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structurally ensuring and promoting integrity and creating awareness of integrity risks. The education
scheme includes initial and on-going specialised courses. The aim is to create an appropriate integrity
culture with sound and moral attitudes. Open talks on problems and dilemmas are encouraged.
148. The Defence Code of Conduct, applying to the KMar, refers to five basic standards for
conduct which can be summarised as relating to professionalism, cooperation, awareness of
responsibility, acting ethically with respect, and security. The GET notes that the Defence Code of
Conduct is general in character and not specific for policing and it is not directly enforceable. It was
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adopted in 2007 and is currently being revised and updated .
149. The Integrity Cluster of the KMar is responsible for the implementation of the integrity
policy. The Cluster works together with the Central Defence Integrity Organisation (COID) and with
NPN integrity bodies such as the Security, Integrity and Complaints Department (VIK). Managers,
advisers, detectives and confidential counsellors implement the integrity policy within their own
divisions. Commanders of high risk KMar units are advised periodically by the Integrity Cluster.
Internal investigations into (possible) integrity breaches, criminal investigations and confidential
investigations within the KMar are carried out by its Internal Investigations Division (SIO). The
integrity policy of the KMar is based on a balance between protection, stimulation and enforcement.
This enables the individual professional to come to appropriate moral behaviour under complex
conditions. This process is also referred to as ‘Moral Fitness’. Incidents are considered opportunities
to learn and so the KMar integrity policy allows for learning from mistakes.
Code of Conduct
150. In the NPN, there are a number of instructions, memoranda etc. regulating the behaviour of
NPN officers, including, for example, secondary activities, financial interests, gifts and the use of
confidential information etc. However, these various documents are fragmented and would clearly
benefit from being consolidated in one document, providing the necessary level of detail and being
complemented by explanations and examples.
151. In 2014, the NPN adopted the Professional Code for the Police. As already noted above, this
Code contains information on police tasks, their mission to serve, values to uphold principles such as
the rule of law, core values of integrity and trust, professionalism (expertise), leadership, etc. This
general instrument is valuable as it provides ethical principles for policing in a democratic society, the
tasks of the police etc.; it fits well into the integrity policy and is also of great value for public
awareness reasons. However, it is clearly not to be regarded as a code of conduct in the meaning of
providing detailed guidance for police action in different situations, including where conflicts of
interest may arise and, furthermore, it is not enforceable.
152. That said, the Professional Code is complemented with “Theme pages”, which are regularly
updated. These Theme pages are attached to the Professional Code and cover a variety of issues (one
issue per theme) such as gifts, invitations, behaviour in free time, use of resources, safe working
climate, handling of information, social media, representation, ancillary activities, truthful reporting,
use of force etc. Each theme page lists the relevant provisions for a particular theme, where that
exists, and includes a number of questions, as “food for thought”. Reference is made to more
detailed regulations and documents, that are easily accessible through hyperlinks. The GET welcomes
the Theme Pages as very useful tools, in particular for training and reflection purposes; however,
they cannot be considered as a consolidated code of conduct in their present form. The GET believes
the NPN has come a long way in establishing ethical standards; however, a logical next step would be
to add further guidance and examples and lessons learned to the Theme pages.
40 It is expected that the revised code of conduct should be ready by the end of 2018.
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