In 2011, the Association of Chief Police Officers (ACPO) approached Transparency International UK (TI-UK) to commission an external review of a report written by ACPO itself, entitled ‘Managing Police Integrity: ACPO Approach 2011’. ACPO asked TI-UK to review this report, make recommendations for amendments, and identify areas for improvement.
TI-UK is an anti-corruption organisation that has extensive experience in reviewing policies and practices relating to organisational integrity. TI-UK has published a series of guides to good practice in this area, for example ‘The 2010 UK Bribery Act – Guidance on Good Practice procedures.’ TI-UK works with organisations in the private, public and voluntary sectors.
TI-UK had previously undertaken an in-depth research project on UK corruption, the most comprehensive research ever undertaken in this area. ‘Corruption in the UK’ published in 2011, reviewed twelve pillars of ‘national integrity’ including law enforcement. The research found little evidence of systemic corruption in the UK police, but significant, and growing, opportunity for corruption of and by individual officers and support staff. ‘Corruption in the UK’ highlighted the need for well-designed and adequately-resourced integrity programmes reinforced by ethical leadership. In TI-UK’s view, engaging with organisations such as ACPO presents an opportunity to create change from within, and to do so by highlighting good practice from TI’s experiences both within the UK and globally.
TI-UK took on the assignment from ACPO in November 2011 and submitted its report entitled ‘Benchmarking Police Integrity Programmes’ in May 2012. The terms of reference for the report are available to download here.
Since the completion of ‘Benchmarking Police Integrity Programmes’, the Leveson report has been published and Police and Crime Commissioners have been elected in England and Wales. These developments have shone the spotlight on police corruption and police governance structures.
The ‘Benchmarking Police Integrity Programmes’ report sets out TI-UK’s views on what constitutes good organisational integrity practice and how this could be applied to the police. The paper then comments on how the ACPO review, ‘Managing Police Integrity’, compared with TI-UK’s view on good practice. It identifies recommendations for improvement in policy integrity programmes.
The core finding identified in TI-UK’s report is that there is considerable variability in the quality of integrity systems and governance in police forces in England, Wales, and Northern Ireland. ACPO therefore needs to ensure that:
• common standards, that are robust, clear and consistent, are embedded across Forces;
• those standards should be characterised by clarity and consistency.
In addition, TI-UK made eight other recommendations:
• Model integrity code: ACPO should build on its work in developing a model police integrity code supported by tools and resources to be applied in a consistent manner across Forces;
• Clarity and consistency: All those who manage integrity programmes or are governed by them should be able to easily understand their roles, obligations, procedures and rights, and the integrity programmes should also be clear to the public and other stakeholders;
• Positive integrity management: ACPO should assist Forces to move from a reactive approach to a stance of active promotion of integrity, based on the principle of zero tolerance of corruption;
• Common systems: Forces should implement common robust systems supported by guidance and tools to ensure that risks are identified, monitored, and managed;
• Governance: ACPO must consider how necessary independent oversight can be brought into and embedded within the governance process;
• Disciplinary measures: Further consideration should be given to disciplinary measures in the context of The Police (Conduct) Arrangements of 2008 - a good practice integrity programme should be founded on a zero tolerance approach to integrity violations. Any relaxation of disciplinary measures could undermine an effective integrity programme;
• Public reporting: ACPO should take the lead in developing a common nation-wide standard for public reporting by Forces;
• Comprehensive and continuous approach to risk assessment: The risk assessment process should be reviewed and strengthened to ensure that the process is robust, comprehensive and up-to-date in capturing emerging or changing risks such as those related to outsourcing, procurement, secondary employment and post-service employment.
TI-UK urges ACPO and the Forces to accept its recommendations in full.