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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
                                                                    40
               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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