Guía Metodológica para la Evaluación de los Riesgos de Soborno

Abstract

When Colombia joined the Organization for Economic Cooperation and Development (OECD), it assumed a series of commitments in the fight against corruption and specifically against bribery, expressly establishing the obligation to take actions to neutralize the commission of this type of conduct.

This research specifically seeks to structure a methodology that allows identifying and preventing possible acts of bribery in public sector entities and allowing them to generate alerts that facilitate the adoption of corrective actions for the prevention and mitigation of risks related to the phenomenon of bribery, and of In this way, strengthen the fight against corruption through a procedure that is applicable to all institutions of the Colombian public sector.

The methodology for assessing the risks of bribery seeks to prevent the materialization of acts of corruption and generate a culture against bribery crimes in the National Superintendency of Health and other superintendencies and public sector entities that decide to adopt it, especially to facilitate adoption. of the pertinent controls that allow to avoid bad practices related to the events that have to do with bribery.

In this sense, the Colombian state has been making efforts to generate measures to counteract it by promoting ethics among public sector officials through policies, plans and programs articulated with the Integrated Planning and Management Model (MIPG) led by the Administrative Department of the Public Function (DAFP); Similarly, the Colombian Institute of Technical Standards and Certification ICONTEC ratified in 2011 and 2017 the NTC-ISO 31000 and NTC-ISO 37001 standards respectively, standards that establish principles for risk management and their integration into the processes first and principles and good practices for the management of anti-bribery risk the second, facilitating its implementation in organizations.

The guide proposed in this investigation is aimed at generating preventive actions for public officials and facilitating the implementation of reasonable policies, procedures and controls to counteract the risks of bribery faced by public sector organizations, and is especially aimed at Senior officials, where decisions related to the management of public resources or functions related to the procedures carried out by the entity are made, in order to satisfy the requirements of interest groups or services within the organization , among those, those who lead the processes of human talent, internal control and hiring.

The methodology includes the following steps: 1) Implementation of the anti-bribery policy; 2) identification of the risks and critical points of bribery risks in the entity's processes; 3) assessment of bribery risks; 4) adoption of measures to address the risks of bribery identified; 5) systematization of the information obtained in the previous steps; 6) communication and consultation with relevant stakeholders.

In each of the steps of the methodology, there are the formats required to collect the necessary information for the management of this type of risk, in order to implement bribery prevention actions in the National Superintendence of Health or in other public entities who decide to adopt this methodology.