Preventing corruption and promoting public ethics at the local and regional level in Eastern Partnership countries.
Date: 2017-02-21
Institutions: European Committee of the Regions
Subjects: Armenia, Azerbaijan, Belarus, Georgia, Moldova, Ukraine, administrative structures, administrative transparency, corruption, ethics, public contract, public sector, public service, regional and local authorities

Preventing Corruption and Promoting 
Public Ethics at the Local and Regional 
Level in Eastern Partnership Countries 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
This  file  note  was  written  by  Clara  Volintiru,  PhD  (London  School  of 
Economics and Political Science – LSE / Bucharest Academy of Economic 
Studies  -  ASE),  Sergiu  Gherghina,  PhD  (University  of  Glasgow), 
Eleanor Knott,  PhD  (London  School  of  Economics  and  Political  Science  - 
LSE),  Professor  Radu  Mușetescu  –  (Bucharest  Academy  of  Economic 
Studies - ASE). 

It does not represent the official views of the Committee of the Regions. 

More information on the European Union and the Committee of the Regions is 
available  online  at  http://www.europa.eu  and  http://www.cor.europa.eu 
respectively. 

Catalogue: QG-02-17-215-EN-N 
ISBN: 978-92-895-0912-1 
doi:10.2863/3807 

© European Union, 2017 
Partial  reproduction  is  permitted,  provided  that  the  source  is  explicitly 
mentioned. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

Executive Summary ............................................................................................ 1 

Introduction: Methodology and Scope of Investigation .................................. 3 

Prevalence of Corruption at the Local and Regional Level in Eastern 
Partnership (EaP) Countries: Country Assessments ....................................... 6 

Armenia ............................................................................................................. 6 

Azerbaijan ......................................................................................................... 7 

Belarus ............................................................................................................... 9 

Georgia ............................................................................................................ 10 

Moldova ........................................................................................................... 11 

Ukraine ............................................................................................................ 13 

Prevalence of Corruption at the Local and Regional Level in Eastern 
Partnership (EaP) Countries: Cross-Country Comparisons ........................ 15 

Policy Recommendations for Strengthening the Institutional Capacity 
of  Local  and  Regional  Authorities  (LRAs)  in  Eastern  Partnership 
(EaP) Countries ................................................................................................. 24 

Annex 1. Prioritization Matrix for Corruption Problems in EaP 

Countries ............................................................................................ 28 

Annex 2. Expert Survey Questionnaire ........................................................... 29 

 
 
Executive Summary 

This  study  identifies  the  main  current  vulnerabilities  of  local  and  regional 
authorities  (LRAs)  in  Eastern  Partnership  (EaP)  countries  regarding  public 
procurement  and  public  services,  and  provides  a  systematic  assessment  of 
priority avenues of intervention. 

Research methods employed here involved an original expert survey designed 
to  systematically  evaluate  the  main  forms  of  corruption  occurring  at  the 
subnational  level  in  EaP  countries.  Targeting  relevant  experts  from  the  public 
sector, academia and CSOs, we aimed to disentangle the prevalence of specific 
forms  of  corruption  in  each  country,  as  well  as  the  most  suitable  means  to 
counter it. The original expert survey data was triangulated with existent studies 
and reports, as well as other primary data sources (e.g. institutional webpages). 

Key  findings suggest that the lack of transparency is the main vulnerability of 
LRAs  in  all  case  studies.  Nepotism  and  untrained  personnel  is  predominant 
concerns for public procurement across cases. Abuse of administrative resources 
in electoral campaigns along with nepotism are predominant concerns in terms 
of  public  service  delivery.  In  depth  country  analysis  shows  that  the  lack  of 
transparency  is  of  primary  concern  in  Azerbaijan  and  Belarus,  ambiguous 
legislation  is  the  most  stringent  problem  in  Armenia  and  Ukraine  (recent 
progress has been reported here); personnel recruitment and qualification is the 
core  issue  in  Georgia  and,  favoritism  in  public  procurement  procedures  is  the 
main  concern  in  Moldova.  Overall,  there  is  an  estimate  of  average  capacity  to 
counter corruption at the level of the LRAs in EaP countries. Georgia stands out 
as the most willing to engage in anti-corruption efforts, while Azerbaijan has the 
lowest  institutional  competence  to  engage  in  preventive  anti-corruption 
measures. 

Examples  provided  through  the  experts’  qualitative  assessment  illustrate 
specific corruption manifestations: preferential mechanisms in allocating public 
contracts  for  road  repairs  and  transportation  (e.g.  Kyiv,  Kharkiv,  Chișinău), 
construction  works  (e.g.  Minsk)  or  waste  management  (e.g.  Yerevan,  Bila 
Tservka,  Bălți),  as  well  as  those  referring  to  access  to  social  services  (e.g. 
Tblisi), public utilities – especially energy (e.g. Shuakhevi Hydropower plant), 
or construction permits (e.g. Chișinău). 

Recommendations  formulated  here  are  informed  by  the  benchmark  practices 
we  have  identified  in  each  case,  as  well  as  the  existent  challenges.  These 
include: digitalisation of bureaucratic public services (e.g. permits, certificates), 
centralised  online  system  for  announcing  job  openings  in  the  public  sector, 

1 

 
 
 
 
 
training  public  sector  employees  in  the  implementation  of  transparency 
measures  and  ethical  conduct,  allowing  citizens’  access  to  the  deliberative 
process of local councils etc.  

2 

Introduction:  Methodology  and  Scope  of 
Investigation 

is  one  of 

Corruption 
the  most  pervasive  phenomena  affecting  public 
administrations across the globe. With increasing prerogatives being transferred 
from  the  central  government  to  the  local  and  regional  authorities,  it  is  of 
paramount  importance  to  understand  the  mechanisms  that  favour  corruption  at 
the  subnational  level.  In  doing  so,  we  can  subsequently  engage  with  the  best 
measures to prevent it and promote public ethics. 

Figure 1: Sample Distribution for Expert Survey (January 2017, n = 127 ) 

Belarus 

11 experts 

Azerbaijan 

10 experts 

Armenia 

15 experts 

Georgia 

23 experts 

Moldova 

30 experts 

Ukraine 

38 experts 

3 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The  present  study  is  anchored  in  an  expert  survey  conducted  in  all  Eastern 
Partnership  (EaP)  countries  between  12  December  2016-20  January  2017.  We 
used  a  systematic  coverage  of  expert  databases:  public  sector  and  politicians 
the  European  Committee  of  Regions  (CoR),  civil  society 
network  of 
organizations  network  of 
the  European  Bank  for  Reconstruction  and 
Development (BERD), and the Romanian Academic Society (SAR) network of 
experts.  We  also  employed  snowballing  techniques  (i.e.  at  the  end  of  the 
questionnaire  the  experts  were  asked  to  provide  further  references)  as  well  as 
targeted invitations. 

The  survey  was  translated  in  all  6  national  languages,  and  we  have  126 
respondents  in  total.  The  targeted  category  of  respondents  were:  academics, 
public sector employees, politicians, journalists and representatives of local and 
international  civil  society  organizations  (CSO)  (e.g.  Freedom  House,  Open 
Society,  Transparency  International,  German  Marshall  Fund),  international 
organizations experts (e.g. NATO, OSCE, Council of Europe, GRECO, World 
Bank) and other senior local experts. The effort of collecting primary data was 
possible due to the translation work of several scholars and civil society persons 
who translated the expert survey questionnaire.1 

The  survey  (see  Annex  2)  consisted  of  19  questions  that  allowed  us  to  collect 
three kinds of information: 

(1) ranking  of  pre-established  typologies  of  corruption  and  institutional 

practices in Local and Regional Authorities (LRAs), 

(2) illustrative  examples  and  semi-structured  assessment  of  corruption  and 
institutional practices in Local and Regional Authorities (LRAs), and 

(3) personal details (e.g. professional experience, age, gender, nationality)   

The questionnaire was distributed to targeted experts online via SurveyMonkey, 
using  web  links,  mailing  lists  and  social  media.  The  number  of  respondents 
varies across questions because we report only the valid answers. Some skipped 
questions or did not complete the survey overall.2 

1 Special  thanks  go  to  Marina  Galstyan  (Armenia),  Aytan  Gahramanova  (Azerbaijan),  Ryhor  Nihznikau  and 
Hanna  Asipovich  (Belarus),  Nanuli  Silagadze  (Georgia),  and  Olena  Podolian  and  Valentyna  Romanova 
(Ukraine).  The  compilation  of  the  data  base  and  dissemination  towards  relevant  experts  in  the  targeted  case 
studies benefitted  from  the  contribution of Simona  Ernu  (SAR),  Valentina  Dimulescu (SAR),  Cristina  Buzașu 
(BERD), Bianca Toma (CRPE), and Oskar Whyte and Joris Wagemakers (CoR). 
2 Regarding the latter, this happened quite randomly, there was no particular question after which respondents 
stopped participating. 

4 

 
 
 
 
 
 
                                           
 
In addition to the Expert Survey, the present study benefited from a triangulation 
of data with Country Reports (for the past 3 years), such as Nations in Transit 
(Freedom House), and other in-depth assessments of corruption and institutional 
capacity realized by Transparency International, World Bank and the Council of 
Europe. We did not however benefit from the insight of polls to judge directly 
citizens’ perceptions on corruption at the LRA level. While the latest Corruption 
Perception Index scores for EaP countries suggest a relatively stable situation3, 
there  is  little  data  on  popular  concerns  regarding  different  types  of  corruption. 
For EU countries more specific indicators have been developed (e.g. electronic 
tenders)4,  while  for  South  Eastern  Europe,  several  citizens’  surveys  have  been 
deployed5.  In  the  present  study  we  piloted  the  assessment  of  citizen’  concerns 
via  representative  categories  of  experts  (i.e.  Civil  Society  Organizations  and 
Journalists), but we recommend a future  deployment of a systematic survey of 
the  population  in  EaP  states  which  goes  beyond  measuring  perceptions  of 
corruption,  and  examines  forms  of  corruption  (e.g.  nepotism,  transparency)  as 
we do here. 

The structuring of the present analysis was informed, firstly, by the 31st Session 
Report  of  the  Congress  of  Local  and  Regional  Authorities,  Preventing 
corruption and promoting public ethics at local and regional levels. Secondly, it 
was  based  on  previously  assessments  by  the  authors  with  regards  to  the 
phenomenon of corruption in public administrations6  

30 

57, 

40, 

Georgia 

Moldova 

3 According  to  Freedom  House’s  Corruption  Perception  Index  in  2016,  Armenia  scored  35,  Azerbaijan  30, 
Belarus 
29. 
http://www.transparency.org/news/feature/corruption_perceptions_index_2016  (last  accessed  on  the  27th  of 
January 2017).  
4 https://www.hertie-school.org/blog/time-dig-deeper-measure-corruption/  
5 http://seldi.net/home/  
6 Gherghina,  S.  and  Volintiru,  C.,  2015.  A  new  model  of  clientelism:  political  parties,  public  resources,  and 
private contributors. European Political Science Review, pp.1-23. Volintiru, C., 2015. The exploitative function 
of  party  patronage:  does  it  serve  the  party's  interest?.  East  European  Politics,  31(1),  pp.39-55.  Volintiru,  C., 
2013.  How  Public  Spending  is  Fuelling  Electoral  Strategies  in  Romania.  Südosteuropa.  Zeitschrift  für  Politik 
und  Gesellschaft,  (02),  pp.268-289.  Volintiru,  C.  2013.  Corruption  in  Romania:  Manifestation  Form  and 
Prevention Efforts. PRIAD Policy Journal (1):2. 

Ukraine 

and 

5 

 
                                           
 
Prevalence  of  Corruption  at  the  Local  and 
in  Eastern  Partnership 
Regional  Level 
(EaP) Countries: Country Assessments 

Armenia 

The  most  prevalent  forms  of  corruption  in  Armenia,  according  to  the  experts 
are:  favoritism  in  public  procurement  (71%),  conflicts  of  interests  (57%)  and 
nepotism  in  appointing  public  officials  (50%).  Abuse  of  power  (7%)  is  not 
considered by respondents to be of average or significant importance.  

The Nations in Transit Report shows a slight improvement of corruption issues 
in Armenia over the past decade, falling from 5.75 to 5.50 in 2009, and later on, 
to  5.25  in  2012.  The  latter  improvement  of  the  score  was  based  on  the 
introduction  of  E-government  services  that  ‘reduced  opportunities  for  bribery’ 
as well as new regulations that led to ‘higher numbers of corruption lawsuits and 
fines against senior officials and large companies’.7 

The main problems in Armenia regarding public procurement that were reported 
by experts are: lack of transparency (77%), nepotism (69%) and an ambiguous 
legislation (46%). The legislative reforms of 2012 regarding the conduct of civil 
servants have been an important step forward, but there is still a regulatory gap 
regarding public procurement procedures.  

Experts  provided  us  with  illustrative  examples  of  corruption  in  the  process  of 
public procurement at the local or regional level. In Armenia, within the capital 
city  of  Yerevan,  one  of  the  sectors  in  which  public  procurement  issues  have 
caught the public’s attention is garbage disposal, as in the recent example of a 
large  contract  awarded  by  the  public  zoo  with  no  public  announcement  in 
advance. 

While  in  press  and  annual  CSOs’  reports,  most  instances  of  corruption  in 
Armenia  are  reported  at  the  national  level,  there  is  some  collusion  between 
political  and  private  contractors  at  the  local  level  too.  Such  is  the  case  of  the 
Kotayk  Province  which  is  under  the  influence  of  the  prominent  businessmen 
Gagik Tsarukyan.8 

7 Freedom House (2012), Nations in Transit - Armenia, p 67-68. 
8 Freedom House (2016) Nations in Transit -Armenia, p 8. 

6 

 
 
 
 
 
 
                                           
 
The main problems in Armenia regarding public services that were reported by 
experts are: abuse of administrative resources in election campaigns (92%) and 
lack  of  transparency  (62%).  Our  study  reveals  that  employees  in  the  public 
services and subordinated or coordinated public sector institutions (e.g. school) 
are pressured to vote for the incumbent parties in power at the local level. 

Institutional  capacity  is  not  very  good  at  the  level  of  Local  authorities  in 
Armenia given the stalled efforts to reform the administrative structures through 
consolidation  so  far.  The  territorial  reforms  left  many  of  the  smaller 
communities with an uncertainty about the way they will be financed from the 
central budget in the future. Experts believe that both for preventive as well as 
corrective  measures  to  counteract  corruption,  there  is  a  good  level  of 
competence in LRAs, but a limited willingness to engage.  

Effective  measures  to  reduce  corruption  in  Armenia  are  seen  to  be:  increasing 
transparency and public awareness on activities (92%), raising awareness among 
citizens and NGOs (42%) and informing the public employees about the causes 
and consequences of  the phenomenon (33%). 

Azerbaijan 

The most prevalent forms of corruption in Azerbaijan, according to experts are 
abuse of power (100%) and to a much lower degree, conflict of interests (43%). 
Decisions contrary to public interest (14%) are not considered by respondents to 
be of average or significant importance. The prominence of abuse of power in 
Azerbaijan is linked to the centralization of the decision-making process in the 
public administration system. Along with Belarus, it is one of the EaP countries 
where  self-governance  in  local  and  regional  authorities  is  weakest,  and  the 
institutional  structure  of  the  central  government  allows  for  a  high  degree  of 
discretionary control over public resources.   

The  Nations in Transit Report reflects a deterioration of corruption prevalence 
in Azerbaijan over the past decade, with an increase from 6.25 to 6.50 in 2009, 
and  later  on  to  6.75  in  2013.  Still,  the  source  of  the  graft  and  corruption 
problems  is  generally  found  within  the  central  administrative  structures  of  the 
state.  The  low  prevalence  of  corruption  in  local  authorities  is  mostly  linked  to 
their  weak  institutional  status  with  limited  prerogatives  and  funding.  This 
explains  why  some  of  the  more  pervasive  practices  of  wasteful  allocation  of 
resources  and  favoritism  in  public  procurement  contracts  are  not  judged  by 
experts to be relevant to LRAs in Azerbaijan.   

7 

 
 
 
 
 
 
 
The  main  problems  in  Azerbaijan  regarding  public  procurement  that  were 
reported  by  experts  are:  lack  of  transparency  (100%),  poor  protection  for 
whistleblowers  (71%)  and  nepotism  (46%).  Similarly,  for  public  service 
delivery,  the  main  problems  are  (once  again)  lack  of  transparency  (86%)  and 
nepotism  (71%).  In  Azerbaijan  there  is  also  a  much  smaller  evaluation  of 
competence and willingness to engage in preventive anti-corruption measures as 
opposed to corrective ones. 

A legislative framework for whistleblowing protection would increase both the 
transparency of administrative procedures, as well as signal the abuses of power 
that  take  place  at  the  local  level  in  Azerbaijan.  In  the  absence  of  such  a  state 
initiative,  local  civil  society  entities  can  be  encouraged  to  develop  their 
watchdog capabilities. 

While  not  developed  by  LRAs  but  providing  many  of  the  local  public  service 
delivery, in Azerbaijan there is a newly established e-government application—
ASAN SERvice (Azerbaijan Service and Assessment Network).9 Created by the 
State  Agency  for  Public  Administration  and  Social  Innovations  (ASAN)  and 
acting under the authority of the President’s Office, for a number of bureaucratic 
public  service  provisions  it  allows  citizens  to  see  how  many  people  have  been 
serviced, how many are queued and average service delivery time. It is available 
for five public service centers in Baku and six other major cities (i.e. Sumaqayit, 
Gyandhza, Sabirabad, Barda, Gabala, Masally).  

Furthermore, since 2015, the online portal for fees and taxes payment is live,10 
giving  citizens  the  possibility  to  pay  fines  (e.g.  traffic  fines),  duties, 
administrative fees (e.g. identity card, driving license, ordinary passport), utility 
payments (e.g. energy fees), and other payments (e.g. mobile service). It is not 
only effective in diminishing petty corruption and interaction with clercs, but it 
is also creating a system of interoperability of citizens data, between the various 
Ministries (e.g. Department of Internal Affairs, Ministry of Public Finances) so 
that monitorization is more effective. 

9For further details see the institutional portal here: 
http://www.asan.gov.az/en/content/index/329/state_agency_for_public_service_and_social_innovations_under_t
he_pr#.WIOQerZ97_Q, last accessed by the authors on 15.02.2017. 
10For  further  details  see  the  institutional  portal  here:    www.asanpay.az,  ,  last  accessed  by  the  authors  on 
15.02.2017. 

8 

 
 
 
 
                                           
 
Belarus 

The most prevalent forms of corruption in Belarus, according to the experts are: 
abuse  of  power  in  public  office  (64%),  conflicts  of  interests  (46%)  and 
clientelistic  distribution  of  goods  and  services  (46%).  In  contrast  to  what  they 
regard  as  the  most  prevalent  forms  of  corruption,  experts  believe  that  the 
citizens’  concerns  are  much  higher  regarding  nepotism  in  appointing  public 
officials  (46%)  and  decisions  contrary  to  public  interest  (64%).  This  shows  a 
limited awareness of the public on the extent and effects of various corruption 
practices in Belarus, which is in accordance with the lack of transparency being 
the main vulnerability of LRAs in Belarus.  

The Nations in Transit Report reflects a stable evaluation of corruption and local 
democratic governance as being poor in Belarus over the past decade. With no 
clear  legislative  provisions  for  self-governance,  the  local  authorities  remain 
largely  controlled  by  central  state.  There  is  however  an  active  control  against 
corruption  (to  constrain  the  power  of  local  office  holders,  not  necessarily  to 
reduce wasteful allocations).  

The  main  problem  within  the  LRAs  in  Belarus  both  in  terms  of  public 
procurement  and  public  service  delivery  is  the  lack  of  transparency.  Public 
procurement procedures are equally affected by an ambiguous legislation (44%) 
and  untrained  personnel  (44%),  while  public  services    are  affected  by  the 
clientelistic distribution of goods and services (78%).  

While  legally  accountable  to  the  citizens,  LRAs  in  Belarus  are  captured  by 
national  political  elites  as  regional  councils  are  dominated  by  heads  of  state 
enterprises  and  organizations 11 .  Furthermore,  since  2011  regional  governors 
have  been  integrated  into  the  military  hierarchy  as  coordinators  of  local  army 
units.  This  dilutes  even  further  their  democratic  accountability  as  heads  of 
administrative institutions.  

In  Minsk,  Belarus’s  capital,  the  incumbent  mayor’s  project  of  building 
swimming  pools  raised  concern,  especially  as  he  excluded  the  offers  of 
international bidders. According to our expert survey data, in the cities of Gomel 
and  Bobruisk  in  Belarus  there  are  issues  with  the  contracting  procedures  for 

11 Freedom  House  (2016)  Nations  in  Transit  -  Belarus,  p  8,  for  further  details  see  Andrey  Kazakevich  and 
Vadzim Smok, "Алігархія ці вертыкаль? Рэгіянальныя эліты ў Беларусі: эвалюцыя ў 1999–2014 гадах на 
прыкладзе абласных Саветаў" [Oligarchy or vertical? Regional elites in Belarus: Evolution in 1999-2014, the 
case  of  the  local  councils],  Institute  of  Political  Studies  "Political  Sphere,"  2014, http://palityka.org/wp-
content/uploads/2014/03/Reg_elites_Political_Sphere-2014.pdf. 

9 

 
 
 
 
 
                                           
 
apartment  buildings.  Nevertheless,  local  administrations  in  urban  areas  of 
Belarus are still much more likely to be reactive to citizens’ concerns and needs 
than regional authorities will ever be. 

Apart  from  increasing  transparency  and  public  awareness  on  the  activities  of 
LRAs,  experts  believe  Belarus  would  benefit  from  raising  awareness  amongst 
citizens and NGOs about the causes and effects of corruption, as well as training 
public sector employees in preventive measures.  

Georgia 

The  single  most  prevalent  forms  of  corruption  in  Georgia,  according  to  the 
experts  is  nepotism  in  appointing  public  officials  (91%).  Experts  believed 
citizens to also be concerned about abuse in public office, but do not regard it 
themselves as a significant manifestation of corruption. The high prevalence of 
nepotism in Georgia is linked to a weak legislative framework on the selection 
and evaluation of employees in the public administration. 

In the Corruption Perception Index (CPI), Georgia has the highest score (57) in 
the EaP region—averaged at 30, which shows both a popular and an institutional 
commitment to fighting corruption. Similarly, in the Nations in Transit Report, 
we find here across the past decade one of the lowest score in the region for both 
local  democratic  governance  and  corruption.  Legislative  reforms  to  local  self-
governance  have  influenced  in  2015  the  decrease  of  the  score  for  local 
democratic governance from 5.50 to 5.2512. Procedural reforms in bureaucratic 
interaction between citizens and the public administration (e.g. online payments) 
in 2012 have increased transparency and limited petty corruption and as such the 
corruption score for Georgia fell to its lowest, from 4.75 to 4.50.   

The  main  problem  of  public  procurement  in  Georgian  LRAs  is  the  untrained 
personnel (71%)—the highest manifested experts’ concern across the EaP set of 
cases. This reflects the evaluations of high prevalence of nepotism (52%) as the 
main  problem  regarding  public  service  delivery  in  Georgia.  At  the  root  of  this 
problem is the lack of a formalized system of recruitment and promotion within 
the  public  sector,  poor  publicly  advertised  openings,  and  a  heavy  reliance  on 
recommendations in the employment process (to the detriment of qualifications 
or experience)13. All of these issues are much greater at the level of LRAs than 

12 Freedom House, 2015 Nations in Transit - Georgia, p. 250. 
13 Charkviani,  T.,  2013.  Post-Soviet  Georgia  in  the  Process  of  Transformation-Modernization  Challenges  in 
Public Service. Romanian Journal of Political Science, 13(2), p.137. 

10 

 
 
 
 
 
 
                                           
 
at  the  central  government  level,  as  the  lower  attractiveness  of  the  former 
positions further diminishes the employment competitions. 

Based on the qualitative analysis of corruption occurrences, the poor allocation 
of  financial  and  human  resources  in  Georgian  LRAs  creates  vulnerabilities  for 
corruption in social service delivery, not necessarily in the overall public service 
system. 

Georgian  experts  have  specifically  chosen  to  refer  to  inadequate  budgetary 
allocations  for  LRAs  and  unqualified  staff  as  main  vulnerabilities  of  LRAs  in 
the provision of public services . Nevertheless, within the institutional capacity 
assessment,  Georgia  scores  slightly  above  all  other  EaP  countries,  as  having  a 
good  institutional  capacity  especially  in  terms  of  willingness  to  engage  and 
competence (surpassed here only by Armenia). Furthermore, Georgia seems to 
have  a  strong  will  to  tackle  corruption  both  in  preventive  and  corrective 
measures. Beyond the increase of transparency and public awareness on LRAs 
activities  (which  is  a  constant  recommendation  across  the  region),  experts 
believe  that  Georgia  would  also  benefit  from  civil  servants’  instruction  on 
corrective measures to counter corruption. 

Third  party  monitoring  (whether  from  public  audit  bodies  or  civil  society 
organizations)  is  highlighted  as  a  benchmark  of  anti-corruption  efforts  in 
Georgia,  within  the  legislative  framework  of  the  recently  amended  Law  no. 
157/2016 on Conflict of Interest and Corruption in Public Institutions. 

Moldova 

The most prevalent form of corruption in Moldova, according to the experts is 
favoritism  in  public  procurement  (83%),  followed  by  nepotism  in  appointing 
public officials (48%) and conflicts of interests (48%). Experts also believe that 
there is a high concern amongst citizens’ about the prevalence of favoritism in 
public  procurement,  thus  reflecting  a  much  higher  awareness  of  the  public 
regarding institutional distortions in Moldova. 

The Nations in Transit Report reflects a deterioration of the overall prevalence 
of  corruption  in  Moldova,  following  the  theft  of  1  bil.  $  and  other  graft 
allegation 14.  Nevertheless,  the  same  source  reports  a  recent  improvement  of 
local democratic governance in Moldova, following the adoption of the Law on 

14 Freedom House (2016) Nations in Transit - Moldova, p 3. 

11 

 
 
 
 
 
 
 
                                           
 
Local Public Finances in 2015 which effectively diminishes the significance of 
political 
the  central 
in  ensuring  budgetary  allocations  from 
government, as it provides a standard formula for such transfers.15  

leverage 

The main problems in Moldova regarding public procurement that were reported 
by  experts  are:  lack  of  transparency  (77%),  nepotism  (65%)  and  untrained 
personnel  (54%).  In  the  Moldovan  municipality  of  Balți,  waste  disposal  and 
cleaning  contracts  are  flagged  as  opaque  and  preferential.  Often,  improprieties 
in the administrative process are publicly linked to the personal interests of the 
incumbent  mayor,  as  in  such  cases  as  Renato  Usatii  (Balți,  Moldova).  Other 
public  services  affected  by  corruption  in  the  procurement  process  are  the 
medical  and  educational  centers  that  fall  under  the  authority  of  local 
administrations (given the process of decentralization).  

The  main  problems  in  Moldova  regarding  the  provision  of  public  services 
reported by experts are: lack of transparency (77%), clientelistic distribution of 
public goods (69%) and nepotism (65%).  

As a direct reflection of the main problem that affects both public procurement 
and  the  provision  of  public  services,  experts  account  for  the  most  effective 
measures to counter corruption in Moldavian LRAs to be: increase transparency 
and  public  awareness  on  activities  (91%),  as  well  as  raising  awareness  among 
citizens and NGO (61%).  

Our  survey  suggests  as  a  main  method  of  countering  corruption  the 
implementation  of  internal  or  external  programmes  of  strengthening  the 
administrative  capacity  of  LRAs  (Moldova  is  the  only  country  where  this  was 
suggested as one of the main measures to counter corruption). 

Over  half  of  country  experts  said  that  external  consultants  were  employed  by 
Local  Authorities  in  Moldova  with  the  purpose  of  providing  transparency  to 
administrative  activities  and  preventing  the  wasteful  allocation  of  public 
resources.  Experts  positively  assessed    the  impact  of  public  acquisition  plans 
and  strategies,  and  public  consultations  on  the  topic  of  public  procurement,  in 
addition  to  live  streaming  of  deliberative  sessions  of  some  of  the  LRAs’ 
councils.  

15 Freedom House (2016) Nations in Transit - Moldova, p 8-9. 

12 

 
 
 
 
 
 
 
 
                                           
 
Ukraine 

The  most  prevalent  form  of  corruption  in  Ukraine,  according  to  the  experts  is 
favoritism in public procurement (79%), followed by abuse of power in public 
office  (55%)  and  clientelistic  distribution  of  public  goods  (48%).  Experts 
believe  Ukrainians  are  very  much  concerned  by  decisions  contrary  to  public 
interest (66%) and nepotism in appointing public officials (40%) (even if their 
own  expert  assessment  places  a  lower  emphasis  on  these  instances  of 
corruption). 

The  Nations  in  Transit  Report  reflects  a  recent  improvement  in  the  local 
democratic  governance  of  Ukraine,  falling  from  5.50  to  5.25  this  year  as  the 
constitutional  changes  regarding  decentralization  passed  through  the  national 
deliberative forums.16 These reforms aim at increasing the budgetary autonomy 
of  local  governments,  as  well  as  their  decision-making  functions  (e.g.  local 
strategies of development). Additionally, much like in Armenia, the process of 
decentralization  also 
involves  a  consolidation  of  smaller  communities 
effectively reducing the number of LRAs in Ukraine17.  

The main problems in Ukraine regarding public procurement that were reported 
by  experts  are:  nepotism  (70%),  ambiguous  legislation  (60%)  and  untrained 
personnel  (47%).  Contracts  for  road  repairs  and  public  transportation  are 
highlighted  by  experts.  One  of  the  signaled  incidents  in  public  procurement  is 
the  hastily  contracting  for  major  repair  works  in  Kiev  Oblast  at  the  end  of  the 
budgetary  year,  with  the  payments,  and  reception  of  the  contracts  being  done 
only  a  few  days  after 18.  Also,  most  of  the  road  repairs  in  Kharkiv  seem  to  be 
carried by companies close to decision-makers involved in the tender process.  

Public service delivery in Ukraine is hindered by the clientelistic distribution of 
goods and services (73%) and the lack of transparency (60%). Private interests 
are flagged in the case of the introduction of new public service facilities (e.g. 
electronic  ticketing,  permits  or  insurance  provisions)  as  providers  are  political 
clientele companies that are certificated and funded by local authorities. 

One  of  the  most  important  positive  benchmarks  in  public  procurement  in  EaP 
countries  is  the  recent  introduction  in  Ukraine  of  the  electronic  procurement 

16 Freedom House (2016) Nations in Transit - Ukraine, p 9-10. 
17Decentralization Reform, National Reforms Council, http://reforms.in.ua/en/reforms/decentralization-reform    
18Suggested  source  by  the  expert  respondent:  https://www.kyivpost.com/ukraine-politics/activists-report-raft-
state-procurement-violations-december.html  

13 

 
 
 
 
 
                                           
 
system,  ProZorro,  with  the  new  Law  no.  922/2015  on  Public  Procurement 
coming into force in 2016.  
A second example is the development of “one-stop-shop” administrative centers 
in Ukraine. While not as digitally advanced, these territorial centers do provide 
additional  facilities  of  accessibility  to  the  beneficiaries  of  public  services.  The 
“Transparent Offices” (TSNAP) providing administrative services operate in the 
city  councils  of  regional  centers:  in  Western  Ukraine  (e.g.  Ivano-Frankivsk, 
Lutsk,  Vinnitsa,  Khmelnytsky),  Central  Ukraine  (e.g.  Dnepropetrovsk,  Krivoy 
Rog, Pavlograd, Dnipropetrovsk), Eastern and Northern Ukraine (e.g. Kharkiv, 
Luhansk,  Sumy,  Chernigov,  Zhitomir)  and  in  Kyiv.  Several  TSNAP  (in 
Kharkiv,  Kyiv,  Dnipropetrovsk)  have  a  web  platform  where  you  can  order 
individual services, appointment, monitor the movement of the case, and other 
informative consultations through a web portal. Administrators TSNAP inform 
applicants by email or by phone about the status of processing of their solicited 
document.  In  some  centers  you  can  even  order  the  finished  document  by  mail 
and do not have to collect it in person from the TSNAP.  

Nevertheless,  unlike  in  Azerbaijan  where  the  local  and  regional  prerogatives 
meet  central  government  prerogatives  on  the  same  platform,  in  Ukraine  these 
remain separate. Consequently, most of the popular administrative services (e.g. 
passports,  cadaster)  remain  under  the  executive  power:  the  State  Registration 
Service of Ukraine, State Migration Service, State Land Agency and others. 

Finally,  the  Ukrainian  municipality  of  Bila  Tserkva  recently  launched  a 
blockchain  based  platform  for  public  property  lease  –  Auction  3.0.  The  new 
system aims to use public monitorization of the auction process to reduce fraud 
to the minimum. After being piloted in certain LRAs the Ukrainian authorities 
hope to scale it nation wide.  

14 

 
 
Prevalence  of  Corruption  at  the  Local  and 
in  Eastern  Partnership 
Regional  Level 
(EaP) 
Cross-Country 
Comparisons 

Countries: 

In every EaP country there is one form of corruption on which the large majority 
(approximately  two  thirds)  of  the  experts  agreed  to  be  prevalent,  and 
significantly  more  prevalent  than  other  forms.  This  suggests  that  there  are 
country specific conditions and mechanisms through which corruption manifests 
itself at the level of Local and Regional Authorities (LRAs).  

Based on the triangulation of both quantitative and qualitative survey data, we 
were able to discern the main traits for each country. For Azerbaijan and Belarus 
the  lack  of  transparency  is  the  most  stringent  issue;  for  Armenia  and  Ukraine 
most  of  the  issues  stream  from  ambiguous  legislation;  in  Georgia  the  most 
poignant  issue  is  personnel  recruitment  and  qualification,  and  in  Moldova  it  is 
favoritism in public procurement.  

Table 1: The perception about the most prevalent forms of corruption in LRAs (%) 

EXPERT 
ASSESSMENT 

Favoritism in 
public 
procurement 

Nepotism 
in 
appointing 
public 
officials 

Abuse of 
power in 
public 
office 

Decisions 
contrary 
to public 
interest 

Conflicts 
of interest 

Clientelistic 
distribution 
of public 
goods 

Armenia 

Azerbaijan 

Belarus 

Georgia 

Moldova 

Ukraine 

71 

29 

27 

36 

83 

79 

50 

29 

36 

91 

48 

34 

7 

100 

64 

41 

21 

55 

43 

14 

36 

41 

45 

37 

57 

43 

46 

41 

48 

37 

36 

29 

46 

32 

38 

42 

Note:   The  sum  of  percentages  is  greater  than 100%  because  it  was  a  multiple-choice  question.  The  “other” 
category is not reported here because only 2% of the experts in all countries used it. 

15 

 
 
 
Table 1 includes the answers of experts for each of the most prevalent form of 
corruption  in  their  countries  (in  percentage).19 One  important  similarity  across 
the  six  countries  is  the  high  number  of  experts  indicating  conflicts  of  interest 
and  nepotism  as  prevalent  forms  of  corruption.  In  spite  the  country-level 
variation, these two forms appear to be common concerns in the EaP countries.  

Table  2  includes  the  percentage  of  experts  in  every  country  indicating  a 
particular form as being of major concern to citizens.20 The present study could 
not  build  a  representative  sample  for  a  citizen  survey 21 ,  and  there  are  no 
available large sample survey data for the EaP countries of the type available in 
EU  countries  (e.g.  Eurobarometer,  SELDI).  Our  methodology  attempted  to  fill 
this gap with a dedicated question on the popular concerns in their countries (as 
opposed  to  their  own  expert  assessment).  Because  our  sample  included  such 
categories  of  respondents  as  civil  society  leaders  or  journalists,  we  expect  the 
data from this question provides us with a partial assessment of citizens’ main 
corruption-related grievances.  

Table  2:  The  perception  about  the  forms  of  corruption  in  LRAs  of  major  concern  to 
citizens (%) 

CITIZENS’ 
PERCEPTIONS  

Favoritism in 
public 
procurement 

Nepotism in 
appointing 
public officials

Abuse of 
power in 
public office 

Decisions 
contrary to 
public 
interest 

Conflicts 
of 
interest 

Clientelistic 
distribution 
of public 
goods 

Armenia 

Azerbaijan 

Belarus 

Georgia 

Moldova 

Ukraine 

21 

29 

9 

27 

59 

24 

64 

57 

46 

86 

55 

40 

21 

100 

64 

55 

35 

66 

50 

43 

64 

27 

69 

66 

29 

29 

9 

36 

45 

32 

64 

43 

36 

5 

31 

34 

Note:   The  sum  of  percentages  is  greater  than 100%  because  it  was  a  multiple-choice  question.  The  “other” 
category is not reported here because only 2% of the experts in all countries used it. 

19 Experts were asked to identify the most prevalent forms of corruption at the level of LRAs in their country. 
They were provided with a list of potential forms, having the possibility of a multiple answer with a maximum 
of  three  choices.  On  top  of  the  predetermined  answer  options,  they  had  the  possibility  to  add  a  form  of 
corruption through an open answer made available via the “other” option. For the forms of corruption there were 
only isolated instances in which respondents chose the “other” option; for reasons of simplicity we did not report 
those answers in this report. 
20 Experts were also asked to estimate what forms of corruption present at the level of LRAs in their countries 
are  of  major  concern  for  citizens.  Respondents  had  again  the  possibility  to  provide  a  multiple  answer,  with  a 
maximum of three choices being permitted. 
21 We recommend a future deployment of a systematic survey of the population in EaP states which goes beyond 
measuring  perceptions  of  corruption,  and  examines  forms  of  corruption  (e.g.  nepotism,  transparency)  as  in 
similar population survey studies conducted in the EU member states. 

16 

 
 
                                           
 
One  relevant  conclusion  of  these  distributions  is  the  salience  of  all  forms  of 
corruption  for  citizens  and  their  relatively  high  importance;  there  are  only 
isolated instances in which particular forms are less significant (e.g. favoritism 
in  Azerbaijan,  clientelism  in  Georgia).  Another  relevant  conclusion  is  that 
experts  differentiate  between  what  they  consider  to  be  the  prevalent  form  of 
corruption in their country and what is of concern to the public.  

Table  1  and  2  demonstrate  little  direct  association  and  sometimes  demonstrate 
more  of  an  inverse  association  (e.g.  Armenia’s  expert  assessments  on  the 
prevalence  of  favoritism  and  clientelism  as  opposed  to  how  concerned  they 
believe  citizens  to  be  of  these  phenomena).  This  suggests  that  experts  believe 
the  true  magnitude  of  corruption  instances  sometimes  escapes  the  attention  of 
citizens, especially in administrative and procedural areas with which they have 
lesser contact (e.g. public procurement, conflict of interests).  

As  specific  functions  of  the  Local  and  Regional  Authorities  (LRAs),  we 
compare  and  contrast  the  incidence  of  corruption  in  public  procurement  with 
that occurring in the delivery of public services.  

Public procurement is considered as the administrative process by which public 
administrations  (i.e.  LRAs)  purchase  works,  goods,  or  services  from  private 
companies 22 .  Adjacent  to  public  procurement  issues  are  usually  problems 
interests,  and  nepotism  (contracting 
regarding 
component).  Public  procurement  can  be  applied  for  investment  purposes  (e.g. 
building swimming pools in Minsk), as well as everyday public service delivery 
(e.g. transportation, cleaning). 

transparency,  conflict  of 

Table 3: The perception about the main vulnerabilities of LRAs in public procurement 
(%) 

PUBLIC 
PROCUREMENT 
Ambiguous 
legislation 
Lack of 
transparency 
Untrained 
personnel 
Poor protection 
for whistle blowers 

Nepotism 

Armenia  Azerbaijan 

Belarus 

Georgia  Moldova 

Ukraine 

46 

77 

8 

31 

69 

0 

100 

29 

71 

71 

44 

89 

44 

0 

22 

29 

38 

71 

19 

57 

35 

77 

54 

31 

65 

60 

40 

47 

30 

70 

Note:   The  sum  of  percentages  is  greater  than  100%  because  it  was  a  multiple-choice  question.The  “other” 
category is not reported here because only 3% of the experts in all countries used it. 

22 http://cor.europa.eu/en/events/Documents/Preventing%20Corruption%20and%20promoting%20public%20ethi
cs%20at%20local%20and%20regional%20levels%2023%20August%202016.pdf  (last  accessed  on  the  27th  of 
January 2017)  

17 

 
 
 
 
                                           
 
Corruption  can  be  reflected  in  a  restricted  or  conditional  access  to  public 
services,  the  decrease  of  their  quality  and  quantity,  or  their  use  for  electoral 
gains.  As  such,  adjacent  to  issues  of  public  service  we  find  the  following 
corruption  categories:  lack  of  transparency,  clientelism,  nepotism  (recruitment 
of  staff  component),  no  whistleblower  protection  or  abuse  of  administrative 
resources in election campaigns. 

In  general,  poor  protection  for  whistle  blowers  is  not  seen  as  a  major 
vulnerability  in  EaP  countries.  While  whistleblowers  protection  does  not  seem 
to be amongst the main suggestions for anti-corruption measures in our survey, 
the experts did point out that civil servants are often pressured into covering for 
illegal  or  distortive  practices  for  fear  of  being  fired  (e.g.  Ukraine).  One 
exception is Azerbaijan where whistleblower protection is placed second. There 
is  also  great  difference  between  countries  regarding  the  role  of  ambiguous 
legislation,  ranging  from  no  perceived  vulnerability  in  Azerbaijan  to  60%  of 
experts mentioning it in Ukraine. 

Furthermore,  the  issuance  of  permits  (e.g.  building  permits)  or  certification  is 
one  of  the  most  frequently  signaled  cases  of  distorted  institutional  procedures, 
either due to bribes or preferential treatment. Information is withheld to increase 
the  dependency  of  beneficiaries  on  the  public  employees.  Social  services  and 
benefit  allocation,  as  well  as  preferential  access  to  medical  services  are 
especially  vulnerable  to  this  patrimonial  approach  (e.g.  Azerbaijan,  Georgia, 
Belarus).  

The interpenetration between the businessmen and political elites are frequently 
mentioned  as  an  issue  of  public  procurement  process  in  EaP  countries.  In 
various  forms  of  state  capture,  the  public  procurement  process  is  filled  with 
loopholes  to  ensure  the  access  of  party  loyal  clients  to  public  contracts. 
Examples 
(in  Georgia), 
procurements  bellow  the  more  transparent  electronic  acquisition  threshold  (in 
Ukraine),  no  publication  of  tenders  (in  Armenia,  Azerbaijan  and  Ukraine),  as 
well as a generalized inflation of acquisition prices.  

include:  confidential  agreements 

for  prices 

Overall, the lack of transparency or criteria for budgetary allocations, as well as 
the  preferential  treatment  given  to  certain  contractors  are  the  main  traits  of 
public  procurement  problems  in  the  analyzed  set  of  cases.  Public  and  private 
interests  collide  in  all  cases  when  awarding  public  contracts  (e.g.  fictitious 
tenders,  companies  controlled  by  mayors).  Furthermore,  in  cases  such  as 
Belarus,  there  is  a  widespread  practice  of  granting  presidential  pardons  to 
they  make  some 
businessmen  prosecuted  for  corruption,  as 
compensatory payments, leading to weak incentives for anti-corruption efforts. 

long  as 

18 

 
 
 
 
 
PUBLIC 
SERVICES 
Abuse of 
administrative 
resources in 
electoral 
campaigns 

Clientelistic 
distribution of 
public goods 

Lack of 
transparency 

46 

62 

Nepotism 

46 

Other 

8 

Table  4:  The  perception  about  the  main  vulnerabilities  of  LRAs  in  the  provision  of 
public services (%) 

Armenia  Azerbaijan 

Belarus 

Georgia  Moldova 

Ukraine 

92 

43 

56 

38 

54 

57 

43 

86 

71 

14 

78 

100 

22 

0 

29 

43 

52 

38 

69 

77 

65 

0 

73 

60 

57 

7 

Note:   The sum of percentages is greater than 100% because it was a multiple-choice question. 

Figure 2: The lack of transparency as vulnerability for LRAs (%) 

The  empirical  evidence  presented  in  Tables  3  and  4  indicate  the  lack  of 
transparency  as  the  major  vulnerability  for  the  activity  of  LRAs  in  the  EaP 
region. Figure 2 compares these levels for the public procurement and provision 
of services across the six countries. Across countries, the two that are labeled as 

19 

 
 
 
“consolidated  authoritarian  regimes”23—Azerbaijan  and  Belarus  have  the  most 
severe  lack  of  transparency  in  LRAs  for  both  public  procurement  and  public 
service  delivery.  Consistent  with  other  reports  on  corruption  and  institutional 
capacity, as well as with its sustained reform efforts, Georgia seems to have the 
lowest problem with transparency standards.  

In  the  case  of  Armenia  and  Azerbaijan,  the  lack  of  transparency  is  seen  as  a 
bigger problem in the public procurement process, than in the public services. In 
contrast,  Belarus,  Georgia  and  Ukraine  show  a  higher  vulnerability  of  lack  of 
transparency  in  public  services,  while  for  Moldova  administrative  procedures 
seem to be equally marked by poor transparency.  

Most  of  the  problems  raised  with  regards  to  corruption  in  public  services  are 
related  to  simultaneous  problems  with  public  procurement  procedures.  For 
example,  the  quality  of  such  public  services  as  waste  management  and 
collection  (e.g.  Ukraine),  sewage  (e.g.  Armenia),  or  transportation  (e.g. 
Moldova), the desire of the local authorities to favor certain contractors lowers 
the quality of services provided to the population.  

In  the  case  of  most  of  the  EaP  subnational  authorities,  the  inventory  and/or 
administration  of  private  and  public  property  falls  under  their  prerogatives. 
Nevertheless, cadaster records have been historically poorly kept24, and the lack 
of transparency and improper filing of records continues to be an issue today. In 
Moldova,  Ukraine  Armenia,  municipal  LRAs  are  accused  of  selling  lands, 
factories  or  forests  from  the  public  patrimony  to  the  profit  of  elected  political 
elites.  State  capture  also  influences  the  way  urban  planning  is  developed  and 
permits are granted.  

We have also developed an institutional capacity assessment built on four levels 
of assessment: affordability, availability, competence, and willingness to engage 
(see Figure 3 and 4).  

The affordability layer is designed to reflect the extent to which LRAs in each 
country  have  the  possibility  to  allocate  material  and  human  resources  to 
designing  and  deploying  anticorruption  tools  and  tactics.  The  layer  of 
availability  refers  to  both  access  to  international  cooperation  and  training 

23 Based  on  Nations  in  Transit  taxonomy  Georgia,  Moldova  and  Ukraine  are  considered  to  be  “Transitional 
Government  or  Hybrid  Regime”,  Armenia  is  regarded  as  “Semi-Condolidated  Authoritarian  Regime”,  and 
Regime”, 
Azerbaijan 
https://freedomhouse.org/report/nations-transit/nations-transit-2016, last accessed by the author on 15.02.2017. 
24 D'Arcy,  M.  and  Nistotskaya,  M.,  2016.  State  First,  Then  Democracy:  Using  Cadastral  Records  to  Explain 
Governmental Performance in Public Goods Provision. Governance. 

“Consolidated 

Authoritarian 

Belarys 

seen 

and 

are 

as 

20 

 
 
 
 
 
                                           
 
sessions  on  anticorruption,  as  well  as  local  or  grassroots  initiatives  to  monitor 
the LRAs (e.g. Go Local25, Ukraine). Competence and willingness to engage are 
both dimensions of assessment of the human resource employed in LRAs.  

We  do  not  restrict  the  category  of  anticorruption  agents  to  public  sector 
employees,  as  important  measures  can  be  taken  from  outside  the  institutions 
(e.g.  third  party  monitorization),  but  a  long-term  perspective  on  anticorruption 
efforts  is  fundamentally  reliant  on  the  integration  of  public  ethics  within  the 
institutional process of the LRAs.  

We  applied  this  assessment  framework  for  both  preventive  and  corrective 
measures  in  the  fight  against  corruption  at  the  level  of  Local  and  Regional 
Authorities (LRAs). Preventive measures are here considered to be those that try 
to  stop  the  occurrence  of  corruption  beforehand  (e.g.  transparency  of 
administrative  procedures,  rotation  of  personnel  in  positions  at  risk,  codes  of 
ethics/of conduct, mandatory declarations of personal interests).  

to  appropriate  regulatory  agencies).  The 

Corrective  measures  are  here  considered  to  be  those  that  are  deployed  in  an 
attempt to stop or punish corruption after it has occurred (e.g. whistleblowing, 
referral 
latter  can  also  have 
confounding  effects  with  preventive  efforts  as  anticorruption  campaigns  can 
sometimes create deterrence effects. Nevertheless, for the purpose of the present 
study,  we  distinguish  between  the  two  as  different  institutional  approaches  to 
anticorruption efforts.  

The  key  to  understanding  the  inclination  of  decision-makers  in  LRAs  to 
implement anti-corruption measures is to link them to any electoral capital these 
might  bring  them.  Public  ethics  can  be  in  general  a  positive  attribute  for  any 
incumbent, but it is reliant on the public’s awareness. In this sense, we can see 
the case of Belarus where preventive anticorruption measures are judged to have 
a limited capacity, while corrective ones have a good one—one of the highest in 
the  region  alongside  Armenia.  This  can  be  explained  by  the  fact  that 
anticorruption  campaigns  have  the  dual  goal  of  generating  deterrence  (or 
hierarchical obedience), while reassuring the public of the vigilence of relevant 
oversight bodies. In contrast, little is done to improve the quality or transparency 
of the public procurement system and public service delivery.  

When  ranking  together  the  institutional  capacity  assessment  for  all  types  of 
anticorruption measures based on the EaP regional averages we find almost all 

25 http://golocal-ukraine.com  

21 

 
 
 
 
 
                                           
 
of  them  to  have  a  moderate  capacity.  Only  the  willingness  to  engage  in 
preventive measures is below average, judged by experts to be limited.  

Figure 3: Institutional Capacity in Developing Preventive Anti-corruption Measures  

Note: 1=very limited, 5=very high 

Figure 4: Institutional Capacity in Developing Corrective Anti-corruption Measures  

Note: 1=very limited, 5=very high 

This  is  counterproductive,  as  preventive  measures  are  some  of  the  least  costly 
(e.g.  sharing  best  practices,  increasing  transparency  and  accountability).  In  the 
electoral  gains  light,  they  are  however  less  noticeable  as  correcting  already 
manifested problems. In this sense, as we will detail in the final section of this 

22 

 
 
 
 
 
 
 
report,  many  of  the  efforts  to  counter  corruption  at  the  LRAs  level  in  EaP 
countries have to increase the conceptualization of personal benefits to decision-
makers in engaging in preventive anticorruption measures.  

Regardless of country differences, the main method indicated by the experts is 
to increase transparency and public awareness about the activities of the LRAs. 
This  is  intuitive  when  scrutinizing  the  answers  about  the  forms  of  corruption. 
Favoritism,  nepotism  and  abuse  of  power  in  public  office  emerged  as  relevant 
forms  of  corruption  in  almost  all  the  investigated  countries.  The  positive 
experiences  of  countries  dealing  with  corruption  in  the  past  illustrate  that  the 
increase of transparency can effectively help in the fight against corruption.  

There is no single preferred method to counteract corruption, with the exception 
of increasing transparency, which is favored by the majority of experts within a 
country. In other words, there is little agreement among experts about the impact 
of other methods. Some methods are generally considered to have less impact, 
such  as  information  about  the  causes  and  consequences  of  corruption, 
employees’  training  on  preventive  measures  or  employees’  instruction  on 
corrective measures. 

23 

 
 
Policy  Recommendations  for  Strengthening 
the  Institutional  Capacity  of  Local  and 
Regional  Authorities  (LRAs)  in  Eastern 
Partnership (EaP) Countries 

The first set of recommendations streams from benchmark observations within 
EaP  LRAs  streaming  from  the  present  study  (i.e.  based  on  the  original  data 
collection  of  the  expert  survey).  Benchmarking  good  practices  is  an  easy  and 
effective  exercise  that  should  surpass  the  present  study,  and  develop  a 
continuous  form  of  collecting  examples  from  the  territories—as  for  example 
within a permanent dedicated online platform, or a quarterly newsletter. While 
such  measures  involve  LRAs  and  increases  the  quality  of  the  services  they 
provide, they can however be achieved only with the regulatory and budgetary 
support of the national or international institutions.  

Good practice examples: 

(cid:57)  introduction  of  an 

integrated,  universal  and  easily  accessible 
electronic  system  for  public  procurement  procedures,  such  as 
Prozorro26 in  Ukraine.  Our  examples  show  that  corrupt  intentions  can 
still  manipulate  the  public  procurement  system  to  avoid  submitting 
tenders via Prozorro platform (e.g. dividing contracts into smaller bits to 
fall under the mandatory e-procurement threshold). Nevertheless, it is still 
an  effective  tool  for:  (1)  private  contractors  who  want  to  engage  in  fair 
and  open  competition,    (2)  LRA  decision-makers  who  might  violate 
transparency and ethical procedures due to incompetence, and not corrupt 
intentions, and finally (3) citizens and civil society organizations who can 
exert a watchdog function if they wish.   

(cid:57)  publicly  available  list  of  targeted  social  assistance  beneficiaries  in 
Azerbaijan. Many European countries do not make the list of taxpayers 
or social assistance beneficiaries publicly available in order to protect the 
citizens’  right  to  the  intimacy  of  private  life.  However  where  such 
measures  have  been  introduced,  they  proved  to  be  an  effective  self-
targeted  social 
regulating 
beneficiaries  in  Azerbaijan  can  have  a  deterrence  effect  for  both  the 

tool  of  society.  The  public 

listing  of 

26For further details please see:  https://prozorro.gov.ua/en/, last accessed by the authors on 15.02.2017.  

24 

 
 
 
 
                                           
 
corruption demand (i.e. prevent fraudulent intentions of beneficiaries that 
would  not  be  entitled  to  these  services)  as  well  as  the  corruption  supply 
(i.e. prevent clientelistic distribution of favours or abuse of administrative 
resources in election campaigns). 

(cid:57)  digitalization  of  bureaucratic  procedures  in  order  to  increase  the 
accessibility  to  public  services  (e.g.  ASAN  e-governance  platform27, 
ASAN  online  payments  platform28). The implementation of “one-stop-
shop” online platforms for the provision of bureaucratic public services is 
one  of  the  most  desired  reforms  of  the  administrative  system  by  the 
citizens. This is a field of activity where petty corruption is often present 
and restricts the accessibility of public services as well as decreases their 
quality  by  imposing  additional  direct  (e.g.  no.  of  taxes,  bribes)  and 
indirect  costs  (e.g.  time  spent).  The  slow  progress  achieved  in  EaP 
countries in this respect (along with other EU countries as well) is mainly 
driven  by:  (1)  high  costs  of  developing  such  online,  integrated  systems 
(usually  requiring  a  big  data  consolidation  and  interoperability  of 
institutional databases beforehand), and (2) difficulties in linking together 
different  institutions  from  both  the  national  (e.g.  Ministry  of  Internal 
Affairs) and local administrative layers (e.g. cadaster records).  

The second set of recommendations responds to country-specific vulnerabilities 
that we have identified in the present study. Such examples should once again 
be  collected  in  a  continuous  process  of  evaluation  of  good  and  bad  examples 
from  the  region.  Often  the  vulnerabilities  can  be  annulled  through  simple 
measures  reliant  primarily  on  procedural  know-how,  and  only  to  a  marginal 
extent on resource allocation. 

Suggestions based on identified country-specific problems: 

(cid:57)  Developing  a  systematically  deployed  training  programme  aimed  at 
raising  the  awareness  on  the  affordability  and  availability  of  preventive 
anti-corruption measures in Azerbaijan. 

(cid:57)  Strengthening the whistle protection legislation and watchdog capabilities 

in Azerbaijan and Belarus. 

27For  further  details  please  see:  http://www.asan.gov.az/en/content/tree/150/,  last  accessed  by  the  authors  on 
15.02.2017. 
28 For further details please see: https://www.asanpay.az, last accessed by the authors on 15.02.2017. 

25 

 
 
 
 
 
                                           
 
(cid:57)  Creating a centralized online portal for LRAs job openings in Georgia, to 
counter  the  discretionary  appointments  and  the  poor  qualification  of  the 
staff. 

(cid:57)  Increase  funding  available  to  LRAs  in  Ukraine  for  the  contracting  of 
external expertise – technical assistance programmes for both preventive 
and corrective measures.  

(cid:57)  Declarations of interests by elected officials and a mandatory verification 
of  ownership  structure  of  private  contractors,  to  prevent  collusion 
between  business  interests  and  administrative  functions  in  the  public 
procurement process. 

(cid:57)  Public database of acquisition prices for any public procurement of LRAs 

for comparative purposes – deters price inflation. 

Finally, a last set of recommendations on measures that can be taken by LRAs in 
EaP is informed by international, overview assessment of anticorruption efforts, 
which the authors believe can and should be transferred to EaP countries. This 
set of recommendations is linked to the ability of EU and national authorities to 
empower LRAs to absorb and develop good practices.  

Further recommendations:  

⇒ Develop  local  initiatives  for  electronic  procurement  systems,  as  well  as 
more  progressive  digital  systems  of  citizen-driven  monitorization  of 
administrative procedures and decisions (e.g. Auction 3.0 in Ukraine, live 
streaming Local Council Meetings in Moldova). 

⇒ Extended  declarations  of  interests  for  elected  officials,  councilmen,  and 
civil  servants  to  include  family  members,  so  as  to  deter  the  preferential 
allocation of public contracts to ones’ own company.  

⇒ Reports  of  activity  at  the  end  of  every  year,  with  a  detailed  account  of 
public  investments  and  public  services  delivered,  constructed  on  the 
system of set goals and self-monitorization of progress.  

⇒ Consolidated registries of legislative provisions accessible to the public. 

⇒ Comparative  public  procurement  price  database  (ideally  realized  by 

LRAs, but it can also be done by CSO). 

26 

 
 
 
 
 
 
 
 
 
 
⇒ Participative budgetary construction (i.e. public consultations on the main 
investment  priorities  of  the  LRA,  at  least  for  medium  and  long  term 
investments). 

⇒ Online  modules  that  could  benefit  local  and  regional  authorities  and 
administrations across the EaP on various procedural aspects that impact 
significantly  on  public  procurement  procedures,  transparency  standards, 
or conflict of interests and clientelism. Based on the present evaluation we 
make  several  recommendations  on  the  potential  topics  of  such  online 
the 
modules:  regional  benchmark  practices  –  good  examples  of 
region/own country; designing accessible institutional webpages; content 
upload  on  institutional  webpages;  constructing  interoperable  databases; 
using  e-governance  portals’  specific  tools;  standardized  forms  of 
decision-makers’  reporting  (e.g.  personal  wealth, 
interests,  annual 
performance  reports);  national  and  international  regulations  concerning 
public procurement process; whistleblower rights etc.  

27 

 
Annex 1. Prioritization Matrix for Corruption Problems 

in EaP Countries 

Prioritization Matrix scale (1-5) 
Transparency; 
Conflicts of interest and clientelism; 
Protecting whistleblowers; 
Nepotism (recruitment of staff); 
Public procurement; 
Abuse of administrative resources in election campaigns; 

Eastern Partnership (EaP) 
1 
3 
6 
2 
5 
4 

Armenia  

Main Problems in Public 
Procurement 

Lack of transparency 

Nepotism 
Ambiguous legislation 

Lack of transparency 
Poor protection for whistle 
blowers 

Main Problems in Public Service Delivery 

Abuse of administrative resources in election 
campaigns 

Lack of transparency 
Clientelistic distribution of public goods 
Nepotism 
Lack of transparency 

Nepotism 

Azerbaijan 

Belarus 

Georgia 

Nepotism 

Untrained personnel 

Untrained personnel 
Nepotism 

Lack of transparency 
Ambiguous legislation 

Abuse of administrative resources in election 
campaigns 
Clientelistic distribution of public goods 
Lack of transparency 
Clientelistic distribution of public goods 
Abuse of administrative resources in election 
campaigns 
Nepotism 
Lack of transparency 
Abuse of administrative resources in election 
campaigns 
Lack of transparency 
Nepotism 
Clientelistic distribution of public goods 
Clientelistic distribution of public goods 
Lack of transparency 
Abuse of administrative resources in election 
campaigns 
Nepotism 
Source: Based on original expert survey conducted for this study. 

Lack of transparency 
Nepotism 
Untrained personnel 
Nepotism 
Ambiguous legislation 

Lack of transparency 

Untrained personnel 

Moldova 

Ukraine 

28 

 
 
 
  
  
  
  
Annex 2. Expert Survey Questionnaire 
(Page 1 – General Overview) 

1. 

In your opinion, who has been primarily responsible for public service delivery in the last five years? 

Central government 
only 

Central government 
executes majority of 
tasks; local 
governmental units 
executes minority of 
tasks 

Both central 
government  and 
sub-national unit 
execute amount of 
services equally 

Local governmental 
units executes 
majority of tasks; 
central government  
executes minority of 
tasks 

Sub-national units 
only 

2. 

In your opinion, what has been the capacity of local civil service to perform in a satisfactory manner their 
administrative tasks, over the last five years? 

Very low capacity 

Low capacity 

Moderate capacity  High capacity 

Very high capacity  

3. 

4. 

In  your  opinion,  what  are  the  most  prevalent  forms  of  corruption  at  the  level  of  Local  and  Regional 
Authorities (LRAs) in COUNTRY? (multiple choice, maximum 3 answers) 
a.  Favoritism in public procurement 
b.  Nepotism in the appointment of public officials 
c.  Abuse of power while in public office  
d.  Decisions being taken contrary to public interest 
e.  Conflicts of interest 
f.  Clientelistic distribution of public goods and/or services 
g.  Other (please specify) 

In your opinion, what forms of corruption present at the level of LRAs in COUNTRY are of major concern 
for citizens? (multiple choice, maximum 3 answers) 
a.  Favoritism in public procurement 
b.  Nepotism in the appointment of public officials 
c.  Misuse of prerogatives and administrative powers 
d.  Decisions being taken contrary to public interest 
e.  Conflicts of interest 
f.  Clientelistic distribution of public goods and/or services 
g.  Other (please specify) 

(Page 2 – Public Procurement and Public Service) 
5. 

In  your  opinion,  what  are  the  main  vulnerabilities  of  Local  and  Regional  Authorities  (LRAs)  regarding 
public procurement contracts? (multiple choice, maximum 3 answers) 
a.  Ambiguous legislation 
b.  Lack of transparency 
c.  Untrained personnel 
d.  Poor or non-existent protection for whistle blowers 
e.  Nepotism 
f.  Other (please specify) 

6.  Could you please briefly provide some illustrative examples of corruption in public procurement at the level 

of Local and Regional Authorities (LRAs) in your country?  

(open question) 

7. 

In your opinion, what are the main vulnerabilities of Local and Regional Authorities (LRAs) regarding the 
provision of public services in COUNTRY? (multiple choice, maximum 3 answers) 
a.  Abuse of administrative resources in electoral campaigns 
b.  Clientelistic distribution of goods and services 
c.  Lack of transparency 
d.  Nepotism 
e.  Other (please specify) 

29 

 
 
 
 
 
 
 
8.  Could you please briefly provide some illustrative examples of corruption in the provision of public services 

at the level of Local and Regional Authorities (LRAs) in COUNTRY? 

(open question) 

(Page 3 – Fighting Corruption) 
9. 

In  your  opinion,  what  would  be  the  best  method  through  which  corruption  at  the  level  of  LRAs  in 
COUNTRY can be counteracted? (multiple choice, maximum 3 answers) 
a. 
b.  Dedicated  training  on  preventive  measures  against  corruption  (e.g.  ethical  conduct)  for  public 

Inform public employees about the causes, forms and effects of corruption 

employees 
Instruct public employees on corrective measures against corruption (e.g. whistleblowing) 

c. 
d.  Raise  awareness  amongst  citizens  and  local  NGOs  about  the  causes,  forms  and  effects  of  corruption 

through dedicated campaigns 
Increase central transfer to strengthen the administrative capacity of LRAs 

e. 
f.  Use external expertise to increase the institutional capacity in the fight against corruption 
g. 

Increase  transparency  and  public  awareness  on  the  activities  conducted  by  LRAs  (e.g.  public 
procurement, criteria for the allocation of public resources) 

h.  Other (please specify) 

10.  Can  you  think  of  any  examples  of  good  practice  on  preventive  measures  against  corruption  in  Local  and 

Regional Authorities (LRAs) in your country? 

(open question) 

11.  Can  you  think  of  any  examples  of  good  practice  on  corrective  measures  against  corruption  in  Local  and 

Regional Authorities (LRAs) in your country? 

(open question) 

12.  How  would  you  rate  the  administrative  capacity  of  the  LRAs  in  COUNTRY  to  prevent  and  correct 

corruption from the point of view of: (scaling matrix) 

Row: Preventive—stop the occurrence of corruption beforehand (e.g. transparency of administrative procedures, 
rotation  of  personnel  in  positions  at  risk,  codes  of  ethics/of  conduct,  mandatory  declarations  of  personal 
interests),  Corrective—stop  corruption  after  it  has  occurred  (e.g.  whistleblowing,  referral  to  appropriate 
regulatory agencies)  
Column: Affordability, Availability, Competence, Willingness to engage 

13.  Do LRAs in your country employ external consultants—either from the private sector or civil society –  to 

strengthen their capacity to fight corruption?  

Yes (go to question 14) 
No (jump to question 15) 

14.  What does their technical assistance cover? 
a.  Transparency of LRAs activities  
b.  Preventing the misuse of public resources 
c.  Training the LRAs’ personnel with regards to ethical conduct and fighting corruption 
d.  Training  the  LRAs’  personnel  with  regards  to  international  standards  and  legislative  provisions 

regarding corruption 

e.  Strengthening the administrative capacity of LRAs 
f.  Other (please specify) 

30 

 
 
 
 
 
 
15.  ow long is the experience of <COUNTRY> with the fight against corruption at the LRA level? 
<5 years 

13-16 years 

9-12 years 

5-8 years 

>16 years 

(Page 5 – Final Aspects) 
16.  How would you rate your general knowledge about COUNTRY? 
Very basic 

Average 

Basic 

Good 

Very good 

17.  Field of activity: 

Academic 

NGO 

Journalist 

Politician 

Other (please specify): 

18. Gender 

Male 

Female 

19. Age: completed years 

Final page: 
We  would  like  to  thank  you  for  filling  in  this  questionnaire,  and  to  reassure  you  that  all  answers  will  remain 
confidential and anonymous!  

The results will be used exclusively for research purposes. Our goal is to have an assessment of corruption in 
your  country  from  as  many  experts  (e.g.  academics,  journalists,  civil  society  representatives  or  politicians)  as 
possible. Accordingly, we would be grateful if you could specify in the field below the e-mail addresses of at 
least two other people who could also inform us about the topic.  

31