Page 31 - Aanbevelingen om de integriteit

153. The Defence Code of Conduct (KMar) is a rather general document, stating a number of
principles (professionalism, team work, responsibility, ethical treatment, respect and safe working
environment). It is accompanied by some further guidance on confidential information, secondary
activities, invitations and gifts, media relations, etc.). However, it does not provide much guidance in
particular situations and it does not have a special police focus (Defence Code).

154. To sum up, the GET acknowledges that the anticorruption and integrity policy in the NPN and
KMar is an integral part of the professionalism of the employees. The integrity policy is updated
regularly, which is in line with GRECO standards; i.e. that codes of conduct are to be “living
instruments” and they are public. The Theme pages, which are attached to the Professional Code of
the NPN, are designed in a flexible way, which is to be welcomed. However, they need to be
developed to include further guidance, examples as well as lessons learned. Likewise, the GET would
see much value in establishing a code of conduct for the KMar regarding their particular law
enforcement functions. To the extent possible, the authorities could opt for a joint instrument
covering both the NPN and KMar in relation to their common task, as appropriate. GRECO
recommends (i) that the Theme pages of the Professional Code of the National Police (NPN) be
further developed with guidance, examples and lessons learned, offering adequate guidance on
conflicts of interest and other integrity related situations (e.g. gifts, third party contacts, accessory
activities, handling of confidential information) and that a similar instrument be established for the
Royal Marechaussee (KMar); and (ii) to ensure supervision and enforcement of these instruments.

Risk management measures for corruption prone areas

155. In the NPN, risk analyses are conducted from three perspectives,: 1) specific risk prone areas
(e.g. information security, physical security, management, personal integrity resilience,
professionalism and trustworthiness), which call for promoting professional and ethical conduct, 2)
certain positions in charge of high risk activities which require vetting and screening and 3) certain
activities (requiring adapted risk analyses). Various entities and divisions within the force are
responsible for conducting these analyses, including VIK department, AIVD, Working Undercover
Department, HRM and Information Directorates.

156. There are many internal NPN regulations that aim at reducing risks of corruption in day-to-
day work. Risks differ for each position; these are therefore incorporated in protocols for specific
situations, for example, the four-eyes principle, maximum terms for certain positions, the use of two
detectives per informant for criminal intelligence, authorisation management, annual mental health
checks and interaction with suppliers to prevent conflicts of interest etc.

157. The KMar uses Integrity Risk Assessment (RAI) as part of its integrity policy. The Central
Defence Integrity Organisation (COID) is in charge of risk assessments. The assessment,
recommendations and control measures are included in a report presented to and discussed with the
commander of the unit concerned. The Integrity Cluster regularly consults with units about the risks
identified and the control measures implemented. It carries out awareness raising and educational
measures for managers and employees. The assessments of the Defence Integrity Policy conducted
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in recent years by external organisations and investigative committees are publicly available online .
A risk inventory of the KMar was carried out in 2014. The risk prone areas include misuse of
information and other systems; abuse of power; embezzlement/theft.
Multiple eyes principle and other internal measures

41 Limits to Unity (Grenzen aan de Eenheid’) (organization culture), Netherlands Institute for Social Research/SCP (2016);
“Moral Fitness” (tendering procedure, integrity), Van der Steenhoven Investigative Committee (2016); Mali Mortar Incident
(Mortierongeval Mali), Security Research Council, Defence sector (2017); Organised Crime and the Integrity of Law
Enforcement Organisations (Georganiseerde Criminaliteit en Integriteit van Rechtshandhavingsorganisaties), WODC (2017).

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