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National Anti-Corruption StrategyDiscussion Document

DISCUSSION DOCUMENTTowards a National Anti-Corruption Strategy

for South Africa

This document re�ects the inclusion of some of the comments and recommendations made during the initial consultations in

September and October 2016

December 2016

National Anti-Corruption Strategy Discussion Document

Published in the Republic of South Africa, 2016

This discussion document was commissioned by the Steering Committee responsible for the development of

a National Anti-Corruption Strategy (NACS), as part of the South African Government’s anti-corruption

programmes. The work towards the development of a resilient anti-corruption system, as envisioned by the

National Development Plan, was done under the guidance of the Anti-Corruption Inter-Ministerial

Committee (ACIMC).

NACS Steering Committee members : Department of Cooperative Governance (DCoG)

Department of Public Service and Administration (DPSA)

Department of Planning, Monitoring and Evaluation (DPME)

Government Communication and Information System (GCIS)

O�ce of the Public Service Commission (PSC)

National Intelligence Coordinating Committee (NICOC)

South African Local Government Association (SALGA)

State Security Agency (SSA)

Technical assistance : Deutsche Gesellschaft für Internationale

Zusammenarbeit (GIZ1)

Researched and compiled by : Public A�airs Research Institute

Distributed by : Government Communications (GCIS)

Private Bag X745, Pretoria, 0001

Street address: Tshedimosetso House

1035 cnr Frances Baard and Festival streets

Hat�eld

PRETORIA

Tel: (012) 473 0000

Fax: (012) 325 2030

E-mail: [email protected]

Design & layout : SSA Reprographic Unit

1 The GIZ is a federal enterprise specialising in the �eld of international cooperation for sustainable development, with the German Federal Ministry for Economic Cooperation and Development (BMZ) as its main commissioning party. The GIZ has provided ongoing support to the South African government through bilateral cooperation since 1993. The Governance Support Programme (GSP) was established through a bilateral agreement between South Africa and Germany. The GSP aims, among other things, to strengthen the capacity of state institutions and their cooperation with the private sector and civil society.


ContentsGlossary of key terms used in the document List of abbreviations and acronyms

Introduction 1

PART A : Background 21. Process for developing proposals for the strategy 22. Next steps: roadmap for developing a �nal strategy 23. Policy context 24. Role players and stakeholders 55. Challenge 8

PART B : Proposals for a national anti-corruption strategy 171. Rationale for a national anti-corruption strategy 172. Vision 173. Objectives 184. Conceptual framework 185. Strategic pillars and programmes 19

Pillar 1 : Support citizen empowerment in the �ght against corruption 21Pillar 2 : Develop sustainable partnerships with stakeholders 22Pillar 3 : Improve transparency 23Pillar 4 : Improve the integrity of the public procurement system 24Pillar 5 : Professionalisation 25Pillar 6 : Improve adherence to integrity management and anti-corruption mechanisms and improved consequence management for non-compliance 26Pillar 7 : Strengthen oversight mechanisms 27Pillar 8 : Strengthen the resourcing, cooperation and independence of dedicated anti-corruption agencies 28Pillar 9 : Vulnerable sector management 29

6. Institutional mechanisms to implement the strategy 30

Appendices 31Appendix A : Roadmap for developing a �nal national anti-corruption strategy 31

Purpose 31Proposed Process 31Phase 1 : Research, Initial Consultation And Drafting 32Phase 2 : Public Consultations 33Phase 3 : Finalisation of the NACS 35

Appendix B : Summary of Programme Elements under each Strategic Pillar 36Appendix C : United Nations Guidelines On Developing National Anti-Corruption Strategies 37


GLOSSARY OF KEY TERMS USED IN THE DOCUMENT

Accountability: is understood as the acknowledgment and assumption of responsibility for actions and decisions, and being answerable to a person or group of people (such as Government being answerable to citizens, a �rm being answerable to a regulator, a non-governmental organisation being answerable to donors).

Business sector: refers to private sector �rms in the formal and informal sector, as well as organised business, including their employees and members of the Board.

Civil society sector: refers to non-governmental organisations outside the business sector, inclusive of organised labour, community-based organisations, religious bodies, social movements, the media, academia, professional bodies and non-pro�t organisations (NPOs).

Corruption: According to South Africa’s Prevention and Combating of Corrupt Activities Act (PRECCA), Act 12 of 2004 corruption occurs when any person directly or indirectly accepts or o�ers (or agrees to o�er or accept) any form of grati�cation (i.e. not necessarily monetary) that will either bene�t themselves or another person. In terms of this legislation, corruption is de�ned as acts that involve an improper/corrupt exchange between two or more parties. In South Africa, as in many other countries, there is some debate about the de�nition of corruption. For the purposes of this document, the de�nition of corruption includes the acts de�ned as corrupt under the PRECCA, and is broadened slightly to include the concept of “abuse of entrusted power or authority for private gain” that does not have to involve more than one party (for example, theft of public monies where there is only one witting party to this theft).

Government or public sector: includes employees and elected and nominated o�cials in all three spheres of government (including those of state-owned and state-controlled entities).

Local government: includes employees of local municipalities, local government agencies and councillors.

Professionalise: refers to the orientation and skills set of employees. A professionalised sector is one in which its employees see their commitment �rst and foremost to the citizens of the country, according to the values and requirements of the Constitution of the Republic of South Africa and to implementing policies/services/products in the interest of social and economic transformation,


and not to private or party interests where these deviate from formal policy. Further, it incorporates a vision in which employees have the necessary skills and experience to undertake their work.

Provincial and national government: covers employees and executive authorities of national and provincial departments and entities.

Public service: refers to employees of national and provincial departments and entities as de�ned in the Public Service Act.

Transparency: refers to an organisation or individual operating and providing information in such a way that it is easy for others to see what actions are performed and to enable relevant groups of people to hold the organisation/sector/leader accountable for their actions, including whether due process has been followed.

Vulnerable sector or high-risk sector: refers to an area, sector and/or institution with a high risk or speci�c vulnerability to the manifestation of corrupt practices or activities. This extends to business/private industries or sectors (e.g. mining or construction), or institutions inclusive oforgans of state (e.g. departments, institutions, state-owned entities or municipalities) or large-scale projects (e.g. infrastructure development) at risk of being targeted by actors or facilitators (both domestic or foreign) of corrupt practices, or that could be at risk due to their position or involvement in procurement or decision-making processes (e.g. regulatory or compliance monitoring functions, procurement, investigative, judicial) and/or that could place the development of the country or functioning of government systems at risk or make it vulnerable to exploitation.


LIST OF ABBREVIATIONS AND ACRONYMS

ACIMC Anti-Corruption Inter-Ministerial CommitteeACTT Anti-Corruption Task TeamAEPF Anti-Intimidation and Ethical Practices ForumAFU Asset Forfeiture UnitAGSA Auditor-General of South AfricaANC African National CongressAU African UnionBAC Business against CrimeB-BBEE Broad-Based Black Economic EmpowermentBEE Black Economic EmpowermentBUSA Business Unity South AfricaCEO Chief Executive O�cerCPI Corruption Perceptions IndexDBE Department of Basic EducationDCoG Department of Cooperative GovernanceDPCI Directorate of Priority Crime InvestigationDPLG Department of Provincial and Local GovernmentDPME Department of Planning, Monitoring and EvaluationDPSA Department of Public Service and AdministrationDTI Department of Trade and IndustryEA Executive AuthorityEthicsSA Ethics Institute of South AfricaFATF Financial Action Task ForceFIC Financial Intelligence CentreGCIS Government Communication and Information SystemGIZ Deutsche Gesellschaft für Internationale ZusammenarbeitHR Human Resource ManagementHSRC Human Sciences Research Council IGI Inspector-General of IntelligenceIPID Independent Police Investigative DirectorateJCPS Justice Crime Prevention and Security ClusterMEC Member of the Executive CommitteeMFMA Municipal Finance Management ActMPAT Management Performance Assessment ToolMPS Municipal Police ServicesMTSF Medium Term Strategic Framework


NACF National Anti-Corruption ForumNACS National Anti-Corruption Strategy NDP National Development PlanNEOF National Ethics O�cers Forum NICOC National Intelligence Coordinating CommitteeNPA National Prosecuting AuthorityNPC National Planning CommissionNGO Non-governmental organisationOCPO O�ce of the Chief Procurement O�cerOECD Organisation for Economic Cooperation and DevelopmentPAIA Promotion of Access to Information ActPAJA Promotion of Administrative Justice ActPARI Public A�airs Research InstitutePFMA Public Finance Management ActPRECCA Prevention and Combating of Corrupt Activities ActPSC Public Service CommissionRSA Republic of South AfricaSADC Southern African Development CommunitySALGA South African Local Government AssociationSANDF South African National Defence ForceSAPS South African Police ServiceSARS South African Revenue ServiceSCM Supply chain managementSCOPA Parliament’s Standing Committee on Public AccountsSIU Special Investigating UnitSMS Senior Management ServiceSOE State-owned enterprise / state-owned entitySSA State Security AgencyTAU Technical Assistance Unit (of the National Treasury)UNCAC United Nations Convention against CorruptionTAU Technical Assistance Unit (of the National Treasury)UNCAC United Nations Convention against Corruption

National Anti-Corruption Strategy Discussion Document1

INTRODUCTIONThe Government’s commitment to reduce corruption in South Africa is articulated in the Medium Term Strategic Framework (MTSF) 2014–2019, the National Development Plan (NDP), and the National Security Strategy (NSS). The MTSF 2014-2019 requires the development of a National Anti-Corruption Strategy (NACS) and a supporting implementation plan.

This document outlines proposals for a National Anti-Corruption Strategy. As noted in the National Development Plan, tackling corruption involves commitments from all members and sectors of society. A national strategy should serve as a guide for developing a set of shared commitments across sectors, to support collaboration within and between sectors, and to direct renewed energy towards the goal of reducing corruption and building an ethical society.

The document is divided into two parts:

• Part A provides background to the development of the strategy: it outlines the process followed up until now to develop proposals for a national strategy. It details a roadmap that will ensure that the process for developing the �nal strategy is inclusive and transparent, and developed with substantial contributions of leaders from government, business and civil society. Part A concludes with a summary of the challenges facing the country: the current manifestations of corruption in South Africa; the foundations on which further anti-corruption e�orts can be built; and the issues the strategy should aim to tackle.• Part B outlines proposals for inclusion in a strategy: outlining a vision, objectives, strategic pillars and programmes for the strategy.

National Anti-Corruption StrategyDiscussion Document 2

2 A summary of the review is contained in this document. The full review is covered in the document, ‘Diagnostic Review and Situational Analysis: Corruption and Anti-Corruption Initiatives in South Africa’, May 2016.

PART A: Background

1. Process for developing proposals for the strategyThe proposals for a National Anti-Corruption Strategy contained in this document are based on:

• A thorough situational review of corruption and anti-corruption initiatives to date2. • Consultations undertaken with stakeholders in government, business, civil society and academia.• The scrutiny of relevant national policy that articulates government commitments and plans for reducing corruption, such as the National Development Plan; the Medium Term Strategic Framework (2014-2019); and documents outlining the programmes of the Anti-Corruption Task Team (ACTT) and the National Anti-Corruption Forum (NACF).• Readings of international guides for developing anticorruption strategies, including the United Nations document, ‘National Anti-Corruption Strategies: A Practical Guide for Development and Implementation’ (2014).• Academic literature in the area of institutional change, corruption and related fields.

2. Next steps: Roadmap for developing a �nal strategyA roadmap outlining the process for developing a �nal National Anti-Corruption Strategy is proposed. Appendix A of this document contains more details in this regard.

The roadmap was developed to meet the following goals:

• Achieve a “whole of government and society” approach in the fight against corruption.• Be open, transparent and inclusive of all sectors of South African society.• Arrive at a robust National Anti-Corruption Strategy that has buy-in from Government, business and civil society.• Foster ownership of the process and the resulting National Anti-Corruption Strategy by all sectors.

3. Policy contextThe Constitution of the Republic of South Africa, Act 108 of 1996 (the Constitution) and a range of statutory provisions and speci�c legislation provide the broad framework and founding principles for anti-corruption work in South Africa.


3 The King Committee on Corporate Governance has already issued four King Reports that provide guidelines for the governance structures and operation of companies in South Africa, setting out what ethical and e�ective leadership entails. The reports are referred to as: King I (issued in 1994), King II (issued in 2002), King III (issued in 2009) and the most recent revision King IV (issued in 2016).

Recognition of the rule of law, and the accountability and transparency of Government, are founding principles of the Constitution, which also provides for the establishment of oversight bodies that play a role in supporting accountability and transparency of the public and private sectors. Various pieces of legislation have been developed to give greater legal e�ect to the principles of accountability and transparency contained in the Constitution.

The King Code3 of Governance Principles in South Africa has relevance for reducing corrupt practices by members of the private sector and state-owned as well as state-controlled entities, as does Business Unity South Africa’s Code of Good Corporate Citizenship.

Recommendations for reducing corruption in the private sector, as provided by the Organisation for Economic Cooperation and Development, have been incorporated into Regulation 43 of the South African Companies Act, Act 71 of 2008.

South Africa is a signatory to various international conventions and treaties that commit the country to implementing a range of interventions aimed at reducing corruption. These conventions include the United National Convention Against Corruption (2003), the Organisation for Economic Cooperation and Development Convention on Combating Bribery of Foreign Public O�cials in International Business Transactions (1997), the African Union Convention on Preventing and Combating Corruption (2003), the Southern African Development Community Protocol against Corruption (2001), and the United Nations Convention against Transnational Organised Crime (2000) and its associated Protocols. Further, South Africa is an active participant in relevant intergovernmental bodies and forums, such as the Group of 20’s (G20’s) Anti-Corruption Working Group and the Financial Action Task Force (FATF), and is implementing various FATF recommendations.

Policy proposals for reducing corruption and improving accountability and transparency of the public and private sectors are articulated in the National Development Plan. The National Development Plan contains proposals for building a resilient anti-corruption system through strengthening the protection of whistle-blowers; developing greater central oversight over the awarding of large tenders or tenders with long duration; and empowering the tender compliance monitoring o�ce (now the Chief Procurement O�cer) to investigate corruption and the monetary value of tenders. It also outlines proposals for strengthening the accountability and responsibility of public servants as well as judicial governance and the rule of law.


Improved resources for a revitalised National Anti-Corruption Forum are also recommended, as well as calls for commitments by the various sectors to ensure that the Forum is e�ective. Several National Development Plan recommendations on building the capacity of the State are also relevant for anti-corruption initiatives, including proposals regarding the professionalisation of the public service; strengthening delegation, accountability and oversight in the public sector; and improving governance of state-owned and state-controlled entities.

Government outlined several goals and indicators with relevance to reducing corruption in the latest Medium Term Strategic Framework (2014-2019). A number of these priorities are drawn directly from the National Development Plan:

• Under the outcome, “All South Africans are, and feel, safe” the strategy targets “an improvement in South Africa’s ranking on the Transparency International Corruption Perception Index”; and notes that Government will prioritise “coordinated initiatives to make the criminal justice system more efficient and effective”. Government further commits to improving conviction rates for serious corruption cases. The strategy also noted that revisions are needed for legislation “to provide for more stringent penalties [for corruption-related crimes], to protect whistle-blowers including those in the private sector, and to strengthen the independence of anti-corruption agencies to insulate them from political pressure”.• Under the outcome, “Responsive, accountable, effective and efficient local government”, the strategy notes a decline in public trust in municipalities owing to “weak leadership or political interference in operations, vacancies in critical posts, poor �nancial management, lack of transparency and accountability, and weak and ine�ective platforms for public participation and communication with communities”. It aims to promote citizen participation in local government processes and to improve skills development and capacity building, focusing on improving “the quality of municipal administrative and management practices including human resources and recruitment practices, supply chain and �nancial management, and anti-corruption initiatives”.• Under the outcome, “An efficient, effective and development-oriented public service”, the strategy sets goals for “institutionalising long-term planning, forging a disciplined, people-centred and professional public service, [and] empowering citizens to play a greater role in development and building an ethical public service”. The document outlines a central role for the Chief Procurement Officer in strengthening oversight of procurement processes and pricing to ensure “cost-effectiveness and transparency, better value for money, and adherence to procedures and fairness”. It also notes that, “as part of steps to promote an


4 In July 2010 the Justice, Crime Prevention and Security Cluster was tasked with the establishment of a task team to fast-track investigations and prosecution. The Anti- Corruption Task Team was formed in October 2010 to give e�ect to this, aimed at a multi-disciplinary and integrated operational approach based on the mandate of the South African Police Service Directorate for Priority Crime Investigation.

ethical public service, measures will be introduced to prevent public servants from doing business with the state, as set out in the election manifesto. These will be supported by improved implementation of the Financial Disclosure Framework, strengthened protection of whistle-blowers, and the provision of technical assistance to departments for the e�ective management of discipline.”

4. Role players and stakeholdersPoliticians are elected representatives to champion the interests of the public. They are obliged to uphold the Constitution, especially the principles of transparency and accountability. Their contribution towards the development of a National Anti-Corruption Strategy is therefore both necessary and critical.

The Anti-Corruption Inter-Ministerial Committee (ACIMC) was established in June 2014 and is mandated to coordinate and oversee the work of state organs aimed at combating corruption in the public and private sectors. The Committee is convened and chaired by the Minister for Planning, Monitoring and Evaluation in the Presidency, and comprises the Ministers of Justice and Correctional Services, State Security, Police, Cooperative Governance and Traditional A�airs, Public Service and Administration, Finance, Home A�airs and Social Development. The Committee also provides strategic direction for the operational activities of the multi-agency Anti-Corruption Task Team.4

In 2014 the Anti-Corruption Inter-Ministerial Committee expanded the role of the Anti-Corruption Task Team, which is the central body mandated to give e�ect to Government’s anti-corruption agenda. Guided by the Anti-Corruption Inter-Ministerial Committee and Anti-Corruption Task Team Executive Committee, this collective of government stakeholders is mandated to implement Government’s anti-corruption agenda and programmes. The task team currently consists of representatives from the National Prosecuting Authority, the Asset Forfeiture Unit, the Directorate for Priority Crime Investigation (“Hawks”) in the South African Police Service, the Special Investigating Unit, the South African Revenue Service, the O�ce of the Accountant-General and the Chief Procurement O�cer in the National Treasury, the Financial Intelligence Centre, the National Intelligence Coordinating Committee, the State Security Agency, the Presidency, the Department of Justice and Constitutional Development, the Department of Public Service and Administration, and the Government Communication and Information System.


Other government organisations playing a role in the anti-corruption landscape include the Auditor-General of South Africa (Auditor-General) and the Department of Cooperative Governance, in the case of local government. These departments work with the Anti-Corruption Task Team on speci�c programmes.

Important oversight bodies include the Public Service Commission (mandated to provide oversight of the public service); the Public Protector (investigating and redressing maladministration and abuse of power in state a�airs); the Independent Police Investigative Directorate (mandated to provide oversight of policing); the Inspector-General of Intelligence (oversight of intelligence services); and committees tasked with executive and government oversight in Parliament, the provincial legislatures and local government councils.

The Competition Commission plays a role in combating corruption through its work in investigating and regulating against private sector collusion: certain collusive practices are de�ned as corrupt in terms of the Prevention and Combating of Corrupt Activities Act.

The National Anti-Corruption Forum, a coalition formed by the public, business and civil society sectors, was established in 2001 with the aim of driving the national anti-corruption campaign. Its mandate is to contribute towards the establishment of a national consensus through the coordination of sectoral strategies against corruption, to advise Government on the implementation of strategies to combat corruption, to share information and good practice on sectoral anti-corruption work and to advise sectors on the improvement of sectoral anti-corruption strategies. It comprises various representatives of Government, the civil society sector, including trade unions, and the business sector.

Several bodies in the business sector have been active in anti-corruption work. These include those representing organised business, professional associations, and networks and forums set up to undertake anti-corruption work in the sector, or in partnership with Government to address corruption as it manifests more broadly in society.

A number of other civil society organisations play a role in monitoring the use or abuse of state resources, transparency and access to information, governance of organisations and instances of possible illegal activity. Some of these organisations also run campaigns to raise awareness of the damaging e�ects of engaging in corrupt activity. Corruption Watch was established in 2012 with the sole purpose of �ghting corruption and is the accredited chapter of Transparency Internation


al in South Africa. Corruption Watch �ghts corruption through public mobilisation, litigation, investigations and research. The media are also important players in exposing corruption, and potential partners in anti-corruption campaigns. Trade unions are well placed to monitor and report corruption in the organisations and business sectors in which they are active. The members of trade unions have an especially important role in blowing the whistle on corruption, both in organisations in which they represent workers, as well as in the respective workplaces, and the unions have a crucial role in supporting e�orts to build whistle-blower protection programmes. The unions are potentially valuable partners in national e�orts to prevent corruption and in future anti-corruption campaigns.

Civil society and non-governmental organisations feature prominently in the detection of, and reporting on corruption as it manifests in the broader society. They also play a key role in educating and representing particular constituents and remain a powerful mechanism to promote positive behaviour. Some of these organisations and emerging social movements are vital in mobilising people around rights (such as access to information) and demanding transparency and accountability for organs of state. Corruption however also manifests within this sector, given that many people who work in the sector are economically vulnerable, making it di�cult for them to blow the whistle on corruption in their own sectors. In addition to the promotion of general reporting of corruption by citizens and their empowerment to do this, leaders in the civil society sector can play a key role to support greater integrity within the sector itself by subjecting themselves to the same stringent standards demanded from both business and the public sector.

Lastly, the individual South African citizen’s awareness and participation, either through joining public campaigns or blowing the whistle on suspected cases of corruption, are crucial in national anti-corruption e�orts. To play this role, ordinary members of the public should be able to recognise corrupt behaviour and feel empowered to take a stand against it, for example, by bringing it to the attention of the relevant authorities. Whistle-blowing should be promoted and encouraged by publicising stories of successful prosecutions as a result of information provided by whistle-blowers, as well as reporting on the e�ective protection of such persons from any form of harm or victimisation. Further, the citizenry can provide pressure for improved accountability and transparency in various sectors in South Africa. The proposed National Anti-Corruption Strategy should empower more citizens to play an active role in reducing corruption.


5 Van Vuuren, H. 2006. ‘Apartheid grand corruption: assessing the scale of crimes of pro�t in South Africa from 1976 to 1994’. Institute of Security Studies, Pretoria, commissioned by the civil society representatives of the Second National Anti-Corruption Summit.6 Patronage is generally accepted to mean the power to control appointments to o�ce or the right to privileges, but is also used in this context as synonymous with favouritism, nepotism, partisanship, partiality, preferential treatment and “the old boy network”.7 Posel, D. 1999. ‘Whiteness and Power in the South African Civil Service: Paradoxes of the Apartheid State.’ In Journal of Southern African Studies 25 (1): 99–119.8 O’Meara, D. 1996. Forty Lost Years: The Apartheid State and the Politics of the National Party, 1948-1994. Randburg: Ravan Press.9 Peires, J.B. 1992. ‘The Implosion of the Transkei and Ciskei.’ In African A�airs, 91: 365–87’.10 Hyslop, J. 2005. ‘Political Corruption: Before and after Apartheid’. In Journal of Southern African Studies, 31(4): 773–789.11 Van Vuuren, ‘Apartheid grand corruption: assessing the scale of crimes of pro�t in South Africa from 1976 to 1994’.

5. ChallengeCorruption undermines the values of the Constitution and progress towards greater social and economic transformation as well as democratic processes. It not only results in the loss of state revenue for economic and social development and service delivery, but also erodes the capacity and legitimacy of the State.

Under National Party rule, a form of capitalism developed that blurred the boundaries between party, private capital and the State. A report commissioned by the National Anti-Corruption Forum details examples of entrenched corruption that was observed and prevalent under the previous dispensation.5 Academics have described patronage6 in the appointment of people to the public sector7 and in the development of white, and in particular Afrikaner, capital.8 Furthermore, parts of the homeland administrations were ruled through patrimonial networks that extended from the central apartheid state to local chiefs and public servants.9 By the late 1970s and 1980s, as the apartheid state unravelled, fraud, theft and other corrupt activity appear to have grown in the top echelons of the State.10 The state security agencies and police were particularly implicated in corruption, and the climate was ideal for these abuses given the levels of secrecy under which they operated.11 Some of the institutional legacies of this past have interacted with contemporary politics and changes to the structure of society and the state bureaucracy to shape the nature of corruption in South Africa today.

Corruption is usually a hidden phenomenon and attempts to determine its current prevalence are therefore di�cult. However, research on perceptions of corruption, experiences of corruption and related crimes, and compliance with legislation aimed at improving accountability and reducing corruption can provide an indication of the nature of the problem to be tackled.

Assessments of public perceptions over the last 15 years show that citizens feel that corruption has increased. Although a rough indicator of corruption in the country, these perceptions are important pointers in terms of the level of trust between the State and citizens. A report issued by the Human Sciences Research Council that used data from the South African Social Attitudes Survey indicated that the vast majority of those surveyed in 2011 (91%) believe that corruption is a serious problem in South Africa.


12 Human Sciences Research Council (HSRC). 2012. ‘Business Unusual: Perceptions of Corruption in South Africa’ In HSRC Review, Vol 10 (2), Human Sciences Research Council, Pretoria.13 Afrobarometer. 2016. ‘Summary of Results. Round 6 Survey in South Africa.’ Available at www.afrobarometer.org14 “The Corruption Perceptions Index (CPI) ranks countries and territories based on how corrupt their public sector is perceived to be. It is a composite index – a combination of polls – drawing on corruption-related data collected by a variety of reputable institutions. The CPI re�ects the views of observers from around the world, including experts living and working in the countries and territories evaluated.” Source: http://www.transparency.org/cpi2013/in_detail#myAnchor2 (accessed May 2016).15 See Transparency International. 2015. ‘Exporting Corruption: Assessing Enforcement of the OECD Convention on Combating Foreign Bribery’, results per country posted on the Transparency International website: http://www.transparency.org/exporting_corruption (accessed April 2016); HSRC, ‘Business Unusual: Perceptions of Corruption in South Africa.’; Afrobarometer, ‘Summary of Results. Round 6 Survey in South Africa.’; National Victims of Crime Survey, cited in Bruce, D. 2014. ‘Counting the covert: Using data to understand corruption in South Africa’. ISS Monograph No. 198, Institute of Security Studies, Pretoria.16 Newham, G. and Faull, A. 2011. ‘Protector or predator? Tackling police corruption in South Africa.’ ISS Monograph, Institute of Security Studies, Pretoria.

In 2003, 9% of respondents put corruption in the top three most serious national challenges, which increased to 26% in 2011.12 In the latest Afrobarometer survey, undertaken in 2015, 64% of the respondents stated that they felt that corruption had increased signi�cantly over the last year, and 19% felt that it had increased slightly.13

Transparency International’s 2015 global Corruptions Perception Index currently scores South Africa at 44, down from the past high of 51 in 2007. (A score of 0 means a country is considered “very corrupt”, and a score of 100 means a country is considered “very clean”.) South Africa’s ranking compared to other countries in terms of the Corruption Perception Index has also deteriorated, dropping 29 places in the global perceptions ranking since 2001. (The higher the ranking of a country, the “cleaner” it is considered to be.)14

A range of surveys, among others the National Victims of Crime Survey, Human Sciences Research Council’s Quality of Life Survey (2012), the Afrobarometer and Transparency International’s research, suggest that instances of bribery are fairly common in some services in which the public interfaces with government o�cials. This is the case in tra�c policing and, to a lesser extent, in home a�airs, local government and policing.15

In policing, corruption more generally, i.e. not just bribery but also theft, fraud and other forms of corruption, has been described as systemic16, limiting the State’s ability to tackle it and other forms of crime. Immigration and border control are also particularly vulnerable to corruption. Citizens’ experience of these services or sectors is of central importance in shaping public perceptions of corruption in South African society more generally.

The South African Government has developed several strategies, campaigns and frameworks to speci�cally reduce corruption and support ethical practice in the public sector. These include the National Crime Prevention Strategy, 1996; the Batho Pele programme, aimed at supporting an ethical and citizen-orientated public service that was �rst developed in 1997 and relaunched under a dedicated campaign in 2004; the Public Service Anti-Corruption Strategy, 2002, and mechanisms resulting from the strategy, such as the development of guidelines for minimum


17 See Auditor-General of South Africa (AGSA) consolidated reports on the PFMA and MFMA for the years 2012-2015; and PSC reports in the case of the public service: 2011. ‘Report on Financial Misconduct for the 2009/2010 Financial Year’ (2011); ‘Fact Sheet on Actions Taken by the Executive Authorities with regard to Identi�ed Cases of Potential Con�icts of Interests and Compliance with the Financial Disclosure Framework.’ (2013); ‘Factsheet on Financial Misconduct and the Recovery of Money Lost through Financial Misconduct for the 2013/2014 Financial Year.’ (2015); ‘Assessment of the Handling of Disciplinary Cases in the Public Service.’ (2016).

anti-corruption capacity in public service departments and entities; the development of the Financial Disclosure Framework for managers in the public service; the development of a Public Service Integrity Management Framework; and the Local Government Anti-Corruption Strategy, which was approved in May 2016. Further, some provinces, municipalities and public sector organisations have developed their own anti-corruption strategies.

The Public Service Anti-Corruption Strategy (PSACS) was particularly important for bolstering the legislative framework to �ght corruption, and establishing policies, norms and guidelines for supporting anti-corruption and integrity management work in the public service. The PSACS proposed a review of the legislative framework surrounding corruption, and the consolidation of this framework into a new corruption act. The PSACS also suggested that departments foster a minimum capacity to �ght corruption, and pointed to the need for mechanisms to coordinate the numerous government entities involved in anti-corruption initiatives. The PSACS called for the improvement of management policies and practices related to areas such as the management of employment, discipline, procurement, risk, information and �nances; the establishment of a comprehensive system of professional ethics; as well as greater stakeholder participation. It also suggested that these initiatives should all be underpinned by training and education programmes.

South Africa has developed a fairly comprehensive legislative framework for combating corruption, ranging from the Prevention and Combating of Corrupt Activities Act, through other legislation dealing with �nancial and organised crime, public �nance management and procurement legislation, to legislation promoting the public’s access to information held by the public and private sectors. As mentioned previously, South Africa is also a signatory to several international conventions and treaties. However, the implementation or enforcement of some of these obligations and aligned legislation remains uneven and, in some cases, weak.

A generally clear set of rules and values has been articled for guiding the conduct of public servants and members of the executive. Despite many public servants and politicians being committed to serving the public, compliance with these regulations and codes has been generally weak. This is especially the case in supply chain, human resource management and in compliance with frameworks for disclosing business and other �nancial interests.17 An environment of non-compliance enables corruption and makes it hard to detect.


18 See Auditor-General of South Africa (AGSA) consolidated reports on the PFMA and MFMA for the years 2012 to 2015.19 Based on Auditor-General reports 2009 to 2013, in Brunette, R. et al. 2014. ‘The Contract State: Outsourcing and Decentralisation in Contemporary South Africa’. Public A�airs Research Institute, Johannesburg.20 Presidential Review Committee on State-Owned Enterprises. 2012. Presidential Review Committee on State-Owned Enterprises: Main Report, Volume 2.’ The Presidency, Pretoria.21 Public Service Commission (PSC). 2013. ‘Fact Sheet on Actions Taken by the Executive Authorities with regard to Identi�ed Cases of Potential Con�icts of Interests and Compliance with the Financial Disclosure Framework.’ PSC, Pretoria.

In national, provincial and local government, the Auditor-General �ndings show rising irregular expenditure (despite an improvement in the number of clean audits) in local government and the public service.18 Between 2009 and 2013, 75% of the total irregular and wasteful expenditure was attributed to the contravention of supply chain management regulations.19 Public procurement is a signi�cant area of potential risk for corruption by public and private sector players in South Africa.

Private sector involvement in corruption remains a concern with many companies still failing to report corrupt activity as a result of the stigma attached to admitting control and governance failures. Corruption in state procurement usually implicates both public and business sector players. Private sector involvement in corruption has taken the form of bribery, locally and in business dealings with other African countries, and fraud in procuring with the State. In addition, the Competition Commission has uncovered practices of collusion in tendering with the State. Another business practice that remains particularly problematic is “fronting” or the deliberate or attempted circumvention of the B-BBEE Act, Act 53 of 2003 and the related codes.

Data on the integrity and compliance with relevant legislation in state-owned entities remains scanty. Scandals in several large state-owned entities around board and management instability, and procurement and appointment irregularities, are however a cause for concern, especially in view of the substantial procurement budget of these entities. The Presidential Review Committee on state-owned entities cited the African National Congress’s Committee on Schedule 2 state-owned entities that rising corruption is a problem facing these companies.20

Regulations and codes preventing elected o�cials from doing business with the State, and regulating the conditions under which family members of elected o�cials can do business with the State, are not being adhered to in many cases. Further, public servants and local government employees are not facing appropriate (legislated) sanction for non-compliance. On average, the executive has not ensured compliance with these frameworks and regulations in the public, 21 and oversight structures in municipal councils are not always working e�ectively. Further, monitoring of compliance in the government sector has relied heavily on self-reporting, but has not su�ciently included citizens. Self-reporting has thus far not led to improved compliance, and consideration should be given to improving processes for feedback on corruption to the public, for example interaction and feedback to the community and other interested groups as proposed in the revised Local Government Anti-Corruption Strategy.


22 See African Union and the United Nations Economic Commission for Africa. 2015. ‘Illicit Financial Flow: Report of the High Level Panel on Illicit Financial Flows from Africa.’ African Union and the United Nations Economic Commission for Africa Conference of Ministers of Finance, Planning and Economic Development; and the Panama Papers website. The Panama Papers refers to the analysis and presentation of leaked data from the Panama-based law �rm Mossack Fonseca. See: https://panamapapers. icij.org/video/ (accessed April 2016).23 Illegal movement of money or capital from one country to another. 24 Global Financial Integrity. 2016. Data on the Global Financial Integrity website: http://www.g�ntegrty.org/report/illicit-�nancial-�ows-from-developing-countries-2004- 2013/ (accessed April 2016).25 African Union et al, ‘Illicit Financial Flow: Report of the High Level Panel on Illicit Financial Flows from Africa.’26 Economic Justice Network, Financial Transparency Coalition, and the Tax Justice Network. 2016. ‘A month after Panama Papers, South Africa commits to end anonymous companies.’ Joint press release, 6 May 2016.27 Archival Platform. 2015. State of the Archives: An Analysis of South Africa’s National Archival System. Archival Platform, Cape Town.

The recent release of the African Union and the United Nations Economic Commission for Africa report on illicit �nancial �ows from Africa, and the release of the “Panama Papers” by the International Consortium of Investigative Journalists, provide some insight into the extent of monies �owing illegally across borders linked to tax evasion, bribery, illegal arms dealing and �nancial fraud involving politicians, state o�cials, business people and corporates.22 South Africa is ranked seventh in the world in terms of the volume of illicit �nancial �ows from developing and middle-income countries. This �gure is based on the highest average illicit �nancial �ows23 between 2003 and 2014, which was $20,922 billion.24 The African Union report notes that, "Transparency of ownership and control of companies, partnerships, trusts and other legal entities that can hold assets and open bank accounts is critical to the ability to determine where illicit funds are moving and who is moving them.”25 In this regard, at the recent Open Government Partnership Africa Regional Meeting in Cape Town, the South African Government announced an action plan that includes commitments to compile a register of bene�cial ownership of all companies in the country.26

The National Development Plan has noted that the implementation of the Promotion of Access to Information Act 2 of 2000 and the Promotion of Administrative Justice Act 3 of 2000 needs to be improved. Currently, the state of recordkeeping in several government departments and municipalities is poor27, which a�ects citizens’ right to access information and departments’ capacity to support the Promotion of Access to Information Act, Act 2 of 2000 and Administrative Justice Act, Act 3 of 2000.

Improved institutional mechanisms to support whistle-blowers are also needed. As outlined by various reports produced under the United National Convention Against Corruption, providing this protection requires a range of interventions, such as improved systems to provide for appropriate legal aid for whistle-blowers, ensuring that whistle-blowers can report anonymously to the extent possible and that their identities and the information they provide are recorded, stored and used in such a way that this does not unnecessarily increase the risk of harm to the whistle-blower and so forth.

Further e�orts are also required to engage and empower more citizens in the �ght against corruption, through for example awareness-raising campaigns, national debates on the nature of


28 Newham, G. 2016. Interview with Gareth Newham, Institute of Security Studies, 7 April 2016.

corruption, its e�ects on society and the kinds of pressures and institutional factors that enable corruption. Campaigns which provide people with information on their rights in terms of accessing services are also needed: if citizens have good information about the functioning of a particular administrative process, and the rights they have in terms of the expected conduct of a public servant or private sector service provider, they are in a better position to resist requests for bribes, and in a better position to blow the whistle on possible cases of corruption.

Regarding enforcement of legislation regulating the business sector, large companies follow the King Code. The �rst two iterations of the code applied to listed companies and government departments at national, provincial and local levels; the third has been developed so that civil society can incorporate these governance codes into the management of their organisations. King IV was launched in 2016. The King Code is not adequately enforced through domestic legislation, though legislation such as the Companies Act now incorporates some of the aspects covered in the Code.

This has to some degree assisted in improving the transparency of private sector activity. However, notwithstanding the obligation to report corruption and various other o�ences in terms of the Prevention and Combating of Corrupt Activities Act, many companies still fail to report corrupt activity as a result of the stigma attached to admitting control and governance failures. Furthermore, initiatives are needed to bring unlisted and smaller companies into the national dialogue on corruption.

The Prevention and Combating of Corrupt Activities Act has thus far been insu�ciently used to prosecute cases of corruption. Law-enforcement agencies prefer to investigate and prosecute potentially corrupt activities through the use of legislation pertaining to other �nancial crimes or common law o�ences such as fraud, than to investigate or prepare cases based on o�ences listed under the Corrupt Activities Act.28 This appears to be due to the lack of police training on how to develop cases for prosecution under the Act, and the need for training on the Act in the courts, and due to di�culties in proving that bribery took place. Signi�cantly, the enforcement of the Act, and other acts dealing with �nancial and organised crime, are a�ected by the capacity of the criminal justice system and relevant oversight bodies.

Some oversight bodies have developed a public reputation of independence, integrity and capacity, including the Auditor-General, the Financial Intelligence Centre, and the Public Protector.


29 National Planning Commission. 2016. ‘The National Development Plan’; Tamukamoyo, H, and Mofana, R. 2013. ‘Is South Africa really complying with the anti-corruption protocols it has rati�ed?’. In ISS Today, 9 July 2013, Institute for Security Studies, Pretoria; Corruption Watch. 2015. ‘Hawks saga: the feather continue to �y’, published on Corruption Watch’s website on the 15 January 2015: http://www.corruptionwatch.org.za/hawks-saga-feathers-continue-to-�y/ (accessed April 2016); Newham, G. 2016. Interview with Gareth Newham, Institute of Security Studies, 7 April 2016; De Vos, P. 2015. ‘Turmoil at the Hawks: A birds eye view of the legalities’, published online on the Daily Maverick, 8 January 2015: http://www.dailymaverick.co.za/opinionista/2015-01-08-turmoil-at-the-hawks-a-birds-eye-view-of-the-legalities/#.Vw0Mc-mKh68 (accessed April 2016).30 Constitutional Court of South Africa. 2011. ‘Case CCT 48/10 [2011] ZACC 6.’ Constitutional Court of South Africa, Johannesburg.31 Constitutional Court of South Africa. 2014. Press release in respect of case CCT 07/14 and CCT 09/14, posted on the Southern African Legal Information Institute: http:// ww.sa�ii.org/za/cases/ZACC/2014/32media.pdf (accessed May 2016).

The Specialised Commercial Crimes Courts have achieved success in prosecuting corruption, the Asset Forfeiture Unit has been successful in seizing assets, and the Special Investigating Unit has successfully pursued cases of corruption.

A central issue of concern raised by civil society organisations and the National Development Plan is that the independence of the criminal justice agencies tasked with investigating and prosecuting corruption has not been e�ectively maintained.29 A 2011 Constitutional Court ruling found that the State has a constitutional obligation to establish and maintain an independent body to combat corruption and organised crime, and that the Directorate for Priority Crime Investigation lacked this structural and operational independence.30 This was rea�rmed in a Constitutional Court ruling in 2014.31 E�ective independence is needed to improve the appetite for pursuing senior politicians, o�cials and business people, and to build public con�dence in Government’s commitment to reduce corruption, as well as to strengthen the rule of law in the country.

South Africa’s anti-corruption system requires adequate safeguards of independence, and adequate resourcing in the form of su�cient budget and the appropriately trained and experienced sta�. Furthermore, improved coordination between the various government agencies tasked with reducing corruption and supporting ethical practice is needed. Speci�cally, mechanisms are required to ensure that representatives of the various bodies on the Anti-Corruption Task Team do not prioritise their own agency work over cross-agency collaboration.

There are also real challenges to collaboration and information-sharing across the government, business and civil society sectors. The National Anti-Corruption Forum (NACF) is no longer meaningfully active, limiting cross-sectoral collaboration in developing anti-corruption mechanisms. Intersectoral collaboration is crucial and proper planning to revitalise this or to constitute a similar intersectoral platform should ensure su�cient institutional capacity and resources (permanent sta� and adequate budget / sectoral contributions) are available to enable meaningful implementation of intersectoral anti-corruption programmes. Given the intersectoral nature of such an organisation, it can play a signi�cant role in the promotion and implementation of a national strategy.


Outside of the conduct of o�cials and employees in their organisational settings across various sectors, improved adherence to certain laws by the public would reduce the room for corruption. For example, greater compliance with tra�c laws by the public potentially provides fewer opportunities for tra�c o�cers to solicit bribes. Conversely, ensuring that the rules of the road are appropriately enforced by tra�c o�cers could increase compliance by road users and reduce the incentives to o�er bribes.

Better data is needed to improve anti-corruption e�orts in South Africa. The data already captured by the State and private sector could be better reported. Data on investigations and convictions of cases involving corruption is inconsistently reported by various crime-�ghting agencies; data on compliance with regulations relevant to corruption is inconsistently collected and reported by government agencies, and not su�ciently consolidated and used to inform risk pro�ling, etc. Further, private sector reporting of corruption remains too low. Improving the collection, reporting and analysis of these kinds of statistics are important for monitoring the State and other sectors’ impact on reducing corruption, and identifying areas of potential or current risk for corruption.


In summary, the following major issues should be given consideration in a National Anti-Corruption Strategy:

• The need for efforts to empower citizens in the fight against corruption through awareness-raising campaigns, campaigns on citizens’ rights in terms of administrative process and improved whistle-blower protection.• Building ethical leadership across government, business and civil society sectors.• Building a professional public sector orientated towards serving citizens and implementing policy.• Improving adherence to anti-corruption and integrity management regulations and other regulations with relevance for anti-corruption, and ensuring improved consequence management for non-compliance with these regulations and codes of conduct across sectors.• Improving transparency of activity and use of resources in the government, business and civil society sectors.• Improving the transparency and accountability of the public procurement system to ensure fair, effective and efficient use of public resources.• Improving the collection, reporting, analysis and use of data relevant to anti-corruption work.• Developing or strengthening programmes aimed at tackling corruption in sectors particularly vulnerable to corruption.• Strengthening the capacity of government organisations tasked with combating corruption and providing oversight of government’s work through adequate resourcing and strengthened independence.• Ensuring personnel in organisations tasked with anti-corruption and integrity management work have the necessary training and organisational support to undertake their work.• Improving platforms for cooperation between the various anti-corruption bodies.• Strengthening stakeholder partnerships to support anti-corruption work across sectors.

South Africa can build on progress already made. This includes generally robust legislation for �ghting corruption; some very strong investigative skills in senior police ranks in South Africa; Chapter 9 and 10 institutions committed to promoting integrity in public and private sectors; a generally clear set of rules and values for guiding the conduct of government employees and members of the executive in the government sector; organised business and civil society having shown earlier commitments to collaborating on anti-corruption e�orts which can be revived; and South Africa having a free media and active civil society to support e�orts to build accountability.

At this point there is a need to develop a comprehensive strategy that can establish an integrated approach to support improved coordination between the numerous role players in the �ght against corruption, and to tackle the systemic causes of corruption in the country.


Part B: Proposals for a national anti-corruption strategy

1. Rationale for a national anti-corruption strategyThe National Anti-Corruption Strategy is intended to serve as a guide for Government, the business sector and civil society organisations, to help coordinate and support their e�orts to reduce corruption. The strategy therefore provides a set of strategic pillars and programmes around which sectors, organisations and other forums within these sectors can direct and attempt to align their work. It also provides a tool for citizens and others to monitor South Africa’s progress in achieving a substantial reduction in corruption in the country.

Several state organisations and spheres of government, and organisations or representative bodies in the business and civil society sectors, have already developed anti-corruption and integrity management strategies of their own. Where these are bearing fruit they should clearly be continued. The proposals for a National Anti-Corruption Strategy outlined below include nine strategic themes or pillars under which organisations and sectors can develop new programmes as well as a common set of concepts and commitments for reducing corruption.In summary, the rationale of an overarching National Anti-Corruption Strategy is to:

• Rejuvenate a national dialogue and direct energy towards practical mechanisms to reduce corruption and improve ethical practices across sectors and among citizens in South Africa.• Support coordination of government, business and civil society efforts to reduce corruption and improve accountability and ethical practice.• Provide a robust conceptual framework and strategic pillars to guide anti-corruption approaches across relevant sectors in the country.• Provide a tool for monitoring progress towards a less corrupt society.

2. VisionThe vision of the National Anti-Corruption Strategy is a South Africa that has:

• An ethical and accountable state, business and civil society sectors in which those in positions of power and authority act with integrity.• Citizens who respect the rule of law and are empowered to hold those in power to account.• Zero tolerance of corruption in any sphere of activity and substantially reduced levels of corruption.


In line with the National Development Plan, the vision of the National Anti-Corruption Strategy further entails a society in which police o�cers and others involved in enforcement do not wield power inappropriately over the vulnerable; one in which principals manage school funds in the best interests of learners; small business owners and corporates seek to provide value for money to customers; leaders of corporates seek to ensure their actions do not undermine the environmental or economic sustainability of communities and regions; traditional leaders serve the interests of their communities; citizens respect the rule of law; the judiciary acts with integrity and impartiality; trade union leaders are motivated by service to workers; members of parliament, legislatures and councillors hold o�cials and members of the executive to account; and public servants and politicians see their commitment �rst towards the citizens of the country, according to the values and requirements of the Constitution, and to implementing policy in the service of social and economic transformation, and not towards private or other interests. In order to achieve this vision, South Africa requires leaders across all sectors to set an example in acting with integrity and accepting accountability to their constituencies and stakeholders.

3. ObjectivesThe objectives of the National Anti-Corruption Strategy are to:

1. Improve citizens’ awareness of their rights and responsibilities relevant to the �ght against corruption.2. Improve whistle-blower protection and active participation in anti-corruption e�orts by members of the public.3. Improve transparency across sectors.4. Improve compliance with anti-corruption and integrity management obligations and mechanisms across sectors.5. Improve the structures for detection and enforcement (an independent, resourced, skilled and coordinated anti-corruption system).6. Improve structures of oversight and accountability.7. Improve domestic and international partnerships in and across sectors for reducing corruption and building accountability.

4. Conceptual frameworkCorruption a�ects and involves the actions of people in the government, business and civil socie-ty sectors. Tackling it will require commitment from all sectors, and interventions to empower citizens to support e�orts aimed at reducing corruption. Substantially reducing corruption in South Africa therefore requires “a whole of government and society approach”, as called for in the National Development Plan and Government’s Medium Term Strategic Framework (2014-2019).Furthermore, corruption is not simply caused by a few “bad apples”. In order to deal with the systemic factors enabling corruption it is important to recognise that corruption and, conversely, ethical practice are shaped by particular organisational, social and political contexts.


Behavioural change is supported through changes to the institutions that govern or shape behaviour. Institutions are those structures, processes and mechanisms that shape people’s behaviour in a particular context or community. Examples of relevant institutions are the organisations that govern training, such as schools or universities, workplace or organisational cultures and religions. Therefore, ensuring people have knowledge about anti-corruption regulations, ethics frameworks, etc, is a �rst important step towards reducing corruption and supporting ethical practice. It is however not su�cient. The aim of programmes initiated under the National Anti-Corruption Strategy should be to provide guidance on how to shift the incentives and constraints under which people and organisations operate, and build institutions that provide public servants, private sector professionals, citizens and others with a blueprint for ethical practice.

5. Strategic pillars and programmesThe National Anti-Corruption Strategy is built around nine strategic pillars, which are mutually supportive:

1. Support citizen empowerment in the �ght against corruption, including increased support for whistle-blowers.2. Develop sustainable partnerships with stakeholders to reduce corruption and improve integrity management.3. Improve transparency by government, business and civil society sectors.4. Improve the integrity of the public procurement system to ensure fair, e�ective and efficient use of public resources.5. Support the professionalisation of employees.6. Improve adherence to integrity management and anti-corruption mechanisms and improve consequence management for non-compliance of these across government, business and civil society sectors.7. Strengthen oversight and governance mechanisms in the government sector.8. Strengthen the resourcing, cooperation and independence of dedicated anti-corruption agencies.9. Build specific programmes to reduce corruption and improve integrity in sectors particularly vulnerable to corruption (vulnerable sector management), with an initial focus on the Justice, Crime Prevention and Security Cluster.

Some of the programmes undertaken under the strategic pillars will be cross-cutting, i.e. supporting more than one of the strategic pillars. For example, professionalising supply chain management can support the integrity of the public procurement system; strengthening the capacity of anti-corruption agencies can support improved whistle-blower protection; etc.


These strategic pillars will be supported by the following programme elements and actions:

• Awareness-raising and public dialogues.• Integrity pacts and public commitment campaigns.• Research and analysis.• Development of guidelines and systems to support compliance with regulations.• Education and training interventions.• Improvement or development of platforms for enhanced coordination across and within sectors.• Improvement or development of institutionalised platforms for detection, investigation and prosecution.• Improvement of mechanisms to support increased reporting of corruption and whistle- blowing, including the protection of whistle-blowers.• Development, review or amendments to legislation and policy frameworks.

Monitoring and evaluation should be a built-in component of all programmes. The United Nations O�ce on Drugs and Crime has developed a high-level guide for developing anti-corruption strategies. It dedicates a chapter to the monitoring and evaluation of anti-corruption strategies and highlights the importance of a strong monitoring and evaluation component to support implementation of the strategy and institutional learning. The indicators should be very carefully developed to ensure that they refer to actions that can meaningfully contribute to reducing corruption or improving ethical practice.

A number of constructive recommendations for the reorganisation and reduction of some of the proposed pillars and strengthening of possible programmes were made during the initial sectoral consultations with select government, business and civil society stakeholders in September and October 2016.

• These recommendations and comments were not included in this version of the Discussion Document, as the discussion of these should form part of the public consultation phase.• Comments related to the roadmap and consultation process were, where feasible, included in the Roadmap (Appendix A).


Pilla

r 1: S

uppo

rt c

itiz

en e

mpo

wer

men

t in

the

�ght

aga

inst

Cor

rupt

ion

(incl

udin

g im

prov

ed w

hist

le-b

low

er p

rote

ctio

n)

Th

roug

h pa

ying

a b

ribe

to a

gov

ernm

ent

o�ci

al, o

rdin

ary

mem

bers

of

the

publ

ic c

an p

erpe

tuat

e co

rrup

t ac

tivity

. Con

vers

ely,

thr

ough

join

ing

publ

ic c

ampa

igns

, or

blow

ing

the

whi

stle

on

susp

ecte

d ca

ses

of c

orru

ptio

n, o

rdin

ary

mem

bers

of

the

publ

ic, c

ivil

soci

ety

and

med

ia p

lay

a ro

le in

ant

i-cor

rupt

ion

wor

k, a

nd c

an p

rovi

de

pres

sure

for

im

prov

ed a

ccou

ntab

ility

in

vario

us s

ecto

rs i

n So

uth

Afr

ica.

The

Uni

ted

Nat

ions

Con

vent

ion

Aga

inst

Cor

rupt

ion

and

othe

r in

tern

atio

nal

trea

ties

urge

si

gnat

ory

coun

trie

s to

est

ablis

h m

echa

nism

s th

at e

ncou

rage

par

ticip

atio

n in

the

�ght

aga

inst

cor

rupt

ion

by th

e m

edia

, civ

il so

ciet

y an

d or

dina

ry c

itize

ns.

Stra

tegi

c pr

ogra

mm

es u

nder

pill

ar1:

Stra

tegi

c Pr

ogra

mm

e Ra

tion

ale

1.1

Deve

lop an

d im

plem

ent a

ware

ness-

raisi

ng ca

mpa

igns o

n the

natu

re an

d e�e

cts of

co

rrupt

ion, a

nd th

e mec

hanis

ms a

vaila

ble to

redu

ce co

rrupt

ion, in

cludin

g cor

rupt

ion-

re

porti

ng ho

tline

s, in

partn

ersh

ip wi

th ci

vil so

ciety.

Impr

oved

awar

enes

s of t

he im

pact

of co

rrupt

ion in

parti

cular

serv

ices o

r sec

tors

can p

lay a

role

in in�

uenc

ing po

sitive

be

havio

ur ch

ange

away

from

corru

ption

, and

enco

urag

e peo

ple to

repo

rt ins

tanc

es of

corru

ption

, if ca

mpa

igns h

ave a

cle

ar th

emat

ic fo

cus t

hat a

llow

peop

le to

iden

tify i

n quit

e spe

ci�c w

ays w

ith th

e issu

es be

ing ra

ised.

Furth

erm

ore,

thes

e ca

n help

build

shar

ed un

derst

andin

g of w

hat c

onsti

tute

s cor

rupt

ion.

1.2

Deve

lop an

d im

plem

ent i

nfor

mat

ion ca

mpa

igns o

n citi

zens

’ righ

ts an

d how

adm

inistr

ative

pr

oces

ses s

hould

func

tion t

o ser

vice c

itize

ns in

:

• Fro

ntlin

e ser

vices

and i

n sec

tors

offer

ing se

rvice

s tha

t give

effec

t to s

ocio-

econ

omic

right

s in t

he Co

nstit

ution

, suc

h as i

n the

healt

h and

educ

ation

secto

rs (p

ublic

and

priva

te).

•

On ci

tizen

s’ righ

ts as

they

parti

cular

ly aff

ect p

eople

living

in ru

ral a

reas

, on i

ssues

such

as

acce

ssing

land

and o

ther

serv

ices.

Whe

re ci

tizen

s hav

e goo

d inf

orm

ation

abou

t how

a pa

rticu

lar ad

mini

strat

ive pr

oces

s wor

ks, a

nd w

hat t

hey h

ave a

rig

ht to

expe

ct fro

m th

e con

duct

of a

publi

c ser

vant

or pr

ivate

secto

r ser

vice p

rovid

er, th

ey ar

e in a

bette

r pos

ition

to

resis

t req

uests

for b

ribes

, and

in a

bette

r pos

ition

to bl

ow th

e whis

tle on

possi

ble ca

ses o

f cor

rupt

ion. T

his st

rate

gic

prog

ram

me a

lso co

ntrib

utes

to th

e im

plem

enta

tion o

f the

Prom

otion

of Ad

mini

strat

ive Ju

stice

Act.

1.3

Ensu

re st

reng

then

ed w

histle

-blow

er pr

otec

tion t

hrou

gh m

echa

nism

s suc

h as:

•

Deve

loping

appr

opria

te sy

stem

s for

the p

rote

ction

of th

e ide

ntity

of w

histle

-blow

ers

and f

or th

e pro

vision

of le

gal a

id to

them

.

• De

velop

impr

oved

inve

stiga

tive/

refer

ral c

apac

ity to

supp

ort s

ucce

ssful

pros

ecut

ion

ba

sed o

n inf

orm

ation

prov

ided t

o hot

lines

.

• Re

port

posit

ive su

ccess

storie

s in r

educ

ing co

rrupt

ion du

e to i

nfor

mat

ion fr

om

wh

istle-

blowe

rs.

The O

rgan

isatio

n for

Econ

omic

Deve

lopm

ent W

orkin

g Gro

up as

sessi

ng co

mpli

ance

with

prov

ision

on co

mba

ting

bribe

ry no

tes t

hat e

�orts

are n

eede

d in S

outh

Afric

a to e

nsur

e tha

t in p

racti

ce w

histle

-blow

ers a

re pr

ovide

d with

the

prot

ectio

n out

lined

in la

w. 32

To be

e�ec

tive,

the p

ublic

shou

ld se

e exa

mple

s of c

ases

of co

rrupt

ion be

ing pr

osec

uted

as

a re

sult

of th

ese h

otlin

es.

32 O

rgan

isatio

n for

Econ

omic

Coop

erat

ion an

d Dev

elopm

ent (

OECD

). 20

16. ‘S

outh

Afric

a Pha

se 3

Writ

ten F

ollow

-up R

epor

t.’ OE

CD, P

aris.


Pilla

r 2: D

evel

op s

usta

inab

le p

artn

ersh

ips

wit

h st

akeh

olde

rs

Pa

rtne

rshi

ps a

nd c

olla

bora

tive

foru

ms

are

need

ed t

o st

reng

then

and

sus

tain

the

�gh

t ag

ains

t co

rrup

tion.

The

se p

artn

ersh

ips

and

foru

ms

can

impr

ove

coor

dina

tion

arou

nd a

nti-c

orru

ptio

n e�

orts

, bui

ld g

reat

er c

onse

nsus

aro

und

the

need

for

inte

rven

tions

to

redu

ce c

orru

ptio

n, d

evel

op c

onse

nsus

abo

ut a

ppro

pria

te a

nti-c

orru

ptio

n e�

orts

and

bui

ld s

ocia

l cap

ital b

etw

een

sect

ors

in th

e co

untr

y.

Stra

tegi

c pr

ogra

mm

es u

nder

pill

ar 2

:

Stra

tegi

c Pr

ogra

mm

e Ra

tion

ale

2.1

Rejuv

enat

e the

Nat

ional

Anti-

Corru

ption

Foru

m as

a pla

tform

to co

ordin

ate a

nd st

reng

then

anti-

co

rrupt

ion an

d int

egrit

y e�o

rts ac

ross

busin

ess,

civil s

ociet

y and

gove

rnm

ent s

ecto

rs; en

surin

g the

foru

m

has t

he ne

cessa

ry le

ader

ship

supp

ort,

reso

urcin

g and

appr

opria

te st

ructu

re to

be e�

ectiv

e.

Ther

e are

chall

enge

s to c

ollab

orat

ion an

d inf

orm

ation

on an

ti-co

rrupt

ion m

easu

res,

and t

o obt

aining

secto

r inp

ut on

how

corru

ption

and a

nti-c

orru

ption

a�ec

ts va

rious

secto

rs an

d ind

ustri

es. T

he N

ation

al An

ti-Co

rrupt

ion Fo

rum

was

a po

sitive

deve

lopm

ent i

n the

anti-

corru

ption

land

scap

e. Ho

weve

r, the

foru

m ha

s not

be

en ve

ry ac

tive s

ince t

he Fo

urth

Sum

mit

in 20

11. T

his bo

dy sh

ould

be re

vived

, as e

ncou

rage

d in t

he N

ation

al De

velop

men

t Plan

and b

y pub

lic st

atem

ents

of th

e Mini

ster in

the P

resid

ency

: Plan

ning,

Mon

itorin

g and

Ev

aluat

ion, M

r Rad

ebe.

33 To

be e�

ectiv

e it w

ill re

quire

the a

ctive

parti

cipat

ion of

very

senio

r lea

ders

from

all

secto

rs; ap

prop

riate

insti

tutio

nal d

esign

; ade

quat

e res

ourci

ng, e

spec

ially

from

gove

rnm

ent;

and a

supp

ortin

g ad

mini

strat

ion/se

creta

riat.

Long

- ter

m pa

rtner

ships

betw

een e

duca

tion i

nstit

ution

s, pr

ofes

siona

l bod

ies an

d gov

ernm

ent s

take

holde

rs ca

n bu

ild st

rong

capa

city f

or tr

aining

and d

evelo

pmen

t in t

he ar

ea of

anti-

corru

ption

.

Awar

enes

s-rais

ing ab

out c

orru

ption

and d

iscus

sions

of et

hical

prac

tice i

n a ra

nge o

f set

tings

are a

part

of th

e sch

ool c

urric

ulum

. Inte

rven

tions

are n

eede

d to b

ring s

ome o

f the

issu

es ra

ised i

n the

curri

culum

to lif

e for

lea

rner

s and

to ex

pand

the d

iscus

sion t

o sup

port

spec

i�c a

nti-c

orru

ption

cam

paign

s bein

g im

plem

ente

d und

er

the N

ation

al An

ti-Co

rrupt

ion St

rate

gy.

Guide

lines

are n

eede

d for

deve

loping

syste

ms t

o ens

ure t

hat w

histle

-blow

ers c

an re

port

anon

ymou

sly to

the

exte

nt po

ssible

, tha

t the

ir ide

ntiti

es an

d the

info

rmat

ion th

ey pr

ovide

are r

ecor

ded,

store

d and

used

in su

ch a

way t

hat t

his do

es no

t unn

eces

saril

y inc

reas

e the

risk o

f har

m to

the w

histle

-blow

er.

2.2

Deve

lop pa

rtner

ships

betw

een t

he N

ation

al Sc

hool

of G

over

nmen

t and

othe

r gov

ernm

ent t

raini

ng

acad

emies

, cen

tral g

over

nmen

t dep

artm

ents

such

as th

e Dep

artm

ent o

f Pub

lic Se

rvice

and

Ad

mini

strat

ion an

d Nat

ional

Treas

ury,

educ

ation

al ins

titut

ions a

nd pr

ofes

siona

l bod

ies to

ensu

re

impr

oved

insti

tutio

nal c

apac

ity to

unde

rtake

e�ec

tive e

duca

tion,

train

ing an

d qua

lity c

ontro

l in su

ppor

t

of an

ti-co

rrupt

ion, in

tegr

ity m

anag

emen

t and

prof

essio

nalis

ation

of th

e pub

lic se

ctor.

2.3

Deve

lop pa

rtner

ships

betw

een G

over

nmen

t, civ

il soc

iety a

nd sc

hools

in th

e pub

lic an

d priv

ate s

yste

ms t

o

unde

rtake

awar

enes

s-rais

ing pr

ogra

mm

es ar

ound

corru

ption

and a

nti-c

orru

ption

, and

in su

ppor

t of t

he

relev

ant s

ectio

ns of

the s

choo

l cur

riculu

m. T

hese

could

inclu

de dr

ama a

nd m

usic

even

ts, an

d oth

er

creat

ive in

terv

entio

ns.

2.4

Secto

ral in

put i

nto s

treng

then

ed w

histle

-blow

er pr

otec

tion:

gove

rnm

ent,

busin

ess a

nd ci

vil so

ciety

to

deve

lop gu

idelin

es an

d pro

cedu

res f

or ho

w or

ganis

ation

s in t

heir s

ecto

rs ca

n sup

port

and p

rom

ote

wh

istle-

blowi

ng, a

nd th

e dev

elopm

ent o

f guid

eline

s for

coor

dinat

ing in

form

ation

colle

cted f

rom

re

porti

ng ho

tline

s.

33 Ra

debe

, J. 2

014.

Mini

ster R

adeb

e’s sp

eech

at In

tern

ation

al An

ti-Co

rrupt

ion D

ay, 9

Dec

embe

r 201

4.


esen

tativ

es. G

over

nmen

t acc

ount

abili

ty

is s

ubst

Nat

iona

l D

evel

opm

ent

Plan

. re

leva

nt s

take

hold

ers

in t

heir

sect

ors:

from

cus

tom

ers

and

St

rate

gic

prog

ram

mes

und

er p

illar

3:

Pilla

r 3: I

mpr

ove

tran

spar

ency

(by

gove

rnm

ent,

busi

ness

and

civ

il so

ciet

y se

ctor

s)

The

Cons

titut

ion

incl

udes

var

ious

cla

uses

requ

iring

tran

spar

ency

in th

e op

erat

ions

of g

over

nmen

t dep

artm

ents

and

ele

cted

repr

antia

lly e

nabl

ed b

y tr

ansp

aren

cy i

n de

cisi

on-m

akin

g an

d th

e m

anag

emen

t of

pub

lic r

esou

rces

. Th

is i

s a

key

them

e of

the

Fu

rthe

rmor

e, t

he b

usin

ess

and

civi

l soc

iety

sec

tors

als

o ha

ve a

dut

y to

ens

ure

appr

opria

te t

rans

pare

ncy

to

othe

r citi

zens

a�e

cted

by

busi

ness

act

ivity

, to

dono

rs, b

ene�

ciar

ies

and

othe

r gro

ups

a�ec

ted

by c

ivil

soci

ety

activ

ity.

Stra

tegi

c Pr

ogra

mm

e Ra

tion

ale

3.1

Deve

lop an

d im

plem

ent a

ware

ness-

raisi

ng ca

mpa

igns a

nd tr

aining

inte

rven

tions

on le

gislat

ion th

at gi

ve co

ncre

te e�

ect t

o

trans

pare

ncy,

with

a fo

cus o

n the

Prom

otion

of Ac

cess

to In

form

ation

Act a

nd th

e Pro

mot

ion of

Adm

inistr

ative

Justi

ce Ac

t, in

pa

rtner

ship

with

civil

socie

ty an

d med

ia.

3.2

Impr

ove s

yste

ms f

or re

cord

keep

ing in

orga

ns of

stat

e to s

uppo

rt ov

ersig

ht of

gove

rnm

ent a

ctivit

y and

the i

mple

men

tatio

n of t

he

Prom

otion

of Ac

cess

to In

form

ation

Act a

nd th

e Pro

mot

ion of

Adm

inistr

ative

Justi

ce Ac

t in p

artic

ular, t

hrou

gh:

•

The d

evelo

pmen

t of a

ppro

priat

e pro

fessio

nal re

cord

keep

ing st

anda

rds a

cross

all sp

here

s of G

over

nmen

t.

• Pr

ovidi

ng eff

ectiv

e tra

ining

for r

ecor

d man

ager

s and

arch

ivists

.

• M

aking

avail

able

small

gran

ts fo

r app

licat

ion by

gove

rnm

ent d

epar

tmen

ts an

d mun

icipa

lities

in de

velop

ing ap

prop

riate

reco

rd

ke

eping

syste

ms.

•

Prov

iding

tech

nical

supp

ort b

y Gov

ernm

ent f

or th

is pu

rpos

e.

3.3

Impr

ove t

he av

ailab

ility a

nd qu

ality

of go

vern

men

t dat

a rele

vant

to co

rrupt

ion an

d ant

i-cor

rupt

ion e�

orts

thro

ugh:

•

The d

evelo

pmen

t of s

tand

ardis

ed gu

idelin

es an

d oth

er m

echa

nism

s for

reco

rding

and r

epor

ting o

n cor

rupt

ion-re

lated

inves

tigat

ions a

nd pr

osec

ution

s for

vario

us se

ctors.

•

Alloc

ating

resp

onsib

ility t

o a go

vern

men

t bod

y to c

ollec

t, an

alyse

and r

epor

t on d

ata r

eleva

nt to

corru

ption

and a

nti-c

orru

ption

e�or

ts.

• M

appin

g and

rese

arch

ing th

e pot

entia

l futu

re ar

eas o

f risk

for c

orru

ption

.

3.4

Esta

blish

appr

opria

te in

strum

ents

and m

echa

nism

s to p

rovid

e for

info

rmat

ion on

bene

�cial

owne

rship

thro

ugh:

•

Amen

dmen

ts to

or de

velop

men

t of le

gislat

ion.

•

Appr

opria

te sy

stem

s to c

aptu

re an

d rep

ort o

n ben

eficia

l own

ersh

ip.

• In

form

ation

and a

ware

ness-

raisi

ng ca

mpa

igns o

n the

natu

re of

bene

ficial

owne

rship

and t

he pu

rpos

e of t

rans

pare

ncy i

n this

area

, in pa

rtner

ship

with

civil

socie

ty an

d med

ia.

3.5

Esta

blish

mec

hanis

ms f

or im

prov

ing tr

ansp

aren

cy of

gove

rnan

ce in

civil

socie

ty or

ganis

ation

s and

priva

te se

ctor �

rms,

in pa

rtner

ship

wi

th th

ese s

ecto

rs, fo

r exa

mple

thro

ugh:

•

The d

evelo

pmen

t of g

uideli

nes f

or in

form

ation

to be

prov

ided t

o the

publi

c.

• Aw

aren

ess-r

aising

cam

paign

s and

dialo

gues

on tr

ansp

aren

cy.

•

Othe

r mec

hanis

ms.

3.6

Deve

lop m

echa

nism

s to i

mpr

ove b

usine

ss se

ctor c

ompli

ance

with

repo

rting

requ

irem

ents

on co

rrupt

ion as

outli

ned i

n the

Prev

entio

n

and C

omba

ting o

f Cor

rupt

Activ

ities

Act,

thro

ugh m

echa

nism

s suc

h as:

•

Awar

enes

s-rais

ing ca

mpa

igns.

•

The d

evelo

pmen

t of g

uideli

nes r

egar

ding h

ow an

d wha

t to r

epor

t.

The P

rom

otion

of Ac

cess

to In

form

ation

Act g

ives g

reat

er le

gal e

�ect

to pr

ovisi

ons i

n the

Cons

titut

ion an

d the

Bill o

f Righ

ts pr

ovidi

ng

for a

ccess

to in

form

ation

in th

e pub

lic an

d priv

ate s

ecto

rs. Th

e Pro

mot

ion of

Adm

inistr

ative

Justi

ce Ac

t sta

tes t

hat m

embe

rs of

the

publi

c hav

e the

right

to ad

mini

strat

ive ac

tion b

y the

Stat

e tha

t is l

awfu

l, rea

sona

ble an

d pro

cedu

rally

fair,

and t

o be p

rovid

ed w

ith

reas

ons i

n circ

umsta

nces

whe

re on

e’s rig

hts a

re ad

verse

ly a�

ecte

d by a

dmini

strat

ive ac

tion.

The N

ation

al De

velop

men

t Plan

has

highl

ighte

d the

need

to gi

ve gr

eate

r e�e

ct to

thes

e Acts

by go

vern

men

t dep

artm

ents

and a

genc

ies.

The s

tate

of re

cord

keep

ing in

a nu

mbe

r of g

over

nmen

t dep

artm

ents

and m

unici

palit

ies is

poor.

This

creat

es ro

om fo

r cor

rupt

ion by

re

ducin

g the

Stat

e’s ab

ility t

o ide

ntify

and p

rose

cute

case

s of c

orru

ption

. Fur

ther,

poor

reco

rdke

eping

mak

es it

di�

cult

or ti

me-

cons

um-

ing fo

r dep

artm

ents

to co

mply

with

requ

ests

for in

form

ation

unde

r the

Prom

otion

of Ac

cess

to In

form

ation

Act a

nd Pr

omot

ion of

Ad

mini

strat

ive Ju

stice

Act.

Data

on in

vesti

gatio

ns an

d con

victio

ns of

case

s inv

olving

corru

ption

are i

ncon

siste

ntly

repo

rted b

y gov

ernm

ent a

genc

ies, a

nd da

ta on

co

mpli

ance

with

regu

lation

s rele

vant

to co

rrupt

ion is

inco

nsist

ently

colle

cted a

nd re

porte

d by p

ublic

secto

r dep

artm

ents.

Furth

er, th

is da

ta is

not p

rope

rly co

nsoli

date

d. Im

prov

ing th

e coll

ectio

n and

repo

rting

of th

ese k

inds o

f sta

tistic

s in G

over

nmen

t is i

mpo

rtant

for

mon

itorin

g ant

i-cor

rupt

ion w

ork,

and i

dent

ifying

area

s of p

oten

tial a

nd cu

rrent

risk f

or co

rrupt

ion.

At th

e Ope

n Gov

ernm

ent P

artn

ersh

ip Af

rica R

egion

al M

eetin

g in C

ape T

own i

n May

2016

, the

Sout

h Afri

can G

over

nmen

t ann

ounc

ed an

ac

tion p

lan th

at in

clude

s com

mitm

ents

to co

llecti

ng in

form

ation

on be

ne�c

ial ow

nersh

ip of

all c

ompa

nies i

n the

coun

try an

d mak

ing

this

publi

cally

avail

able.

This

will r

equir

e am

endm

ent t

o exis

ting l

egisl

ation

or th

e dev

elopm

ent o

f new

legis

lation

, and

the

deve

lopm

ent o

f sup

porti

ng re

gulat

ions a

nd in

stitu

tions

.

Whil

e som

e org

anisa

tions

in ci

vil so

ciety

and t

he bu

sines

s sec

tor h

ave t

aken

the l

ead i

n ens

uring

their

proc

esse

s are

tran

spar

ent a

nd

acco

unta

ble to

their

stak

ehold

ers,

ther

e is s

till a

need

to im

prov

e the

tran

spar

ency

of op

erat

ions o

f som

e civi

l soc

iety o

rgan

isatio

ns an

d pr

ivate

secto

r �rm

s, an

d to i

mpr

ove r

epor

ting o

n how

orga

nisat

ions a

re ta

cklin

g cor

rupt

ion in

their

own o

rgan

isatio

ns. T

he dr

aft K

ing IV

ou

tline

s pro

posa

ls fo

r pro

mot

ing go

od co

rpor

ate g

over

nanc

e in a

ll sec

tors

– inc

luding

prop

osals

for im

prov

ed tr

ansp

aren

cy.

Regu

lation

s on r

epor

ting c

orru

pt ac

tivity

in th

e bus

iness

secto

r by b

usine

sses i

s writ

ten i

nto l

aw, b

ut co

mpli

ance

with

thes

e pro

vision

s is

not w

hat i

t sho

uld be

, in pa

rt du

e to t

he st

igma a

ttach

ed to

adm

itting

cont

rol a

nd go

vern

ance

failu

res.


Pilla

r 4: I

mpr

ove

the

inte

grity

of t

he p

ublic

pro

cure

men

t sys

tem

The

Med

ium

Ter

m S

trat

egic

Fra

mew

ork

and

the

Nat

iona

l Dev

elop

men

t Pla

n in

clud

e st

reng

then

ing

over

sigh

t of t

he p

ublic

pro

cure

men

t sys

tem

as

a st

rate

gy fo

r red

ucin

gco

rrup

tion.

The

inte

rfac

e be

twee

n pu

blic

and

priv

ate

sect

ors

in th

e pr

ocur

emen

t pro

cess

is w

here

a g

ood

deal

of c

orru

pt a

ctiv

ity ta

kes

plac

e. S

uppo

rtin

g im

prov

ed

over

sigh

t of c

ompl

ianc

e by

ele

cted

o�

cial

s, p

ublic

sec

tor e

mpl

oyee

s an

d th

e bu

sine

ss s

ecto

r with

regu

latio

ns a

nd c

odes

inte

nded

to e

nsur

e ac

coun

tabi

lity

in th

e us

e of

pu

blic

reso

urce

s is

vita

l to

redu

cing

cor

rupt

ion

and

ensu

ring

that

pub

lic m

onie

s ar

e sp

ent o

n de

velo

pmen

t and

ser

vice

del

iver

y. T

he O

�ce

of t

he C

hief

Pro

cure

men

t O�

cer

was

est

ablis

hed

to s

uppo

rt a

mor

e tr

ansp

aren

t, fa

ir an

d e�

ectiv

e pu

blic

pro

cure

men

t sys

tem

. Im

port

ant r

efor

ms

of th

e pr

ocur

emen

t sys

tem

are

und

erta

ken

and

led

by th

is

o�ce

, whi

ch s

houl

d be

sup

port

ed b

y th

e N

atio

nal A

nti-C

orru

ptio

n St

rate

gy.

St

rate

gic

prog

ram

mes

und

er p

illar

4:

Stra

tegi

c Pr

ogra

mm

e Ra

tion

ale

4.1

Impr

ovem

ents

in pu

blicly

avail

able

data

on st

ate p

rocu

rem

ent i

n org

ans o

f sta

te th

at en

able

citize

ns, c

ivil

so

ciety

and c

once

rned

busin

ess t

o mon

itor t

he in

tegr

ity of

the p

ublic

proc

urem

ent s

yste

m. T

his

prog

ram

me s

hould

inclu

de a

majo

r foc

us on

ensu

ring t

he av

ailab

ility o

f suc

h dat

a on p

rocu

rem

ent b

y

state

-own

ed en

tities

.

4.2

Unde

rtake

annu

al fo

rens

ic re

views

of a

small

sam

ple of

proc

uring

entit

ies an

d lar

ge pr

ocur

emen

t

cont

racts

acro

ss all

leve

ls of

Gov

ernm

ent. T

he sa

mple

met

hod s

hould

vary

depe

nding

on th

e sph

ere o

f

Gove

rnm

ent.

For e

xam

ple:

•

In lo

cal g

over

nmen

t, a s

mall

rand

om sa

mple

of m

unici

palit

ies co

uld be

iden

tified

annu

ally.

•

In th

e cas

e of s

tate

-own

ed en

tities

, a ra

ndom

sam

ple of

cont

racts

abov

e a ce

rtain

value

could

be

ide

nti�

ed.

Thes

e inv

estig

ation

s wou

ld ne

ed to

be fo

llowe

d up w

ith ap

prop

riate

crim

inal o

r disc

iplina

ry ac

tion.

4.3

Deve

lop an

d im

plem

ent e

duca

tion a

nd aw

aren

ess c

ampa

igns t

o im

prov

e bus

iness,

civil

socie

ty an

d

med

ia ov

ersig

ht of

proc

urem

ent,

includ

ing:

•

Orga

nised

busin

ess p

artn

ering

with

Gov

ernm

ent t

o und

erta

ke tr

aining

for fi

rms,

civil s

ociet

y and

m

edia

rega

rding

the p

rocu

rem

ent p

roce

ss (h

ow th

e pro

cess

work

s, wh

ere t

o �nd

relev

ant

infor

mat

ion on

tend

ers,

wher

e to r

epor

t sus

pecte

d cas

es of

corru

ption

, etc.

).

• Th

e dev

elopm

ent o

f a su

ppor

ting h

andb

ook o

n how

proc

urem

ent i

s reg

ulate

d cou

ld be

deve

loped

.

Su

ch m

ater

ial ha

s alre

ady b

een d

evelo

ped i

n som

e sec

tors,

by or

ganis

ed bu

sines

s, th

e Eth

ics

In

stitu

te of

Sout

h Afri

ca an

d oth

ers. T

hese

could

be up

date

d and

mor

e wide

ly dis

tribu

ted.

Deve

loping

cons

olida

ted p

ublic

ly av

ailab

le da

ta on

stat

e pro

cure

men

t cou

ld aid

in bu

ilding

grea

ter t

rans

pare

n-cy

and a

ccoun

tabil

ity of

the g

over

nmen

t and

busin

ess s

ecto

rs in

the c

ount

ry.

Inte

rven

tions

are n

eede

d to c

reat

e a hi

gher

leve

l of r

isk of

dete

ction

of co

rrupt

activ

ity by

impr

oved

enfo

rce-

men

t of r

eleva

nt le

gislat

ion ar

ound

proc

urem

ent;

and t

o im

prov

e con

sequ

ence

man

agem

ent f

or tr

ansg

ressi

ons

of la

w re

gulat

ing pr

ocur

emen

t.

Civil s

ociet

y, or

ganis

ed bu

sines

s and

med

ia ca

n sup

port

impr

oved

mon

itorin

g of t

he pu

blic p

rocu

rem

ent

syste

m. O

rgan

isatio

ns th

at ar

e tra

ined o

n the

natu

re of

the r

eform

s to t

he pr

ocur

emen

t sys

tem

and t

he

com

plian

ce ex

pecte

d fro

m go

vern

men

t ins

titut

ions a

nd pr

ivate

secto

r com

panie

s in c

ontra

cting

with

the s

tate

ca

n assi

st Go

vern

men

t in p

rovid

ing pr

essu

re fo

r com

plian

ce.


Pilla

r 5: P

rofe

ssio

nalis

atio

n (o

f pub

lic s

ervi

ce e

mpl

oyee

s)

Prof

essi

onal

isat

ion

of t

he p

ublic

sec

tor

is a

key

the

me

of t

he N

atio

nal

Dev

elop

men

t Pl

an,

as o

utlin

ed i

n Ch

apte

r 13

, an

d is

not

onl

y in

clud

ed i

n th

e ch

apte

r on

co

mba

ting

corr

uptio

n bu

t al

so a

n ou

tcom

e of

the

Med

ium

Ter

m S

trat

egic

Fra

mew

ork

2014

2019

. A p

rofe

ssio

nalis

ed p

ublic

sec

tor

is o

ne in

whi

ch it

s em

ploy

ees

see

thei

r com

mitm

ent �

rst a

nd fo

rem

ost t

o th

e ci

tizen

s of

the

coun

try

and

to im

plem

entin

g po

licy

in th

e se

rvic

e of

soc

ial a

nd e

cono

mic

tran

sfor

mat

ion,

and

not

to p

rivat

e or

par

ty in

tere

sts

whe

re th

ese

devi

ate

from

form

al p

olic

y. F

urth

er, i

t inc

orpo

rate

s a

visi

on o

f a p

ublic

sec

tor i

n w

hich

em

ploy

ees

have

the

nece

ssar

y sk

ills

and

expe

rienc

e to

und

erta

ke t

heir

wor

k. P

rofe

ssio

nalis

atio

n re

quire

s an

app

roac

h to

tra

inin

g an

d re

crui

ting

civi

l ser

vant

s th

at c

an h

elp

shap

e a

sens

e of

com

mitm

ent

to s

ervi

ng t

he

publ

ic. I

nitia

tives

to

supp

ort t

he p

roce

ss o

f pro

fess

iona

lisat

ion

are

alre

ady

unde

rtak

en b

y th

e D

epar

tmen

t of P

ublic

Ser

vice

and

Adm

inis

trat

ion

, the

Nat

iona

l Sch

ool o

f G

over

nmen

t, th

e So

uth

Afr

ican

Loc

al G

over

nmen

t A

ssoc

iatio

n, a

nd o

ther

s. F

urth

er s

take

hold

ers

in t

his

proc

ess

incl

ude

othe

r tr

aini

ng b

odie

s an

d pr

ofes

sion

al

asso

ciat

ions

.

The

deve

lopm

ent

of a

wel

l-ski

lled

publ

ic s

ervi

ce f

eatu

res

prom

inen

tly i

n co

mpa

rativ

e po

litic

al s

cien

ce l

itera

ture

as

a ke

y fe

atur

e of

les

s co

rrup

t so

ciet

ies,

and

st

reng

then

ing

this

in

Sout

h A

fric

a w

ill r

equi

re d

edic

ated

res

ourc

es a

nd a

tten

tion

and

shou

ld o

btai

n pr

omin

ence

in

the

natio

nal

disc

ours

e on

cor

rupt

ion.

Hum

an

reso

urce

s, s

uppl

y ch

ain

man

agem

ent

and

�nan

ce s

houl

d be

par

ticul

arly

targ

eted

und

er th

is s

trat

egic

pill

ar. A

n im

prov

ed h

uman

reso

urce

func

tion

is v

ital f

or e

nsur

ing

bett

er c

onse

quen

ce m

anag

emen

t and

dis

cipl

ine

for n

on-c

ompl

ianc

e in

dep

artm

ents

, for

sup

port

ing

trai

ning

and

impr

oved

recr

uitm

ent i

n th

e pu

blic

sec

tor.

Impr

oved

�n

anci

al m

anag

emen

t an

d su

pply

cha

in m

anag

emen

t is

vita

l to

ensu

re m

ore

e�ci

ent

use

of p

ublic

res

ourc

es a

nd t

o re

duce

the

roo

m f

or c

orru

pt a

ctiv

ity

in p

ublic

pr

ocur

emen

t. O

ther

occ

upat

iona

l gro

ups

that

requ

ire in

terv

entio

ns re

late

to th

e pr

ofes

sion

s th

at d

etec

t and

inve

stig

ate

unet

hica

l or c

orru

pt b

ehav

iour

suc

h as

inte

rnal

au

dit a

nd fo

rens

ic in

vest

igat

ions

.

Stra

tegi

c pr

ogra

mm

es u

nder

pill

ar 5

:

Stra

tegi

c Pr

ogra

mm

e Ra

tion

ale

5.1

Deve

lop co

re cu

rricu

lum fo

r sup

ply ch

ain m

anag

emen

t, �n

ance

and h

uman

reso

urce

s; to

be de

velop

ed by

the

Na

tiona

l Sch

ool o

f Gov

ernm

ent,

in pa

rtner

ship

with

senio

r pra

ctitio

ners

in th

ese o

ccup

ation

s in t

he pu

blic s

ecto

r,

relev

ant p

rofes

siona

l asso

ciatio

ns an

d univ

ersit

ies. T

he cu

rricu

lum sh

ould

be ca

refu

lly de

velop

ed to

supp

ort

pr

actic

al tra

ining

that

re�e

cts th

e wor

king e

nviro

nmen

t of p

ublic

secto

r em

ploye

es.

5.2

Deve

lop a

coho

rt of

expe

rt tra

iners

and l

ectu

rers

in th

e Nat

ional

Scho

ol of

Gov

ernm

ent,

prov

incial

acad

emies

and

tra

ining

for l

ocal

gove

rnm

ent. T

his co

hort

shou

ld inc

lude t

raine

rs wh

o hav

e had

leng

thy p

eriod

s of e

xper

ience

at a

se

nior l

evel

in th

e pub

lic se

rvice

.

5.3

Phas

ed-in

exam

inatio

ns an

d tra

ining

requ

irem

ents

for s

ta�

at Se

nior M

anag

emen

t Ser

vice l

evel

in su

pply

chain

m

anag

emen

t, �n

ance

and h

uman

reso

urce

s. En

tranc

e exa

ms f

or po

sition

s in t

he Se

nior M

anag

emen

t Ser

vice o

r

anot

her a

ppro

priat

e lev

el in

thes

e occ

upat

ions c

ould

be ph

ased

in ov

er a

perio

d of t

ime,

begin

ning w

ith

know

ledge

testi

ng of

relev

ant l

egisl

ation

and c

odes

, the

n mov

ing sl

owly

towa

rds s

tand

ardis

ed co

mpe

tenc

y-ba

sed

ex

amina

tions

as tr

aining

insti

tutio

ns an

d cou

rses f

or pu

blic s

erva

nts m

atur

e.

5.4

Deve

lop or

stre

ngth

en pr

ofes

siona

l asso

ciatio

ns to

supp

ort t

he pr

ofes

siona

lisat

ion of

supp

ly ch

ain m

anag

emen

t,

�nan

ce an

d hum

an re

sour

ces i

n the

publi

c sec

tor.

5.5

Deve

lop a

grad

uate

recru

itmen

t pro

gram

me f

or su

pply

chain

man

agem

ent,

�nan

ce an

d hum

an re

sour

ces,

which

inc

ludes

a ce

ntra

l stra

tegy

for p

rovid

ing tr

aining

, men

torin

g and

supp

ort t

hrou

ghou

t the

�rst

year

s on t

he sc

hem

e,

as ca

lled f

or in

the N

ation

al De

velop

men

t Plan

.

The d

evelo

pmen

t of c

ore c

urric

ula fo

r the

se oc

cupa

tions

can s

uppo

rt im

prov

ed an

d sta

ndar

dised

train

ing, s

uppo

rt th

e de

velop

men

t of s

tand

ardis

ed cr

iteria

for a

ppoin

ting p

erso

nnel

in th

ese o

ccup

ation

s and

deve

lop a

com

mun

ity of

prac

tition

ers

in th

ese o

ccup

ation

s.

Traini

ng to

supp

ort p

rofes

siona

lisat

ion sh

ould

ideall

y tak

e the

form

of sp

ecial

ised,

long-

term

coho

rt tra

ining

, to d

evelo

p stro

ng

skills

and t

o dev

elop a

shar

ed et

hos.

Entra

nce e

xam

inatio

ns an

d tra

ining

requ

irem

ents,

if ap

prop

riate

ly ph

ased

in, c

an im

prov

e the

skills

leve

ls of

perso

nnel

in th

ese

posit

ions a

nd th

e sta

tus o

f the

se oc

cupa

tions

in th

e pub

lic se

ctor.

In a

num

ber o

f pro

fessio

ns, re

gistra

tion w

ith a

prof

essio

nal a

ssocia

tion o

r bod

y is s

tand

ard.

The p

rofes

siona

l asso

ciatio

ns (f

or

exam

ple th

e Sou

th Af

rican

Insti

tute

of Ch

arte

red A

ccoun

tant

s) ac

credit

mem

bers

of a

prof

essio

n, of

ten t

hrou

gh re

quiri

ng of

ap

plica

nts a

mini

mum

leve

l of q

uali�

catio

n or r

equir

ing th

at ap

plica

nts p

ass a

stan

dard

ised e

xam

inatio

n. Th

roug

h par

tner

ing

with

exist

ing pr

ofes

siona

l bod

ies, t

hese

form

s of a

ccre

ditat

ion co

uld be

built

up ov

er ti

me a

nd sh

ould

includ

e mem

bers

signin

g a c

ode o

f con

duct

for a

ccre

dited

entry

into

the p

rofes

sion.

The N

ation

al De

velop

men

t Plan

prop

oses

the d

evelo

pmen

t of a

grad

uate

recru

itmen

t pro

gram

me.

This

could

assis

t in

deve

loping

a co

mm

unity

of su

ppor

t and

prac

tice a

mon

g gra

duat

es in

thes

e occ

upat

ions a

nd in

impr

oving

the r

ecru

itmen

t of

skille

d gra

duat

es in

to th

e pub

lic se

ctor in

thes

e occ

upat

ions.


Pilla

r 6: I

mpr

ove

adhe

renc

e to

inte

grit

y m

anag

emen

t an

d an

ti-co

rrup

tion

mec

hani

sms

and

impr

oved

con

sequ

ence

man

agem

ent f

or n

on-c

ompl

ianc

e

St

rate

gic

prog

ram

mes

und

er p

illar

6:

Stra

tegi

c Pr

ogra

mm

e Ra

tion

ale

6.1

Deve

lop re

gulat

ions a

nd gu

idelin

es to

supp

ort t

he im

plem

enta

tion o

f the

Publi

c Adm

inistr

ation

Man

agem

ent A

ct, Ac

t 11 o

f 201

4 in t

he

publi

c ser

vice a

nd m

unici

palit

ies.

6.2

Deve

lop su

ppor

ting g

uideli

nes a

nd tr

aining

for t

he im

plem

enta

tion o

f the

Loca

l Gov

ernm

ent A

nti-C

orru

ption

Stra

tegy

.

6.3

Inve

stiga

te an

d ins

titut

e app

ropr

iate d

iscipl

inary

proc

edur

es ag

ainst

non-

com

plian

ce by

an ap

prop

riate

ly pla

ced a

nd ca

pacit

ated

unit

in

Gove

rnm

ent,

such

as th

e Pub

lic Ad

mini

strat

ion Et

hics,

Inte

grity

and D

iscipl

inary

Tech

nical

Assis

tanc

e Unit

in th

e Dep

artm

ent o

f Pub

lic

Serv

ice an

d Adm

inistr

ation

(esta

blish

ed by

the P

ublic

Adm

inistr

ation

Man

agem

ent A

ct). T

his ne

wly c

reat

ed un

it, or

anot

her

ap

prop

riate

ly pla

ced b

ody,

shou

ld be

give

n the

man

date

to en

sure

that

disci

plina

ry ac

tion i

s tak

en ag

ainst

emplo

yees

foun

d guil

ty of

o�

ence

s, an

d tha

t whe

re th

ere i

s rea

sona

ble su

spici

on of

illeg

al ac

tivity

this

is ha

nded

over

to la

w en

force

men

t. Fu

rther,

it sh

ould

be

prov

ided w

ith th

e res

ourci

ng to

unde

rtake

this

work

e�ec

tively

.

6.4

Imple

men

t tra

ining

for e

thics

o�ce

rs an

d per

sonn

el re

spon

sible

for d

etec

ting a

nd re

porti

ng on

corru

ption

in go

vern

men

t dep

artm

ents

an

d mun

icipa

lities

. The

train

ing sh

ould

be pr

actic

al in

cont

ent:

helpi

ng pe

rsonn

el de

al wi

th th

e situ

ation

s the

y are

likely

to fa

ce in

the

wo

rkpla

ce.

6.5

Stre

ngth

en go

vern

men

t em

ploye

e well

ness

prog

ram

mes

in th

e are

a of p

erso

nal �

nanc

ial m

anag

emen

t, th

roug

h im

prov

ed tr

aining

,

awar

enes

s rais

ing an

d deb

t cou

nsell

ing se

rvice

s.

6.6

Imple

men

t awa

rene

ss-ra

ising

prog

ram

mes

on th

e ant

i-cor

rupt

ion re

quire

men

ts fo

r priv

ate �

rms a

nd st

ate-

owne

d ent

ities

cont

ained

in

the C

ompa

nies A

ct, th

e Pre

vent

ion an

d Com

batin

g of C

orru

pt Ac

tiviti

es Ac

t and

othe

r rele

vant

piec

es of

legis

lation

, in pa

rtner

ship

with

or

ganis

ed bu

sines

s and

prof

essio

nal a

ssocia

tions

.

6.7

Deve

lop gu

idelin

es to

supp

ort c

ompli

ance

with

anti-

corru

ption

legis

lation

by pr

ivate

com

panie

s and

SOEs

. The

se gu

idelin

es co

uld be

de

velop

ed th

roug

h a pa

rtner

ship

betw

een g

over

nmen

t and

orga

nised

busin

ess.

6.8

Deve

lop an

anti-

corru

ption

com

plian

ce cu

lture

in pr

ivate

com

panie

s and

stat

e-ow

ned e

ntiti

es th

roug

h the

deve

lopm

ent o

f a ne

w

o�en

ce, i.

e. fai

lure b

y a co

mm

ercia

l org

anisa

tion t

o pre

vent

bribe

ry an

d pos

sibly

othe

r for

ms o

f cor

rupt

ion, w

hich r

equir

es co

mpa

nies t

o

proa

ctive

ly pu

t mea

sure

s in p

lace t

o man

age t

he ris

k of c

orru

ption

and t

o ens

ure t

hat t

hey h

ave a

defen

ce ag

ainst

the o

�enc

e of f

ailur

e

to pr

even

t brib

ery a

nd ot

her f

orm

s of c

orru

ption

.

The A

ct es

tabli

shes

a Pu

blic A

dmini

strat

ion Et

hics,

Inte

grity

and D

iscipl

inary

Tech

nical

Assis

tanc

e Unit

in th

e DPS

A; re

gulat

es pu

blic

serv

ants

cond

uctin

g bus

iness

with

the S

tate

; pro

vides

for t

he es

tabli

shm

ent o

f the

Nat

ional

Scho

ol of

Gov

ernm

ent;

prov

ides f

or th

e M

iniste

r of P

ublic

Serv

ice an

d Adm

inistr

ation

to se

t mini

mum

norm

s and

stan

dard

s for

publi

c adm

inistr

ation

; and

esta

blish

es an

O�

ce of

Stan

dard

s and

Com

plian

ce to

ensu

re co

mpli

ance

with

mini

mum

norm

s and

stan

dard

s.

The L

ocal

Gove

rnm

ent A

nti-C

orru

ption

Stra

tegy

was

laun

ched

this

year,

and o

utlin

es sp

eci�

c pro

gram

mes

for r

educ

ing co

rrupt

ion

and i

mpr

oving

acco

unta

bility

in lo

cal g

over

nmen

t.

Audit

or-G

ener

al an

d Acco

unta

nt-G

ener

al �n

dings

rega

rding

case

s of p

ossib

le or

actu

al co

rrupt

ion an

d non

-com

plian

ce w

ith

regu

lation

s and

code

s gov

ernin

g pub

lic se

ctor e

mplo

yees

’ cond

uct a

re no

t bein

g su�

cient

ly ac

ted u

pon b

y Acco

untin

g O�

cers

and

Exec

utive

Auth

oriti

es in

Gov

ernm

ent,

nor a

re th

e rec

omm

enda

tions

of th

e Pub

lic Se

rvice

Com

miss

ion be

ing ac

ted o

n with

rega

rd to

co

n�ict

s of in

tere

st as

discl

osed

in Fi

nanc

ial D

isclos

ure f

orm

s.

Traini

ng is

need

ed in

the a

rea o

f enf

orce

men

t and

inte

grity

man

agem

ent i

n gov

ernm

ent d

epar

tmen

ts an

d mun

icipa

lities

. Per

sonn

el as

signe

d to r

eleva

nt po

sts in

gove

rnm

ent o

rgan

isatio

ns of

ten d

o not

have

spec

ialise

d tra

ining

to su

ppor

t the

m in

helpi

ng to

prev

ent,

dete

ct an

d act

on po

ssible

case

s of c

orru

ption

.

The l

evel

of in

debt

edne

ss of

som

e pub

lic se

rvan

ts an

d the

risk t

hat t

his m

ight s

ee em

ploye

es m

ore l

ikely

to en

gage

in th

eft o

r oth

er

form

s of �

nanc

ial m

iscon

duct

requ

ires a

meli

orat

ion th

roug

h im

prov

ed tr

aining

and c

ouns

elling

supp

ort o

n man

aging

perso

nal

�nan

ces.

The a

nti-c

orru

ption

com

plian

ce re

quire

men

ts fo

r �rm

s are

not w

idely

know

n in t

he bu

sines

s sec

tor.

The r

egula

tions

of th

e Com

panie

s Act

do no

t spe

cify i

n det

ail w

hat k

inds o

f ant

i-cor

rupt

ion co

mpli

ance

mea

sure

s sho

uld be

un

derta

ken b

y �rm

s.

Som

e com

panie

s hav

e bee

n ver

y pro

activ

e in p

uttin

g in p

lace m

echa

nism

s to r

educ

e the

ir exp

osur

e to b

riber

y and

othe

r for

ms o

f co

rrupt

ion in

Sout

h Afri

ca an

d oth

er co

untri

es. H

owev

er, co

mpa

nies f

ace a

repu

tatio

nal r

isk fo

r rep

ortin

g on c

orru

ption

, and

putti

ng

in pla

ce an

ti-co

rrupt

ion co

mpli

ance

mea

sure

s can

be se

en as

yet a

noth

er co

mpli

ance

burd

en or

cost.

Awar

enes

s-rais

ing ca

mpa

igns

are n

ot su

�cie

nt: a

n app

ropr

iate s

et of

pres

sure

s or in

cent

ives i

s nee

ded t

o im

prov

e rep

ortin

g on b

riber

y and

to im

prov

e com

plian

ce

with

anti-

corru

ption

regu

lation

s by c

ompa

nies. T

here

are s

ucce

ssful

inter

natio

nal m

odels

that

Sout

h Afri

ca ca

n dra

w fro

m. T

he

Unite

d King

dom

, for e

xam

ple, h

as cr

eate

d a co

rpor

ate o

�enc

e kno

wn as

“the

failu

re by

a co

mm

ercia

l org

anisa

tion t

o pre

vent

br

ibery

”. This

oblig

es co

mpa

nies a

ssocia

ted w

ith th

e Unit

ed Ki

ngdo

m to

proa

ctive

ly pu

t mea

sure

s in p

lace t

o man

age t

he br

ibery

risk

to en

sure

that

they

have

a de

fence

again

st th

is ne

w “co

rpor

ate o

�enc

e”. Th

e Unit

ed Ki

ngdo

m G

over

nmen

t has

also

issu

ed ve

ry cl

ear

guide

lines

to co

rpor

ates

abou

t wha

t the

y reg

ard a

s “ad

equa

te pr

oced

ures

” to p

reve

nt br

ibery,

whic

h, if

prop

erly

put i

n plac

e, wi

ll co

nstit

ute a

defen

ce ag

ainst

a cha

rge o

f fail

ing to

prev

ent b

riber

y. Th

e UK R

egula

tor u

tilise

s defe

rred p

rose

cutio

n agr

eem

ents

as an

inc

entiv

e for

com

panie

s to e

nter

nego

tiatio

ns w

here

bribe

ry vi

olatio

ns ar

e alle

ged.

Whe

re ve

ry cl

ear e

viden

ce of

corru

ption

is

obta

ined,

law en

force

men

t stil

l inve

stiga

tes a

nd ca

n pro

secu

te cr

imina

l acti

vity.

Thes

e init

iative

s are

havin

g a dr

amat

ic e�

ect o

n m

ultina

tiona

l priv

ate s

ecto

r com

panie

s.

A ra

nge

of la

ws i

n So

uth

Afr

ica

requ

ire o

rgan

isat

ions

in G

over

nmen

t and

bus

ines

s to

impl

emen

t mec

hani

sms a

imed

at r

educ

ing

corr

uptio

n an

d su

ppor

ting

inte

grity

man

agem

ent i

n th

eir

orga

nisa

tions

. For

exa

mpl

e, in

the

cas

e of

the

bus

ines

s se

ctor

and

sta

te-o

wne

d en

titie

s, th

e Pr

even

tion

and

Com

batin

g of

Cor

rupt

Act

iviti

es A

ct o

utlin

es r

epor

ting

requ

irem

ents

on

corr

uptio

n, a

nd t

he C

ompa

nies

Act

req

uire

s co

mpa

nies

to

esta

blis

h So

cial

and

Eth

ics

Com

mitt

ees

whi

ch a

re t

o ov

erse

e, a

mon

g ot

her

thin

gs, t

he d

evel

opm

ent

of a

nti-c

orru

ptio

n co

mpl

ianc

e m

echa

nism

s to

redu

ce c

ompa

nies

’ exp

osur

e to

brib

ery

and

othe

r cor

rupt

ion-

rela

ted

risks

. The

dia

gnos

tics d

evel

oped

in p

repa

ratio

n fo

r thi

s str

ateg

y sh

owed

that

com

plia

nce

with

the

se r

egul

atio

ns is

stil

l too

low

. In

the

gove

rnm

ent

sect

or, c

lear

reg

ulat

ions

, pol

icy

guid

elin

es a

nd c

odes

of

cond

uct

have

bee

n de

velo

ped

to s

uppo

rt in

tegr

ity m

anag

emen

t, in

clud

ing

the

Fina

ncia

l D

iscl

osur

e Fr

amew

ork,

gui

delin

es a

roun

d re

port

ing

on s

uspe

cted

cas

es o

f co

rrup

tion,

on

inve

stig

atio

ns w

ithin

dep

artm

ents

, etc

. How

ever

, Pub

lic S

ervi

ce

Com

mis

sion

and

Aud

itor-

Gen

eral

rep

orts

and

the

�nd

ings

of

the

Acco

unta

nt-G

ener

al h

ave

note

d th

e lo

w le

vels

of

appr

opria

te s

anct

ion

appl

ied

to e

mpl

oyee

s an

d m

embe

rs o

f th

e ex

ecut

ive

in G

over

nmen

t who

do

not a

dher

e to

thes

e co

des

and

regu

latio

ns, a

nd th

ose

susp

ecte

d of

ille

gal a

ctiv

ity. E

�ort

s ar

e ne

eded

to e

nsur

e gr

eate

r com

plia

nce

and

cons

eque

nce

man

agem

ent i

n or

gani

satio

ns in

the

gove

rnm

ent a

nd b

usin

ess

sect

ors

thro

ugh

both

enf

orce

men

t and

pre

vent

ativ

e m

easu

res.


Pilla

r 7: S

tren

gthe

n ov

ersi

ght m

echa

nism

s (in

the

gove

rnm

ent s

ecto

r)

The

Cons

titut

ion

of th

e Re

publ

ic o

f Sou

th A

fric

a es

tabl

ishe

d a

num

ber o

f ove

rsig

ht b

odie

s w

ith re

leva

nce

to a

nti-c

orru

ptio

n e�

orts

. The

se in

clud

e th

e Pu

blic

Pro

tect

or,

the

Aud

itor-

Gen

eral

, and

the

Pub

lic S

ervi

ce C

omm

issi

on.

The

natio

nal

and

prov

inci

al p

arlia

men

ts (

legi

slat

ures

), an

d th

e lo

cal

gove

rnm

ent

coun

cils

are

to

prov

ide

gene

ral o

vers

ight

ove

r the

act

iviti

es o

f gov

ernm

ent d

epar

tmen

ts a

nd a

genc

ies.

In a

dditi

on, b

odie

s ha

ve b

een

esta

blis

hed

in le

gisl

atio

n to

pro

vide

ove

rsig

ht o

f par

ticul

ar

sect

ors,

suc

h as

pol

icin

g an

d th

e in

telli

genc

e se

rvic

es. T

he in

tegr

ity a

nd e

�ect

iven

ess

of th

ese

bodi

es is

cen

tral

ly im

port

ant i

n th

e �g

ht a

gain

st c

orru

ptio

n.

Stra

tegi

c pr

ogra

mm

es u

nder

pill

ar 7

:

Stra

tegi

c Pr

ogra

mm

e Ra

tion

ale

1.1

Ensu

re ap

prop

riate

reso

urcin

g and

ethic

al lea

dersh

ip of

Chap

ter 9

and 1

0 Con

stitu

tiona

l ove

rsigh

t

bodie

s, an

d of o

versi

ght b

odies

of th

e poli

ce an

d int

ellige

nce s

ervic

es so

as to

build

publi

c con

�den

ce

in th

eir ov

ersig

ht ro

le an

d stre

ngth

en th

eir e�

ectiv

enes

s.

1.2

Deve

lop an

d im

plem

ent p

ublic

awar

enes

s-rais

ing ca

mpa

igns a

bout

the r

ole an

d im

porta

nce o

f

Chap

ter 9

and 1

0 ove

rsigh

t bod

ies in

stre

ngth

ening

dem

ocra

cy an

d im

prov

ing go

vern

men

t

acco

unta

bility

.

1.3

Initi

ate p

ublic

conv

ersa

tion a

bout

the r

ole an

d man

date

of th

e Pub

lic Se

rvice

Com

miss

ion in

str

engt

henin

g dem

ocra

cy, im

prov

ing ov

ersig

ht of

gove

rnm

ent e

mplo

yees

and b

uildin

g a pr

ofes

siona

l

publi

c sec

tor, a

nd de

velop

prop

osals

for h

ow to

stre

ngth

en th

e aut

horit

y of t

he Co

mm

ission

’s

reco

mm

enda

tions

in lin

e with

reco

mm

enda

tions

mad

e in t

he N

ation

al De

velop

men

t Plan

.

1.4

Impr

ove t

he ca

pacit

y of m

unici

pal o

versi

ght f

uncti

ons t

hrou

gh:

•

Traini

ng in

terv

entio

ns fo

r cou

ncillo

rs an

d mun

icipa

l man

ager

s.

• Tra

ining

for c

ivil s

ociet

y org

anisa

tions

to pl

ay a

stron

ger r

ole in

publi

c par

ticipa

tion p

roce

sses.

•

Natio

nal a

nd re

giona

l dial

ogue

s on t

he na

ture

and p

urpo

se of

acco

unta

bility

and o

versi

ght

mec

hanis

m in

loca

l gov

ernm

ent.

Thes

e ove

rsigh

t bod

ies sh

ould

be ap

prop

riate

ly re

sour

ced a

nd in

depe

nden

t of p

ressu

re fr

om th

e exe

cutiv

e or

othe

r sec

tors

to pl

ay th

eir ro

le in

actin

g aga

inst a

buse

s of p

ower

and o

ther

form

s of c

orru

ption

.

Thes

e bod

ies ar

e vita

lly im

porta

nt in

ensu

ring i

mpr

oved

gove

rnm

ent a

ccoun

tabil

ity an

d req

uire t

he ac

tive

supp

ort o

f mem

bers

of th

e pub

lic.

Over

the l

ast 2

0 yea

rs, th

e Pub

lic Se

rvice

Com

miss

ion ha

s play

ed a

valua

ble ro

le in

mon

itorin

g the

cond

uct o

f pu

blic s

erva

nts a

nd m

embe

rs of

the e

xecu

tive.

Howe

ver, t

he Co

mm

ission

does

not h

ave t

he m

anda

te to

en

sure

com

plian

ce by

depa

rtmen

ts an

d poli

tician

s with

its �

nding

s. A p

ublic

deba

te on

the p

ossib

le str

engt

hene

d role

of th

e Com

miss

ion w

ould

be va

luable

.

At lo

cal g

over

nmen

t lev

el, st

ructu

res e

stabli

shed

to im

prov

e ove

rsigh

t of m

unici

pal d

ecisi

on-m

aking

and

spen

ding,

such

as th

e Mun

icipa

l Pub

lic Ac

coun

ts Co

mm

ittee

s, ar

e not

wor

king a

s e�e

ctive

ly as

they

shou

ld.


Pilla

r 8: S

tren

gthe

n th

e re

sour

cing

, coo

pera

tion

and

inde

pend

ence

of d

edic

ated

ant

i-cor

rupt

ion

agen

cies

Sout

h A

fric

a fo

llow

s a

mul

ti-ag

ency

app

roac

h to

com

batin

g co

rrup

tion:

it d

oes

not

have

one

ent

ity s

olel

y fo

cuse

d on

enf

orce

men

t an

d an

ti-co

rrup

tion

mea

sure

s.

Irres

pect

ive

of w

heth

er c

ount

ries

follo

w a

sin

gle

or m

ulti

-age

ncy

mod

el, t

hose

tha

t ha

ve b

een

succ

essf

ul i

n re

duci

ng c

orru

ptio

n ha

ve d

emon

stra

ted

a nu

mbe

r of

im

port

ant c

hara

cter

istic

s.

Sout

h A

fric

a m

ust e

nsur

e th

at it

s an

ti-co

rrup

tion

syst

em d

emon

stra

tes

the

follo

win

g ch

arac

teris

tics:

•

Inde

pend

ence

from

the

exec

utiv

e, a

nd fr

om s

ecto

ral i

nter

ests

. •

Acc

ount

abili

ty, t

hrou

gh c

ivili

an a

nd/o

r par

liam

enta

ry o

vers

ight

. •

A tr

ansp

aren

t pro

cess

for a

ppoi

ntin

g le

ader

s an

d se

nior

man

ager

s on

the

basi

s of

thei

r int

egrit

y, c

ompe

tenc

y an

d sk

ills.

•

Job

secu

rity

thro

ugh

fair

and

tran

spar

ency

pro

cess

es fo

r dis

mis

sing

sta

�.

• A

dequ

ate

reso

urce

s in

the

form

of b

udge

t and

infr

astr

uctu

re.

• A

ppro

pria

tely

ski

lled

sta�

that

are

spe

cial

ised

and

hav

e be

en a

ppro

pria

tely

trai

ned.

St

rate

gic

prog

ram

mes

und

er p

illar

8:

Stra

tegi

c Pr

ogra

mm

e Ra

tion

ale

8.1

Ensu

re th

e stru

ctura

l and

oper

ation

al ind

epen

denc

e of k

ey ag

encie

s inv

olved

in in

vesti

gatin

g and

pros

ecut

ing co

rrupt

ion (c

urre

ntly

the

Di

recto

rate

for P

riorit

y Crim

e Inv

estig

ation

; the

Spec

ial In

vesti

gatin

g Unit

; and

the N

ation

al Pr

osec

uting

Auth

ority

) thr

ough

:

• Im

prov

ing th

e tra

nspa

renc

y and

rigou

r of t

he pr

oces

ses f

or se

lectin

g and

dism

issing

senio

r lea

ders

in th

ese o

rgan

isatio

ns.

•

Ensu

ring o

versi

ght o

f the

se ag

encie

s wor

k thr

ough

dire

ct re

porti

ng to

parli

amen

t or s

ome c

ivil o

versi

ght b

ody.

8.2

Revie

w an

d im

prov

e the

desig

n of a

coor

dinat

ing bo

dy fo

r ant

i-cor

rupt

ion w

ork,

ensu

ring t

hat t

he bo

dy ha

s:

• su

fficie

nt le

gal s

tatu

re

• is

appr

opria

tely

struc

ture

d

• is

appr

opria

tely

reso

urce

d to b

e effe

ctive

in co

ordin

ating

anti-

corru

ption

dete

ction

, inve

stiga

tion a

nd pr

osec

ution

.

Th

is sh

ould

includ

e im

prov

ed m

echa

nism

s for

supp

ortin

g:

• Pr

osec

ution

-guid

ed in

vesti

gatio

ns, a

nd fo

r

• Tra

cking

case

s of c

orru

ption

in G

over

nmen

t whe

re re

levan

t par

ties a

re no

t crim

inally

char

ged,

but w

here

disci

plina

ry ac

tion i

s

re

com

men

ded b

y the

inve

stiga

ting u

nit, i.

e. m

onito

ring c

onse

quen

ce m

anag

emen

t of s

uch c

ases

by or

ganis

ation

s in g

over

nmen

t.

8.3

Unde

rtake

capa

city b

uildin

g, inc

luding

train

ing, fo

r impr

oved

enfo

rcem

ent,

amon

g oth

ers:

•

Impr

oved

syste

ms f

or ca

ptur

ing an

d ana

lysing

inte

lligen

ce an

d dat

a on r

epor

ted o

r sus

pecte

d cas

es of

corru

ption

in su

ppor

t of

inves

tigat

ions,

risk a

ssessm

ents,

etc

•

Traini

ng fo

r inve

stiga

tors

on bu

ilding

succe

ssful

case

s und

er th

e Pre

vent

ion an

d Com

batin

g of C

orru

pt Ac

tiviti

es Ac

t

• Tra

ining

on de

aling

with

soph

istica

ted f

orm

s of fi

nanc

ial cr

ime a

nd cy

bercr

ime.

8.4

Impr

ove b

ilate

ral c

oope

ratio

n with

othe

r cou

ntrie

s in t

he �g

ht ag

ainst

corru

ption

(and

�nan

cial c

rimes

in pa

rticu

lar) e

nsur

ing m

utua

l

legal

assis

tanc

e in i

nves

tigat

ions,

pros

ecut

ions a

nd ju

dicial

proc

eedin

gs in

relat

ion to

corru

ption

.

8.5

Stre

ngth

en en

gage

men

t bet

ween

Sout

h Afri

ca an

d the

relev

ant i

nter

natio

nal c

usto

dians

of th

e agr

eem

ents

to w

hich S

outh

Afric

a is a

sig

nato

ry.

Furth

er e�

orts

are r

equir

ed in

Sout

h Afri

ca to

build

the i

ndep

ende

nce o

f the

crim

inal ju

stice

agen

cies t

o sup

port

anti-

corru

ption

wor

k esp

ecial

ly in

pursu

ing se

nior p

olitic

ians,

gove

rnm

ent o

�cia

ls, bu

sines

s peo

ple an

d oth

er

leade

rs, an

d buil

ding p

ublic

con�

denc

e in g

over

nmen

t’s co

mm

itmen

t to r

educ

ing co

rrupt

ion. T

he N

ation

al De

velop

men

t Plan

high

light

s the

impo

rtanc

e of in

sulat

ing cr

imina

l justi

ce ag

encie

s fro

m po

litica

l pre

ssure.

Ther

e is a

need

for im

prov

ed co

ordin

ation

betw

een t

he va

rious

crim

inal ju

stice

agen

cies (

and o

ther

s in G

over

nmen

t ta

sked

with

com

batin

g cor

rupt

ion) i

n Sou

th Af

rica.

The P

reve

ntion

and C

omba

ting o

f Cor

rupt

Activ

ities

Act h

as th

us fa

r rar

ely be

en us

ed to

pros

ecut

e cas

es of

corru

ption

. Po

lice a

re m

ore l

ikely

to us

e leg

islat

ion pe

rtaini

ng to

frau

d and

othe

r �na

ncial

crim

es th

an th

is Ac

t. Tra

ining

on

build

ing ca

ses u

nder

the A

ct co

uld as

sist w

ith im

prov

ing pr

osec

ution

rate

s.

The c

halle

nges

with

data

on co

rrupt

ion an

d ant

i-cor

rupt

ion ha

ve al

read

y bee

n men

tione

d.

Sout

h Afri

ca is

a sig

nato

ry to

a nu

mbe

r of in

tern

ation

al co

nven

tions

and t

reat

ies th

at co

mm

it th

e cou

ntry

to

imple

men

ting p

artic

ular in

terv

entio

ns ai

med

at re

ducin

g cor

rupt

ion. Im

prov

ed m

echa

nism

s are

need

ed to

incre

ase

the c

ount

ry’s c

ompli

ance

with

the v

ariou

s con

vent

ions a

nd ag

reem

ents,

impr

ove c

oope

ratio

n bet

ween

Sout

h Afri

ca

and o

ther

coun

tries

in th

e �gh

t aga

inst c

orru

ption

, esp

ecial

ly �n

ancia

l crim

es, a

nd to

stre

ngth

en en

gage

men

t with

th

e rele

vant

inte

rnat

ional

custo

dians

of th

ese a

gree

men

ts.


Pilla

r 9: V

ulne

rabl

e se

ctor

man

agem

ent:

build

spe

ci�c

pro

gram

mes

to re

duce

corr

upti

on a

nd im

prov

e in

tegr

ity

in s

ecto

rs p

arti

cula

rly

vuln

erab

le to

cor

rupt

ion

Ce

rtai

n se

rvic

es o

r sec

tors

are

mor

e vu

lner

able

to c

orru

ptio

n th

an o

ther

s. T

he W

orld

Ban

k an

d th

e G

roup

of 2

0 su

ppor

t and

hav

e in

tern

atio

nally

prio

ritis

ed a

num

ber o

f in

dust

ry s

ecto

rs in

whi

ch g

over

nmen

ts a

nd b

usin

esse

s pl

ay im

port

ant

role

s fo

r pr

iorit

ised

focu

s re

gard

ing

anti-

corr

uptio

n m

easu

res.

In m

any

coun

trie

s, t

hese

sec

tors

in

clud

e th

ose

serv

ices

in w

hich

pub

lic s

ecto

r pe

rson

nel h

ave

a gr

eat

deal

of p

ower

ove

r th

e fa

te o

f mem

bers

of t

he p

ublic

suc

h as

pol

icin

g, im

mig

ratio

n an

d bo

rder

co

ntro

l, co

rrec

tiona

l ser

vice

s, s

ocia

l ser

vice

s, th

e al

loca

tion

of li

cenc

es o

r cer

ti�ca

tes,

e.g

. min

ing

or e

nviro

nmen

tal e

xplo

ratio

n/ex

ploi

tatio

n, o

r are

as th

at a

re o

f nat

iona

l or

str

ateg

ic in

tere

st t

o th

e de

velo

pmen

t or

eco

nom

ic s

tabi

lity

of t

hat

coun

try,

e.g

. ene

rgy

prov

isio

n or

infr

astr

uctu

re d

evel

opm

ent.

Impr

ovin

g th

e in

tegr

ity o

f th

ese

sect

ors

in a

n in

tegr

ated

man

ner m

ust t

here

fore

be

an im

port

ant c

ompo

nent

of t

he N

atio

nal A

nti-C

orru

ptio

n St

rate

gy.

In li

ne w

ith c

urre

nt g

over

nmen

t pro

gram

mes

, the

em

phas

is o

n sp

eci�

c at

tent

ion

to v

ulne

rabl

e se

ctor

s al

read

y ex

ists

. In

keep

ing

with

this

app

roac

h it

is p

ropo

sed

that

th

e se

ctor

s in

the

Just

ice,

Crim

e Pr

even

tion

and

Secu

rity

Clus

ter a

re p

riorit

ised

�rs

t und

er th

is s

trat

egic

pill

ar, p

artic

ular

ly p

olic

ing,

imm

igra

tion

and

bord

er c

ontr

ol, a

nd

corr

ectio

nal s

ervi

ces.

Per

sonn

el in

the

se s

ecto

rs a

re in

clo

se p

roxi

mity

to

crim

e ne

twor

ks, a

nd in

Sou

th A

fric

a, t

here

are

a n

umbe

r of

add

ition

al c

onte

xt-s

peci

�c a

nd

hist

oric

al f

acto

rs t

hat

have

sha

ped

the

Just

ice,

Crim

e Pr

even

tion

and

Secu

rity

Clus

ter’s

vul

nera

bilit

y to

cor

rupt

ion.

Whi

le t

hese

ser

vice

s ar

e pa

rtic

ular

ly v

ulne

rabl

e to

co

rrup

tion,

they

are

als

o vi

tal t

o th

e �g

ht a

gain

st c

orru

ptio

n.

Stra

tegi

c pr

ogra

mm

es u

nder

pill

ar 9

:St

rate

gic

Prog

ram

me

Rati

onal

e

9.1

Deve

lopm

ent o

f spe

ci�c i

ndus

try, s

ecto

r or d

epar

tmen

tal a

nti-c

orru

ption

stra

tegie

s for

prior

itise

d

area

s (as

appli

cable

).

9.2

Deve

lopm

ent o

f app

ropr

iately

reso

urce

d pro

ject p

lans t

o im

plem

ent f

ocus

ed, p

arall

el, m

ulti-l

evel

int

erve

ntion

s to m

itiga

te ve

ry sp

eci�

c risk

s in a

secto

r.

9.3

Cent

rally

mon

itor a

nd ev

aluat

e pro

gres

s on i

mple

men

tatio

n of t

hese

indu

stry/

depa

rtmen

tal

an

ti-co

rrupt

ion st

rate

gies a

nd/o

r pro

jects

with

in a s

ecto

r.

Dedic

ated

indu

stry,

secto

r or d

epar

tmen

t-spe

ci�c a

nti-c

orru

ption

stra

tegie

s are

need

ed to

guide

and

impr

ove a

nti-c

orru

ption

e�or

ts in

prior

itise

d are

as, c

urre

ntly

in pa

rticu

lar in

the J

ustic

e, Cr

ime P

reve

ntion

an

d Sec

urity

clus

ter. T

hese

shou

ld inc

lude:

•

Each

of th

e dep

artm

ents

unde

r a sp

ecifi

c sec

tor/i

ndus

try de

velop

ing (o

r rev

iewing

, whe

re th

ese

have

been

deve

loped

) det

ailed

and a

ppro

priat

ely co

sted a

nti-c

orru

ption

stra

tegie

s and

proje

cts.

•

Thes

e sho

uld al

locat

e tim

efram

es an

d role

s as w

ell as

resp

onsib

ilities

for im

plem

enta

tion o

f the

va

rious

com

pone

nts o

f the

stra

tegy

/pro

ject (

includ

ing bu

sines

s sec

tor p

artic

ipatio

n).

•

The i

nten

tion i

s tha

t a st

rate

gy sh

ould

targ

et a

perio

d of 5

�10 y

ears,

and r

elate

d pro

jects

targ

et

pe

riods

of 3-

5 yea

rs un

til ris

ks in

thes

e sec

tors,

indu

stries

or de

partm

ents

are s

igni�

cant

ly

re

duce

d or s

yste

ms r

egula

rised

.

• Th

ese s

hould

be au

gmen

ted w

ith an

d sup

port

the r

egula

r/ins

titut

ionali

sed m

echa

nism

s to

impr

ove i

nteg

rity m

anag

emen

t pro

fessio

nalis

ation

and d

iscipl

inary

actio

n or in

itiat

e

inv

estig

ation

s aga

inst c

orru

pt pa

rties

in th

e prio

ritise

d clus

ter.


6. In

stit

utio

nal m

echa

nism

s to

impl

emen

t the

str

ateg

y

6.1

Key

depe

nden

cies

for t

he N

ACS

will

be

de�n

ed a

s pa

rt o

f the

con

sulta

tion

proc

ess.

6.2

Impl

emen

tatio

n m

echa

nism

s

A l

ead

orga

nisa

tion

shou

ld b

e id

enti�

ed t

o su

ppor

t the

impl

emen

tatio

n, c

oord

inat

ion

and

mon

itorin

g of

the

Nat

iona

l A

nti-

Corr

uptio

n St

rate

gy,

and

to a

ct a

s a

secr

etar

iat t

o or

gani

satio

nal p

latf

orm

s th

at a

re im

port

ant f

or it

s de

liver

y, s

uch

as th

e N

atio

nal A

nti -

Cor

rupt

ion

Foru

m. I

t is

prop

osed

that

suc

h a

unit

is e

stab

lishe

d in

the

Pres

iden

cy. A

pro

pose

d st

ruct

ure

is o

utlin

ed

in th

e di

agra

m b

elow

.

MIN

ISTE

RIA

L O

VERS

IGH

TW

ith d

esig

nate

d as

pol

itica

l cha

mpi

on o

f the

�gh

tag

ains

t cor

rupt

ion

Body

to c

oord

inat

e an

ti-co

rrup

tion

agen

cies

Func

tions

:O

pera

tiona

l coo

pera

tion

on la

w e

nfor

cem

ent

and

inte

llige

nce

gath

erin

g

Nat

iona

l Ant

i-cor

rput

ion

Foru

m o

r oth

erin

ter-

sect

oral

coo

rdin

atin

g bo

dyCh

air:

Min

iste

r (po

litic

al c

ham

pion

)

Opt

ion

1: C

ompo

sitio

n, o

pera

tiona

l and

fund

ing

mod

aliti

es to

be

dete

rmin

ed th

roug

h a

polit

ical

cons

ulta

tion

proc

ess,

star

ting

imm

edia

tely

.

Opt

ion

2: C

ompo

sitio

n, o

pera

tiona

l and

fund

ing

mod

aliti

es to

be

dete

rmin

ed th

roug

h co

nsul

tatio

npr

oces

s (ro

ad m

ap) a

nd in

ter-

sect

oral

bod

yes

tabl

ishe

d at

end

of t

he p

roce

ss.

Prop

osed

func

tions

:•

Prom

ote

cohe

sion

and

com

mon

pur

pose

in

so

ciet

y on

�gh

ting

corr

uptio

n•

Alig

n an

d co

ordi

nate

sec

tora

l ant

i-cor

rupt

ion

pr

ogra

mm

es•

Esta

blis

h, c

oord

inat

e an

d m

onito

r int

er-

se

ctor

al w

orki

ng g

roup

s on

them

atic

s/sp

eci�

c

area

s•

Out

com

e m

onito

ring

of th

e N

atio

nal A

nti-

co

rrup

tion

Stra

tegy

O�

ce fo

r the

pro

mot

ion

of in

tegr

ity

and

�ght

ing

corr

uptio

nPe

rman

ent O

�ce

with

per

man

ent h

ead

and

sta�

and

prog

ram

mic

bud

get

Func

tion

• Po

licy-

mak

ing

on fi

ghtin

g co

rrpu

tion

• Co

ordi

natio

n of

impl

emen

tatio

n of

the

Nat

iona

l

Ant

i-cor

rupt

ion

Stra

tegy

• M

onito

ring

the

effica

cy o

f the

ant

i-cor

rupt

ion

sy

stem

• M

onito

ring

the

impl

emen

tatio

n of

the

Nat

iona

l

Ant

i-cor

rupt

ion

Stra

tegy

• Re

port

ing

(dom

estic

and

inte

rnat

iona

l ins

trum

ents

/

foru

ms)

• Ev

alut

ion

• Co

mm

unic

atio

n, a

war

enes

s an

d ed

ucat

ion

• Se

cret

aria

t sup

port

to th

e in

ter-

sect

oral

co

ordi

natin

g bo

dy


App

endi

x A

: Roa

dmap

for d

evel

opin

g a

�nal

Nat

iona

l Ant

i-Cor

rupt

ion

stra

tegy

Purp

ose

The

purp

ose

of th

is ro

adm

ap is

to o

utlin

e th

e pr

oces

s to

be

follo

wed

in th

e de

velo

pmen

t of t

he N

atio

nal A

nti-c

orru

ptio

n St

rate

gy.

The

goal

s of

the

prop

osed

pro

cess

are

to:

•

Achi

eve

a “w

hole

of g

over

nmen

t and

soc

iety

” app

roac

h to

the

fight

aga

inst

cor

rupt

ion.

•

Be o

pen,

tran

spar

ent a

nd in

clus

ive

of a

ll se

ctor

s of

Sou

th A

fric

an s

ocie

ty.

•

Arr

ive

at a

robu

st N

atio

nal A

nti-C

orru

ptio

n St

rate

gy th

at h

as b

uy-in

from

the

stat

e, b

usin

ess

and

civi

l soc

iety

.

• Fo

ster

ow

ners

hip

of th

e pr

oces

s an

d th

e re

sulti

ng N

atio

nal A

nti-C

orru

ptio

n St

rate

gy b

y al

l the

sec

tors

.

Prop

osed

pro

cess

Belo

w is

the

cons

ulta

tion

proc

ess

to b

e fo

llow

ed, f

rom

the

appr

oval

of t

he c

onso

lidat

ed c

onsu

ltatio

n do

cum

ent t

o th

e ap

prov

al o

f the

�na

l na

tiona

l ant

i-cor

rupt

ion

stra

tegy

and

its

impl

emen

tatio

n pl

an.

This

com

preh

ensi

ve p

roce

ss is

aim

ed a

t ach

ievi

ng w

ide

cons

ulta

tion,

giv

ing

the

stra

tegy

max

imum

pub

licity

and

ach

ievi

ng h

igh

leve

ls o

f cr

edib

ility

and

thus

buy

-in fr

om a

ll or

gani

sed

sect

ors

of S

outh

Afr

ican

soc

iety

as

wel

l as

ordi

nary

citi

zens

. Thi

s pr

oces

s is

pro

pose

d as

the

rout

e fo

r bui

ldin

g pu

blic

con

�den

ce in

Gov

ernm

ent a

nd o

ther

sec

tors

’ com

mitm

ent t

o �g

htin

g co

rrup

tion.


Phas

e 1:

Res

earc

h, in

itia

l con

sult

atio

n an

d dr

afti

ng

A

ctio

ns

Resp

onsi

bilit

y Ti

mel

ine

1 D

raft

con

sult

atio

n do

cum

ent d

evel

oped

•

Dia

gnos

tic a

sses

smen

t and

dra

ft p

ropo

sals

for a

n an

ti-c

orru

ptio

n st

rate

gy d

evel

oped

(in

the

form

of a

dr

aft c

onsu

ltatio

n do

cum

ent)

. •

Dev

elop

ed b

y th

e Pu

blic

A�a

irs R

esea

rch

Inst

itute

(WIT

S), s

uppo

rted

by

a St

eerin

g Co

mm

ittee

(cha

ired

by th

e D

epar

tmen

t of P

ublic

Ser

vice

and

Adm

inis

trat

ion)

.

Stee

ring

Com

mitt

ee a

nd

Publ

ic A

�airs

Res

earc

h In

stitu

te

May

to A

ugus

t 201

6

2 Si

gn-o

� b

y A

CTT:

•

Cons

ulta

tion

docu

men

t sig

ned

o� b

y A

nti-C

orru

ptio

n Ta

sk T

eam

A

nti-C

orru

ptio

n Ta

sk

Team

Ju

ly 2

016

3 Su

ppor

ting

org

anis

atio

ns a

nd s

truc

ture

s id

enti

�ed

•

Stee

ring

Com

mitt

ee re

mai

ns a

refe

renc

e gr

oup

until

the

end

of th

e pr

oces

s.

• A

dep

artm

ent i

s ap

poin

ted

to a

ssum

e re

spon

sibi

lity

for d

rivin

g th

e pr

oces

s.

• A

gree

d-up

on a

ppro

ach

to re

vive

a re

conc

eptu

alis

ed a

nd re

desi

gned

cro

ss-s

ecto

ral A

nti-C

orru

ptio

n Fo

rum

(pre

viou

sly

the

Nat

iona

l Ant

i-Cor

rupt

ion

Foru

m)

Ant

i-Cor

rupt

ion

Inte

r-M

inis

teria

l Com

mitt

ee

July

201

6

4 In

tern

al g

over

nmen

t aw

aren

ess

rais

ing

• A

war

enes

s ra

isin

g of

the

proc

ess

with

oth

er g

over

nmen

t dep

artm

ents

thro

ugh

the

clus

ter s

yste

m.

Lead

dep

artm

ent

End

July

201

6

5 In

itia

l con

sult

atio

n w

orks

hops

•

Initi

al c

onsu

ltatio

n do

cum

ents

with

civ

il so

ciet

y, b

usin

ess

and

wid

er g

over

nmen

t.

• A

imed

at r

aisi

ng a

war

enes

s an

d ge

t buy

-in fo

r a th

orou

gh p

ublic

con

sulta

tion

proc

ess

that

will

follo

w

afte

r the

9 D

ecem

ber 2

016

laun

ch o

f the

con

sulta

tion

docu

men

t.

Stee

ring

Com

mitt

ee

Sept

embe

r 201

6

6 U

pdat

e th

e N

ACS

dis

cuss

ion

docu

men

t •

Prep

are

�nal

con

sulta

tion

docu

men

t, in

corp

orat

ing

inpu

t fro

m th

e th

ree

cons

ulta

tion

wor

ksho

ps.

• Pr

epar

e sh

ort s

umm

ary

of d

ocum

ent a

nd tr

ansl

ate

sum

mar

ies

into

all

o�ci

al la

ngua

ges.

Stee

ring

Com

mitt

ee a

nd

Publ

ic A

�airs

Res

earc

h In

stitu

te

Oct

ober

201

6

7 Fi

nalis

e an

ti-c

orru

ptio

n co

nsul

tati

on d

ocum

ent

• Pr

esen

t con

sulta

tion

docu

men

t to

Ant

i-Cor

rupt

ion

Inte

r-M

inis

teria

l Com

mitt

ee fo

r �na

l app

rova

l. Le

ad D

epar

tmen

t su

ppor

ted

by S

teer

ing

Com

mitt

ee

End

Oct

ober

201

6

8 In

form

Par

liam

ent,

the

Legi

slat

ures

and

Jud

icia

ry o

f the

pro

cess

•

Parli

amen

t, pr

ovin

cial

legi

slat

ures

, and

the

o�ce

of t

he C

hief

Just

ice

info

rmed

of t

he p

roce

ss.

• En

gage

with

the

Hou

se o

f Tra

ditio

nal L

eade

rs.

Stee

ring

Com

mitt

ee

Oct

ober

201

6

9 Pl

anni

ng fo

r the

laun

ch o

f the

con

sult

atio

n do

cum

ent

• Pl

anni

ng fo

r an

even

t whi

ch w

ill la

unch

the

wid

er c

onsu

ltatio

n pr

oces

s fo

r dev

elop

ing

a N

atio

nal A

nti-

Corr

uptio

n St

rate

gy fo

r Sou

th A

fric

a.

• In

volv

e bu

sine

ss a

nd c

ivil

soci

ety

in p

lann

ing

for t

he la

unch

.

Lead

Dep

artm

ent w

ith

supp

ort f

rom

Ant

i-Co

rrup

tion

Inte

r-M

inis

teria

l Com

mitt

ee

End

Nov

embe

r 201

6


• Re

activ

atio

n of

NA

CF o

r est

ablis

hmen

t of a

cro

ss-s

ecto

ral A

nti-C

orru

ptio

n Fo

rum

. •

Dev

elop

a d

etai

led

proc

ess

map

to s

uppo

rt p

lann

ing

(map

the

activ

ities

ass

ocia

ted

with

the

step

s ou

tline

d in

the

Road

map

for P

hase

s 2

and

3, p

rovi

ding

as

prec

ise

an e

stim

ate

as p

ossi

ble

of th

e tim

e ne

eded

to u

nder

take

thes

e ac

tiviti

es, a

nd p

reci

sely

how

they

sho

uld

be s

eque

nced

). 10

Re

leas

e of

the

Publ

ic C

onsu

ltat

ion

Doc

umen

t and

laun

ch o

f Pub

lic C

onsu

ltat

ion

Phas

e •

Expr

essi

ons

of s

uppo

rt b

y se

nior

bus

ines

s an

d ci

vil s

ocie

ty le

ader

s at

a p

ress

con

fere

nce

alon

gsid

e th

e M

inis

ter.

• St

atem

ent o

f int

entio

n to

revi

ve a

rest

ruct

ured

cro

ss-s

ecto

ral A

nti-C

orru

ptio

n Fo

rum

(pre

viou

sly

the

Nat

iona

l Ant

i-Cor

rupt

ion

Foru

m).

• G

CIS

to la

unch

maj

or c

oord

inat

ed c

omm

unic

atio

n ca

mpa

igns

nat

iona

lly a

nd in

pro

vinc

es, i

nclu

ding

a

web

pla

tfor

m.

• Co

ncur

rent

pro

vinc

ial l

aunc

hes

of P

ublic

Dis

cuss

ion

Doc

umen

t.

Iden

ti�ed

Cha

mpi

on

9 D

ecem

ber 2

016

Phas

e 2:

Pub

lic C

onsu

ltat

ions

Act

ivit

ies

Resp

onsi

bilit

y Ti

mel

ine

11

Pr

ovin

cial

info

rmat

ion

and

awar

enes

s se

ssio

ns

Hos

ted

by th

e O

�ce

of t

he P

rem

ier a

nd/o

r Pro

vinc

ial T

reas

ury

at p

rovi

ncia

l ant

i-cor

rupt

ion

or s

imila

r fo

rum

mee

tings

. CO

MM

ENT:

The

pro

vinc

ial w

orks

hop

(201

6-10

-13)

pro

pose

d th

at th

is c

ould

be

join

tly fa

cilit

ated

by

a Pr

ovin

cial

Ste

erin

g Co

mm

ittee

(OTP

, DPM

E D

CoG

, etc

.) or

the

Inte

grity

Man

agem

ent U

nits

. Ta

rget

aud

ienc

e:

• SA

LGA

gov

erna

nce

grou

p •

Busi

ness

cha

mbe

rs

• N

GO

um

brel

la b

odie

s/si

gni�

cant

NG

Os

• EC

OSO

C pr

ovin

cial

repr

esen

tativ

es

• Pr

ovin

cial

and

Loc

al G

over

nmen

t com

mun

icat

ion

stru

ctur

es

• Pr

ovin

cial

legi

slat

ure:

Cha

irper

sons

of a

ppro

pria

te c

omm

ittee

(s)

• O

ther

pro

vinc

ial d

epar

tmen

ts

• Pr

ovin

cial

gov

ernm

ent a

nti-c

orru

ptio

n co

ordi

natin

g fo

rum

s/st

ruct

ures

, whe

re th

ey e

xist

.

Lead

dep

artm

ent w

ith

the

supp

ort o

f the

NA

CS

Stee

ring

Com

mitt

ee

Janu

ary

2017

12G

ener

al a

war

enes

s-ra

isin

g ac

tivi

ties

/eng

agem

ents

• Br

oad-

base

d m

edia

cam

paig

n to

enc

oura

ge e

very

one

to p

rovi

de in

put.

• En

gage

men

ts a

t dis

tric

t and

loca

l lev

el.

• In

clus

ion

in e

xist

ing

depa

rtm

enta

l pla

ns/a

ctiv

ities

.

Janu

ary

to M

arch

201

7


• Co

nven

e a

wor

ksho

p w

ith o

vers

ight

and

regu

lato

ry b

odie

s on

mon

itorin

g an

d im

plem

enta

tion

of

the

stra

tegy

. M

inis

teria

l Com

mitt

ee

Nat

iona

l Ant

i-Cor

rupt

ion

Foru

m

16

Cons

olid

atio

n of

inpu

t and

dra

ftin

g of

NA

CS

• Te

chni

cal p

roce

ss.

• Po

ssib

ly in

clud

e pu

blic

feed

back

ses

sion

(or p

ublic

hea

ring)

to c

omm

ent o

n th

e co

nsol

idat

ed

docu

men

t.

Dra

ftin

g Te

am s

uppo

rted

by

NA

CS S

teer

ing

Com

mitt

ee

NA

CF/m

ulti-

sect

oral

team

June

201

7

13

Invi

tati

on fo

r sec

tor a

nd in

dust

ry s

peci

�c e

ngag

emen

ts (n

atio

nal a

nd p

rovi

ncia

l) Th

e �n

al n

umbe

r of e

ngag

emen

ts a

nd fo

rmat

s ar

e st

ill to

be

dete

rmin

ed. T

his

is to

be

base

d on

two

cons

ider

atio

ns:

1) C

ritic

al s

ecto

rs/in

dust

ries

that

mus

t be

cons

ulte

d, a

nd

2) E

xpre

ssio

ns o

f int

eres

t and

em

erge

nce

of s

take

hold

ers

base

d on

the

resp

onse

s to

the

med

ia/m

ass

com

mun

icat

ion

cam

paig

ns.

Targ

et a

udie

nce(

s):

• N

atio

nal d

epar

tmen

ts (x

1)

• G

over

nmen

t dep

artm

ents

in p

rovi

nces

(x9)

•

Prov

inci

al A

nti-C

orru

ptio

n/Et

hics

For

ums

(mul

ti-se

ctor

al) (

x9)

• Ke

y Se

ctor

s/In

dust

ries:

–

Loca

l gov

ernm

ent s

truc

ture

s an

d m

unic

ipal

ities

–

Trad

ition

al le

ader

s (C

ON

TRA

LESA

) –

Min

ing

– Co

nstr

uctio

n –

Educ

atio

n –

Labo

ur o

rgan

isat

ions

/ Tr

ade

unio

ns

– Pr

ofes

sion

al b

odie

s –

Busi

ness

sec

tor (

orga

nise

d an

d in

form

al)

– Ci

vil s

ocie

ty o

rgan

isat

ions

.

Lead

dep

artm

ent

Febr

uary

to A

pril

2017

PA

RI

Reco

mm

enda

tion

: Th

e tim

ing

allo

cate

d fo

r th

e se

ctor

al

cons

ulta

tions

nee

ds to

be

ext

ende

d to

at l

east

3

mon

ths,

and

in a

dditi

on

to th

is, a

mon

th sh

ould

be

incl

uded

(Jan

uary

20

17) t

o or

gani

satio

ns

logi

stic

s in

supp

ort o

f th

e co

nsul

tatio

ns n

ext

year

.

14

Subm

issi

ons

of w

ritt

en in

put t

hrou

gh e

lect

roni

c m

eans

/pla

tfor

m

• Po

litic

al p

arty

inpu

ts

Cons

olid

ated

doc

umen

t sen

t to

polit

ical

par

ties

and

rece

ive

writ

ten

inpu

t. •

Citi

zen

inpu

t (ad

ded

step

) To

be

sent

thro

ugh

to le

ad d

epar

tmen

t.

Lead

dep

artm

ent a

nd

Ant

i-Cor

rupt

ion

Inte

r-M

inis

teria

l Com

mitt

ee

Apr

il / M

ay 2

017

15

Cros

s-se

ctor

al c

onsu

ltat

ion

wor

ksho

ps

• Co

nven

e a

wor

ksho

p w

ith M

inis

ter a

nd h

igh-

leve

l gov

ernm

ent d

eleg

atio

n, b

usin

ess

and

civi

l soc

iety

le

ader

s to

ach

ieve

con

sens

us o

n w

hat t

he �

nal s

trat

egy

need

s to

incl

ude.

Lead

dep

artm

ent (

DPM

E),

NA

CS S

teer

ing

Com

mitt

ee,

Ant

i-Cor

rupt

ion

Inte

r-

May

201

7


Phas

e 3:

Fin

alis

atio

n of

the

NA

CS

A

ctiv

itie

s Re

spon

sibi

lity

Tim

elin

e 17

Fi

nalis

e a

Nat

iona

l Ant

i-Cor

rupt

ion

Stra

tegy

•

Dra

ft im

plem

enta

tion

plan

ass

igni

ng c

lear

role

s an

d re

spon

sibi

litie

s to

line

func

tion

depa

rtm

ents

, bu

sine

ss a

nd c

ivil

soci

ety.

•

Dra

ft a

mon

itorin

g an

d ev

alua

tion

plan

. •

Begi

n pr

oces

s of

ent

erin

g N

atio

nal A

nti-C

orru

ptio

n St

rate

gy in

to th

e ag

enda

in ti

me

for t

he n

ext

Cabi

net m

eetin

g af

ter A

nti-C

orru

ptio

n Ta

sk T

eam

or A

CIM

C ap

prov

al.

Dra

ftin

g te

am

Lead

dep

artm

ent

June

/Jul

y 20

17

18

Ant

i-Cor

rupt

ion

Inte

r-m

inis

teri

al C

omm

itte

e ap

prov

al o

f Nat

iona

l Ant

i-Cor

rupt

ion

Stra

tegy

•

App

rova

l of t

he �

nal d

ocum

ent b

efor

e be

ing

tabl

ed a

t the

nex

t Cab

inet

mee

ting

for �

nal a

ppro

val.

Lead

dep

artm

ent

end

July

201

7

19

Cabi

net a

ppro

val o

f Nat

iona

l Ant

i-Co

rrup

tion

Str

ateg

y •

App

rova

l of �

nal N

atio

nal A

nti-C

orru

ptio

n St

rate

gy.

Cham

pion

Fi

rst C

abin

et

mee

ting

afte

r Ant

i-Co

rrup

tion

Task

Te

am a

ppro

val

20

Dis

trib

ute

Nat

iona

l Ant

i-Cor

rupt

ion

Stra

tegy

•

Prin

t cop

ies

of �

nal n

atio

nal s

trat

egy

docu

men

t. •

Dis

trib

ute

the

docu

men

t acr

oss

the

coun

try

via

vario

us m

edia

.

Lead

dep

artm

ent

Imm

edia

tely

aft

er

Cabi

net a

ppro

val

21

LAU

NCH

of t

he �

nal N

atio

nal A

nti-

Corr

upti

on S

trat

egy

• La

unch

of t

he N

atio

nal A

nti-C

orru

ptio

n St

rate

gy.

• Be

ginn

ing

of im

plem

enta

tion.

Lead

dep

artm

ent

Cham

pion

20

17


Appendix B: Summary of programme elements under each strategic pillar

Anti-corruption interventions are commonly organised or reported under the themes of prevention, detection and enforcement. The table below shows which of these forms of intervention are incorporated under each pillar.

Strategic pillar Prevention Detection Enforcement Monitoring, evaluation and response1. Support citizen empowerment in the x x x �ght against corruption, including increased support for whistle-blowers. 2. Develop sustainable partnerships with x x x stakeholders to reduce corruption and improve integrity management. 3. Improve transparency of activity by the x x x government, business and civil society sectors. 4. Improve the integrity of the public x x x procurement system to ensure fair, e�ective and e�cient use of public resources. 5. Support the professionalisation of x x public sector employees in organs of state. 6. Improve adherence to integrity x x x x management mechanisms and consequence management in organisations across government, business and civil society sectors. 7. Strengthen oversight and x x governance mechanisms in the government sector. 8. Strengthen the structures for x x x enforcement: an independent, resourced, skilled, and coordinated multi-agency anti-corruption system. 9. Vulnerable sector management: build x x x x speci�c programmes to reduce corruption and improve integrity in sectors particularly vulnerable to corruption, with a focus on the JCPS Cluster.


Appendix C: United Nations guidelines on developing national anti-corruption strategies

The United Nations O�ce on Drugs and Crime has developed a high-level guide for developing anti-

corruption strategies. The UNODC notes that it is “important that the strategy contains a set of concrete

recommendations, rather than simply stating objectives in broad, abstract terms without connecting

them to any speci�c reforms or policy changes”. It also stresses that the programmes or actions proposed

should be linked to evidence that the approach adopted could plausibly impact on the nature of

corruption it seeks to address.

The UN report dedicates a chapter to monitoring and evaluating the strategy. It highlights the

importance of a strong monitoring and evaluation component to the strategy to support

implementation and institutional learning. The indicators should be very carefully developed to ensure

against indicator gaming in which organisations choose indicators that are easy to achieve, but do not

necessarily show substantive reform or progress on anti-corruption.

The United Nations Convention against Corruption calls for a range of actions against corruption that can

act as a (broad) guide for developing national anti-corruption strategies. These are:

(a) Strengthening anti-corruption law and law enforcement […].

(b) Implementing more e�ective measures to prevent corruption measures while reducing the

incentives and/or the opportunities for corruption. Such reforms might include:

(i) Measures to prevent corruption in the public sector, including through promotion of

integrity in public administration, strengthening public sector ethics, addressing

corruption risks in procurement and in the budgeting process and promoting

transparency and civic participation (articles 7 to 10 and 13); and

(ii) Measures to prevent corruption in the private sector, including transparency and

reporting measures, accounting controls and auditing (article 12).

(c) Establishing education programmes, publicity campaigns and awareness-raising initiatives

intended to change attitudes towards corruption, shift cultural norms and encourage reporting

(article 13).

(d) Bolstering institutional capacity, providing adequate training and ensuring the e�ectiveness,

autonomy and integrity of the government bodies that implement anti- corruption policy

(articles 6, 11, 36, 58 and 60).

(e) Improving both domestic and international coordination between law enforcement authorities

and other agencies responsible for combating corruption, as well as between the public and

private sectors (articles 37 to 39 and 43 to 50).

(f ) Enhancing the collection and analysis of data and other information on corruption, in order to

address uncertainties and knowledge gaps (article 61).

Reproduced from: United Nations O�ce on Drugs and Crime. 2015. ‘National Anti-Corruption Strategies: A Practical Guide for Development and Implementation.’ United Nations O�ce on Drugs and Crime, Vienna

Department of Planning, Monitoring and EvaluationADDRESS:

330 Grosvenor StreetPentagon House

Hat�eld, Pretoria, 0028Telephone: 012 312 0000

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