The Municipality of Milan is of the strong opinion that corruption can only be fought effectively if preventative, as well as punitive, measures are employed. In January 2014, the city approved a Three-Year Anti-Corruption and Transparency Plan, which is updated annually.
The Plan, approved by the Municipal Council on the proposal of the Secretary General acting as the Anti-Corruption and Transparency Officer, is the result of an analysis shared with all executive members of the Municipality. The analysis takes the following into account: the external and internal environment of the administration; the strengths and weaknesses of its work processes; the information coming from the Anti-Mafia and Transparency Council Commission and the various stakeholders who deal with the Entity.
The Anti-Corruption Plan of Milan is a very practical working tool that identifies:
- areas of activity exposed to a greater risk of corruption
- organisational measures to be taken to avoid/reduce the possibility of corruption events
- the timetable for implementing the measures
- the executives responsible for implementing the measures
The Plan’s strength is its involvement of all the Municipality’s political bodies and its employees, who are asked to share and implement its rules. Their main objectives are to create a hostile environment to corruption, to reduce the opportunity for corruption events to occur and to be able to uncover any cases of corruption that have occurred within the Entity.
With the support of the Internal Audit Department and a risk manager, the Municipality of Milan has developed a particularly effective method of mapping out corruption risk which, for the purposes of identifying the degree of exposure to corruption risk, takes into account the extent to which administrative activity is discretionary; the existence of transparency rules; the presence of third-party economic interests; the existence of conflicts of interest; and progress in implementing the anti-corruption measures laid out in the Plan.
The Municipality, which has also adopted an ethical code of conduct, invests heavily in training its staff in both specific anti-corruption issues and on ethical values, and is aware that the fight against corruption first requires a process of cultural development.
Of the main measures set out in the plan, those on staff rotation, control measures, the introduction of transparency rules, integrity pacts for public procurement, pantouflage and the possibility of reporting unlawful acts are particularly significant.
The Municipality of Milan has recently strengthened the Integrity Pacts in its tendering procedures, with the inclusion of express reference to so-called revolving door rules aimed at preventing the hiring of former public employees (who have issued authorisations or stipulated contracts) by the contractor in the three years following the termination of public sector employment.
The Municipality of Milan has also promoted, again through Integrity Pacts, better knowledge of the practice of the reporting of illegal actions, or so-called whistleblowing, including by workers and contractors of companies supplying goods or services or carrying out works for the Public Administration. The Law also allows the above-mentioned parties to make use of the practice of whistleblowing to report any irregularities arising in the management of the contractual relationship with the Municipality of Milan.
In addition to the above, the Municipality of Milan has taken no less significant action to combat the practice of recruiting labour in violation of the legislation on human trafficking, by including clauses in its tender regulations that require those bidding for the contract to declare their commitment when fulfilling contracts to not employ subcontractors that use recruitment and labour practices in violation of the legislation on human trafficking.
As is well known, the issues and actions in question are of particular importance in the context of the strategy for combating corruption and illegality, and the Integrity Pacts are a useful tool to achieve this goal. This is because they aim to establish a set of rules of conduct to prevent the occurrences described above. They also seek to promote ethically appropriate behaviour for all bidders and all company employees when carrying out procedures for the awarding of goods, services and work, and when monitoring the fulfilment of the associated contract awarded.
