Standards of public life, and attitudes to ethical behaviour
Many public organisations have adopted integrity frameworks and explanations about the values they pursue in their work and work attitude. But what determines these ethical values and duties they commit themselves to? Amita Patel, who works as principal auditor at the ECA, looks at possible sources for such values, including the United Kingdom’s ‘Seven principles of public life’ as a skeleton for underpinning many institutions’ ethical values and duties. She also draws on her experiences to illustrate cross-cultural attitudes to ethical behaviour in development aid.
By Amita Patel, Audit Quality Control Committee Directorate
Searching for theory and matching practice of ethical values
When I joined the ECA in 1992, I faced questions and moral dilemmas that had not even occurred to me when I was working as a private sector auditor in Luxembourg. As a chartered accountant I had signed up to the code of ethics of the Institute of Chartered Accountants in England and Wales. But this seemed to me to be more about maintaining professional standards and behaviour aiming to avoid conflict of interest in order to maintain public trust in the audit profession, rather than dealing with societal issues.
To illustrate how attitudes to ethics and moral behaviour can change over time: Luxembourg at the time had banking secrecy and was implementing anti-money laundering legislation. My private sector audit firm required me to follow ‘deontology’ courses (on normative ethical theory). However, the business climate was such that no one was questioning practices that helped people and companies avoid paying taxes in their home countries, or looking too closely at the provenance of their funds. This situation has evolved, especially with the events of the last ten years that have called for greater transparency, accountability and paying taxes where they are due.
Working for a European organisation (the ECA was not yet an institution) was a steady job with good prospects, but what was I required to do in order to be a good civil servant? What does public interest mean? How does one carry out the role of a public sector auditor, how does the stewardship role function when taxpayers’ money is everyone’s money and no-one’s money? The staff regulations for EU civil servants make dry reading for answers to these questions, and in the early 1990s, there was no dedicated induction training on ethics for newcomers, nor any mention of the global standards and guidelines of the International Organisation of Supreme Audit Institutions (INTOSAI).
Seven principles of public life
Our ethical values and obligations are spelled out in a number of documents: the EU Treaty, staff regulations, financial regulations, the ECA ethical guidelines, code of conduct for ECA Members, audit standards and employment laws, and we have training on public ethics. But we need a short, everyday manifesto of what is expected of us as EU civil servants. I have therefore taken the liberty to restate the Nolan Committee’s seven principles of public life with reference of what is required in our behaviour rather than that required of some faceless, invisible bureaucrat.
The UK government’s Committee on standards in public life (the Nolan Committee) was set up to establish a code of conduct for those in public life, including civil servants, after political scandals related to cash for access to politicians.
Box 1 — Seven principles of public life — the Nolan Committee
As holders of public service, we will act with:
Selflessness: we will act solely in terms of the public interest;
Integrity: we will avoid placing ourselves under any obligation to people or organisations that might try inappropriately to influence us in our work. We will not act or take decisions to gain financial or other material benefits for ourselves, our family or our friends. We will declare and resolve any interests and relationships;
Objectivity: we will act and take decisions impartially, fairly and on merit, using the best evidence and without discrimination or bias;
Accountability: we are accountable to the public for our decisions and actions and will submit ourselves to the scrutiny necessary to ensure this;
Openness: we will take decisions in an open and transparent manner. We will not withhold information from the public unless there are clear and lawful reasons for doing so;
Honesty: we will be truthful;
Leadership: we will exhibit these principles in our own behaviour. We will actively promote and robustly support these seven principles, and will challenge poor behaviour wherever it occurs.
Source: based on UK Committee on standards in public life annual report 2017–2018
Cultural context?
Nobody can object to these values per se, but the problems begin when we differ in what they mean to us and how we put them in place in our everyday life. For example, there was a noticeable change in attitudes to ‘how we do things around here’ when the EU with 12 Member States, the EU-12, became the EU-15, with pressure to move away from the more formal, hierarchical culture that existed at the time, with more questioning and less tolerance of practices that were not considered acceptable. This is not to say that nationals of some Member States are perceived to have better values and behaviours than those of others — just that they are expressed differently. This has not gone away with the 2004 enlargement — except that instead of explaining things away as ‘that is just the French/British/German/Belgian etc. ’ way of doing things, I more often hear ‘that is just the way things were done in the former eastern bloc/ that is just the way some people behaved in the former communist countries.’
The meaning we attribute to the words selflessness, integrity, objectivity, accountability, openness, honesty and leadership can be determined by our cultural context. For example, the definition of integrity above from the UK Committee on standards of public life rules out nepotism and using position to help family and friends.
But in another culture where the norm is that a good member of society will take care of their tribe, say by making reciprocal arrangements that benefit its members, for example by ensuring that they have good jobs, the outcome of acting with integrity would result in the opposite outcome!
Ethical dilemma’s appearing while auditing on the spot
Auditing development aid and humanitarian aid in the early 1990s was eye opening about attitudes to public service in Africa and stereotypes about Africans getting into public service in order to line their pockets, about how they could not be trusted to handle projects or money without using it for themselves.
During my first mission to the Ivory Coast for checking the STABEX system (stabilisation of export earnings), we saw plenty of poverty and subsistence farming. We also saw many vanity projects built by President Houphouët-Boigny in his natal village, which he made the political and administrative capital of the country. They included a Basilica to rival St Paul’s in Rome, gifted to the Catholic Church to prevent the building from being dismantled by subsequent governments. Roads wider than the Champs Elysee, a palace surrounded by a moat with crocodiles to which his political rivals were reportedly fed, and an enormous hotel where the only guests were the ECA auditors and the EU delegation.
This and subsequent missions to other countries generated plenty of internal discussions about immoral behaviour from government leaders and civil servants lacking a public service ethos, but no one questioned the role of European and other foreign nationals and companies in aiding and abetting the construction of vanity projects or facilitating corrupt behaviours. Was it good enough to say that this was just the business model with bribery, corruption and dishonesty that was required to buy influence?
Cross-cultural perspectives
Attitudes to fraud and corruption are determined by cross-cultural perspectives, and are based on different conceptions of human nature. What may be considered legitimate in one culture may be considered corruption in another, and it all starts with the intention behind a given behaviour. For example, gift giving and hospitality in many eastern cultures is used to build and cement relationships and to build trust with future business partners, but may be construed by western cultures as bribery and attempts to influence.
If you are interested in learning more, I would highly recommend Fons Trompenaars’ book Riding the waves of culture’, and the eye opening questions that he asks the reader to consider as a way of finding out what their cultural perceptions are. For example, would you lie for a friend who has committed a crime? And if yes, why?
Box 2 — Dimensions of human relationships
Fons Trompenaars identified five dimensions of human relationships that influence how people do business and how they respond to moral dilemmas:
1. Relationships versus particularism (rules versus relationships)
2. Individualism versus communitarianism (individual versus the group)
3. Neutral versus affective (the degree to which feelings are expressed)
4. Diffuse versus specific (the degree of involvement)
5. Achievement versus ascription (how status is accorded)
Source: based on Fons Trompenaars, Riding the waves of culture
Discussing how to put theory into practice
As European civil servants, we should shy away from easy, trite explanations of behaviours by attributing them to national stereotypes. Some people may claim that stereotypes help them navigate and make sense of their environment, but they do disservice by focusing on a narrow view of people’s behaviour in a certain environment, by exaggerating and caricaturing the culture being observed. By looking at differences, there’s a danger that we equate something different with something wrong, and look at individuals as ‘other’ rather than a person with whom we have more in common than appears outwardly.
In the EU institutions we are in an ideal position to create a shared culture and shared meaning for the values that are listed above. But this requires honest conversations, time and energy to think and discuss about what these values mean and how we would put them into practice in our behaviours and decisions.
Awareness about integrity does not come by itself, integrity issues have to be lived, shared and practiced. Examples of real life situations, either from our own organisation or from others, both good and bad practices, can make the ‘seven principles of public life’ alive and an integral [inherent] part of an ethical culture that staff members seek for themselves and others in public life. Ethical values and principles can be learned by doing. In conclusion, a good starting point when doing something should be ‘would this stand up to public scrutiny?’
This article was first published on the 2/2019 issue of the ECA Journal. The contents of the interviews and the articles are the sole responsibility of the interviewees and authors and do not necessarily reflect the opinion of the European Court of Auditors.
