Krisha Nell B.

Lopez July 1, 2023

2021-70022

PA/BA 401 – Organization and Management

REACTION PAPER 2
Enhancing Ethical Decision Making in Government Procurement

The process through which the government purchases the products, services, and labor it
requires from commercial enterprises is known as government procurement (GMP, 2023). To promote
transparency, responsibility, competitiveness, and public oversight in government procurement, several
laws and regulations are in place (GPPB, 2003). Republic Act No. 9184, often known as the Government
Procurement Reform Act (GPRA, 2003), is the fundamental law in the Philippines that regulates public
procurement (GPPB, 2003). The organization in charge of carrying out and overseeing the government's
procurement policies and initiatives is known as the Government Procurement Policy Board-Technical
Support Office (GPPB-TSO) (GPPB, 2003).

The process of selecting the optimal course of action that is consistent with the moral standards
and principles of the public sector is known as ethical decision-making in government procurement. The
interests of many stakeholders must be balanced, the rule of law and professional standards must be
upheld, conflicts of interest and corruption must be prevented, and transparency and accountability
must be promoted.

In order to serve the common good, ethical decision-making in government procurement must
ensure that public resources are used effectively, fairly, and efficiently. Making ethical decisions also
contributes to preserving the public's trust in the government and its institutions as well as preserving
the civil service's reputation and integrity (Whitton , 2021).

Some of the factors that affect ethical decision making in government procurement are:

 The project governance criteria, include the project's goals, scope, finances, quality, risk, and
stakeholder management (Hassim, Kajewski, & Trigunarsyah, 2017).
 The values, traditions, beliefs, and practices that make up the organizational culture influence
how government employees behave and think (Hassim, Kajewski, & Trigunarsyah, 2017).
 The technical requirements, evaluation techniques, selection processes, and contract clauses are
the contract award criteria (Hassim, Kajewski, & Trigunarsyah, 2017).
 The particular standards, such as a public servant's moral character, skill level, drive, and
professionalism (Hassim, Kajewski, & Trigunarsyah, 2017).
 The demands, expectations, and preferences of the project's end users or beneficiaries are
examples of the client's requirements (Hassim, Kajewski, & Trigunarsyah, 2017).
 The procedures of the government, including the laws, rules, policies, and directives that control
the procurement process. (Hassim, Kajewski, & Trigunarsyah, 2017).
 The professional ethics that apply to government employees and other parties involved in the
procurement process, such as codes of conduct, standards of behavior, and ethical principles
(Hassim, Kajewski, & Trigunarsyah, 2017).
 The solution on the case “Enhancing Ethical Decision Making in Government Procurement”
provided by the 2nd group identified weaknesses of the Philippine government procurement process
such as potential for corruption and lack of transparency. The ethical considerations and dilemmas
like bribery, kickbacks, conflict of interest, unfair labor practices, environmental damage, and
extortion are also an issue in the procurement process. While confirmation and unconscious bias are
cognitive biases that can affect the objectivity and fairness of government procurement.

The fairness, efficiency, and transparency of government procurement are seriously hampered
by corruption and a lack of transparency. Transparency is the ability of the public to obtain accurate,
thorough, timely, and reliable information about the procedures and results of government
procurement. Accountability, involvement, and confidence in the government are all fostered by
transparency (Batalla, 2020). Corruption thrives in environments where there is a lack of
transparency, particularly when it comes to large-scale infrastructure or military projects with foreign
funding. Additionally, a lack of transparency lowers the caliber and efficacy of public goods and
services as well as the taxpayers' return on investment. On the other hand, fairness entails that the
rules of equality, non-discrimination, and competition are followed in the government's
procurement process. Fairness makes certain that each prospective supplier has equal access to
information and chances to submit a bid for a contract (Freeman, 2016). When it comes to awarding
contracts, a lack of impartiality breeds favoritism, nepotism, collusion, and bribery. Injustice also
erodes the public interest and the private sector's ability to innovate and act with confidence.
Efficiency refers to how well the government uses its resources to buy goods and services. Efficiency
necessitates streamlining, standardizing, and simplifying the procurement procedures (Freeman,
2016). Lack of efficiency leads to contract implementation delays, cost overruns, waste, and fraud.
Efficiency issues also threaten the longevity and effectiveness of public investments.

Employees of one corporation may bribe or kickback other employees or public authorities in
order to gain an advantage. This is known as "bribery" or "kickbacks." Examples include bribing
procurement employees in order to influence their choice in the paying company's favor, sending a
costly gift to a bank manager in order to obtain a loan, and different kickback schemes. As bribery
and kickbacks lower the quality and efficiency of goods, works, or services delivered, increase the
costs and risks of projects, and waste public resources, they can jeopardize the lives and well-being
of people who depend on the public services. This can also compromise the transparency and
fairness of the procurement process as well as the quality and cost-effectiveness of the goods or
services procured.

Extortion and solicitation take place when a worker for a corporation or a public official asks for a
cash, unfair advantage, pricey presents, or sexual favors in exchange for carrying out particular
responsibilities or coming to a decision. Additionally, it may undermine the fairness and integrity of
the bidding process and foster an atmosphere of intimidation and fear among prospective bidders.

A conflict of interest arises when a public official has a personal or financial interest in a
business, contract, or transaction that he intervenes in, participates in, or is banned from him having
any involvement in. This may result in favoritism, nepotism, cronyism, clientelism, or other types of
preferential treatment, which can skew the procurement process and give some parties unjustified
advantages, privileges, or preferences.
 Unfair labor practices are when employers or contractors violate labor laws or standards, such as
when they underpay employees, violate health and safety laws, discriminate against workers, or use
forced or child labor. These may have an impact on the procurement process' effectiveness and
quality, as well as the social and economic well-being of the workforce and the communities where
they live.

Environmental damage is when contractors or suppliers disrupt the environment or break

environmental rules or standards, such as by contaminating water supplies, damaging habitats,
generating greenhouse gases, or utilizing hazardous chemicals. These have an impact on the
environment's resilience and sustainability as well as the effectiveness and caliber of the
procurement process.

Employee embezzlement occurs when they take anything of value that was given to them
because of their position. This may have an impact on the procurement process's effectiveness and
quality, as well as the transparency and reliability of public monies.

The existing decision-making models and processes used in government procurement in the
Philippines have strengths and weaknesses.

Strengths:

 The Government Procurement Reform Act (GPRA) of 2003 consolidated all fragmented
laws and policies on public procurement and established open, transparent, and
competitive bidding as the standard.
 The Government Procurement Policy Board (GPPB) was established to provide policy
recommendations, rule-drafting, training, evaluation, and monitoring of the government
procurement system.
 The Agency Procurement Compliance and Performance Indicators (APCPI) was adopted
to assess the procurement practices of the agencies and to identify areas of risk and
weakness.
 The Philippine Government Electronic Procurement System (PhilGEPS) was modernized
to expand its functionalities and to enable e-bidding.
 The Procurement Service (PS) was maximized to leverage the bulk-buying powers of the
government and to save on costs.

Weaknesses:

 The procurement rules and procedures are complex, unclear, and create barriers to
access procurement opportunities.
 The institutions that conduct procedures and conclude, manage, and monitor public
contracts are ineffective and lack coordination.
 The human resources that plan and carry out the procurement processes are
unsustainable and lack capacity.
 The electronic tools that facilitate the process are inadequate and unreliable.
 The contract management is incompetent and prone to corruption.
 The GPRA of 2003 is compliant with ethical norms and best practices in public procurement
because it is based on international standards like the World Trade Organization Agreement on
Government Procurement and the UNCITRAL Model Law on Procurement of Goods, Construction, and
Services. Value for money, effectiveness, efficiency, justice, and honesty in government procurement are
also included in the law.

The GPRA of 2003 is still being implemented and enforced, although there are still certain
difficulties and problems, such as delays, capacity gaps, political intervention, and corruption. As a result,
ongoing efforts are required to enhance the procurement system and guarantee that it complies with
the highest moral principles and industry best practices.

By ensuring that the procurement process is carried out in line with the principles of good
governance, such as competition, transparency, accountability, efficiency, and economy, the APCPI aligns
with ethical standards and best practices. The APCPI also encourages the use of performance indicators
to evaluate outcomes and compliance, as well as to spot problem areas and take corrective action. The
APCPI also encourages the creation of systems for the evaluation of data pertaining to procurement and
their integration with other databases used by the government for the formulation of policy and
decision-making.

The GPRA and its Implementing Rules and Regulations (IRR) require the PhilGEPS to adhere to moral
principles and best practices in public procurement. However, there could be difficulties and weaknesses
in the system's implementation and operation, such as technological problems, the need to build
capacity, monitor compliance, and receive input from stakeholders.

Here are some specific examples of where decision makers in the government procurement
process may have been influenced by time constraints, limited information, or personal biases:

Time constraints: Decision makers may rush to award a contract before a deadline or a budget
cut, leading to insufficient evaluation of bids or overlooking important criteria. For example, a study by
Dekel and Schurr (2014) found that time pressure increased the likelihood of choosing the lowest bidder,
even when other factors such as quality and reliability were more important.

Limited information: Decision makers may rely on incomplete or inaccurate information to make
their judgments, leading to suboptimal choices or errors. For example, a bid protest by Oracle against the
Department of Defense’s $10 billion JEDI cloud contract award to Microsoft claimed that the
procurement process was flawed due to lack of information about Microsoft’s compliance with security
requirements (Tsipursky, 2022).

Personal biases: Decision makers may be influenced by their own preferences, emotions,
relationships, or cognitive biases, leading to unfair or irrational decisions. For example, a common bias in
procurement is favoring the incumbent bidder or the bidder who has established rapport with the
evaluators, regardless of their actual performance or suitability. Another common bias is groupthink,
where evaluators conform to the opinions of a dominant or influential member of the group, rather than
expressing their own independent views.
 The role of the BAC in government procurement may be affected by various group dynamics,
power imbalances, or instances of groupthink. For example:

If the BAC has the following characteristics: a well-balanced and diverse membership with
relevant expertise and experience; a democratic and participatory structure that permits open
communication and constructive feedback; a high level of cohesion and trust that fosters cooperation
and commitment; and if it operates with these characteristics, the BAC may experience positive group
dynamics.

The BAC may encounter negative group dynamics if it has an unclear or conflicting goal of
satiating multiple or competing interests in the procurement process, if its membership is unbalanced or
homogeneous and has limited or biased knowledge or skills, if its structure is authoritarian or chaotic
and prevents communication and feedback, if there is a lack of cohesion and trust that fosters conflict
and apathy, and if its leadership is ineffective or coercive.

The BAC may experience power disparities if some members have more authority or influence
than others due to their rank, position, seniority, expertise, connections, or resources; if some members
depend more on others for information, support, or rewards; if some members enjoy greater privileges
or favors than others due to their personal traits or affiliations; or if some members are more exposed or
vulnerable than others due to their roles or responsibilities.

The BAC could become subjected to groupthink if it is extremely cohesive and cut off from
outside sources of information or evaluation, if it is threatened or under pressure from internal or
external factors, if it is influenced by a directive leader who has a preferred solution or agenda, or if it is
lacking in diversity or processes for generating and testing alternatives.

These are but a few hypothetical situations that show how group dynamics, power disparities, or
groupthink may influence the function of the BAC in public procurement. These are by no means all
possible or deterministic explanations. The performance and behavior of the BAC may be impacted by
additional elements or circumstances. Additionally, the BAC may take action to prevent or address these
potential difficulties by implementing best practices, such as establishing precise and uniform rules and
criteria for procurement, obtaining opinions and suggestions from experts and stakeholders, fostering a
culture of integrity and professionalism, and fostering critical thinking and constructive dissent.

The Code of Conduct and Ethical Standards for Public Officials and Employees (Republic Act No.
6713), which was approved on February 20, 1989 and went into effect on March 25, 1989, serves as the
foundation for the ethical decision-making framework currently used by government agencies in the
Philippines. The Code covers the duties and obligations, behavior and ethical standards, and disciplinary
mechanisms for public officials and employees. It also outlines the State's intention to encourage a high
standard of ethics in public service.

The Code also mandates that all departments, offices, and agencies begin implementing value-
development initiatives for their officials and staff in order to strengthen their dedication to public
service and support the idea that the public interest should take precedence over individual interests
when carrying out their duties1. These programs ought to cover topics including moral and ethical
principles, the obligations of public employees, patriotism and nationalism, justice and human rights,
democracy, Philippine history and culture, and socioeconomic realities.
 In order to improve the professionalism, excellence, intelligence, and abilities of officials and
employees in the performance of their duties and obligations, the Code also requires professional,
scientific, and technological trainings and education programs.

In addition to the Code, there are other mechanisms and initiatives that aim to implement
effective ethics standards in government and the civil service, such as:

Identifying specific challenges to the public sector's ethics standards and integrity and putting
the required political and management measures in place in response (Whitton , 2021);

Building an ethical culture that encourages professional responsibility, self-discipline, and

support for the rule of law; strengthening the ethical competence of civil workers (Whitton , 2021);

Establishing administrative procedures and practices that support moral principles and integrity,
such as accountability procedures, performance management methods, and anti-corruption agencies
(Whitton , 2021);

Applying moral principles and making decisions in a way that takes into account the rights,
interests, virtues, and concerns of all parties involved.

The government procurement reform agenda in the Philippines, according to the Government
Procurement Policy Board - Technical Support Office (GPPB-TSO), aims to modernize, standardize, and
regulate the government's procurement activities while adhering to the guidelines set forth in The
Government Procurement Reform Act of 2003 (R.A. 9184).

In the Philippines and other nations, long-term objectives, stakeholder participation, and risk assessment
are significant elements that may influence decision-making in government procurement. They might be
able to affect the procedure in the following ways:

Long-term goals

The vision, mission, and objectives of the government procurement system, as well as the anticipated
effects and consequences of the procurement activities, can be defined with the use of long-term goals.
In order to ensure alignment with public interest and national development priorities, long-term goals
can also be used to influence the creation of policies, strategies, plans, and budgets for government
procurement. Long-term objectives can serve as a framework for assessing the efficiency and
performance of the government procurement system as well as pinpointing opportunities for innovation
and improvement.

Stakeholder engagement

By incorporating individuals who are affected by or interested in the procurement process, stakeholder
engagement can assist increase the legitimacy and quality of government procurement decisions.
Engagement of stakeholders can also aid in identifying and evaluating the requirements, preferences,
worries, and expectations of various stakeholder groups, as well as potential risks and possibilities linked
to various procurement solutions. Stakeholder engagement can increase the public's understanding of
and involvement in government procurement, as well as trust, openness, accountability, and
collaboration among stakeholders.
Risk assessment

Risk analysis can be used to pinpoint and examine the causes, propensities, and effects of uncertainty
and variability in public procurement, including market circumstances, supplier performance, logistical
difficulties, legal issues, corruption, fraud, environmental effects, etc. The development and use of
suitable risk management plans and strategies, as well as the monitoring and reaction to new or
changing hazards, can all be aided by risk assessment. By offering pertinent data and insights on the
costs, advantages, and trade-offs of various procurement options, risk assessment can assist evidence-
based decision making in government procurement.

Due to the fact that they include the distribution of public funds and the provision of public goods and
services, procurement decisions are crucial for attaining the agency's strategic goals and the public
interest. Several instances of strategic considerations in decision-making include:

Value for money refers to selecting the procurement strategy and supplier that will best meet the needs
of the agency and the end users in terms of quality, cost, and performance. Value for money also takes
into account the costs and advantages of the purchase over its whole life, including maintenance, the
influence on the environment, social responsibility, and the possibility for innovation.

Transparency and accountability entail making sure the procurement process is transparent, equitable,
and competitive as well as that all parties involved are informed of the decisions made and how they
were reached. The establishment of procedures for oversight, assessment, and feedback as well as the
prompt and efficient resolution of complaints and disagreements are further aspects of transparency
and accountability.

Alignment with policy goals entails taking into account how the acquisition can contribute to or promote
the agency's and the government's overarching objectives, such as environmental sustainability, social
inclusion, innovation, economic development, and regional integration. Coordination and coordination
with other agencies, governmental levels, and outside partners who have similar interests or obligations
are also necessary for aligning with policy objectives.

Some strategies to integrate these strategic dimensions into the procurement process in the Philippines
are:

Creating a strategy and plan for the procurement: This is a document that specifies the goals,
parameters, strategy, tactics, risks, and resources of the procurement. The best solutions should be
chosen, responsibilities should be assigned, and deadlines should be established for each stage of the
procurement process. In addition to informing and consulting with stakeholders, a procurement strategy
and plan also serves as a benchmark for tracking and assessing the performance of the purchase.

Observing the legal and regulatory framework: In the Philippines, public procurement is governed and
overseen by a series of laws and regulations. It seeks to guarantee that public procurement adheres to
the interests of the nation, good governance, transparency, responsibility, and efficiency. The
Government Procurement Policy Board (GPPB) is established as the policy-making body and governing
authority on public procurement by Republic Act No. 9184 (R.A. 9184), commonly known as the
Government Procurement Reform Act. The GPPB develops and updates policies, guidelines, and rules
governing public procurement, creates standard bid documents and manuals, ensures that procuring
entities follow them correctly, holds training sessions, and assesses the efficacy of R.A. 91842.
Using alternative or creative means for acquiring goods or services might result in better value for
money, transparency, accountability, and alignment with policy goals than conventional techniques.
Examples include:

Green public procurement (GPP): This method involves choosing products or services that have a smaller
overall environmental impact. GPP can support green innovation, the promotion of renewable energy
sources, and the reduction of greenhouse gas emissions. How to apply GPP in public procurement
systems is provided by the OECD (OECD, 2019).

Innovation procurement: This is a process that encourages or supports the creation or acceptance of
fresh, improved responses to problems that face public sector organizations or society as a whole.
Innovation procurement can improve the delivery of public services, promote economic expansion, aid
in R&D, and open up new markets. The European Commission offers resources and assistance for the
EU's purchase of innovation (OECD, 2019).

Socially responsible public procurement (SRPP): This method involves including social factors, such as
human rights, labor laws, gender equality, social inclusion, and empowerment, in choices about public
procurement. SRPP can support social cohesion, promote inclusion and diversity, lessen poverty and
inequality, and improve working conditions. Guidelines on how to adopt SRPP in public procurement
practices are provided by the European Commission (OECD, 2019).

Comprehensive plan with specific actions, timelines, and metrics to evaluate the success of the
implemented solutions in enhancing ethical decision making in government procurement:

The plan tries to address any ethical problems that might come up during the project's procurement
process, including conflicts of interest, bid-shopping, collusive tendering, bid-cutting, corruption, and the
payment game. The strategy also aspires to further the key ethical principles of accountability, openness,
and professionalism in the public sector.

The plan consists of four main components:

1. Creating and enforcing an ethics and conduct code for public officers and employees who work
on project procurement.
2. Enhancing through education and training the ethical consciousness and competence of public
personnel.
3. Establishing and enforcing efficient systems for tracking, reporting, and punishing unethical
project procurement activities.
4. Improving the project's procurement process's openness and transparency to attract more
public interest and engagement.

Component Action Timeline Metric

Code of ethics and 1. Review existing 1. 3 months 1. Number and
conduct codes of ethics and 2. 6 months quality of
conduct for public 3. 9 months gaps or areas
officials and civil 4. 12 months for
servants and improvement
identify gaps or identified
areas for 2. Number and
 improvement quality of
2. Consult with stakeholder
relevant inputs
stakeholders, such received
as government 3. Level of
agencies, approval
professional obtained
associations, civil 4. Percentage
society of public
organizations and officials and
private sector civil servants
representatives, to who receive
develop a draft and sign the
code of ethics and code of
conduct that ethics and
reflects the specific conduct
challenges and
expectations of
project
procurement
3. Seek approval from
the appropriate
authority for the
adoption and
implementation of
the code of ethics
and conduct
4. Disseminate the
code of ethics and
conduct to all
public officials and
civil servants
involved in project
procurement and
ensure they sign a
pledge to abide by
it
Ethical competence 1. Conduct a baseline 5. 3 months 1. Score or
and awareness assessment of the 6. 6 months rating of
current level of 7. 9 months ethical
ethical 8. 12 months competence
competence and and
awareness among awareness
public officials and before the
civil servants program
involved in project 2. Number and
procurement quality of
2. Design and deliver training
 a comprehensive sessions
training and delivered
education program 3. Score or
on ethical decision rating of
making in project ethical
procurement, competence
covering topics and
such as ethical awareness
principles, values, after the
dilemmas, program
frameworks, tools 4. Number and
and best practices quality of
3. Evaluate the support or
effectiveness and guidance
impact of the requests
training and received
education program
on improving the
ethical
competence and
awareness of
public officials and
civil servants
4. Provide ongoing
support and
guidance to public
officials and civil
servants on ethical
issues or
challenges they
may encounter in
project
procurement
Monitoring, 1. Establish an 1. 6 months 1. Number and
reporting and independent 2. 9 months quality of
sanctioning oversight body 3. 12 months members or
or committee 4. 12 months staff
to monitor, onwards appointed to
investigate and the oversight
sanction body or
unethical committee
practices in 2. Number and
project quality of
procurement. procedures
2. Develop clear and criteria
procedures and developed
criteria for 3. Number and
reporting, quality of
 verifying, reports
investigating received
and sanctioning from whistle-
unethical blowers
practices in 4. Number and
project quality of
procurement reports
3. Implement a published by
whistle-blower the oversight
protection body or
policy to committee
encourage
reporting of
unethical
practices in
project
procurement
without fear of
retaliation
4. Publish regular
reports on the
activities,
findings and
outcomes of
the oversight
body or
committee
Transparency and 1. Implement a 1. 12 months 1. Number and
openness transparent 2. 12 months quality of bids
bidding process 3. 12 months received and
that ensures 4. 12 months contracts awarded.
fair 2. Number and
competition, quality of
equal access to information requests
information, received and
objective responded
evaluation 3. Number and
criteria, timely quality of
feedback and participants and
public inputs in the
disclosure of participatory
contract awards monitoring
2. Implement a mechanism
freedom of 4. Number and
information law quality of feedback
that allows received and
public access to addressed
information on
 project
procurement
processes,
decisions,
contracts,
performance,
audits and
evaluations
3. Implement a
participatory
monitoring
mechanism
that involves
civil society
organizations,
private sector
representatives
, media outlets
and other
stakeholders in
overseeing
project
procurement
processes,
outcomes and
impacts
4. Implement a
feedback
mechanism
that allows
public officials,
civil servants,
contractors,
suppliers,
beneficiaries
and other
stakeholders to
provide
comments,
suggestions or
complaints on
project
procurement
processes or
outcomes.

Evaluation
The success of the plan will be evaluated based on the following indicators:

1. The degree to which public officials and civil servants involved in project procurement uphold
the code of ethics and conduct.
2. The extent to which public authorities and civil servants participating in project procurement
have improved their ethical competence and awareness.
3. The extent to which unethical project procurement practices have decreased in frequency and
intensity.
4. The degree to which the project procurement process has become more transparent and open.
5. The degree to which beneficiaries, suppliers, contractors, and other stakeholders are satisfied
with and trust the project procurement process.

An independent external evaluator will carry out the assessment utilizing a mixed-methods approach,
which will include surveys, interviews, focus groups, document analysis, case studies, and statistical
analysis. After the first year of implementation, the evaluation will be done once, and then every year
after that.

References
Batalla, E. V. (2020). Grand corruption scandals in the Philippines. Public Administration and Policy: An
Asia-Pacific Journal.

Freeman, S. P. (2016, August 3). Transparency and accountability in military spending. Retrieved from
STOCKHOLM INTERNATIONAL PEACE RESEARCH INSTITUTE:
https://www.sipri.org/commentary/topical-backgrounder/2016/transparency-and-
accountability-military-spending

GMP. (2023). WHAT IS GOVERNMENT PROCUREMENT? Retrieved from Government Marketing &
Procurement: https://www.gmpgov.com/what-is-government-procurement/

GPPB. (2003). Government Procurement Policy Board – Technical Support Office. Retrieved from
Government Procurement Policy Board: https://www.gppb.gov.ph/government-procurement-
policy-board-technical-support-office/

Hassim, A. A., Kajewski, S., & Trigunarsyah, B. (2017). Factors Affecting Project Governance in Ethical
Decision Making for Public Sector Project Procurement – A Delphi Study. Journal of
Administrative Science.

OECD. (2019). Reforming Public Procurement : Progress in Implementing the 2015 OECD
Recommendation. Retrieved from OECD Library: https://www.oecd-ilibrary.org/sites/717274af-
en/index.html?itemId=/content/component/717274af-en

Tsipursky, G. (2022, December 7). The Danger Of Bias In Bid Procurements And Contract Awards.
Retrieved from Forbes: https://www.forbes.com/sites/glebtsipursky/2022/12/07/the-danger-of-
bias-in-bid-procurements-and-contract-awards/?sh=36b64c832dd4

Whitton , H. (2021). IMPLEMENTING EFFECTIVE ETHICS STANDARDS IN GOVERNMENT AND THE CIVIL
SERVICE. Transparency International.