End of Commitment Report – Establishment of an Integrity System

Name of Evaluator

Anahit Gharibyan

Email

anagharibyan@gmail.com

Member Name

Yerevan, Armenia

Action PlanAction plans are at the core of a government’s participation in OGP. They are the product of a co-creation process in which government and civil society jointly develop commitments to open governmen... Title

Action plan – Yerevan, Armenia, 2023 – 2024

CommitmentOGP commitments are promises for reform co-created by governments and civil society and submitted as part of an action plan. Commitments typically include a description of the problem, concrete action...

Establishment of an Integrity System

Problem

The effective operation of the Ethics Officer and the Ethics Committee is important from the point of view of the full institutionalization of the ethics and integrity system in Yerevan Municipality, which is in line with the paragraph 3.16. Full institutionalization of the ethics and integrity system in the State system of Appendix 2 (Pillar 3: human resource management and public service) of the RA Government’s May 13, 2022 Decision No. 691-L

1.1 What was the overall level of progress in the commitment implementation at the time of this assessment?

Substantial

Provide a brief explanation of your answer:

In general, the commitment has achieved its main goal to some extent. Although it initially had a more comprehensive plan, significant changes were made during its implementation to facilitate progress.
The most significant progress represents the steps taken towards the establishment of that body, raising awareness about the integrity issue among community servants, and adopting the Code of Conduct for Community Workers.
In particular, the results of pre-testing and post-testing of the capacity-building courses show that the tests, which were completed anonymously, have indicated positive progress in the mastery of knowledge among community servants.
Interdepartmental contacts that arose during the implementation of the commitment are also significant achievements. Due to the commitment, it became possible to conduct interdepartmental discussions on Integrity, contributing to the reinvigoration of the topic and ensuring the continuity of the commitment.

Provide evidence that supports and justifies your answer:

In-depth interviews:

1. Arsen Manukyan – Team leader, USAID’S Armenia Integrity project
2. Natali Mkrtchyan – USAID’S Armenia Integrity project
3. Syuzanna Soghomonyan – Program Coordinator at the Armenian Lawyers Association
4. HPM Department of Yerevan Municipality
5. Meri Harutyunyan- Yerevan Municipality/ Deputy Head of the Department of Development and Investment Programs
6. Tigran Mughnetsyan – TransparencyAccording to OGP’s Articles of Governance, transparency occurs when “government-held information (including on activities and decisions) is open, comprehensive, timely, freely available to the pub... More International Anticorruption Center

Website article: “Rules of conduct will be developed for community servants, including the introduction of an Integrity institute”

1.2 Describe the main external or internal factors that impacted implementation of this commitment and how they were addressed (or not).

In the initial stages of the development of the commitments, the second commitment had a more ambitious plan, but subsequent revisions enabled the completionImplementers must follow through on their commitments for them to achieve impact. For each commitment, OGP’s Independent Reporting Mechanism (IRM) evaluates the degree to which the activities outlin... More of the planned activities.
Specifically, the initiative’s background arises from the necessity to establish an Integrity institute introduced in 2018, connected to various external and internal factors.
The adoption of the code of conduct for community workers, which includes several provisions related to integrity, has had a positive impact on the commitment. Additionally, the inclusionOGP participating governments are working to create governments that truly serve all people. Commitments in this area may address persons with disabilities, women and girls, lesbian, gay, bisexual, tr... More of provisions regarding the acceptance of gifts in the amendment to the law on community service has clarified the introduction of the system and the implementation of the anti-corruption policy. Interdepartmental contacts with officials from the Corruption Prevention Commission and the Open Government PartnershipThe Open Government Partnership (OGP) is a multi-stakeholder initiative focused on improving government transparency, ensuring opportunities for citizen participation in public matters, and strengthen... More project at the national level, along with all the training sessions conducted among community servants, have also had a positive impact.
The external factors affecting the fulfillment of the obligation pertain to the overall security of the country and the socio-psychological problems of the population. The holding of electionsImproving transparency in elections and maintaining the independence of electoral commissions is vital for promoting trust in the electoral system, preventing electoral fraud, and upholding the democr... More, political instability, and frequent changes of positions have also had a certain impact. Because of the mayoral elections, the planned courses among high-ranking officials of the municipality have been partially postponed and have not been implemented until now.
At the same time, the negative factors that significantly affected the fulfillment of the commitment are more of an internal institutional nature. In particular, the change in the position of the person responsible for the performance of the commitment was the primary factor, but it occurred near the end of the commitment’s execution.
However, interviewees from the municipality state that in the last two months, the planned operations were left incomplete due to the change in the responsible person.

1.3 Was the commitment implemented as originally planned?

Most of the commitment milestones were implemented as planned.

Provide a brief explanation of your answer:

The implementation of the commitment has significantly deviated from the initially planned action plan. The responsible person for the commitment was the head of the HR Department of the Municipality, and the commitment was fulfilled with the financial and professional support of the USAID Integrity Armenia project.
Although a small number of meetings were held with CSO representatives, they did not have any influence or participation in the fulfillment of the commitment. The reason, according to representatives of the Integrity Armenia project team, was due to the specifics of the program and the necessity not to direct the participation of any organization and to maintain neutrality.
On the other hand, the Municipality also attempted to involve all parties participating in the process but did not compel their participation in any commitment. However, this approach caused CSO representatives, who could have contributed significantly to the commitment, to feel neglected and isolated.

2.1.1. – Did the government disclose more information; improve the quality of the information (new or existing); improve the value of the information; improve the channels to disclose or request information or improve accessibility to information?

Yes

Degree of result:

Marginal

Explanation: In narrative form, what has been the impact on people or practice.

Public discussions on the establishment of the Integrity system have taken place, but experts note that the frequency and dissemination of these discussions are not sufficient to yield more tangible results. In particular, representatives of civil society organizations (CSOs) participated in some meetings after being informed about the process but did not engage in any other meetings or awareness activities.
Although the municipality distributed the Code of Conduct for Community Servants among the beneficiaries (i.e., employees), experts interviewed find that not all community servants are aware of it. According to the experts, municipal employees frequently make inquiries and seek clarifications regarding its implementation. The same challenges extend to the entire process of introducing the Integrity system and the topics covered during the courses.
Nevertheless, for the sessions conducted within the community servant circle, participants were mainly chosen based on the nature of their work, emphasizing those with more direct contact with citizens and a closer relationship with them.
The other aspect that also had a minimum impact is related to the ingrained ideas, personal qualities, and professional abilities among community servants. In other words, the culture of integrity is still unfamiliar to community workers, and changing their thinking and consequently, their behavior requires significant effort. Speaking up and reporting through the Whistle-blowing system during the training were also viewed negatively because many believe that transmitting and reporting information about the behavior and work of other employees creates tension in the work environment. It can also impact the overall working atmosphere and trust in the workplace, potentially leading to a higher level of personnel turnover and a crisis of confidence in the state system.
However, the same integrity system that was discussed and presented during the training also had another positive effect on community workers – it is about protecting their rights and interests. By becoming familiar with the Integrity specialist position, some workers are able to assert their rights and resolve laborTransparent workforce data and increased representation of workers in labor policy-making lead to policies that better protect workers’ rights and remove barriers for underrepresented groups in the ... disputes. In other words, as the employees of the HRM department of the municipality say, they learn to advocate for their rights and speak out about emerging problems concerning integrity.
On a positive note, the course also had a significant impact on the topics of conflict of interest and acceptance of gifts. According to the integrity officer, many community workers were previously unaware but showed great interest in these issues to apply them in their work.
In this regard, the adoption of the code of conduct for community servants has had a positive impact. Many individuals, possessing the code, find the implementation of the Integrity system in community service more understandable and applicable.
Another internal issue pertains to the inflexibility of community workers and their challenges in accepting provided information. The problem lies in the fact that most community workers, who underwent the course, are primarily middle-aged men with different perspectives on their work. They operate with the inertia of the Soviet years and are largely guided by those values and principles. In other words, according to representatives of the municipality, accepting gifts is considered a gesture of attention and unrelated to corruption. Similarly, the Whistle-blowing system and the reporting on corruption cases are perceived as betrayal and a detrimental practice of reporting on colleagues. In such instances, the only solution is to consistently educate or bring about a generational change in the system, which, according to representatives of the municipality, is challenging to implement in the current conditions.
The next issue was uncertainty regarding inter-departmental powers related to the approval of the code of conduct for community workers by the Ministry of Territorial Administration.
The issue was that, according to the municipality employee, the Ministry was uncertain about who should approve it – themselves or the Corruption Prevention Commission – as the rulebook had to be developed based on the Commission’s model.
The project team notes that due to the uncertainty created, the project was implemented intermittently, primarily stemming from issues with the commission. That is when the municipality undertook the commitment, it did not engage in discussions with the Commission, or they did not obtain their agreement. Since the primary executor in the public administrative reform/law was the Commission for the Prevention of Corruption, which mandates the introduction of integrity in the public service sector as the executor, based on this, they claimed that everything happening in the integrity institute should be coordinated with them.
The program team did not object to the Commission having leadership in this program, but discussions delayed the process. Additionally, the absence of the Ethics Commission is also an obstacle, which, although planned to be established by the 2nd commitment of OGP, was not possible to form due to the uncertainty and underdevelopment of the legislative field.

2.1.2. – Did the government create new opportunities to seek feedback from citizens/enable participation inform or influence decisions; improve existing channels or spaces to seek feedback from citizens/enable participation/ inform or influence decisions; create or improve capabilities in the government or the public aimed to improve how the government seeks feedback from citizens/enables participation/ or allows for the public to inform or influence decisions?

Yes

Degree of result:

Marginal

Explanation: In narrative form, what has been the impact on people or practice.

The commitment did not imply or aim to disseminate information among citizens about the introduction of the Integrity system. Instead, the municipality had committed in the past to educate staff working directly with citizens, imparting knowledge on polite behavior and presentable and pleasant communication.
In meetings with CSO representatives, there was a suggestion to provide separate contact information on the web page of the municipality for an Integrity specialist for external whistle-blowing notifications. However, the municipality rejected the suggestion, citing no legal requirement to submit the specialist’s contact information. The justification for this decision is that the municipality’s call center and one-stop reception for citizens can be used for this task. Many citizens submit numerous applications and complaints regarding the lack of courtesy and politeness of municipality employees, which are documented and examined by the HRM department. Moreover, fines and disciplinary investigations are established if necessary, based on the provisions related to good behavior outlined in the code of conduct for community servants.
Additionally, HRM department employees mentioned that in the process of implementing the commitment to Integrity system establishment, they regularly monitor the social networks of community workers. Upon detecting certain violations, such as political appeals, etc., corresponding screenshots are taken, and if there is sufficient evidence, a disciplinary penalty is imposed on the relevant employee, up to dismissal. There is also an internal whistle-blowing system through which employees can directly contact the Integrity organizer, expressing their concerns and presenting existing problems.
Due to the Mulberry system, municipality employees were informed about the adoption of the code of conduct through circulars sent to everyone. However, this entire awareness process was conducted through existing mechanisms, and the municipality did not create additional platforms or mechanisms to collect feedback from citizens on employee behavior. During this period, the logic of the call center’s operation was simply changed, which, in fact, was not directly related to the performance of the commitment, but the general external notification system was slightly improved.

Provide evidence for your answer:

• Agenda – Training Course for Municipal Servants 

2.1.3 Did the government create or improve channels, opportunities or capabilities to hold officials answerable to their actions?

Unclear

Degree of result:

Marginal

Explanation: In narrative form, what has been the impact on people or practice.

As was mentioned earlier, during the performance of the task, there were suggestions by Transparency International Anticorruption Center to have the contact information of the Integrity specialist on the webpage for external reporting, but the suggestion was rejected. This rejection was based on the absence of such a requirement in the law, the scarcity of individuals occupying that position, and the current lack of resources to manage the received information and coordinate the work.
Within the framework of the commitment, separate activities were not carried out among high-ranking officials and decision-makers, although they were planned. According to the organizer of Integrity issues, they do not have enough leverage and privileges to hold responsible individuals in cases of violation of integrity matters or the rules of conduct of decision-makers. This limitation exists because, in order to have such influence, people with a very high position and authority are needed, who will have enough independence and leverage to act freely.
In the lower echelons, complaints about behavioral problems are not widespread, and they are rarely received. However, the resolution of problems in the lower echelons is episodic, as there is no unified approach and body to examine exemplary cases. The current approach is limited to disciplinary sanctions.
According to representatives of the municipality, a significant change in the lower levels was the targeted courses. They conducted an offline Training of Trainers among HRM officials from 12 municipalities in Yerevan. These officials were then tasked with spreading the knowledge and information they received to the staff of the administrative districts. The municipality’s employees emphasize that the need for the Institute of Integrity is now recognized in the administrative regions. While it may not be possible to have such a responsible employee in every district, continuous training can significantly influence the establishment of the Integrity Institute.
Within the framework of the courses, the Whistle-blowing System was presented, focusing on the use of digital tools as a means to hold decision-makers responsible. Electronic resources operating and available in Armenia were also introduced, viewed by project implementers as tools to limit corruption mechanisms and prevent corruption. The presentation of these digital tools in the field of public service has been crucial in fulfilling this commitment. However, during capacity buildingEnhancing the skills, abilities, and processes of public servants, civil society, and citizens is essential to achieving long-lasting results in opening government. Technical specifications: Set of ac..., one of the challenges was the high staff turnover among the participants of the courses, which, according to municipality representatives, has recently reached a very high level. Often, any member who participated in the training and was approached by community servants with questions had already been fired, resulting in the loss of institutional memory and resources.
Experts also highlight the issue that the law on community service is still from 2005, and there’s a gap in reality regarding the formation of ethics commissions, despite changes in the Public Service Law of 2018. Last year, changes were made in the new community service law, specifying which body is responsible for violations related to ethics, examining the cases, and providing an appropriate assessment.
In this regard, according to the donor organization, it is necessary to establish a management system for integrity issues in the field of community and public service. The first stage of this system is capacity building, conducted within the framework of this commitment. The next step involves developing a toolkit for checking behavior and recording problems. There should also be a body with the authority to investigate arising cases. This body can be formed on a one-time basis, similar to the current practice in the civil service field. In other words, whenever a case arises, an ethics committee should be formed immediately. Therefore, a permanent functioning ethics commission is not required; it should be created based on alarms.
Additionally, a monitoring system should be established by integrity organizers, who, unfortunately, may lack the necessary professional and personal qualities for various reasons. These organizers should raise the issues, and the system should initiate action. Integrity organizers should also compile statistics indicating how many cases were recorded in the structural departments. Ongoing capacity-building training should be conducted as needed, and e-resources on integrity should be created to enable community servants to constantly check for gifts, conflicts of interestA key part of anti-corruption involves preventing or revealing conflicts of interest — when a public official is in a position to use public office for personal or private gain. Technical specificat..., etc. Thus, new digital tools will be necessary for this purpose.
There was a suggestion to provide municipal employees with a questionnaire upon hiring, which would be kept in their personal files. This questionnaire would inquire about various aspects, such as gambling habits or other tendencies. However, this suggestion is not aligned with the legislative framework, as stated by the donor organization, since the Corruption Prevention Commission conducts behavior checks for officials in a distinct group, obtaining official conclusions for further advancement. Representatives of the donor organization stated that these suggestions could not be implemented within the commitment’s framework due to tight deadlines, legal restrictions on system implementation, as well as insufficient personal qualities of the employees and limited resources.
During the commitment implementation, coordinating across various state departments proved to be a significant challenge, taking months to resolve. The scarcity of interdepartmental contacts and limited communication among state bodies has led to many state officers being unaware of the multitude of parallel projects, resulting in occasional project repetitions. In this regard, the exchange of experience is vital for balanced development. Thus, the inefficiency of interdepartmental cooperation results in incomplete project executions and unnecessary delays.

2.1.4 Other Results

Yes

Degree of result:

Marginal

Explanation: In narrative form, what has been the impact on people or practice.

Assessments were conducted at the beginning and end of the course, and the results indicate that the vast majority of participants have mastered the material. Compared to the first and second courses, the evaluations of the participants increased from 10 to 14, showing an increase of 4 points. The components of the course were rated as 90 percent effective for various standards. Specifically, 71 percent of the participants gave a maximum of 5 points, and 17 percent gave 4 points. The total number of participants in the first round was 25, and the training of trainers was conducted among 18 people. According to the program implementers, an additional outcome was the establishment of interdepartmental contacts and connections, providing community servants with opportunities to invest their efforts in the field of Integrity collaboratively. Furthermore, these meetings helped identify ongoing programs, detect repetitions, and optimize resource utilization to avoid duplications.
Raising awareness of the fundamental components and principles of the Integrity system is an added benefit. The program not only aimed to build capacity but also successfully generated interest in the field, according to the program team. Practical examples and topics regarding the conflict of interests and the prohibition of receiving gifts were presented in detail during the active lectures held among community servants. This was significant, considering the lack of ideas and knowledge among community servants about anti-corruption measures.
Secondly, the mandate and activities of the Corruption Prevention Commission were popularized, making the commission more recognizable to community servants as a newly created body. Additionally, the perception of corruption has shifted among community workers. Previously seen as a crime or something related to the work of an investigative committee, it is now viewed differently. Consequently, the work of partner structures has become more visible.

2.2 Did the commitment address the public policy problem that it intended to address as described in the action plan?

Yes

Provide a brief explanation of your answer:

In general, CSO representatives consider this commitment to be one of the most crucial for Yerevan Municipality. The significance is evident through public perceptions, stereotypes, and prejudices about the municipality. These negative perceptions are often objectively justified, supported by various research and the opinions of CSO representatives regularly engaged in the municipality’s work. On the other hand, the transparency and open government of the municipality’s work within the framework of the OGP are directly linked to the introduction of anti-corruption policy and the active implementation of anti-corruption measures. Therefore, the implementation of the Integrity system, directly related to these measures, addresses one of the most serious problems in public policy: the integrity of officials, the open and informal working style, and the establishment of the Integrity Institute.

3. Provide at least one lesson or reflection relating to the implementation of this commitment. It can be the identification of key barriers to implementation, an unexpected help/hindrance, recommendations for future commitments, or if the commitment should be taken forward to the next action plan.

One of the most important lessons learned is that the Integrity organizer, who is involved in other work besides managing the integrity of the staff, struggles to fulfill the responsibilities of the position due to the total number of community workers exceeding 2000. As a solution, a suggestion was made to either create an ethics committee or increase the number of specialists responsible for this area. Some expressed the view that the formation of an Ethics Commission is urgent, but there are still insufficient legal grounds for its creation, including its composition, participants, and operational basis.
Despite the workload, representatives of the municipality point out that the position lacks sufficient leverage and mechanisms to influence the establishment of the overall Integrity system. Currently, there are no effective mechanisms to handle Integrity issues and reports received by staff. The organizer of integrity issues raises this concern, asserting that the chief specialist is not adequately equipped to address such problems. As a result, there is a belief that the organizer of integrity issues should either hold a higher position or be an independent body to influence the behavior of higher echelons and officials.
This cultural challenge is compounded by the fact that official classification does not empower a specialist in a lower position with broad powers to hold superiors accountable. Conversely, this classification restricts the person in charge, limiting their ability to act independently and freely.
Simultaneously, the changes should set a precedent among high-ranking officials so that the lower echelon, witnessing integrity from superiors, can follow suit. Therefore, representatives of the municipality believe there is an urgent need for training for high-ranking personnel of the municipality.