Strengthen Public Procurement
Enhance monitoring of procurement and expanding procurement units’ access to information, as well as by increasing procurement units’ opportunities to intervene in cases of corruption they detect. Corruption will be prevented both through legislative reforms and guidance, and particularly by providing practical information to procurement units.
This commitment identifies a specific anti-corruption mechanism, which is the work of procurement units. Corruption in public procurement is considered one of the most high-risk areas in Finland, as highlighted by the National Competition Authority’s annual reports and the national anti-corruption network.
 Finnish Competition and Consumer Authority, Public Procurement Control Results Reporting 2020, https://www.kkv.fi/uploads/sites/2/2021/12/julkisten-hankintojen-valvonnan-tulosten-raportointi-2020.pdf
Based on the wording of the commitment, it is unclear what concrete actions the government plans to implement to enhance procurement, how it aims to expand access to information for the procurement units, and which measures it wants to use to increase procurement units’ opportunities to intervene in cases of corruption. Based on further desk research, the following measurable actions from the National Anti-Corruption Strategy can be identified in relation to this commitment:
1 Organise thematic training on the risks of corruption for officials, internal auditors and elected officials engaging in procurement.
2. Expanding procurement units’ access to information:
a) Examine means for promoting access to information on direct procurements.
b) Investigate means to improve access to information for contracting entities in connection with procurements.
c) Investigate the possibility of requiring declarations of private interests from persons involved in procurement preparations or other means of preventing conflicts of interest.
3. Improve the competence of persons working with public procurement in procurement processes and procurement legislation by increasing training as part of the activities of the Public Procurement Advisory Unit, and the implementation of the objectives related to the “Effective Public Procurement Operational Program” (Hankinta-Suomi programme).
 Finnish Government, Government Resolution on the National Anti-Corruption Strategy and Action Plan 2021-2023, https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/163398/VN_2021_68.pdf?sequence=1&isAllowed=y
 In 2019 the Ministry of Finance has set up the Effective Public Procurement Operational Program (Hankinta-Suomi) to draw up a national public procurement strategy, increase co-operation between public procurement actors and develop the effectiveness of procurement.
The commitment relates directly to the 2017 GRECO recommendations1 and the findings of the Open Government Partnership IRM (Independent Reporting Mechanism) Evaluation of 2019.2 The GRECO recommendations focused on using financial reporting, such as avoiding conflicts of interest and making public procurement data accessible online. In addition, the OGP evaluation emphasised the need to make public procurement data openly accessible.
The National Anti-Corruption Strategy outlines several actions that directly respond to these recommendations, enhancing public procurement, expanding procurement units’ access to information, and increasing opportunities to intervene when corruption is detected. The Action Plan against the Shadow Economy and Economic Crime for 2016-20203 also included measures to create public access to procurement data. The National Anti-Corruption Strategy includes the following actions:
7.1 Organise thematic training on the risks of corruption for officials, internal auditors and elected officials engaging in procurement. Fulfilled
As part of the national strategy countering the grey economy and financial crime, the Ministry of Justice organised targeted and tailored training for high-risk sectors during 2021 and plans to continue this in 2022. Risk sectors are public procurement, political decision-making – especially at local level – and the building sector. The Ministry of Justice provided a list of training given to law enforcement, prosecutors, court staff and FIUs (Financial Intelligence Unit) included in Annex 6.
7.2 Expanding procurement units’ access to information. Fulfilled
a) Examine means of promoting access to information on direct procurements. Fulfilled
The National Competition and Consumer Authority report examined ways to promote access to information on direct procurements, providing recommendations on measures for better access to information.4
b) Investigate means to improve access to information for contracting entities in connection with procurements. Fulfilled
The Finnish tax authorities carried out a project, connecting contracting entities and financial supervisors to the FCInet system, which provides a platform to match investigative data via information exchange,5 publishing a checklist for procurement units,6 and creating a public website to investigate procurement data.7
c) Investigate the possibility of requiring declarations of private interests from persons involved in the preparation of procurements, or other means of preventing conflicts of interest. Fulfilled
The National Competition and Consumer Authority report examined conflict of interest risks in public procurement. It provided three critical recommendations on measures to address potential issues: (a) introduce policies that do not allow conflicts of interest when selecting civil servants or allocating decision-making roles (b) ensure all organisations in the public sector have guidance and reporting channels to allow anonymous reporting of conflicts of interest or other illicit behaviour, and (c) nominate internal auditing or another similar actor to receive these reports, protect the whistleblower and initiate investigations.4
7.3 Improve the competence of persons working with public procurement in procurement processes and procurement legislation. Fulfilled
Measures under the Action Plan for Tackling the Grey Economy and Economic Crime, such as the project to enhance corruption detection by 2019, have improved the competencies of people working in public procurement.8 In addition, the checklist for procurement personnel was accompanied by the 2021 Hankinta-Suomi initiative guidelines for codes of conduct and a self-assessment form.9 10 Public procurement authorities have also received increased training outlined in 7.1.
Overall, therefore, we consider this commitment fulfilled.
- 30 Jun 2022
- 30 Jun 2022
- Grey Economy and Economic Crime Action Plan against the Shadow Economy and Economic Crime for 2016–202030 Jun 2022
- Finnish Competition and Consumer Authority Grey Economy and Procurement30 Jun 2022
- FCInet FCInet is a decentralised information exchange system for exchanging data to fight financial crime cross borders30 Jun 2022
- About current competition (Expert Writings on Competition and Market Functioning) How to prevent cartels in public procurement? Checklist for contracting entities30 Jun 2022
- Investigate Procurement https://www.tutkihankintoja.fi/30 Jun 2022
- 30 Jun 2022
- Ministry of Finance Finland Procurement Finland – Public Procurement More Impressive, https://vm.fi/hankinta-suomi30 Jun 2022
- Hansel Oy, Karolina Lehto and Liisa Lehtomäki Annex on Minimum Liability Obligations (Code of Conduct) and its use in Public Procurement30 Jun 2022
- KORSI project Immeasurable corruption? Corruption Monitoring Indicators (KORSI) Project and its Main Results, p. 22-2730 Jun 2022
- 30 Jun 2022
- 30 Jun 2022