On 7 December 2018, GRECO published its fifth round evaluation report on Estonia. The main focus of this evaluation round is on preventing corruption and promoting integrity in central governments (top executive functions) and law enforcement agencies. The evaluation sets particular focus on issues such as conflicts of interest, the declaration of assets, and accountability mechanisms (for the fifth evaluation round, see eucrim 2/2017, p. 76; for more recent reports, see eucrim 1/2018, pp. 38–39 and 2/2018, pp. 109–110).

In general, GRECO observed that the comprehensive legislative framework and online tools in place in Estonia provide a sound basis for preventing corruption amongst all officials. There are, however, a number of areas in which improvements are necessary and recommended. Currently, a code of conduct is lacking that would cover all relevant government actors (ministers, senior civil servants, and political advisers). GRECO recommends laying down clear standards, illustrated by concrete examples of the risk of conflicts of interest. These standards should be made clear to anyone taking up a government position from the outset. In addition, political advisers, like ministers and senior civil servants, should also submit declarations of interest as part of their recruitment process, so as to identify any conflicts of interest. While acknowledging the good level of transparency of the legislative process in Estonia, GRECO sees room for further improvement by clear rules on reporting as well as disclosure by ministers, senior civil servants, and political advisers of contact to lobbyists/third parties that seek to influence the public decision-making process. The report further recommends the adoption of rules to prevent the risks of revolving doors – when government officials shift to the private sector – with a view to preventing lobbying of the government or the immediate acceptance of employment in a sector that was previously within the remit of their government duties.

The report acknowledges that, over the last several years, the Police and Border Guard Board has built up a strong practice to prevent corruption within its own ranks, which has also led to an increased level of public trust. GRECO further welcomes that the Estonian police service reportedly has the highest percentage of women in Europe, yet recommends improving gender representation at higher management levels within the police.

The report recommends focusing on two particular issues in order to prevent conflicts of interest in the police service: the increasing number of police officers taking up secondary employment in addition to their regular police work, on the one hand, and the type of employment they take after they leave the Police and Border Guard Board, on the other. The report also recommends reviewing the safeguards in place when it comes to internal police investigations. In addition, GRECO calls for improvements regarding the process of appointing the Director General of the Police and Border Guard Board, the rotation of police staff working in areas exposed to particular risks of corruption, and the protection of whistleblowers.