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Title page 1
Contents 7
Foreword 4
Acknowledgements 5
Executive summary 12
1. Towards an integrity system in the Dominican Republic 16
1.1. Introduction 17
1.1.1. Strengthening the integrity system can make the Dominican Republic more resilient and prepared to face recent and... 18
1.1.2. The regulatory framework of the Dominican Republic for integrity has been strengthened but some gaps remain and... 21
1.2. Strengthening the governance and the co-ordination of the integrity system 24
1.2.1. The Dominican Republic should strengthen the DIGEIG by establishing it through a law with safeguards for its independence and... 24
1.2.2. The Dominican Republic could strengthen and institutionalise the Presidential Transparency and Anti-Corruption Commission (CPTA)... 26
1.2.3. The Dominican Republic could establish a technical working group to improve co-ordination and co-operation between... 30
1.3. Ensuring the implementation of integrity policies throughout the public sector 31
1.3.1. The Dominican Republic could strengthen the Government Integrity and Regulatory Compliance Commissions transforming them... 31
1.3.2. The DIGEIG could empower the CIGCN, or the new integrity units, as the main institutional channel for public servants to seek... 35
1.3.3. The DIGEIG could promote and support the implementation of integrity measures in local administrations 37
1.4. Ensuring a strategic approach to strengthening public integrity 40
1.4.1. The Dominican Republic could develop a first national integrity strategy to set strategic goals and foster co-ordination between... 41
1.4.2. The DIGEIG should promote and co-ordinate the implementation of an integrity strategy via a monitoring system,... 42
1.4.3. The Dominican Republic could improve its evidence base for the monitoring and evaluation of integrity policies 45
1.5. Proposals for action 47
References 48
2. Improving conflict-of-interest management 54
2.1. Introduction 55
2.2. Developing a comprehensive framework for identifying and managing conflict of interest 58
2.2.1. The Dominican Republic could clearly define key concepts such as real, potential and perceived conflict of interest, and private interest 60
2.2.2. The Dominican Republic could establish specific obligations for public officials to declare their private interests and manage their... 62
2.2.3. The Dominican Republic could define clear institutional responsibilities for the conflict-of-interest management system,... 64
2.2.4. The Dominican Republic could ensure that sanctions for breaches of the conflict-of-interest obligations are defined and... 66
2.2.5. The Dominican Republic could establish measures to mitigate integrity risks and manage conflict of interest on pre- and... 67
2.2.6. The Dominican Republic could establish further provisions to ensure implementation and enforcement of gift and gratuities management 73
2.3. Strengthening the asset declarations system for effective detection 74
2.3.1. The Dominican Republic could include advisors in the list of individuals subject to the obligation to declare their assets 75
2.3.2. The Dominican Republic could strengthen efforts to ensure that the Chamber of Accounts receives updated information on... 75
2.3.3. The Dominican Republic could introduce a periodic asset declaration during the term of office 76
2.3.4. The Chamber of Accounts could develop a handbook and guidelines to help individuals subject to the obligation to declare in... 77
2.3.5. The Chamber of Accounts could strengthen processes for the submission, verification, inspection and control of asset declarations 78
2.3.6. The Chamber of Accounts could publish in open data format the non-confidential section of the asset declarations of public officials 81
2.4. Proposals for action 82
References 83
3. Strengthening a culture of integrity in the Dominican public sector 85
3.1. Introduction 86
3.2. Supporting Dominican public officials in applying integrity standards in their daily work and adhering to public service values 86
3.2.1. The DIGEIG could establish a Code of Integrity for all public officials employed in the national and subnational government,... 87
3.2.2. The National Congress could adopt a code of integrity for senators, deputies and officials of the Legislative Branch based on... 89
3.3. Fostering integrity in the human resources management process 90
3.3.1. The Dominican Republic, led by the MAP, must strengthen its career-based public service as the first step to cultivate a culture... 91
3.3.2. The Dominican Republic, led by the MAP, could develop and implement a comprehensive, centralised, reliable and... 91
3.3.3. The Dominican Republic could make better use of performance evaluations as a tool for fostering integrity among public officials 92
3.4. Raising awareness and building capacities on integrity to encourage behavioural change and open organisational cultures in... 94
3.4.1. The DIGEIG could work with the CIGCNs to develop and implement new awareness-raising campaigns in the national and... 95
3.4.2. The DIGEIG could collaborate with the MAP, the INAP and the INFOTEP to develop a comprehensive public integrity capacity... 96
3.4.3. The DIGEIG could collaborate with the MAP and the INAP to develop a training programme for integrity leaders and... 98
3.4.4. Public entities could systematically measure and evaluate the use and impact of integrity training activities and support materials 100
3.4.5. The DIGEIG could use the organisational climate and culture surveys in partnership with the MAP to identify areas for... 102
3.5. Proposals for action 103
References 104
4. Improving transparency and access to information for public integrity 107
4.1. Introduction 108
4.2. Strengthening the legal and institutional framework for effective access to information 113
4.2.1. The Dominican Republic could consider enshrining in primary legislation the principle that government information and... 113
4.2.2. Law No. 200-2004 could be amended to provide clearer procedures for dealing with external appeals regarding reactive disclosure... 115
4.2.3. Oversight of Law No. 200-2004 on access to information could be entrusted to a supervisory authority with functional independence and... 118
4.3. Strengthening operational arrangements for access to information through digital integration, accessibility, and proactive disclosure 121
4.3.1. The DIGEIG could further strengthen and consolidate the SAIP Platform, by ensuring full institutional uptake, improving data quality and... 122
4.3.2. The Dominican Republic could ensure transparency and integrity by applying internationally recognised models and... 124
4.3.3. The Dominican Republic could centralise existing open data platforms into a unified National Transparency Platform 125
4.4. Proposals for action 129
References 130
Note 131
5. Towards a whole-of-society approach to integrity 132
5.1. Introduction 133
5.2. Promoting education for integrity at all levels of the education system 134
5.2.1. The Ministry of Education could extend the content of the "Ethics and Citizenship" core competency to cover other key aspects of... 135
5.2.2. The Ministry of Education could strengthen education for integrity through more customised learning and extracurricular activities 137
5.2.3. Universities could consider including courses on public integrity and anti-corruption in their curricula 138
5.2.4. The Dominican Republic should invest in developing teachers' capacities in integrity and corruption prevention 139
5.3. Promoting a culture of integrity in the Dominican Republic 141
5.3.1. The DIGEIG could lead a national awareness-raising campaign aimed at the whole-of-society and encouraging the country to make... 143
5.3.2. The Ministry of Higher Education, Science and Technology, together with the DIGEIG, could develop a strategy to promote... 146
5.4. Engaging citizens and civil society organisations in public decision making 147
5.4.1. The Dominican Republic could ensure that integrity system entities and entities that provide public services publish relevant... 148
5.4.2. The CASFL could issue a call to non-profit associations to provide training on civic education and integrity, focusing on... 150
5.4.3. The DIGEIG should seek to institutionalise the participation of the public and organised civil society in the development and... 152
5.5. Enhancing the business sector's shared responsibility and engagement with public integrity 154
5.5.1. Through public-private partnerships, the expansion of compliance programme coverage in the private sector could be promoted,... 154
5.5.2. The DIGEIG could strengthen the evidence base on business integrity practices and challenges 159
5.6. Proposals for action 160
References 161
6. Strengthening risk management and auditing 166
6.1. Introduction 167
6.2. Strengthening integrity risk management and internal control 170
6.2.1. The Dominican Republic could set internal control objectives for integrity across policies and programmes and ensuring full coverage... 170
6.2.2. The CGR and the DIGEIG should use a shared notion of "integrity risks" and adopt a common methodological framework for their... 173
6.2.3. The CGR could further strengthen the Anti-Fraud Unit and thus contribute significantly to the analysis and investigation of integrity risks 174
6.2.4. The CGR could clarify the role of UAIs by changing their names, further strengthening their new responsibility and aligning their... 175
6.3. Strengthening the internal audit function 176
6.3.1. The Dominican Republic could strengthen the relationship between the DAI and senior institutional management by further strengthening... 177
6.3.2. Through its Prioritised Training Plan, the CGR should continue supporting the professional development of internal auditors and... 178
6.4. Promoting trust and strengthening the impact of the Chamber of Accounts of the Dominican Republic 181
6.4.1. The National Congress could improve the selection and appointment process for CCRD plenary members based on clear,... 181
6.4.2. The Chamber of Accounts could continue strengthening the quality of its audits, ensuring that the Audit Quality Directorate has... 182
6.4.3. The Chamber of Accounts could continue its efforts to professionalise and promote public integrity among the institution's staff 184
6.4.4. The Chamber of Accounts could increase the impact of its work by widely disseminating the results of its audits to the National Congress... 185
6.4.5. The Chamber of Accounts could elaborate a digital transformation strategy to leverage data and technology for more timely,... 186
6.5. Proposals for action 188
References 189
7. Strengthening whistleblowing and mechanisms for investigating and sanctioning integrity violations 192
7.1. Introduction 193
7.2. Strengthening openness and whistleblowing 194
7.2.1. The Dominican Republic could encourage open organisational cultures by supporting leaders to demonstrate their commitment to... 194
7.2.2. The DIGEIG could publish statistics on the number of reports received and their traceability and improve the information available to... 195
7.2.3. The Dominican Republic could develop a legal, administrative and procedural whistleblowing framework in line with international... 198
7.2.4. The Dominican Republic could establish an inter-institutional working group to identify and analyse common retaliatory practices with... 199
7.2.5. In parallel to the development of the whistleblowing legal safeguards, the Dominican Republic could establish clear policies and... 202
7.2.6. The DIGEIG could establish common procedures for receiving, referring, tracking and monitoring reports of alleged wrongdoing across... 205
7.3. Strengthening the investigation and sanctioning of integrity violations 207
7.3.1. The Dominican Judiciary and the Public Prosecutor's Office could commission an independent evaluation of the effectiveness and... 207
7.3.2. The Dominican Republic could adopt rules on the disciplinary investigation and sanctioning of integrity violations to ensure... 208
7.3.3. The Dominican Republic could strengthen procedural safeguards to strengthen the objectivity of public officials responsible for... 212
7.3.4. The MAP should publish comprehensive statistics and produce regular reports on disciplinary proceedings and investigations,... 214
7.3.5. To produce reliable data for integrity policymaking, the DIGEIG should promote a strategic initiative to improve the evidence base on... 216
7.4. Proposals for action 218
References 219
8. Strengthening transparency and integrity in lobbying and influence activities 222
8.1. Introduction 223
8.2. Building a coherent framework for transparency and integrity in lobbying and influence activities aimed at influencing government... 230
8.2.1. The Dominican Government could adopt a lobbying regulatory framework in primary legislation that clearly specifies definitions and... 231
8.2.2. The proposed lobbying regulatory framework could enhance transparency through a range of complementary transparency tools 237
8.2.3. Transparency and integrity rules could be established for government advisory and expert groups, including lobbying activities... 242
8.3. Establishing a public integrity framework adapted to the risks of lobbying and influence activities for both lobbyists and public officials 243
8.3.1. The Dominican Republic could develop specific rules, standards and guidelines for public officials on their interactions with lobbyists 244
8.3.2. The advisory bodies or units recommended in Chapter 1 could also support public officials on lobbying-related ethical dilemmas and... 246
8.3.3. The Dominican Republic could consider developing and adopting standards of conduct which would apply to all lobbyists 246
8.3.4. The Dominican Republic could adopt specific incentives to encourage more responsible and transparent engagement in... 248
8.4. Ensuring effective compliance and review of the lobbying regulatory framework 250
8.4.1. The monitoring and enforcement of a future lobbying regulatory framework could be entrusted to an oversight body with... 250
8.4.2. The Dominican Government could ensure there are adequate administrative and criminal sanctions for violations of the lobbying... 255
8.4.3. The Dominican Government could promote stakeholder engagement in the design, implementation and review of the lobbying... 255
8.5. Proposals for Action 258
References 259
9. Enhancing transparency and integrity in the financing of political parties and electoral campaigns 261
9.1. Introduction 262
9.2. Establishing fair and transparent rules for public and private funding of political parties and candidates 268
9.2.1. The allocation of public funding to political parties could be improved by establishing more proportional eligibility criteria in... 268
9.2.2. To better frame private funding and promote a balanced funding model between public and private sources,... 271
9.3. Strengthening reporting, transparency and enforcement in political party financing 274
9.3.1. To improve the consistency and completeness of the financial reports submitted by political parties, Law No. 33-2018 and... 274
9.3.2. To close enforcement gaps in political finance regulation, the catalogue of electoral offences and corresponding sanctions... 281
9.3.3. To more effectively combat vote-buying, the legal framework could extend beyond bribery by explicitly prohibiting and... 283
9.4. Addressing transparency gaps in third-party, online and digitally enabled electoral campaigning 285
9.4.1. The Dominican Republic could consider introducing clear regulations and accounting standards for third-party campaigning 285
9.4.2. The Dominican Republic could strengthen rules governing the use of social media and political advertising for electoral purposes 286
9.5. Proposals for Action 289
References 290
Figure 1.1. The OECD Recommendation on Public Integrity 17
Figure 1.2. Dominicans' perception that the government makes decisions in an informed, collaborative and participatory manner... 19
Figure 1.3. Compared to Latin American, levels of trust in government, civil servants and politicians are in general higher in... 19
Figure 1.4. Citizens in Latin America and the Caribbean (LAC) are concerned about crime and violence, corruption and rising prices 20
Figure 1.5. Municipalities rank as the fourth most trusted institution in the country 38
Figure 2.1. The OECD Public Integrity Indicator for conflict of interest in the Dominican Republic and cross-country comparisons 57
Figure 4.1. The OECD Public Integrity Indicator for access to information in the Dominican Republic and cross-country comparison 110
Figure 4.2. The Dominican Republic does not specify in primary legislation that government data are open by default 114
Figure 4.3. The Dominican Republic's access to information legal framework exhibits weaknesses in the dimensions of appeals, sanctions and... 118
Figure 4.4. Bodies responsible for the enforcement, monitoring and/or promotion of ATI laws, 2020 120
Figure 4.5. Statistics published by type of information requested in the SAIP platform 123
Figure 4.6. Canada's Open Government Portal and Brazil's Transparency Portal 128
Figure 5.1. Almost half of the population agrees with the statement "some corruption can be tolerated if problems are solved" 142
Figure 5.2. Citizens who trust in the country's political institutions "a lot" or "somewhat" 147
Figure 6.1. Three Lines Model 168
Figure 7.1. Fear of exposing corruption in Europe, Latin America and the Caribbean, and the Dominican Republic 200
Figure 8.1. Citizens in the Dominican Republic perceive that a few powerful groups govern their country 226
Figure 8.2. The OECD Public Integrity Indicator for lobbying in the Dominican Republic and cross-country comparison 228
Figure 8.3. An increasing number of countries are adopting lobbying regulatory frameworks 231
Figure 8.4. Characteristics of lobbying registers by country 239
Figure 9.1. The OECD Public Integrity Indicator for political finance in the Dominican Republic and cross-country comparison 264
Figure 9.2. Disclosure of campaign donations in the Dominican Republic, compared to OECD and LAC averages 277
Figure 9.3. Most countries have an independent body for supervising political financing, but not many have certified auditors on their payroll 279
Figure 9.4. Prevalence of vote buying in the Dominican Republic, compared to OECD and LAC 284
Boxes 10
Box 1.1. Towards a potential National Integrity and Transparency System in Peru 30
Box 1.2. The added value of a dedicated integrity function at the organisational level 32
Box 1.3. Integrity systems and units in Brazil and Peru 34
Box 1.4. Integrity networks in Austria, Canada, Germany and Sweden 36
Box 1.5. Fostering local integrity in France 40
Box 1.6. Long-term integrity and anti-corruption strategies in OECD countries 41
Box 1.7. Key questions to ask when assessing a national integrity strategy 43
Box 1.8. Integrity monitoring practices in public entities in Korea and Peru 46
Box 2.1. Real, potential and apparent conflict of interest 60
Box 2.2. Outside activities and positions that could give rise to a conflict of interest 61
Box 2.3. Measures to manage conflict of interest 63
Box 2.4. Conflict-of-interest guides and toolkits 65
Box 2.5. Examples of measures to protect the recruitment of private sector employees in government jobs 68
Box 2.6. Provisions requiring the declaration of activities subsequent to public employment in Spain 71
Box 2.7. Procedure for the review of post-employment restrictions on public employment in France 72
Box 2.8. Sanctions for non-compliance with restrictions on post-public employment in Spain 73
Box 2.9. Guidance for asset declarations in Brazil 78
Box 2.10. Co-operation and cross-referencing of databases in France's declaration system 80
Box 3.1. Participatory processes for defining public service values 88
Box 3.2. Example code of integrity for Legislative Branch officials 90
Box 3.3. The Australian Public Service Performance Framework 94
Box 3.4. Use of moral reminders in Mexico 96
Box 3.5. The "Ethics for people managers" guideline in New South Wales 100
Box 3.6. Kirkpatrick's "Four-Level Model" 101
Box 4.1. OECD frameworks where primary legislation specifies that Government data are "open by default" 115
Box 4.2. Independent oversight institutions: Chile's independent Council for Transparency 121
Box 5.1. Examples of extra-curricular programmes for education for public integrity 138
Box 5.2. Examples of communication and awareness-raising campaigns implemented by the private sector and civil society organisations in Ecuador 145
Box 5.3. Integrity awareness and youth participation initiatives 152
Box 5.4. The participatory evaluation of the Romanian National Anti-Corruption Strategy 153
Box 5.5. Characteristics of effective compliance programmes 156
Box 5.6. The Pro-Ethics (Pro-Ética) Programme in Brazil - Good practices in public-private integrity 158
Box 5.7. The French Anti-Corruption Agency's efforts to measure business integrity practices 159
Box 6.1. Internal Audit Framework in the Netherlands 178
Box 6.2. Internal Audit Development Programme and Internal Audit Competency Profiles and Dictionary in Canada 180
Box 6.3. Poland - Najwyższa Izba Kontroli (NIK): Structure audit quality assurance system 183
Box 6.4. Examples of communication 186
Box 6.5. Strengthening Analytics in Mexico's Supreme Audit Institution 187
Box 7.1. International good practices on whistleblowing and whistleblower protection 199
Box 7.2. International good practices in the construction of whistleblower protection regulations 201
Box 7.3. Anonymous whistleblowing via electronic platforms in Austria, Germany and Kenya 203
Box 7.4. Internal Disciplinary Control System in Colombia 211
Box 7.5. Disciplinary system in Brazil: institutional framework and requirements for disciplinary officials 214
Box 7.6. The Disciplinary Proceedings Management System in Brazil 216
Box 8.1. Designation by resolution of public officials targeted by lobbying activities in Chile 234
Box 8.2. Examples of broad definitions of 'lobbying' amongst OECD Members 236
Box 8.3. Open agendas in Argentina and Brazil 241
Box 8.4. Transparency Code for Working Groups in Ireland 243
Box 8.5. Examples of provisions on lobbying cooling-off periods for elected officials and appointed officials in at-risk positions in OECD counties 246
Box 8.6. Standards of conduct for lobbyists in selected OECD countries 247
Box 8.7. OECD standards providing (government) expectations to businesses on lobbying 249
Box 8.8. Challenges related to the oversight of the lobbying framework in Chile 253
Box 8.9. Oversight of the lobbying framework in Lithuania and Slovenia 254
Box 8.10. Consultations on the drafting and revision processes of lobbying regulations in Ireland and Canada 256
Box 8.11. Review of the lobbying framework in Canada and Ireland 257
Box 9.1. Examples of OECD countries' employment of certified auditors in the audit of political parties' finances 280
Box 9.2. Examples of OECD countries requiring political parties to submit accounts certified by certified auditors 280
Box 9.3. Canada's framework for reporting campaign expenditure for digital and social media communications 288
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