyee perception survey “Internetspiegel” Added items on knowledge of regulations, policy and values 6579 respondents (38%)

9 december 2010Auditing integrity22 Audit design 2009 Integrity care system Intermediary effects Outcome Quality Hard controls General controls Soft controls Moral conscious behaviour Following rules Ethical behaviour Compliance with audit criteria Documental evidence Employee perception survey

9 december 2010Auditing integrity23 Benchmarking results

9 december 2010Auditing integrity24 Familiarity with incident procedures Notification procedure Investigation procedure Sanctions Communication Registration

9 december 2010Auditing integrity25 Ethical management: values and standards Clear values and standards Known and understood Relevant and directional Applied

9 december 2010Auditing integrity26 Ethical management: integrity policy Clear management vision Employees informed Actieve management Integrity risks anticipated Dilemma support Employee performance evaluation

9 december 2010Auditing integrity27 Ethical management: tone at the top Showing high ethical standards Sanctioning undesired behaviour Sanctioning immoral behaviour Exemplary behaviour management Ethical decision making Reaction to integrity breaches

9 december 2010Auditing integrity28 Analysis results

9 december 2010Auditing integrity29 Using geospatial information in audit combating money laundering

9 december 2010Auditing integrity30 No Money Laundering, or no detection? Many suspicious transactions, are criminals caught?

9 december 2010Auditing integrity31 Many suspicious transactions, few criminals are caught Very few suspicious transactions, if detected criminals are caught

9 december 2010Auditing integrity32 Criminals that are caught have a 54% chance of getting punished Criminals that are caught have a 81% chance of getting punished

9 december 2010Auditing integrity33 Problem: limited expertise, priority and information for investigation Problem: not enough capacity for investigation

9 december 2010Auditing integrity34 Lessons learned Rule based approach is not enough to make it work Make integrity policy compulsory for all PS organisations Soft controls are vital, therefore involve HRM in integrity policies Less checking, more self assessment and sharing of experiences leads to shared ownership and continuous evaluations and learning Combine layers of information and use benchmark techniques Co-operation between judiciary, advisory and audit Leadership x3

9 december 2010Auditing integrity35 Opportunities for Leadership Innovative risk mapping Use of geospatial information Combining data Benchmarking and international comparison Involving employees and stimulating ownership Involving civil society Integrity Leadership