www.csd.bg
Monitoring anticorruption
policy implementation (MACPI)
Monitoring Anti-Corruption in Europe: Bridging Policy Evaluation and
Corruption Measurement (MONAC)
With the financial support of the
Prevention and Fight against Crime
Programme, European Commission,
Directorate-General Home Affairs
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Identification of two types of gaps in
anticorruption policies/measures:
Implementation
gap
Policy design
gap
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Levels and content of anticorruption
policies
Policies/measures at public organization level
General and specific rules for operation in concrete situations
National policies
Standards (protocols) for the operation of the administration
Macro level policies
Principles of governance
Assessed by
MACPI
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� Anticorruption policies at macro level are related to political
choice (elections)
� National policies can be implemented only if adequately
translated into policies/measures at the level of public
organisations
� At the public organization level anticorruption policies/measures
would be effective if they:
� Address real risks and vulnerabilities (adequacy)
� Have rational/optimal design (implementability)
� Induce both formal and real compliance (implementation)
� Reduce corruption pressure
Assumptions
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MACPI anticorruption policy
assessment indicators
Assessment of activities
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(1) Corruption
interest� Reflects the theoretical
possibility (sense) of corruption
transactions of different types
associated with specific
activities of the public
organisation
� Helps identify corruption
vulnerability zones
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Assessment of corruption vulnerability (risk)
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(2) Corruption pressure
and involvement in
corruption
(results at national and public
organization level)
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Direct measurement of cases of corruption pressure and
involvement in corruption (general population, Bulgaria)
28,7
23,4
17,4 20,3
15,0
15,1
16,4
14,8 16,5
17,2
14,5
9,6
9,4
14,3
13,6
29,3
18,6
34,2
31
22,6
27,5
22,8
22,1 25,2
20,3
21 21,4
18,3
12,4 14,4
20,6
18,8
39,4
27,7
0,0
5,0
10,0
15,0
20,0
25,0
30,0
35,0
40,0
45,0
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
% of the population 18+, who have extended an informal payment or have been
asked to make and informal payment (money, gift favour)
Involvement in corruption Corruption pressure
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Prevalence of corruption pressure(officials and general population)
32%
28%
17%
0%
5%
10%
15%
20%
25%
30%
35%
Slatina municipality, Sofia General population 18+ Border police, Bulgaria
% officials and citizens reporting existence
of corruption pressure (2015)
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Prevalence of corruption pressure among officials
32%
17%
14%
6%
0%
5%
10%
15%
20%
25%
30%
35%
Slatina municipality,
Sofia
Border police, Bulgaria Health service, Trento Riva del Garda, Italy
Share of officials who have been offered a bribe
at least once in the last year (2015)
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General and specific indicators for assessment of
activities
General
indicators
Specific
indicators
Content/interpretation
Corruption
interest
Existence of interest
for basic types of
corruption
transactions
Reflects the principle interest and practical
feasibility/sense of select types of corruption
transactions, given the situation in the country and
the organisation.
Corruption
pressure
Evasion of
regulations
Share of officials who gave above average score on
how many individuals/companies (clients) try to
circumvent the rules in this activity.
Outside pressure
associated with
activity
Share of those who answered that there is some
level of outside corruption pressure in this activity.
Susceptibility to
pressure from above
Share of officials who consider it likely that
employees would perform illegitimate activities if
ordered by a superior.
Susceptibility to
pressure from
outside
Share of officials who consider it likely that
employees would accept or ask for a bribe associated
with activity.
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Corruption vulnerability of activities (Border Police,
Bulgaria)
ActivitiesCorruption
interestCorruption pressure
Theoretical
possibility of
corruption
(0 - 100%)
Evasion of
regulations
(0 - 100%)
Outside
pressure
(0 - 100%)
Suscepti
bility to
pressure
form above
(0 - 100%)
Suscepti
bility to
pressure
form outside
(0 - 100%)
Administrative and
punitive75 33,3 53,8 19,2 23,1
Public procurement 75 30 55,2 27,6 20,7
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MACPI indicators for
assessment of anticorruption
policies/ measures
Assessment of policies/
measures
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Summary: MACPI indicators for assessment of
anticorruption policies/ measures
General
indicators
Specific indicators Content /interpretation
Implementability Ease of
implementation
Share of officials evaluating the policy as “very/rather
easy to implement.”
Difficult to evade Share of officials considering the policy difficult to
evade.
implementation Awareness Share of officials who agree that the policy is well-
known to the employees whom it concerns.
Strict implementation Share of officials who agree that policy is strictly
applied.
Strict control Share of officials who think that control is strictly
applied.
Strict application of
sanctions
Share of officials who think that sanctions are always
applied in cases of violation of the policy.
Estimated
effectiveness
Estimated potential
effectiveness
Share of officials who think that the implementation
of this policy “could reduce cases of corruption.”
Estimated actual
effectiveness
Share of officials who think that this policy “reduces
corruption risk.”
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MACPI assessment of anticorruption policies (Border
police, Bulgaria)
Policies/ measures Implementability
Implementation
EffectivenessFormal
compliance
Real
compliance
Ea
se o
f
imp
lem
en
tati
o
n (
%)
Dif
ficu
lt t
o
eva
de
(%
)
Aw
are
ne
ss (
%)
Str
ick
imp
lem
en
tati
o
n (
%)
Str
ict
co
ntr
ol
(%)
Str
ict
ap
pli
cati
on
of
san
ctio
ns
(%)
Est
ima
ted
po
ten
tia
l
eff
ect
ive
ne
ss
(%)
Est
ima
ted
act
ua
l
eff
ect
ive
ne
ss
(%)
Declarations of assets and
incomes95,1 71,3 93,9 91,1 63,1 59,3 73,1 66,5
Control by direct
supervisors of the
declarations of their
subordinates.
93,6 72,9 91,2 88,8 59,8 51,2 73,1 68,7
….
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MACPI architecture
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Qualitative
diagnostics
Quantitative
diagnistics
Policy
analysis
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MACPI indicators and methods
Indicators Desk
research
In-depth
interview
MACPI
online
MACPI general
population/
stakeholders
Corruption interest Х Х Х
Corruption pressure Х Х
Involvement in corruption Х
Corruption attitudes Х
Corruption reputation of sectors/
officials
Х
Implementability of AC policies Х
Implementation of AC policies Х
Estimated effectiveness of AC policies Х
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MACPI implementation cycle
Anticorruption policy analysis
Design and implementation of new/adjusted
policies
MACPI diagnоstic scan
MACPI benchmarking
scan
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MACPI pilot test
implementation results
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Corruption pressure trend in time
(What we currently have)
0
5
10
15
20
25
30
35
2015 2016 2017 2018 2019 2020 2021 2022
Corruption pressure for the different activities in
Institution X
Activity 1
Activity 2
Activity N
NEW
anticorruption
policies
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MACPI: other possible usage
Types of comparisons:
� Current AC policies’ scores and the ideal values
� Corruption vulnerability for the different activities of the
organization
� Existing AC policies’ scores (and their components –
Implementability, Implementation, Effectiveness)
� Between similar institutions
� Between different groups – employees with and without
management functions, external experts, etc.
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Bulgarian Border Police
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Assessment of the corruption
vulnerability of the activities:
COMPARISON BETWEEN ACTIVITIES; COMPARISON WITH THE IDEAL VALUES
BULGARIAN BORDER POLICE
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Corruption vulnerability of activities
Border Police Bulgaria, pilot MACPI assessment
ActivitiesCorruption
interestCorruption pressure
Border Police Bulgaria
Types of
corruption
possible
(0 - 100%)
Evasion
of
regulations
(0 - 100%)
Outside
pressure
(0 - 100%)
Susceptibility
to pressure
form above
(0 - 100%)
Susceptibility
to pressure
form outside
(0 - 100%)
Administrative and punitive 75 33 54 19 23
Border checkpoints 50 21 41 7 15
Green border security 75 27 33 9 10
Human resources 75 13 41 9 0
Information activities 25 25 33 19 17
Preventive investigation 50 27 52 10 14
Public procurement 75 30 55 28 21
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Corruption vulnerability
16%
20%
21%
23%
26%
32%
33%
0% 20% 40%
Human resources
Green border security
Border checkpoints
Information activities
Preventive investigation
Administrative and punitive
Public procurement
Average corruption pressure for the different activities
Ideal
zone
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Average
Pressure
Sp.
ACP
1
Sp.
ACP
2
Sp.
ACP
3
Sp.
ACP
4
Sp.
ACP
5
Gen.
ACP
6
Gen.
ACP
7
Gen.
ACP
8
Gen.
ACP
9
Gen.
ACP
10
Gen.
ACP
11
Gen.
ACP
12
Human resources 16% Y Y Y Y Y Y Y Y
Public
procurement33% Y Y Y Y Y Y Y
Preventive
investigation26% Y Y Y Y Y Y Y
Green border
security20% Y Y Y Y Y Y Y Y Y
Information
activities23% Y Y Y Y Y Y Y
Border
checkpoints 21% Y Y Y Y Y Y Y Y Y Y Y
Administrative and
punitive32% Y Y Y Y Y Y Y
Corruption vulnerability:
Average corruption pressure and coverage with specific
and general anticorruption policies (ACP)
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Assessment of the implementation of
anticorruption policiesCOMPARISON BETWEEN AC POLICIES; COMPARISON WITH THE IDEAL VALUES
BULGARIAN BORDER POLICE
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70%
83%
75%
77%
83%
78%
82%
79%
83%
85%
81%
86%
83%
90%
87%
84%
93%
91%
86%
85%
86%
89%
89%
90%
49%
56%
50%
45%
61%
52%
47%
49%
48%
52%
53%
63%
80%
71%
85%
88%
70%
82%
84%
88%
88%
88%
92%
91%
0% 100% 200% 300% 400%
Issuance of additional orders and instructions
Direct superiors have to read and sign asset
declarations
Interviews with passengers and illegal
immigrants
Measures for inspection and testing of job
applicants
Declarations of assets and incomes
Rotation
Information campaigns among staff
Anticorruption training of personnel
Information campaigns among the citizens
Unannounced visits
Video surveillance
Immediate reactions to each signal for corrupt
behaviour
Assessment of AC policies
Implementability
Implementation
(Formal compliance)
Implementation
(Real compliance)
Effectiveness
Ideal
zone
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Assessment of AC policies in Border Police
Results and conclusions
Results:
� Control and sanctions have relatively low scores for all policies
� Asset declarations are the most implementable and most strictly
implemented AC policy but at the same time – the least effective
General Conclusions:
� Asset declarations could become more effective (improve scope and
control)
� A more detailed analysis by the organisation experts is needed
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Comparison between Bulgarian and
Italian public organizations
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MACPI AC policy assessments in Bulgarian and
Italian public organizations
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Slatina
Municipality,
Bulgaria
Border Police,
Bulgaria
Municipality of
Riva del Garda,
Italy
Health Service of
Trento, Italy
Implementability of AC policies
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MACPI AC policy assessments in Bulgarian and
Italian public organizations
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
Slatina
Municipality,
Bulgaria
Border Police,
Bulgaria
Municipality of
Riva del Garda,
Italy
Health Service of
Trento, Italy
Implementation of AC policies
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MACPI AC policy assessments in Bulgarian and
Italian public organizations
0%
20%
40%
60%
80%
100%
120%
Slatina
Municipality,
Bulgaria
Border Police,
Bulgaria
Municipality of
Riva del Garda,
Italy
Health Service of
Trento, Italy
Estimated effectiveness of AC policies
www.csd.bg
32%
17%
6%
14%
0%5%
10%15%20%25%30%35%
Slatina Municipality,
Bulgaria
Border Police,
Bulgaria
Municipality of Riva
del Garda, Italy
Health Service of
Trento, Italy
% employees who have been offered a bribe in the previous year
0%
10%
20%
30%
40%
50%
Slatina Municipality,
Bulgaria
Border Police, Bulgaria Municipality of Riva
del Garda, Italy
Health Service of
Trento, Italy
Corruption Pressure for different activities
MACPI AC policy assessments in Bulgarian and
Italian public organizations
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Institutional Patriotism
8,6%10,2%
24,4%
21,1%
0%
5%
10%
15%
20%
25%
30%
Municipality of
Riva del Garda,
Italy
Health Service of
Trento, Italy
Slatina
Municipality,
Bulgaria
Border Police,
Bulgaria
Share of the “institutional patriots”
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Thank you
