1 Katalin Pallai Norbert Kis Towards Integrity Integrity Education and Research at the National University of Public Service Summary: Research and curriculum development for public ethics and integrity have become the most innovative areas of the university, and generated new approaches to both content and methodology. The article positions the NUSP approach within the actual state of art of theory and practice. It proposes that in the post-communist region for effective improvement of integrity the reconceptualisation of corruption as a cultural problem is necessary, corrupt practices as memes, anticorruption as collective action problem. We propose that ample use of argumentative methods are necessary in training, research and technical support - methods that are not widely known or applied in the region yet. The article presents how this approach can be applied for training and the building up of an epistemic community that could support integrity development, and presents the results of the research that was conducted to measuring the effectiveness in the attitude change of participants involved in trainings. Keywords: public ethics, integrity, collective action problem, argumentative method, meme, anti-corruption JEL codes: A2, K420 RReform in public service ethics The perfect public servant without any conflict of interest does not exist. State officials also need ethical support, learning and solidarity. That rough road is the one that leads towards integrity. Integrity lies at the heart of all community activities and public service. The word is derived from the moral essence of in tangere, i.e. purity and blamelessness. In 1945, Sándor Weöres (2000) posited that all this resided within us, and that the only true learning: awakening the dormant knowledge in our being to activity, and there is only one knowledge, the rest is mere extension: the earth is address: beneath and the sky is above, and the ladder is in yourself. Since 2011, following the failure of previous public policy ventures and strategies, the Hungarian government lined up its measures behind the slogan and concept of integrity. The two most important indicators of quality policy in public service are the level of public confidence in government and the perception of bureaucratic corruption. According to the Eurobarometer corruption survey, in per cent of Hungarians considered corruption to be a widespread problem in Hungary (EU average: 76 per cent), whereas 19 per cent of the respondents felt affected by corruption in daily life (EU average: 26 per cent). Of the respondents, 13 per cent claimed to have been expected or called on to pay bribes (EU average: 4 per cent). Of business respondents, 81 per cent were of the Public Finance Quarterly 2014/2 149
2 opinion that favouritism and corruption were impeding market competition (EU average: 73 per cent), and 59 per cent claimed corruption to be a problem for their company while doing business in Hungary (EU average: 43 per cent). The perception index of corruption has shown a declining tendency and average in the past years. According to the OECD s 2013 Government at a Glance survey, confidence in government declined between 2007 and 2012 in three quarters of the countries surveyed, and the OECD average was down 5 per cent from 45 to 40 per cent. The survey is based on responses from 1,000 citizens to the Gallup World Poll concerning their satisfaction with the operation of local police, healthcare, justice, education and government. The latest annual integrity survey by the State Audit Office of Hungary shows a 5 per cent rise in factors increasing the risk of corruption in comparison with the previous year, coupled with a slight improvement in the use of soft control measures such as codes of ethics. Integrity is an approach based on values, and involves value-oriented thinking and organisational operations. In its concept and method, integrity is represented equally in the organisations and human policies of both the public and the private sectors. The purpose of integrity policies is sector neutral, consisting in value conscious organisation and the creation of the individual and organisational web of compliance with values in order to mitigate the risk of defective and corrupt operations. Shared values mean joint learning and solidarity in the community. This increases consciousness within the organisation. A conscious organisation will reinforce the entire culture of vocation and professionalism e.g. in the fields of public administration and law enforcement, allowing the effects to be combined. The public and the private sector differ in the substance of the values represented by integrity. The fundamental value of public service is the enforcement of the common good and public interest. The private sector is the competition of particular interests. On the path to the enforcement of integrity, one important step was to give prominence to public ethics as of 2012 and to adopt measures to reinforce it. The ethical sensitivity of public service and the significance of public ethics as a theme of organisation and human policy have been an increasing trend across Europe (Demmke Moilanen 2011). Increased awareness of public ethics may be explained by a number of interrelated factors: good governance and efficient public service have become public policy priorities, the economic crisis has added to the importance of ethical operations, pressure to respond to poorer public confidence in public offices and public administration, higher expectations from society and citizens for public service, the continuous transformation, reform and reorganisation of the public sector have been putting the skills of public servants to the test, complexity of values, conflicting values and value crisis in all fields of life, stronger requirements for openness, transparency and accountability, the significance of anti-corruption efforts to public policy. In Hungary, a strategic framework for reforms on public ethics was provided by the Magyary Zoltán Public Administration Development Programme (2011). The other framework is provided by the Corruption Prevention Programme for Public Administration [Government Decision 1104/2012. (IV. 6.)] based on the Preamble to Act CXCIX of 2011 on Public Officials. According to the Preamble to the Public Officials Act, the state may rest on the foundations of public service 150 Public Finance Quarterly 2014/2
3 that is held in high esteem by society, efficient and cost-effective, democratic, nonpartisan, legitimate, and is composed of members with upto-date professional knowledge who serve the interests of Hungary and the common good in an impartial and patriotic manner, defining a regulatory framework in the form of a catalogue of public ethics principles. The Act offers the following catalogue of public ethics: loyalty and commitment; priority to national interests; equitable and fair jurisdiction; dignity and honesty; unprejudiced service; impartiality, responsibility and professionalism; cooperation; proportionality in and protection for the adoption of measures. Additional ethical principles for leaders: leading by example; enforcement of professional considerations; a demand for accountability. Public service ethics rests on the pillars of four values: moral value: maintenance of public confidence, exemplary conduct in every situation, human honesty: respect and honesty in dealing with citizens and colleagues, democratic value: serving the public interest, professional value: excellence, efficiency, impartiality. In 2013, following discussion by the government, a Green Book was adopted on the ethical requirements for government agencies. It served as a basis for corporate public bodies and budgetary institutions in public service in the development of their own codes of ethics. The Hungarian Government Officials Corps adopted their Code of Public Ethics for government officials on 21 June Public ethics norms for government officials have a twofold taxonomic classification. ulegal norms: in public service law, they are classified among government officials obligations, the breaching of which has legal implications (disciplinary offence, cause for discharge). The substance of the norms is that of public service law and criminal law without any restrictions. vethical norms: the Hungarian Government Officials Corps adopt their own set of rules for government officials (Code of Public Ethics), the violation of which (ethical offence) involves no direct legal implications (ethical sanctions), but the Code specifies the value substance of legal obligations in public service, and hence application of law in public service. This twofold legal and ethical function is expressed by the definition of ethical offence in the Code of Public Ethics: the act of a government official in violation of the basic principles or specific rules of public ethics which is contrary to the ethical rules set out in Act CXCIX of 2011 on Public Officials or to the provisions of the Code of Public Ethics for Government Officials or those of the Statutes and does not qualify as a crime, an administrative offence or a disciplinary offence. The set of norms developed by the Hungarian Government Officials Corps operate with legal consequences (notice, reprehension) and within a scope (prevention, sanctions) specific to the organisation. The value substance of the norms provides consistent standards for conduct and operations in public administration on the one hand, while on the other it gives uniform substance to the legal provisions of a public ethics nature set out in the Public Officials Act (which, for example, are imposed as legal obligations by employers and courts in the application of law). In the case of public servants (e.g. in local governments), the basic principles of public ethics listed above are applied with the difference that the detailed substance of each principle and the rules of ethical proceedings are determined by the representative council or, as appropriate, by the head of the body concerned. The sanctions available for ethical offences by public servants are notice and reprehension. Public Finance Quarterly 2014/2 151
4 The new system of public ethics is instrumental in raising awareness of officials value conflicts and thus in their resolution. Ethical principles provide frameworks of interpretation; however, there are no ready-made answers. An example of this is the enforcement of the public interest, which is the origin of values. The public interest rarely manifests itself in a clear and obvious form. As a rule, the public interest is a political category. In a decision planning process (decisions on legislation, economy, support and finance), the official does not create public interest. They manage the process of private interest becoming public interest. It is the reasons leading up to the decision and the process of consideration and negotiation that they need to make clear, logical and transparent. The other key moral imperative is the development of public confidence. In Magyary s words, an official is supposed to work towards that aim with their whole personality. They need to show honesty and keep up its appearance. Keep a distance from harmful influence. Remain in tangere. In the new public service ethos, cooperation is given prominence. This points to the quality of communication aimed inwards and outwards : a set of values is needed that is intelligible and perceptible for both colleagues and customers. Clear communication also plays an important role in creating accountable, open and transparent public service. Self-organised public bodies enforcing codes of public ethics (Hungarian Government Officials Corps, Hungarian Law Enforcement Corps) are means of setting community examples. This may be more important than the fact of ethical regulation. Colleagues examples, being manifestations of collective, voluntary and sincere commitment, can exert a positive influence. In 2011, open and professional dialogues were started on ethical issues, and since 2013, corporate ethical proceedings (ethics committees) have been offering precedents to help understanding. Ethics requires the experience of shared learning. In summer 2013, one-day training sessions were held at the National University of Public Service (NUPS) for hundreds of officials. In the course of joint thinking, the relationship of doubts and dilemmas and the purifying effort of a joint search for directions were palpable. Finally, leading by example is perhaps the most important means of the reforms on public ethics; in Zoltán Magyary s words, a leader needs to be superior in terms of character, knowledge and performance. Theoretical approaches to integrity Integrity management is a relatively new approach to anti-corruption, aimed at the prevention of corruption and the effective operation of public administration. In public administration, integrity means a mode of operation that enables public administration and public administration organisations to effectively use the powers and resources entrusted to them for the implementation of the officially accepted and justified public interest. Integrity is a key element of good governance and of public trust. In this relatively new discipline, the role of the NUPS is to provide theoretical and professional underpinnings and a solid conceptual basis for the development of anticorruption interventions that may be applied effectively in the domestic administrative environment, and to provide a link between state of the art international and domestic thinking in theory and praxis. Exploiting its unique position and manifold interrelations with Hungarian public administration, NUPS has launched activities which enable it to create direct links between science and practice, and to contribute to the elaboration of applicable solutions in practice. 152 Public Finance Quarterly 2014/2
5 To define the role of NUPS in integrity education and development, it is appropriate to refer briefly to the relevant theories, and position our own approach and activities among the various disciplines, definitions and views. In our case, this positioning is important because despite serious attempts at providing an integrated interdisciplinary approach (Graaf et al. 2010, Graeff Grieger 2012), neither a single definition nor a single approach has been established across the various disciplines either in scientific work relating to corruption or in the field of integrity development, as a result of which parallel conceptualisations exist (Persson et al. 2013, p. 450). Psychology focuses on personal ethical decisions and behaviours, economics on the interest-based decision of the individual and the group, sociology on the social environment, law on violations of the norms and the sanctions applied, criminology on the process of violating rules and norms, and political science on the process during which rules binding on the community are adopted in deviation from the community interest. Built on Weber s foundations, the traditional study of public administration is based on the legal approach. It interprets and sanctions corruption as a violation of the norms and rules, and as such it tries to counter corruption by specifying public servants values and controls. Gaining ground in the 1980s and 1990s, institutional economics focused on the cost-benefit considerations in the course of corruption, then Klitgaard, applying the principal-agent theory, added the problem of information asymmetry and moral hazard to the key issues of corruption analysis. Principal-agent theory is an important framework of analysis in political science and economics. Characteristics of the situation include conflict of interest, asymmetric information (information that may be withheld from the principal), and ethical risk (benefit is obtained by the agent without being liable for the damage caused). Characteristics of the situation include conflict of interest, asymmetric information (information that may be withheld from the principal), and ethical risk (benefit is obtained by the agent without being liable for the damage caused). The focus has remained on systems of controls and sanctions, with the emphasis shifted from the specification of controls to fixing incentives (Klitgaard 1988). Principal-agent theory has since remained a key underpinning concept in corruption analysis and in administrative responses to corruption despite the fact that a series of studies have demonstrated the Klitgaard model to have an explanatory power only in so-called minor corruption cases, which occur in essentially ethical social and institutional settings as isolated crises (Rose Ackerman 2010, p. 51). (Rose Ackerman 2010, p. 51). Principal-agent theory also plays a key role in new institutionalism, but the focus is shifted from the individual to institutions. In a more complex approach than that of the schools mentioned previously, new institutionalism addresses the problems of corruption and integrity in the complexity of formal and informal institutional effects, hoping to develop means that are also suitable to resolve systemic phenomena. Organisations and experts focus on mutually complementary elements. To highlight only the findings which are the most relevant from our perspective, Pope (1996) builds on a social sense of values and the institutional system underpinned by it, OECD (2009) on ethical infrastructure and public confidence, Peters (2010) on organisational structure, Báger (2013) on competence, while the Australian NISA Project builds on systemic horizontal relationships (Sampford et al. 2005, p. 96). Unquestionably, in recent decades the problem of corruption and integrity development have become increasingly better theoretised, anti-corruption methods have been improving, and an increasing amount of funds have Public Finance Quarterly 2014/2 153
6 been channelled to anti-corruption projects. However, improvement is clearly not proportionate to the resources used. Detailed analyses are being published on the implementation problems of the controls which, apparently, have been improving continuously (Pippidi 2006, EU 2014). Instead of positive progress, in areas heavily infested by corruption an anticorruption industry is observed to have been developing and flourishing alongside corruption (Sampson, 2010). (Sampson, 2010). On the on hand, this paradox has given rise to initiatives on typology with a view to ensuring that environments posing different levels of challenge may be distinguished and that the parameters of the most problematic situations may be specified more accurately (Six Lawson 2013). On the other hand, thinking in recent years has represented a paradigm shift in respect of the areas more heavily infested with corruption 2013). Where corruption is general practice rather than an isolated slip, the theoretical relevance of the principal-agent relationship becomes questionable, which even the father of the concept, Klitgaard himself appears to be moving beyond (Klitgaard 2006). In addition to being the result of a selfish individual choice, corrupt practices may also be the products of cultural patterns that are continuously at work. In an environment more heavily infested with corruption, corrupt practices may be interpreted as a meme (a unit carrying cultural ideas), which spreads rapidly in a social setting tolerant of corruption and in weak organisations operating in such an environment (Pallai 2014). Where the cultural setting allows values to be relativised and corrupt practices to be rationalised, the meme of corruption will become a general pattern of behaviour, damaging its environment like a parasite. In a situation like that, integrity derived from democratic values represents a culture that is different to that of the culture of the environment and the patterns of behaviour and action that belong to it. When in such a situation an individual attempts to break free from the cultural pattern of the environment and act in accordance with the principles of integrity, he/she faces such risks that the majority of the actors have no means to undertake. Namely, resistance to cultural patterns and organisational practices will cost the individual dearly in the short term, while its social benefits are widely spread. In most cases, under pressure from the environment, individuals will feel vulnerable and will, although with aversion, drift into the practices which they find unacceptable. Research has shown that the situation will remain unchanged even where the majority in principle disapprove of the established practices, and consider them harmful. Most individuals will remain unwilling or unable to bear the personal cost of resistance (Rothstein 2005). In many cases, resistance will not even present itself as an alternative on the personal cognitive horizon of the individual. This is the essence of the social trap situation evolving in such environments. It is a mistake to conceptualise a situation like that as a principal-agent problem and treat it as a challenge of regulation or information. International practice clearly shows that EU-conform rules (laws) and transparency requirements built on this approach become empty when implemented in an environment that is alien to them (Dimitrova 2010). A constructive alternative is to conceptualise the situation as a collective action problem (Persson et al. 2013, p. 463). The collective action problem implies that it is difficult to undertake the right action until the individual can assume that others will also take the right path and there should be no concern of taking individual risk. In this conceptual framework, the solution depends not only on taking moral responsibility, but also on mutual expectations, assumptions and trust. The 154 Public Finance Quarterly 2014/2
7 solution to the collective action problem is a matter of coordination: the social trap evolved can only be resolved by coordinated action, on the assumption that action can be simultaneous (Persson et al. 2013, p. 463). As we have seen, it is not sufficient if we rely only on rational, formal external organisational incentives only. In this situation that involves subjective, interpersonal expectations, assumptions and trust. In this conceptual framework, the solution needs partly to break free of the positivist confines that were previously considered authoritative. While retaining and continuing to apply the methods of analysis and intervention elaborated on the basis of the positivist law and public administration explained in the foregoing, it is also important to explore the possibilities of including in our toolkit the interpretative/argumentative approaches and methods of postpositivist political science. The possibilities of complementing the rational public policy and organisational answers to objective problems (such as infringements, fraud, etc.) provided by the positivist approaches as discussed in the foregoing with argumentative tools such as the interpretation and re-interpretation of verbal constructs, joint problem definition and conceptualisation, which are suitable to enable the emergence of a discursive process linking the individual and the community, as well as the development of possible solutions and the mutual trust are required for change. This conclusion appears to be supported by the findings of detailed research on anticorruption policies in the post-communist region, published in the 2010 special issue of Global Crime, according to which the broad social support for anti-corruption efforts played a key role in positive changes (Moroff Schmidt Pfister 2010, p. 97). This required the impact of an epistemic community capable of continuously shaping social narratives and norms (Moroff 2010, p. 94). The following key elements provide the theoretical underpinnings for the training methodology explained below and the concept of the Integrity Knowledge Centre: organisational competences (Peters 2010, Báger 2013) corruption concpetualised as meme/ cultural phenomenon (Pallai 2014) integrity development as a collective action problem (Persson et al. 2013) argumentative theory (Fischer Gottweis 2013) the role of the epistemic (public policy) community (Moroff Schmidt Pfister 2010) Integrity education According to the EU Anti-Corruption Report (2014), Hungary has reinforced its integrity education system, introducing anti-corruption related matters in the national core curriculum since It has set up postgraduate programmes for public servants focused on integrity issues and included integrity programmes in the curriculum of the National University of Public Service since These programmes and training curricula promote innovative learning processes and were tested on targeted public administration groups (management and civil servant level) through close cooperation of government experts, civil society, private sector and academia. Since the programme began in September 2013, about 2,000 public officials and civil society representatives have been trained. [Annex on Hungary to the EU Anti-Corruption Report, Brussels, 3 February 2014, COM(2014) 38 final.] The training programmes are based on Government Decree No. 50/2013. (II. 23.) on the integrity management system of organs of public administration and on the procedural rules applicable to dealing with lobbyists. The scope of regulation includes central organs Public Finance Quarterly 2014/2 155
8 of public administration under the control or supervision of the Government, and their employees, except law enforcement agencies. Integrity is defined in legislation as the organ of public administration being operated in accordance with the rules applicable to it as well as with the objectives, values and principles set out by the head of the official organisation and its managing body. Integrity management system: the functional subsystem of the governance and management system, which is integrated in the internal control system and serves to ensure the integrity of the organisation, comprising the main elements of specifying the values to be complied with, guidance for compliance, monitoring and, as required, enforcement of compliance. The head of the official organisation of each organ of public administration is required to appoint an integrity consultant to provide support for the management of integrity and corruption risks. The tasks of the integrity consultant include the following: participation in the assessment of integrity and corruption risks to the operation of the organ of public administration, as well as in the preparation of the action plan for the management of such risks and of the integrity report on the implementation of the plan; based on the action plan for corruption prevention, submission of a proposal for the delivery of public ethics and anti-corruption training programmes to the organ of public administration, and participation in the delivery of such programmes; based on the legal regulations and the rules of public ethics in effect, provision of information and advice to the heads and employees of the official organisation on any matters of public ethics arising; where authorised by the head of the official organisation, discharge of duties on behalf of the head of the official organisation relating to the receipt and examination of reports on abuse, irregularities, and integrity and corruption risks associated with the operations of the organisation. The NUPS trained 47 integrity consultants in 2013 and 74 in 2014 as part of its one-year specialised extension training programme. The training programme primarily helps with the establishment and operation of an integrity management system (organisational development, training, analysis) relating to internal organisational development processes in public administration, with the main objective of preventing corruption and other forms of abuse. Participants completing the specialised training programme will acquire competencies that enable them to manage and implement the integrity management system and other organisational development processes. Their knowledge will be complemented by a specific understanding and practical training experience relating to the concepts of corruption, corruption prevention and integrity, and to the functional operation of administrative authorities. NUPS also developed a one day awareness raising training programme on public service ethics and integrity for civil servants, as well as a two and a half day integrity management training for public service leaders. The methodology was developed in cooperation with the experts of the Ministry of Public Administration and Justice and outside experts by NUPS associate professor Katalin Pallai. At the time of writing this article, over 8,000 staff and 751 leaders of public administration organisations have been trained, and a training programme was also held for executives with leaders like secretaries of state and state commissioners attending. Currently an additional 3,500 public servants are scheduled for training. The figures speak for themselves: in the course of one year, 10 per cent of Hungar- 156 Public Finance Quarterly 2014/2
9 ian civil servants attended integrity training, and about 40 university teachers and trainers were trained to train, who in subsequent training activities gained considerable experience in teaching integrity. In addition to input indicators, the training methodology introduced a number of important professional and methodological innovations, which have been praised in the EU Anti-Corruption Report (2014) referred to previously. The methodology was also presented in English as part of an international peer review process, where prominent experts of the field rated it as an excellent educational programme that is also applicable in other countries of the region. 1 As the scope of this article does not allow a detailed discussion of the training methodology, only key elements will be highlighted to show what kind of products comply with the conceptual framework explained above. The training programmes were designed for professionally mixed groups of public servants. In training practising professionals, clarity, relevance and an impact on practice are important goals. One reference point in methodology design was the novelty of the subject. Participants entering a training could not be expected to be familiar with the concept of integrity. On the other hand, although participants personal commitment and public service ethos wasn t questioned, participants live in a social setting that is tolerant of corruption. The prevailing social interpretations of key concepts need to be reconceptualised to create a frame of reference in the short time available in which shared understanding of such concepts of democracy, corruption, anti-corruption and integrity can be developed that paves the way for the introduction of the integrity approach, as well as the key concepts and strategies relating to integrity development become comprehensible and memorable. The third condition was the lack of confidence in the possibility of change, as confirmed by the questionnaire survey explained later on. In a situation like that, the methodology had to serve three purposes: uconstructing a conceptual framework that allows the culture of integrity to be passed on, vpassing on the basics required for integrity development: the relationships between the required organisational competences, values and rules, wdealing with participants doubts and where required, cultural responses tolerant of corruption, since passing on the professional substance would hardly have been beneficial without relearning (revaluation) and changing expectations. The solution to the threefold challenge was a professional training programme based on an experiential methodology that creates the communicative space in which spontaneous reflections may be made on personal narratives, situations and critical incidents, the restructuring initiated by the trainer may take place, and it becomes possible to experience the possibility of breaking free from the trap discussed in the foregoing. While the aim is complex, the methodology ensures that participants will experience the training as a problem solving and reflective flow of discourse that may always remain specific, and takes place at a level that participants find understandable and comfortable. Also, rather than in the form of longer, frontal cognitive blocks, professional content is mostly incorporated as summaries, definitions and charts that structure the discourse and, together with the flip charts recording the joint thinking process, shape and develop the group s knowledge and its attitude to the subject. On the walls, reminders of the cognitive process help participants consolidate the relevant change in emotions and attitudes. Instead of a traditional teaching space, an argumentative/interpretative space is created (as a micro-community space but with the features of the argumentative space Public Finance Quarterly 2014/2 157
10 discussed in the theoretical part), in which participants connect through discourse to the community and recreate their reality together (Fischer Gottweis 2013). This process points far beyond unidirectional knowledge transfer. It starts a creative process which also has an effect on the emotions and attitudes towards the substance, and as participants progress along similar paths, group dynamics help clear up their doubts. Of course, the discursive process conveys very tightly structured professional content, which builds up the group s concepts of corruption and integrity starting from democratic values, and progresses from the analysis of ethical dilemmas to the development of ethical infrastructure and culture within the organisation, then, through the analysis of risks and integrity deficits, to the professional and organisational competences constituting the prerequisites for integrity, and to the systemic interrelations of components. Finally, it explains successful strategies and working systems to make the development of organisational integrity a viable alternative, reinforcing positive expectations. Indicators that measure integrity and transparency, as well as those concerning the efficiency of public administration may also show the effects of the progress made in the fields of the culture of vocation and integrity. Impact indicators are influenced by a number of factors, where the ratio of the respective contributions of public service education and leadership training cannot be shown precisely. In this way, cognitive content develops resolution patterns, while discursive tools builds trust that resolution is possible. The effectiveness of the methodology in terms of changing knowledge, interpretations, expectations and attitudes has been demonstrated in follow-up research to the training programme, which is explained later in the article. In addition to changing attitudes to corruption and integrity development, two things happen in the course of the training which are of significance to developing integrity. On the one hand, participants experience how a constructive discursive environment works, and through the trainer s behaviour, they are offered a pattern for building an interdependent setting. This will enable them to experience a pattern or organisational culture and leadership which is relevant in terms of both organisational efficiency and integrity (Pallai 2013, pp ). This the very system of mutual accountability which is not only vertical but essentially horizontal and provided the basis for Sampford s famous bird s nest metaphor of integrity. 2005, p. 96). In the bird s nest, twigs and cementing materials that may be individually weak are bound together so that they are strong enough to protect the fragile egg. According to the metaphor, the integrity system is also constructed in this way from a large number of elements, the cooperation and solidarity of which enables the fragile idea of integrity to be surrounded and protected. Being an interdependent setting, the nest focuses attention, the power of which is derived, in addition to formal rules, from the expectations, commitment and cooperation of the actors. The pattern is a means of resolving the collective action problem. The experience and model of collaboration provided in the training is particularly important to participants who were not socialised in such an organisational culture. Without experiencing it, it is not possible even to imagine and understand such a system, let alone believe in the possibility of its existence. Without the sense of viability, the knowledge transferred will dissolve. Naturally, a brief training programme will serve as a first step only. However, if it is followed by similar trainings within the organisation where staff live through a similar process together, the professional competence and a responsible and co- 158 Public Finance Quarterly 2014/2
11 Chart 1 Training impact It is possible to change people s thinking about what s right and wrong, allowing them to apply self-criticism to previously accepted procedures from which they derive personal benefits. If the administrative institution is adequately organised, it can significantly reduce external attempts at corruption. The new Criminal Code provides clear guidelines on how to judge phenomena of corruption. The best remedy for corruption is fast and efficient administration. Corruption could be reduced by openly stating the price of things for which people have been paying secretly. In Hungary, it is primarily the most senior executives that have no interest in the elimination of corruption. Corruption will only be curbed in Hungary if corruption-related crimes are punished much more severely than today. Corruption will only be curbed in Hungary if corrupt leaders receive exemplary punishment. Corruption is not more widespread in Hungary than in other countries. In Hungary, the hotbed of corruption is politics. In Hungary, the fight against corruption cannot be successful because those who are supposed to fight corruption are also corrupt. In Hungary, corruption has assumed such proportions that fighting it has become impossible. Corruption is as old as mankind and not much should be done to fight it. Corruption can be fought the most effectively through publicity. Corruption should primarily be fought using statutory instruments. The corruption experienced in this country is no particular cause for concern, because it is an inherent feature of transformation Before one day session After one day session Before two and a half day session After two and a half day session Source: Data processing study by Péter Zsolt Public Finance Quarterly 2014/2 159
12 operative community that mutually reinforces the positive expectations of its members may develop simultaneously to provide the core of integrity development. Research to evaluate the effectiveness of the training methodology The effectiveness of the methodology in terms of changing knowledge, interpretations, expectations and attitudes has been demonstrated in follow-up research to the training programme (see chart 1). A key innovation in training design was the abandonment of the common practice of satisfaction questionnaires, which hardly provide any information on effectiveness. Instead, an effectiveness assessment developed with Dr. Péter Zsolt was used, an innovation that has since been adopted by a number of organisations. At the beginning and at the end of the training, participants complete the same questionnaire, which essentially measures their attitudes. The questionnaire uses a 5-point Likert scale for statements as follows: 5 strongly agree, 4 agree, 3 neutral, 2 disagree, 1 strongly disagree. Importantly, the questionnaire does not include any questions to which explicit answers are given in the course of the training, because the focus of the survey is not how well participants can remember the information provided. Chart 1 shows the average score for each question before and after training. An analysis of over 15,000 questionnaires shows that training had a positive impact on all of the dimensions under review. The chart shows averages; the results of the work of about 40 trainers with public servants arriving from various regions of the country, representing a variety of responsibilities. Obviously, the results of groups and trainers show considerable deviation. In many groups, the extent of changes was significantly greater. (Detailed findings will be published later.) Integrity Knowledge Centre The Centre for Excellence in Integrity (CEI) was established on 9 December 2013 at NUPS for the purpose of carrying out and developing activities related to integrity development in the public sector. The contribution of CEI to public integrity is the high standard of scientific underpinning and the technical assistance both to policy development and to the supporting discursive/argumentative process. As a university knowledge centre with direct links to public administration, the CEI serves as a bridge between international and domestic professional innovation. Even before its establishment, during the design of innovative integrity training programmes for Hungarian civil servants, a process started involving an international outlook as well as the collection and adaptation of ideas, methods and publications, and, within the limits of the resources available, their translation into Hungarian. This was also the key to the success of the integrity management training programmes: it incorporated the methodology developer s decades of international and domestic experience. The training was the first step in earning domestic and international recognition for integrity education launched at NUPS. Since its establishment, the CEI has been engaged in the systematic collection, analysis and organisation of international and domestic knowledge and experience in order to make the knowledge required for public service integrity development available to all stakeholders. (A part of the knowledge base emerging including the Hungarian translations of key items of the latest international literature will be available soon in the form of an e-library.) The members of the professional network 160 Public Finance Quarterly 2014/2
13 of the CEI include integrity trainers, consultants and experts, and negotiations have also been launched to enhance cooperation with domestic and international institutional partners. Members of the developing network also contributed to the design of the CEI s operations, and professional workshop discussions have also been initiated to make relationships within the network closer. This marked the beginning of the formation of an epistemic community which, according to the research previously referred to, is essential for change (Moroff Schmidt Pfister 2010). An important activity of the CEI is research related to integrity development. Research has been completed on the possibility of complementing the Common Assessment Framework (CAF) with criteria related to integrity. In addition to the research referred to earlier that measures the short-term attitude changing effect of the trainings, research is also being carried out to assess long-term changes of attitudes. Current and planned further research of CEI exploits the unique position of NUPS to enter administrative organisations, approach practice respectfully, and cooperate with field professionals in formulating relevant research questions and methods. The process involving government officials will not only result in appropriate questions and applicable proposals, but also in transformation, in which a creative role is played by both the researcher and the professional, who, once the research is completed, is likely to become committed and reinforced, and undertake implementation. This is how the work of the CEI incorporates the argumentative process, competence development and collective action for integrity development. Conclusions Training programmes provide input to the development of public service, which has quantifiable results, but its impacts are manifested in the indicators of public confidence and corruption referred to in the introduction to this article. Indicators that measure integrity and transparency, as well as those concerning the efficiency of public administration may also show the effects of the progress made in the fields of the culture of vocation and integrity. Impact indicators are influenced by a number of factors, where the ratio of the respective contributions of public service education and leadership training cannot be shown precisely. Nevertheless, we trust that from 2014 onwards, both domestic and international assessments will produce improving indicators, and research into the underlying factors will also cover the training programmes explained here. Note 1 Members of the Peer Review Commission were Ellen Goldberg (Integrity Action), Ana Vasilache (FLDP) and Ulrika Kilnes (OECD). (Integrity Action runs the largest international network for integrity education and research and integrity development based on social participation. During its more than 20 years of existence, FLDP has become one of the most important organisations supporting democratic leadership. As part of its anti-corruption activities, which have also received the UN Public Service Award, it trains professionals who supervise integrity development processes. Founder and leader Ana Vasilache is also a lecturer at IACA this year.) Public Finance Quarterly 2014/2 161
14 Literaure Báger, G. (2013): Korrupció: büntetés, integritás, kompetencia (Corruption: Punishment, Integrity, Competence). Akadémiai Kiadó Bevir, M. Rhodes, R. A. W. (2010): The State as Cultural Practice. Oxford: Oxford UP Huang, H. B. (2010): What is Good Action Research? Why the Resurgent Interest? Action Research. 2010: 8: (1) p. 93 Demmke, C. Moilanen, T. (2011): Effectiveness of Good Governance and Ethics in Central Administration. EIPA publ Moroff, H. Schmidt-Pfister, D. (2010): Anticorruption Movements, Mechanisms, and Machines an Introduction. Global Crime. Vol. 11, No. 2, May 2010, pp Mungiu-Pippidi, A. (2006): Corruption: Diagnosis and Treatment. Journal of Democracy. 17 (3) pp Pallai, K. (2014): Bevezető gondolatok a közigazgatási integritás és integritás menedzsment témájához (Introductory Thoughts on Public Administration Integrity and Integrity Management). Pro Publico Bono Magyar Közigazgatás. 2014/1 Dimitrova et al. (2010): The New Member States of the EU in the Aftermath of Enlargement: Do New European Rules Remain Empty Shells? Journal of European Public Policy. 17, pp Fischer, F. Gottweis, H. (2012): The Argumentative Turn Revisited: Public Policy as Communicative Practice. Durham-London: Duke UP Nicklin, G. (2012): Strategic Thinking, Shared Meaning-Making and the Interpretive Turn in Policy. The Australian Journal of Public Administration, vol. 71, no. 1, pp de Graaf, G. von Maravic, P. Wagenaar, P. The Good Cause: Theoretical Perspectives on Corruption. Barbara Budrich Graeff, P. Grieger, J. (2012): Was ist Korrupt? Begriffe, Grundlagen und Perspektiven Gesellschaftswissenschaftlicher Korruptionsforschung. Berlin: Nomos Klitgaard, R. (1988): Controlling Corruption. Berkeley Klitgaard, R. (2006): Subverting Corruption. Global Crime 7 (3 4) pp Pallai, K. (2012): Kooperatív tárgyalás és konfliktuskezelés. Jegyzet. (Cooperative Negotiation and Conflict Management. Notes.) Nemzeti Közszolgálati Egyetem. Vezetőképző és Továbbképző Intézet. Budapest. (download: uploads/2010/11/pallai-kooperatív-tárgyalás-és-konflktuskezelés.pdf) Persson, A. Rothstein, R. Teorell, T. (2013): Why Anticorruption Reforms Fail. Systemic Corruption as a Collective Action Problem. Governance: An International Journal of Policy, Administration, and Institutions, Vol. 26, No. 3, July 2013, pp Peters, G. B. (2010): Institutional Design and Good Governance. In: Graaf, Gjalt de Patrick von Maravic, Pieter Wagenaar eds. 2010: The Good Cause: Theoretical Perspectives on Corruption. Barbara Budrich Verlag Pope, J. (Ed.) (1996): National Integrity Systems: the TI Sourcebook. Berlin: Transparency International Ackerman, R. (2010): The Institutional Economics of Corruption. In: de Graaf, G. von Maravic, P. Wagenaar, P. (Eds.) (2010): The Good Cause: 162 Public Finance Quarterly 2014/2
15 Theoretical Perspectives on Corruption. Barbara Budrich Rothstein, B. (2011a): Anti-Corruption: The Indirect Big Bang Approach. Review of International Political Economy. 18 (2) pp Sampford, C. Smith, R. Brown, A. J. (2005): From Greek Temple to Bird s Nest: Towards a Theory of Coherence and Mutual Accountability for National Integrity Systems. Australian Journal of Public Administration. 64(2), pp Sampson, S. (2010): The Anti-corruption Industry: from Movement to Institution. Global Crime, Vol. 11, No. 2, May 2010, pp Six, F. Lawton, A. (2013): Towards a Theory of Integrity Systems: a Configurational Approach. International Review of Administrative Sciences , p. 639 Szabó, M. (2012): Közpolitikai diskurzuselemzés (Discourse Analysis in Public Policy). MTA, PTI: Working Papers in Political Science. 2012/7. pdf Weöres, S. (2000): A teljesség felé (Towards Integrity). Tericum Kiadó. EU (2014): Anti-Corruption Report. Brussels: European Commission Public Finance Quarterly 2014/2 163
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