On 15 January 2021, GRECO published its fifth round evaluation report on Norway. The focus of this evaluation round is on the effectiveness of the frameworks currently in place to prevent corruption among persons with top executive functions (ministers, state secretaries, and political advisers) and members of the police. The evaluation focuses particularly on issues of conflicts of interest, the declaration of assets, and accountability mechanisms (for other reports on this evaluation round: eucrim 4/2020, p. 297 et seq. with further references).

Norway joined GRECO in 2001 and holds an unprecedented record in implementing GRECO recommendations, with 100% of them fully implemented in all evaluation rounds. The country has traditionally performed well in international perception surveys on corruption. It consistently ranks among the top ten countries in Transparency International’s Corruption Perception Index (7th in 2020) and in the fight against corruption (5th among 30 advanced economies, according to the 2017 Inclusive Growth and Development Report of the World Economic Forum). As a result of the World Bank Governance Indicators, Norway has had an average score of nearly 100% on corruption control over the past two decades.

The country’s citizens are highly satisfied with services and institutions (OECD Government at a Glance, 2015), administrative corruption and petty bribery are almost non-existent (GAN Business Anticorruption Portal, Norway Corruption Report), and Norway’s economic crime-fighting unit, ØKOKRIM, has proven its proactivity in investigating and prosecuting corruption in Norway and abroad (OECD Phase 4 Report: Norway, 2018).

There are other corruption-related challenges, however, such as close networks and conflicts of interest. The country essentially relies on high expectations and trust in its senior officials. Violations of integrity standards have limited formal consequences other than political repercussions. As a result, just like in other countries, disagreements in this regard often lead to heated public debate. In 2017, the Office of the Auditor General found that Parliament had disregarded standard procurement rules and other safeguards for major construction projects, leading to an avalanche of costs and the resignation of the President of Parliament. In 2018, the Minister of Fisheries resigned after having violated security rules during a private trip.

GRECO therefore calls for further measures to prevent corruption and recommends strengthening accountability and law enforcement mechanisms. In addition, more effort should be made to ensure formalized training and guidance on ethical issues for all senior executives. Further measures should be taken with regard to the rules governing how persons in top executive positions interact with lobbyists ‒ and with regard to revolving doors.

In this context, GRECO recommends, in particular, that the following be considered in relation to central governments (top executive functions):

• Providing dedicated training on ethics, conflicts of interest, and corruption prevention in a systematic manner to persons entrusted with top executive functions at the start of their term and on a regular basis throughout their terms of office;
• Establishing a system to ensure consistent interpretation of ethical matters among those responsible for giving advice on them;
• Introducing rules/principles and providing guidance on how persons entrusted with top executive functions engage in contacts with lobbyists and other third parties who seek to influence governmental processes and decisions; in addition: increasing the transparency of the purpose of such contacts, e.g., the identity of the person(s) involved and the specific subject matter(s) of the discussions;
• Amending standards for retaining or accepting paid and unpaid secondary positions, occupations, or other paid assignments in connection with the prohibition of such activities, unless a written (well-considered) authorisation is received that is also made available to the public ;
• Developing general guidelines to address the conflicts of interest that can arise from private activities, both when entering and leaving a government position;
• Subjecting state secretaries and political advisors to the same disclosure requirements as ministers and possibly requiring the same information for spouses and dependent family members;
• Filing disclosures electronically to avoid the possibility of transcription errors on the part of the registrar;
• Enacting enforceable sanctions for failing to file or knowingly make false statements on the disclosure reports;
• Enacting formal systems for review of the declarations of persons entrusted with top executive functions.

As for the police, public surveys indicate that corruption within the police force is very rare (Global Corruption Barometer, 2013). The reliability of police services to protect businesses from crime is considered very high (Global Competitiveness Report, 2017). In addition, the Norwegian government has effective mechanisms in place to investigate and prosecute corruption among police officers (Human Rights Report, 2018).

The police is currently being reformed in order to streamline its operations, and steps have been taken to strengthen internal control and audit systems in recent years. There have also been affirmative moves to improve the protection of whistle-blowers, including recent legislative changes in 2020 and the development of guidelines and operational arrangements. Nevertheless, more needs to be done in order to ensure a more well-coordinated and proactive integrity policy, such as refining risk assessment/information collection tools and better monitoring/cross-checking of integrity-related registers (e.g., business interests, disciplinary action data, reviews and reconsiderations, internal deviation reports, etc.). Furthermore, the Code of Conduct for the Police needs to be accompanied by additional measures to make it meaningful.

With regard to law enforcement agencies, GRECO therefore recommends the following:

• Adopting a coordinated corruption prevention and integrity policy for the police, based on systematic and comprehensive review of risk-prone areas, coupled with a regular assessment mechanism;
• Supporting implementation of the Code of Conduct by means of a more uniform, coordinated, and comprehensive approach, including training programmes and awareness-raising measures on integrity/professional ethics and systematic confidential counselling on these matters;
• Developing a streamlined system for authorisation and recording of secondary activities within the police, coupled with effective follow-up measures;
• Conducting dedicated training and awareness-raising activities on whistleblowing for all hierarchy levels and chains of command within the police;
• Establishing national statistics on disciplinary measures and clearly communicating them to the public while respecting anonymity.