Integrity Programs in the Public Sector: New Guidelines

On September 22, 2025, through Resolution 12/2025, the Anti-Corruption Office (OA) approved the Guidelines for the Development of Integrity Programs in the Federal Public Sector. These Guidelines were developed within the framework of the Integrity Policy Observatory and included contributions from public agencies with competence in integrity, transparency, and oversight matters (such as the Data Protection Authority and the General Audit Office) and from civil society.

According to the text of the Guidelines, the document is intended to serve as a roadmap to develop and implement of integrity programs within the jurisdictions, agencies, and entities of the federal public sector, in accordance with the risks, specific characteristics, and challenges of each. Its objective is to establish common guidelines and quality standards to design and implement such programs, preserving consistency, ensuring effectiveness, and aligning them with international best practices.

The Guide is divided into two main sections:

1. Practical Aspects.
2. Components of an Integrity Program.

Section 1 includes guidelines to design, draft, approve, implement, monitor, and evaluate integrity programs. Key elements include:

• Institutional support: the highest authority of the jurisdiction or agency must endorse the initiation of the process through an official communication accompanying the dissemination of the program.
• Initial diagnosis: this is a critical stage that may include various methods:

(a) institutional context analysis,

(b) situational analysis,

(c) integrity and transparency climate, indicators, and metrics.
 

• Risk identification: every integrity program must begin with a proper assessment of vulnerabilities and risks related to ethics and transparency, and then determine their impact on efficiency, effectiveness, and reputation, together with identifying mitigation measures.
• Drafting and approval: this involves consolidating proposals into a document that the highest authority of the jurisdiction or agency will approve.
• Minimum content: every Integrity Program should include:
  1. mission and functions,
  2. applicable regulatory framework,
  3. scope,
  4. objectives, actions, and tools,
  5. internal and external coordination mechanisms,
  6. definition of a governance system,
  7. resources and timelines,
  8. monitoring and evaluation mechanisms,
  1. training plan.
• Implementation and monitoring: these are meant to ensure effective governance and structured, systematic monitoring.
• Assessment: after a period of implementation, results and impact should be evaluated, verifying the achievement of objectives and adopting necessary adjustments to improve effectiveness and efficiency.

Section 2 outlines the main components and key tools that every integrity program should have, including:

• Code of Ethics: to promote the values and principles guiding the behavior of all members of the jurisdiction or agency.
• Actions related to effective transparency: to ensure access to public information.
• Conflict of interest management: to include necessary measures to prevent, detect, and—if applicable—enforce accountability for conflicts of interest.
• Actions to ensure compliance with the Comprehensive Asset and Activity sworn statements: to incorporate mechanisms to ensure compliance with the Comprehensive Asset Disclosure Regime and the Monitoring System for Private and Public Activities Before and After Holding Public Office.
• Actions to ensure compliance with the Registry of Gifts to Public Officers and Registry of Trips financed by third parties: to include mechanisms to ensure compliance with the Gift Regime for Public Officials and Third-Party Funded Travel (Law 25188 and Decree 1179/2016).
• Registry of Interest Management Meetings with Public Officials: to include mechanisms to ensure compliance with the Interest Management Publicity Regime.
• Integrity in public procurement: to include mechanisms to promote ethics and transparency in public procurement.
• Citizen and institutional participation: to include mechanisms to promote citizen engagement.
• Improvement of administrative processes: to encourage collaboration between integrity officers and teams responsible for process improvement within the jurisdiction or agency.
• Promotion of an integrity culture: to encourage public officials to internalize ethical values and commit to their observance.
• Consultation management: to establish a channel for inquiries, assistance, and advisory services.
• Complaint management: to establish a reporting channel and/or provide support for submitting complaints to the competent internal areas (disciplinary proceedings) or to judicial or oversight bodies.
• Periodic risk analysis: to assess the emergence of new threats and vulnerabilities.
• Designation of a specific area or individual within the jurisdiction or agency responsible for integrity and transparency policies.

The Guidelines also include indicators and practical examples, a glossary of terms, and a regulatory and bibliographic appendix to support its proper implementation.

Although the document was designed to be applied within the federal public sector, the OA will also promote that provinces and municipalities adopt them.

This initiative represents another step toward consolidating a comprehensive public integrity system aimed at strengthening transparency; preventing corruption; and promoting a more ethical, transparent, and citizen-oriented public administration.