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CONTENTS Message from the Secretary-General


Conference Overview


Welcoming Remarks


CCAICACB Chairman’s Remarks


Opening Proclamation


Acronyms and Abbreviations


A Note About This Report


Opening Ceremony Agenda


Opening Ceremony Photos


Locations of Delegates


Day 1


Day 2


Day 3


Day 4


Day 5







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Your Excellency,

Globally, we are facing a tidal wave of

honourable ministers,


distinguished delegates, Commonwealth friends

The IMF estimates that bribery costs roughly

and colleagues….

1.5 to 2 dollars trillion annually.

We who are gathered here know only too well the pernicious economic, social and political impact that is wrought by entrenched corruption in the lives of people in our communities and in the lives of our nations.

With such dire social and economic consequences at stake, the fight against corruption has to be a priority for all our member countries. In 2015, the UN Office on Drugs and Crime

International organisations, development

estimated that 2 to 5 per cent of global

practitioners, and leaders who are sensitive to

domestic product is laundered each year,

the plight of their people and the wellbeing of

amounting to something between 800 billion

their countries, all recognise that corruption

and 200 trillion dollars annually.

undermines and undoes development. So, in our determination truly to live up to the meaning and ambition of our name ‘Commonwealth’, corruption is a cancer we are compelled to confront.

World Bank research has revealed that corrupt public officials in developing countries receive between 20 and 40 billion dollars in bribes annually.

It undermines in ways which are truly tragic

So, tackling corruption has to be a priority of

the ability of our countries to deliver inclusive

the highest order if we are in earnest about

and sustainable economic growth and social

achieving the Sustainable Development Goals


– and we are.

Where we are

This makes the theme for our conference as urgent as it is appropriate: “Transforming

Doing so brings multiple benefits; poverty is

Words into Action: Revitalising the Fight

reduced, economic stability and growth are

Against Corruption”.

increased, and standards of living raised.



That is why SDG 16 incorporates specific targets relating to reducing corruption, bribery, and illicit financial flows. And the IMF has made clear that the success of all other SDGs depends crucially on getting to grips with the corrosive cancer of corruption. So, we all need to take swift and decisive action to improve transparency and accountability, and to build confidence that our institutions and systems are corruptionfree. That is why the Commonwealth has been active in providing practical technical assistance and development support for national anti-corruption agencies to build their effectiveness in dealing with corruption.

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Annual meetings of the association have been opportunities to conduct training and gain from peer-to-peer learning, and to select countries for benchmarking. An example of this was the Office of the Contractor General of Jamaica offering capacity-building support to the Grenada Integrity Commission on procurement procedures, monitoring and investigation of government contracts. Another was Grenada providing training centre facilities for the Commonwealth to deliver key capacity-building programmes for institutions in the region. Our Commonwealth anti-corruption work programme demonstrates our collective

In our anti-corruption work we employ a three-pronged approach, which involves research, capacity-building and networking. This is being delivered through a strategy of establishing regional anti-corruption agency networks and training centres, facilitating closer cooperation and learning towards attaining SDG 16. The networks promote collaboration and the exchange among member countries of best practice and of practitioners. They also assist with peer review and with measuring the capabilities of agencies against benchmarks.

determination to eradicate this scourge, and it has achieved a global recognition, notably as recipient of the 2018 International AntiCorruption Excellence Award. There have been many other glowing testimonies from heads of Integrity Commissions and Anti-Corruption Agencies: The Prime Minister of Grenada, The Right Honourable Keith Mitchell, generously said: “I thank the Commonwealth for the technical assistance it has given to Grenada in particular and the Commonwealth Caribbean in general and look forward to the promotion of

The Commonwealth Caribbean Association of

Grenada as centre of excellence in

Integrity Commissions and Anti-Corruption

anticorruption work in the Caribbean.�

Bodies was created by the Commonwealth

Where we are Secretariat in 2015.

Since then, we have seen a clear strengthening of these institutions as a result of the collaboration this network has encouraged and facilitated.


The Grenada Minister of Communications, Works, Physical Development, Public Utilities, ICT & Community Development, the Honourable Gregory Bowen, concurs saying:


“The Commonwealth must be applauded for its anti-corruption efforts under the leadership of Commonwealth SecretaryGeneral Patricia Scotland. This is the fourth year that Commonwealth has trained stakeholders, from Grenada and regional participants.” The Chair of the Grenada Integrity Commission, Lady Trotman-Joseph, wrote: “The Integrity Commission of Grenada would like to express our appreciation for the services Grenada has received from Commonwealth Secretariat through Dr Roger Koranteng."

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financial support and expert advice in the subject areas of public sector governance and international AntiCorruption afforded to the association by the Commonwealth Secretariat through the sterling leadership of Dr Roger Koranteng, each year our association has grown in strength and purpose." “His stewardship has been and continues to be the source of strength for the Association members and we are honour bound and owing gratitude to say Thank You to the Commonwealth Secretariat, we could not have done it had it not been for his hard work and effort.” The Chair of the Trinidad and Tobago Integrity Commission, Justice Melville Baird, stated:

"It was as a result of his inputs and guidance under the auspices of the Commonwealth Secretariat that the Commonwealth Caribbean Association of Integrity Commissions and Anti-Corruption Bodies (CCAICACB) held its inaugural Conference in Grenada, in 2015." “The Commonwealth Secretariat has provided the Integrity Commission in Grenada with invaluable support and through his professional skills and competencies and capacity building programmes. Grenada's Integrity Commission has begun to see the benefits of effecting synergies between all our anti-corruption agencies in Grenada and the development of a National Anti-Corruption Strategic Plan.” The Chair of the Commonwealth Caribbean Association of Integrity Commissions and Anti-Corruption Bodies, Mr Dirk Harrison, writes in similar vein:

Where we are


“Permit me to recognize and acknowledge the exemplary facilitation,

“The Commonwealth Caribbean Association of Integrity Commissions and Anti-Corruption Bodies is deeply indebted to the Commonwealth Secretariat for its unstinting assistance and for the gift of Dr Koranteng.” “The CCAICAB is still in its nascent stage and the waters through which our ship must sail in its battle against corruption are fundamentally uncharted. The Commonwealth secretariat through Dr Koranteng has been an invaluable pilot, guiding, advising, encouraging.” The Secretary of the Saint Lucia Integrity Commission, Ms Jean Morille, wrote: “The Office of Integrity Commission of Saint Lucia wishes to voice its appreciation and gratitude to the Commonwealth Secretariat for the excellent work of Dr Roger Koranteng in assisting Integrity Commissions and AntiCorruption Bodies in the Commonwealth in combating corruption.” “His advice and assistance of to our nation and its citizens are immeasurable and of great necessity.”


Those warm encomiums of praise mean a great deal to us, and they encourage us to work even harder to support all that you are doing both at regional level and in your various national settings to deliver change for the people and communities you serve. In 2016, very soon after I took up the responsibilities of Secretary-General, which had been entrusted to me by Heads of Government, I convened the Commonwealth Tackling Corruption Together conference. It drew attention, in particular, to the need for a simple pan-Commonwealth tool to provide practical guidance on clear steps that can be taken to promote integrity and combat corruption – within government, and in private sector organisations. So, I am delighted to report that we at the Commonwealth Secretariat have responded to that need. Through a consultative process with member countries we have developed Commonwealth Anti-Corruption Benchmarks. Indeed, we continue to rely on your expertise as the process of development and refinement continues. Last month, the Commonwealth Secretariat convened a meeting of experts to review the benchmarks package, and I know that some of you participated and contributed at that gathering. The package consists of a set of 22 benchmarks, covering topics from sanctions for corruption offences to investigating and prosecuting authorities, and from political lobbying to disclosure of asset ownership.

Where we are

Each benchmark is defined by a principle stated at a high level, and contains detailed guidance for meeting the level of achievement set by the principle.


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The principles and guidance are consistent with international standards, and go further in covering other areas of concern not previously addressed. Indeed, this Commonwealth package is the first document of which we are aware that connects all the areas of public and private conduct covered by our 22 benchmarks. Although designed to be achieved nationally, compliance with some benchmarks can also be demonstrated by private sector organisations - for example that on ‘Organisational Anti-Corruption Systems’. This will provide enterprises desiring to engage in procurement processes and panCommonwealth trade with a recognised standard of attainment and compliance. Our intention would be for the benchmarks to be considered by Commonwealth Heads of Government when they meet next year in Rwanda. We will by that time be one third of the way through the implementation period for the UN Sustainable Development Goals. As we move on towards the halfway mark in that period, there is an urgent need for all governments to put in place effective execution, monitoring and evaluation structures for SDG implementation. The Commonwealth SDG Implementation Toolkit supports countries with policy gap analysis, and with integrating SDG planning into national development agendas, and tracking and monitoring results. By impairing the ability of governments to collect tax fairly and efficiently, corruption diverts resources away from the vitally important investments that need to be made in areas such as health, education, and renewable energy.


It tends to attract financing towards wasteful projects with only short-term payoffs or negative impact. Corruption also acts as a tax on investment – or can block it altogether because of uncertainty about demands for future bribes. Young people are deterred from investing in skills and education – because, where there is corruption, getting ahead depends on who you know, not what you know. Most damaging of all, corruption hurts the poor – keeping them poor, robbing them of their life chances and ruining their lives. It hinders economic opportunity and social mobility, undermines trust in institutions, and causes social cohesion to unravel. All of these negative impacts are especially debilitating for youth. When corruption is deeply embedded, far too many young people find that they have no prospects, no sense of purpose, no ability to participate, to make their mark, to flourish, or to contribute to society. They lose the motivation, become disillusioned, disengaged, and disenchanted. They lose hope – because corruption can be soul-destroying. But it does not have to be like that – and I am optimistic that the Commonwealth Caribbean is turning the tide against corruption.

Where we are

And the good news continues - with the

further progress you are making through the

work of your Integrity Commissions and Anti-

TODAY Corruption Bodies.

According to the 2017 Corruption Perception

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Index, Commonwealth countries are perceived as less corrupt than non-Commonwealth countries. The edge Commonwealth countries have over non-Commonwealth countries on corruption perception is corroborated by the World Bank Control of Corruption data from 2012 to 2017. In the Caribbean region, Commonwealth countries are also perceived as less corrupt than non-Commonwealth countries, with respective CPI scores for those groupings in 2017 being 53 and 32. World Bank Control of Corruption data confirms this finding, with 2016 scores of 0.43 for Caribbean Commonwealth countries against 0.32 for Caribbean nonCommonwealth countries. It is encouraging too that according to the Transparency International listing of the ten most corrupt countries in the world, there are no Commonwealth Caribbean countries. A contributory factor to this is Commonwealth leadership and cooperation which brings to our members wherever they are the benefits of collaborative working and collective action with counterparts set in every continent and ocean. Small states such as many in this region face unique development challenges, and are particularly vulnerable to exogenous shocks, such as natural disasters and climate change. With limited economic opportunities and significant migration, they often face capacity constraints. We assist our small states with access to sustainable financing, and help them to build their resilience, and to make their voices heard on the global stage. Indeed, at this time when multilateralism is under threat, and we see nationalism and narrow self-interest on the rise, the Commonwealth shines as a beacon of hope and promise.


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Collaboration, based on the needs and

interdependent lies at the heart of all that the

perspectives of all members of our diverse

Commonwealth brings to our world – and that

family of nations, is central to our

includes the work of this 5th Commonwealth

Commonwealth approach.

Caribbean Integrity Commissions and AntiCorruption Bodies Conference.

We draw together countries at almost every stage of social, economic and political

So let us work together with renewed vigour,

development, including some of the smallest

in hope and harmony, to bring health and

and poorest and some of the largest and

wholeness to our Commonwealth.

richest, including five G20 members. Uniting in a spirit of goodwill and mutual

Rt Hon Patricia Scotland QC

support, the similarities of our systems and

Secretary-General of the Commonwealth

institutions enable lessons learnt in one setting to be shared, adapted and applied elsewhere, so that the benefits of progress can be enjoyed more swiftly by others and for the good of all. So where some of our members may lead on holistic interventions that reduce negative human impacts on the environment and regenerate our common earth, others may show the way on measures to advance social inclusiveness or gender equality, or pioneer pathways towards greater political or economic development. By sharing knowledge of what has worked, and understanding better what has not, any one may encourage others to move in positive directions. By offering practical guidance and support, all can help hasten beneficial change. In response to the expectations of our citizens, we continually raise the standards we set for ourselves – whether through mutual support and encouragement among the anti-

Where we are

corruption agencies of our member nations, or

by working together to develop

Commonwealth Anti-Corruption Benchmarks.


An understanding of how as countries, as

communities and as individuals we are


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I am pleased to give the

Grenada who inaugurated the Association in

overview of the 5th

May 2015.

Annual Commonwealth Caribbean Association of

The effectiveness of the Association is based

Integrity Commissions &

on the “collective ownership” by its members,

Anti-Corruption Bodies

and the trust and confidence that member


countries have in the Commonwealth

As you are no doubt aware, the Commonwealth Secretariat, by means of its convening power, established the Commonwealth Caribbean Association of Integrity Commissions & Anti-Corruption Bodies Conference in 2015 to foster genuine partnerships among all Commonwealth Caribbean member states.

Secretariat to work on this important agenda for dealing with corruption. This partnership, brokered by the Commonwealth Secretariat, has led to the institutionalisation of annual meetings of the heads of Integrity Commissions (ICs) and AntiCorruption Bodies (ACBs) – these annual meetings of heads of ACBs act as a focal point

I would like to recognise Dame Monica

for the Association, providing a forum for

Joseph, the then Chairman, and the

heads to peer-review each country’s anti-

Commissioners and staff of the Integrity Commission in Grenada, Mr Julian Johnson, the then Chairman of the Dominica Integrity Commission who worked with me and introduced me to Dame Monica Joseph, for their pioneering roles in welcoming me to the region and Grenada in particular, that

corruption reports and share transferable experiences and peer learning. As members, we have traversed through a 5-year journey of developing impactful results. The journey started in 2015 with the Association’s meeting held in Grenada, Trinidad and Tobago in 2016,

culminated in the establishment of the

Jamaica in 2017, Turks and Caicos in 2018. This

Commonwealth Caribbean Association.

year the Heads of ICs and ACBs in the

Where we are

I cannot mention the establishment of this

Association without recognising with


Commonwealth Caribbean is meeting here in this beautiful Cayman Islands.

gratitude the strong political will of Prime

While we acknowledge a positive profile

Minister Mitchell and the Governor-General of

achieved by the Association, challenges persist.


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Much work that lies ahead of us include the

will a welcome cocktail evening and closing

pressing need to address issues such as illicit

dinner. Index, Commonwealth countries are

financial flows, unexplained wealth, etc. Since

perceived as less corrupt than non-

corruption has international dimension and

Commonwealth countries.

cross-border crimes, we need concerted efforts to address the menace. That’s why this

The edge Commonwealth countries have over

Association’s meetings have provided

non-Commonwealth countries on corruption

practical platforms for members by pooling

perception is corroborated by the World Bank

together the means, experience and resolve to

Control of Corruption data from 2012 to 2017.

address anti-corruption challenges. There is also an urgent call on governments to

In the Caribbean region, Commonwealth

strengthen and resource ICs and ACBs to

countries are also perceived as less corrupt

make them fit for purpose to combat complex

than non-Commonwealth countries, with

and sophisticated corrupt practices of the 21st

respective CPI scores for those groupings in


2017 being 53 and 32.

In terms of the Conference overview, the

World Bank Control of Corruption data

conference programme is in four parts - these

confirms this finding, with 2016 scores of 0.43

are the opening ceremony, 3-day technical

for Caribbean Commonwealth countries

sessions, sight-seeing and AGM.

against 0.32 for Caribbean nonCommonwealth countries.

The opening ceremony sets the tone for the conference as we receive a welcome message

The AGM is the final part of the Conference

from Mrs Rosie Whittaker-Myles, Chairman,

where the Heads of ICs and ACBs will issue the

Commission for Standards in Public Life;

conference communiqué, select the country to

Remarks by Mr Dirk Harrison, Chairman,

host the next conference, and elect the new

Commonwealth Caribbean Association of

Chairperson for the Association.

Integrity Commission and Anti-Corruption

Bodies; key note address by the special guest of honour, the Commonwealth Secretary-

Dr Roger Koranteng

General, the Rt Hon Patricia Scotland QC; and

Interim Adviser and Head, Public Sector

then the opening proclamation of the

Governance Commonwealth Secretariat

conference by His Excellency the Governor of the Cayman Islands, Martyn Roper OBE. The technical sessions are where the conference business is conducted. These comprise of the country and expert presentations, group discussions and networking during and out of sessions.

Where we are

All work and no fun makes Jack a gloomy

person, so there will be one-day sight-seeing


tour to the Stingray Sandbar & Rum Point

Beach Adventure. I must also mention there


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It is a great honour for me to formally welcome you to the Cayman Islands and to this, the 5th Annual Conference of the Commonwealth Caribbean Association of Integrity Commissions and Anti-Corruption Bodies under the Theme “Transforming Words into Action: Revitalising the Fight Against Corruption”. We are especially pleased to have among us at this gathering the Secretary General for the Commonwealth Secretariat, the Rt Hon Patricia Scotland QC, for the very first time since our inaugural meeting held in Grenada in 2015. Madam Secretary-General, we appreciate your having journeyed with us over the years. Although due to other commitments, you faithfully delivered virtual remarks to us which have always been graciously received, we are truly honoured to have you in our presence today and to have you participate in this Conference. You are no

or laws that have not been brought into force while others have inadequately staffed commissions which impede their effectiveness – this while all our countries have committed to take a stand against corruption, to increased transparency and good governance. In other words, although some strides have been made towards our common goal of eradicating corruption in our societies, there is more to be done. Someone I am honoured to call colleague and friend would always caution, “When you fight corruption, corruption fights back”. The only way to succeed in this fight is to strengthen our own ethical resolve; to lobby our respective governments for the resources and laws needed to carry out our mandate and to have a support unit – such as this Association (as well as the Commonwealth Secretariat) on which we can rely for assistance and guidance when needed. To this end, I am especially

stranger to the Cayman Islands, so we

pleased to announce that since his arrival in

welcome you back.

the Cayman Islands, discussions have started between Dr Koranteng, Interim Adviser and

The theme of this year’s Conference reflects

Head, Public Sector Governance for the

our realities throughout the region. Many of

Commonwealth Secretariat, and our Deputy

us have passed and enforced laws but lack the

Governor and head of the Civil Service, to

Where we are


resources to carry out mandates; few of us

assist in providing/coordinating training on

have no laws and no commissions; some of us

initiatives and policies aimed at corruption

have commissions but inadequate laws or

prevention within the Civil Service.


This week promises to be exciting, informative and extremely busy. With delegates attending from as far away as Guyana and as nearby as Jamaica; illustrious speakers and panellists who have offered their time to shine light and offer some solutions on this important subject, I assure you that each and every delegate in attendance will have an opportunity to participate in a meaningful way and will be able, upon your return home, to have at least one or two take-aways to improve your roles as Integrity Commissions and Anti-Corruption Bodies. Notwithstanding the very busy agenda for the Conference, we have also ensured that you will have the opportunity to enjoy some of the natural beauty that we treasure so dearly in our Islands. I trust that you will enjoy Stingray City, Rum Point and more importantly, the warmth and kindness of the Caymanian people. We are grateful to the Commonwealth Fund for Technical Co-operation, the Commonwealth Secretariat, and the Commission for Standards in Public Life and the Cayman Islands Government for their sponsorship of this Conference. Â Mrs Rosie Whittaker-Myles Cayman Islands CSPL Chair

Where we are


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The abuse of entrusted

Distinguished ladies and gentlemen, our

power for private gain,

taxpayers, those who pay and (unfortunately in

simply put, defines

some cases) those who do not, they represent

corruption. We are all in

in a metaphorical sense, as one stakeholder

this room today as we are part of the global fight against corruption. However it must be acknowledged that the perception of acts of corruption, or actual corruption thriving in any society, are

likened it, to the relationship between a tenant and his landlord, our institutions are perceived as the landlord, and the sentiments are not complimentary, to say the least, of their treatment of the tenant. Our

symptoms of societal norms which,

citizenry throughout the region have

unfortunately, the man on the street believes

witnessed, with their own eyes, corruption

thrives with impunity.

playing out and have in some cases unfortunately relied on anecdotal evidence,

We cannot ignore the cries of apathy by the

which in the absence of proof of real or

citizens of our country that not enough, or

circumstantial evidence, has sentenced many

nothing, is being done to contain or stamp out corruption. Our institutions are facing unprecedented scrutiny by law abiding citizens – but the apathy of our people is of an abominable proportion which seems to be at a breaking point in some cases. The stark fact is that some members of the public have in

a public servant and administrator (the landlords, the gatekeepers) to a place of no return in public opinion. Credibility is shot! Institutions and policy makers are asking our taxpayers to believe in a process of fighting

some cases lost hope, and in some others they

corruption to include drafting appropriate

no longer care, and we, yes (the stakeholders)

laws, having adequate and experienced and

in this room are charged with the

competent staff (who are properly

responsibility to make a difference. A

remunerated) and that they will win the fight

difference, not tomorrow or next week but

against corruption. But let us not kid ourselves

now! The cries ‘We Want Justice, We Want

or be naïve – corruption and greed can never

Justice’ are painfully loud and overbearing,

be eliminated, but we must control these

and especially now the Stevie Wonders of the

forces of evil.

Where we are

TODAY world can see clearly.


Most interestingly, a recent World Bank questionnaire posed the questions (words to the effect):‘has corruption gotten worse, is it on the decline, or has it remained the same?’ I therefore ask the question, then, what if any are the indicators existing that we will rely on to determine change or stagnancy, and, dear Mr Sherlock Holmes, what is the reason why we are here this week, I hope? Or, asked another way: are we going up the down escalator, where no perceived change has occurred? Or has there been improvement? Immediate past Chairman Lady Anande Trotman Joseph, chairman of the Grenada Integrity Commission, has called for and I endorse a call, that the Caribbean Commonwealth needs its own Corruption Barometer. Distinguished ladies and gentlemen, if we wish the tenants to “buy into” the process, any process, that process of implementing anticorruption measures, we need to consider the man in the mirror phenomenal; what you see is what you get, but I will go even further and state we must consider the corruption landscape, to be unequally yoked as in 2 Corinthians 6:14 the Good Book says “Be ye not unequally yoked together with unbelievers; for what fellowship hath righteousness and unrighteousness? And what communion hath light with darkness”. On a lighter note a criminal law practitioner said to me years ago, in discussing the plea bargain regime, that his clients are being asked to plead guilty but that they got no bargain. Having said that relationships matter they are the epicurean centre of success and or failure. So today marks an important milestone in the

Where we are

life of this August association of Caribbean

Commonwealth Integrity Commissions and

Anti-Corruption Bodies. It was just five years


ago that the Association began in the heart of

Grenada through the leadership of the then

Chairman of the Association, Dame Monica

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Joseph, and through the expert facilitation of the Commonwealth Secretariat guided by Dr Roger Koranteng Interim Adviser and Head, Public Sector Governance, of the Commonwealth Secretariat. I thank you Honourable Baroness Patricia Scotland, Secretary-General, for your facilitation; we are indeed and forever grateful for the Commonwealth Secretariat’s tremendous facilitation for the last five years and trust that the support shall continue. We as an association are in the midst of our infancy, not yet able to but crawl on our own. But we must conduct our own self-assessment and determine where we are, up, down or the same place on the Caribbean Commonwealth Barometer after 5 years and I humbly say we have seen growth. We cannot as an Association, however, ignore some of the lessons of the last five years (what is an obvious trend) of Integrity Commissions being understaffed, given little or no resources, their independence and operational effectiveness being muttered by policy makers and legislators on both sides of the political divide, who in some cases lack the wherewithal to do justice to the creation of and existence of these Offices. We have seen powers watered down and functionalism disabled to cause stagnancy in the name of development. Wearing a new set of old clothes each day, as the Great J.K. Holt Jr used to tell a player, Dula, at Kensington cricket club in Jamaica, does not cut it. We must create institutions not just in name but in functionality and purpose. We must be guided by the partnerships and learn and grow from them as the technical expertise and support, for example, provided by the Commonwealth Secretariat through its Anti-Corruption benchmarks and also the United Nations Office on Drugs and Crime (UNODC) Commentary on the Jakarta principles for Anti-Corruption Agencies, the European Union, Canada and other local and international stakeholders.


We must all, in closing, embrace change for good and we must create, establish, implement and enforce anti-corruption rules and regulations on and off the field of play during sporting activities, at the work place, and most importantly with our children, teaching them they must always do the right thing, even when no one is looking. If it is not true do not say it, and if it is not right do not say it. On behalf of the association I thank our Deputy Chair of the CCAICACB Mrs Rosie Whittaker-Myles and the Secretariat for hosting through excellence our 5th Annual Conference. Mr Dirk Harrison CCAICACB Chairman

Where we are


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PAGE | 15


It is a pleasure for me to be standing before you today as Cayman hosts the 5th Annual CCAICACB Conference. The Cayman Islands have made great strides towards developing and implementing policies within the civil service and strengthening our integrity oversight bodies over the last few years. Whilst the Commission for Standards in Public Life awaits the implementation date for the Standards in Public Life Law it does not sit idle, as evidenced by its involvement in hosting this week’s conference. Spearheaded by the Chair, Mrs Rosie Whittaker-Myles, and current members Ms Sheenah Hislop and Ms Isatou Smith, the Commission continues to seek ways to carry out its constitutional remit of preventing conflicts of interest and corruption in the public service. Outside of this conference the Commission’s latest initiative involves the dissemination of a United Nations Office on Drugs and Crime educational programme – Education 4 Justice.

Where we are

This programme seeks to promote a culture of

lawfulness, with modules specifically

addressing corruption and integrity, amongst


our primary, secondary and tertiary students

at local private and public educational


Furthermore, the Anti-Corruption Commission, a sibling to the Commission for Standards in Public Life, remains a strong and active oversight body, having received 166 reports since its inception, with numerous arrests, convictions and ongoing investigations. A Whistleblower Policy was effected for the civil service in 2017, which supports the confidential reporting of wrong-doing by public officials, whilst the Whistleblower Protection Law came into effect in 2018. The civil service now also has the ability to utilize a whistleblower hotline staffed by an overseas office, empowering civil servants to confidentially and safely report suspected fraudulent activity. The civil service policies are all a part of the Deputy Governor’s comprehensive Anti-Fraud Policy from 2017, which includes other provisions for codes of ethics and conduct, offering and receiving gifts, and information management. This conference, therefore, comes at an opportune time for the Cayman Islands to intensify its enhancement of the ethical integrity of its public bodies. I now officially declare the 5th Annual Conference of the Commonwealth Caribbean Association of Integrity Commissions and Anti-Corruption Bodies open. His Excellency The Governor, Mr Martyn Roper OBE


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Anti-Corruption Bodies


Annual General Meeting

BIC Belize Integrity Commission CCAICACB

Commonwealth Caribbean Association of Integrity Commissions and Anti-Corruption Bodies

CSPL Commission for Standards in Public Life

DPP Director of Public Prosecutions GIC Guyana Integrity Commission IC Integrity Commission ICC International Cricket Council ICD

Integrity Commission of Dominica


Integrity Commission of Trinidad and Tobago


Memorandum of Understanding


National Integrity Action


Office of the Integrity Commission, Saint Lucia

OBE Order of the British Empire QC Queen’s Council SPL Standards in Public Life T&T

Trinidad and Tobago

TCI Turks and Caicos Islands TCIIC Turks and Caicos Islands Integrity Commission UNCAC

United Nations Convention Against Corruption


United Nations Office on Drugs and Crime

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Tea & Coffee


Procession of Flags

Cayman Islands Cadet Corps

National Anthem and National Song 9:05AM Miss Jaime Ebanks 9:15AM

Prayer Rev Mary Graham St George’s Anglican (Episcopal) Church

9:20AM Welcoming Remarks

Mrs Rosie Whittaker-Myles Chairman, Commission for Standards in Public Life

9:25AM Conference Overview

Dr Roger Koranteng Interim Adviser and Head, Public Sector Governance

Commonwealth Secretariat Winner of 2018 Int’l Anti-Corruption Excellence Award


Remarks by the CCAICACB Chairman

Mr Dirk Harrison

Address by the Commonwealth Secretary-General 9:35AM The Rt Honourable Patricia Scotland QC 9:40AM Opening Proclamation His Excellency the Governor, Mr Martyn Roper OBE


Group Picture


Media Engagement



Where we are


PAGE | 19


PAGE | 20


1. Mr Neil Coates

Antigua & Barbuda

Wherewe ar

2. Mr Radford Hill

Antigua & Barbuda

3. Ms Deirdre Clarke-Maycock

The Bahamas

4. Mr Franklyn Williams

The Bahamas

5. Ms Deshawn Arzu Torres


6. Ms Helen Ambo


7. Mr Stephenson Hyacinth


8. Mr Tafawa Pierre


9. Mr Robert Robinson 10. Mr Kumar Doraisami

Grenada Guyana

11. Mrs Rosemary Noble


12. Mr Dirk Harrison


13. Colonel Daniel Pryce


14. Ms Jean Morille

Saint Lucia

15. Mr Cleophas Regobert

Saint Lucia

16. Mr Greg Christie

Turks & Caicos Islands

17. Canon Mark Kendall

Turks & Caicos Islands

18. Mr Eugune Otuonye

Turks & Caicos Islands

19. Mr Justice Melville Baird

Trinidad & Tobago

20.. Ms Jasmine Pascal

Trinidad & Tobago

21. Ms Sheenah Hislop

Cayman Islands

22. Mrs Isatou Smith

Cayman Islands

23. Mrs Rosie Whittaker-Myles

Cayman Islands

|DAY 1

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Speaker 1 – James Lager

Adjunct Professor at the Robert H. Smith School of Business at the University of Maryland Collaborator with

Fight Less, Design More: Reducing corruption with behavioural ethics

The first presentation of the Conference was given by Mr James Lager. He explained how to reduce corruption through shifting organisational culture to create an environment that encourages ethical behaviour. Sifting through myth and fact he asserted that it is not always “good vs evil” in fighting corruption; rather, context is often underestimated. Further, unconscious bias creates ethical blind spots and makes us overconfident in the benevolence of our intentions. This can be tackled by truly trying to understand the forces acting on individuals’ actions and removing barriers to upholding integrity. His recommendation – create a system that makes choosing the ethical option easy.

| DAY 1

Panel Discussion 1 – Corruption in Sports: The Cricket Perspective Panellists: Mr Whycliffe ‘Dave’ Cameron – Past President, West Indies Cricket Board Inc. Mr Wavel Hinds – President, West Indies Players Association Mr Steve Richardson – Lead Investigator, ICC Anti-Corruption Unit (via Skype)

Moderator: Mr Hector Robinson QC – Chairman of Cayman Islands Cricket Association

Country Presentations - Session One Grenada Mr Tafawa Pierre made the presentation for Grenada discussing the IC and the Financial Intelligence Unit. The conference was updated on training and development, outreach seminars organised, the logo and mascot competition, International AntiCorruption Day celebrations, investigations, filing of declarations of interest, implementation of new policies and procedures, and advancements in combatting fraud and financial crimes.

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the Commission’s recent progress. She summarised the duties of the BIC, which includes ensuring requirements for declaration are complied with, and described the challenges the BIC encounters with maintaining its independence and efficiency. Amongst other things, she acknowledged Belize’s accession to UNCAC in 2016, assessed some of the primary risks for corruption in the territory and described how the establishment of a BIC Secretariat assists with enforcement responsibilities. She also identified the need for local education and greater inter-country cooperation.

Turks & Caicos Islands Mr Greg Christie made the presentation for TCI. He summarised the current composition of the Board of the Commission and the executive, reviewed TCI’s Integrity Commission’s (TCIIC) compliance activities with regards to declarations, reviewed investigations and enforcement processes, and provided information on its public education campaigns and IT upgrades. Being forward looking, Mr Christie briefly touched on the proposed future organisational requirements of the TCIIC.

Government House Reception

Bahamas Mr Franklyn Williams made the presentation

A reception was hosted by His Excellency the

for the Bahamas reviewing the progress the

Governor, Mr Martyn Roper OBE, and Mrs

Bahamian government has made in fighting

Elisabeth Roper during the evening at

corruption. Legislative reforms highlighted

Government House. His Excellency welcomed

included the Fiscal Responsibility Act, 2018;

all to the reception and expressed his

the Freedom of Information Act, 2017; the

congratulations on the successful opening of

Integrity Commission Bill, 2017; the

the conference and extended best wishes to

Ombudsman Bill, 2017; and the Public

all participants for the remainder of the week.

Procurement Bill 2018.

Local dignitaries and representatives from


Conference’s anti-corruption efforts were in

Ms Deshawn Arzu Torres made the presentation for Belize, beginning with a recap of the history of the Belize Integrity

attendance, along with conference organisers,

entities supporting the CCAICACB

speakers and delegates.


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Where we are


| DAY 2

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Speaker 2 –Stacy de la Torre Regional Anti-Corruption Advisor for UNODC The Jakarta Principles: Moving from vision to reality The lead speaker for the second day was Ms de la Torre. She highlighted the main concerns for ACBs as the inability of ACBs to 1) be truly independent, and 2) to obtain necessary resources and staff. She summarised the Jakarta Principles (developed in 2012 by heads of ACBs to “develop basic standards and guidance on the elements of ‘necessary independence’”) and provided a framework for evaluating ACB independence with 4 main categories. The 16 Jakarta Principles flow from these: Institutional Status – Mandate, Collaboration, Permanence; Leadership – Appointment, Continuity, Removal, Immunity; Resources – Remuneration, HR Authority, Adequate and Reliable Resources, Financial Autonomy; and Accountability – Ethical Conduct, External, Public Reporting and Public Communication. For an effective, framework, she emphasised the need that all principles must be present. The future of the Jakarta Principles is adopting the Colombo Commentary, which seeks to operationalise the Jakarta Principles. Ms de la Torre encouraged all ACBs to use the Jakarta Principles to evaluate themselves.

| DAY 2

Justice Melville Baird - Jakarta Principles Roundtable Discussion Justice Baird, a delegate of T&T, led other conference delegates in a discussion of their countries’ measurement against the Jakarta Principles framework as outlined by Ms de la Torre. He began by reviewing T&T’s status with UNCAC and worked through its status with

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more to persons in public life and highlighted the need for greater advertisement of the ICD’s ability to extend the filing period for declarations.

Antigua & Barbuda Mr Neil Coates provided the presentation for Antigua and Barbuda. He identified a list of factors restricting management/operation of the Commission: lack of funding, inadequate

each of the Principles, concluding that T&T is

staffing, inability to discharge its functions

in compliance with the “spirit and philosophy”

under the Integrity in Public Life Act (IPLA),

of the UNCAC. Other delegates, similarly,

and deficiencies in the IPLA. Mr Coates went

commented on their respective countries’

on to describe the Commission’s major

measurement against the Jakarta Principles

undertakings and events of 2018-19. He also

Framework in an open discussion which was

provided a brief overview of the functions of

engaging and useful. Justice Baird’s presentation on T&T and other countries submissions can be found in full in the appendices.

Country Presentations - Session 2 Dominica Ms Helen Ambo of Dominica made the country presentation for that delegation. She discussed the history of the Integrity Commission of Dominica (ICD) since 2003, its dissolution in 2015 and reconstitution, and the recent passing in 2018 of the immediate past ICD chairman. The ICD’s recent activities have included meeting with the Director of Public Prosecutions, engaging in a series of education initiatives, updating educational materials and the ICD policy and procedure manual, and the handling of declarations of interests. Ms

the Commission (including initiating investigations), the procedure for making Complaints to the Commission, the process of obtaining legal opinions on s.12(1)(d) of the IPLA, statistical data related to declarations by persons in public life and complaints filed, and a review of existing penalties in the law as well as proposed penalties and other proposed amendments to the law.

Trinidad & Tobago Justice Melville Baird reviewed the recent achievements of the Integrity Commission of Trinidad and Tobago (ICTT). The ICTT engaged in various education endeavours, including the organising of a poster design competition, and its involvement with other extracurricular activities for youth such as integrity clubs in secondary schools. The ICTT also participated in various workshops and conferences, and spearheaded awareness events on

Ambo also discussed the procedure used to

International Anti-Corruption Day. He reported

analyse declarations of interests. Ms Ambo

that court orders were obtained against

reported a compliance rate for submitting

persons who failed to file their declarations of

declarations of interests in

interests; and 40 complaints to the ICTT were

Dominica in 2017 of 85%, down from 91% in

received over the reporting period. Justice

2012, and discussed the analysis of this using

Baird also noted that recommendations for

workshops. This resulted in the

amendments to the Integrity in Public Life Act

recommendation for the ICD to reach out

had been made.

| DAY 2

Speaker 3 - Professor Trevor Munroe

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Mr Derek Byrne – Royal Cayman Islands Police Service Commissioner of Police Mr Dirk Harrison – Chairman of CCAICACB

Executive Director, National Integrity Action


(NIA), Jamaica Transforming Words into Action: The Petrojam scandal and citizens engagement in Jamaica

Moderator: Ms Helen Ambo – Dominica delegate

Country Presentations - Session 3

Professor Trevor Munroe took heed of the conference theme and framed it with a timely example – the “Petrojam” scandal. He outlined the public perception of the Jamaican government with respect to corruption, where

Guyana Background on the GIC was provided in the country presentation by Guyana delegate, Mr Kumar Doraisami. Mr Doraisami summarised

approximately 60% of the population felt that

the Guyana Integrity Commission’s (GIC)

the country was more corrupt than it was

recent initiatives, which included identifying

three years ago. He further went on to

persons in public life and distributing

demonstrate a chronic lack of public

declaration paperwork to them (along with

engagement by local anti-corruption bodies.

other aspects of declaration management),

These issues surrounded the Petrojam scandal,

executing a communications strategy,

which Auditor General reports described as

increasing administrative staff and ensuring

having contravened the procurement law “frequently”, resulting in $5.2 billion dollars of unaccountable losses. Professor Munroe illustrated that public engagement waned and grew in proportion to the availability of information on the topic, and public pressure eventually resulted in the Minister of the Energy Portfolio, Andrew Wheatley, resigning from his post. He concluded by emphasising the need for ACBs to continue public education and citizen engagement initiatives in order to see results.

Panel Discussion 2 – The Investigative Fight Against Corruption: Challenges and Successes Panellists: Ms Sophia Harris – Cayman Islands AntiCorruption Commission member

proper training, commencing a review of the Integrity Commission Act, and carrying out other administrative and operational functions. The presentation concluded with reviewing challenges/lessons learned, and projections of the GIC for the upcoming year.

Jamaica "Text Not Available"



Where we are


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| DAY 3

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Panel Discussion 3 - Modernising the Legislative Framework to Combat Corruption and Promote Transparency Panellists: Ms Candia James-Malcolm – Acting Deputy DPP

Ms Cheryl Neblett – First Legislative Council, Attorney General’s Chambers Mr Justice Melville Baird – Trinidad and Tobago delegate

Moderator: Mr Franklyn Williams – Bahamas

The panel spoke about the need to, over the years and looking ahead, continue to amend relevant anti-corruption legislation within each of their respective jurisdictions in order to ensure that the legislative provisions meet the current and future needs of investigators. These amendments are primarily brought about at the request of investigators, given that they are the ones with the “boots on the ground”. From lessons learned legislative amendments seek to address the increasingly complex and protracted investigations being undertaken throughout the region. In addition, amendments seek to promote further independence and security of the ACBs themselves and provide prosecutors with clearer provisions for charging purposes. The panel recognised that whilst current legislation continues to operate and ACBs and ICs are not unable to investigate allegations of corruption, the continued modernisation of all aspects of their functioning must remain a priority; legislative amendments are no different.

| DAY 3

Country Presentations - Session 4

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legislation, regulations and codes of conduct, and continued public relations engagement and education programming, especially with

Saint Lucia A history and overview of the Office of the

rolling out the Education for Justice programme into curriculum.

Integrity Commission of Saint Lucia (OICSL)

Panel Discussion 4 - The Impact of

and its activities up to 2018 was provided by

Information Sharing in Combatting

Saint Lucia delegate Ms Jean Morille. He went on to describe their current mission, i.e., to


ensure the Integrity Commission legislation is amended according to previous issues identified, to establish a secretariat for the OICSL, and to set up an OICSL website. The

Panellists: Mrs Sue Winspear – Cayman Islands Auditor General

parts of the legislation to be amended include

Mr RJ Berry – Director of the Cayman Islands

the definition of ‘persons in public life’, the

Financial Regulatory Authority

threshold for declaring gifts, and the ability to

Ms Deshawn Torres – Belize delegate

coordinate with other anti-corruption agencies. The OICSL also looks forward in the future to instituting a robust budget approval procedure and increasing its enforcement

Moderator: Mr Greg Christie – Turks and Caicos Islands delegate

capabilities with regard to negligent

The panel spoke in general terms about the

declarations of interest.

entities which make up the broader anti-

Cayman Islands

Ms Rosie Whittaker-Myles, delegate from the host country, provided the presentation on the Cayman Islands. She reviewed the history and context of the Cayman Islands and the

corruption institutional framework and network in the region. Whilst some of these entities differ from country to country the Executive is remains responsible for determining anti-corruption policy whilst the Legislature is responsible for determining the

Commission for Standards in Public Life

governing laws. In addition, the panel

(CSPL). Work since February 2018 was

discussed the avenues and impacts of

reviewed, which included fulfilling its

information sharing, the merits of educating

constitutional mandates and further

stakeholders and increasing corruption and

promoting the need for implementing SPL

ethics literacy, benchmarking local anti-

legislation, and proliferating UNODC

corruption efforts against other jurisdictions,

Education for Justice programming amongst

raising awareness of anti-corruption efforts

local schools. The main challenges

amongst persons in public life and potential

encountered included the delays in

offenders, improving local coordination of

implementing the SPL legislation and drafting

efforts, especially amongst various branches of

instructions for regulations, and the effect that the general perceived lack of support from stakeholders has had. Future goals include continued advocacy for the implementation of

anti-corruption institutional systems, and the effectiveness of networks and institutional frameworks to facilitate information sharing on combatting corruption.

| DAY 3

Panel Discussion 5 - Integrity

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Speaker 4 – Dr Roger Koranteng

Reform and Innovation: Use of new measures/technology in the fight against corruption

Adviser and Head, Public Sector Governance with the Commonwealth Secretariat, UK Coordination Mechanisms for Inter-Agency

Panellists: Mr Sean Theron – Principal – Advisory, KPMG Mr Adam Huckle – Associate, Maples Group Mr Nicholas Kedney – Partner, Deloitte Forensic

Moderator: Mr Cleophas Regobert – Saint Lucia delegate The discussion was initiated with a fictional anti-corruption and bribery case study that the panellists utilised to set the context for how the roles in each of their respective companies can help in executing anticorruption efforts. The panel discussed the challenges that presented in the case study and the approaches that could be taken. A range of mitigation measures along with explanations were given on how each of those measures could be scaled down or stepped up depending on the resources, financial or otherwise, of the organisation requesting the services. The audience gained a better understanding of how technology is advancing and being used to fight corruption, and in turn how this can increase the efficiency and effectiveness of corruption investigations. In addition, an explanation of how these tools are utilised during the entire process (by investigators and prosecutors alike) was provided.

Cooperation in Combatting Corruption

Dr Koranteng presented his research on the topic of inter-agency cooperation in combatting corruption. He examined the multi-jurisdictional reach of corrupt actors; the importance of domestic cooperation amongst anti-corruption agencies as a foundation for tackling corruption; entities that should be directly involved in detecting corruption; utilising task forces, a coordinating council, MOUs and interagency intelligence sharing as modes of cooperation (and how this can be done most effectively); how to leverage political and operational perspectives from the design stage of national anti-corruption frameworks; the importance of strong leadership and determination, having clear mandates and lines of responsibility, and imposing the legal obligation to cooperate; and forming appropriate IT and communication strategies.



Where we are


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Where we are


| DAY 5


Closing Remarks

Dr Roger Koranteng gave brief remarks on the purpose of the conference and lessons learned from the week that delegates could take home to their respective countries and incorporate into their integrity commissions and anti-corruption agencies. He requested delegates’ attention and focus for one final time for the AGM to conclude the conference.

CCAICACB Annual General Meeting Below is the agenda for the AGM that was held amongst conference delegates to decide on the business before the Association and the way forward for the next year. A communiqué on the conference was drafted by a selection of conference delegates was reviewed and approved at the AGM. This can be found in the appendices along with the full minutes of the AGM.

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| DAY 5

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AGM Agenda 1. Call to Order 2. Prayer 3. Chairman’s Welcome and Opening Remarks 4. Consideration of Reports a. Chairman’s Report b. Treasurer’s Report 5. Matters for Consideration a.The Constitution of the CCAICACB

i. Membership Forms and Dues ii. Appointment of Executive Committee


iii. Resignation/Removal of Officers of the Executive Committee iv. Formation of Non-Profit/Charitable Company – Opinion v. Appointment of Auditor 6. Model Legislation 7. Communiqué arising out of the 5th Annual Conference 8. Election of Members to the Executive Committee 9. Hosting of 2020 Conference 10. Any Other Business 11. Adjournment


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Conference Overview I am pleased to give the overview of the 5th Annual Commonwealth Caribbean Association of Integrity Commissions & Anti-Corruption Bodies Conference. As you are no doubt aware, the Commonwealth Secretariat by means of its convening power established the Commonwealth Caribbean Association of Integrity Commissions & Anti-Corruption Bodies Conference in 2015 to foster genuine partnerships among all Commonwealth Caribbean member states. I would like to recognise Dame Monica Joseph, the then Chairman and the Commissioners and staff of the Integrity Commission in Grenada, Mr Julian Johnson, the then Chairman of Dominica Integrity Commission who worked with me and introduced me to Dame Monica Joseph for their pioneering roles in welcoming me to the region and Grenada in particular that culminated in the establishment of the Commonwealth Caribbean Association. I cannot mention the establishment of this Association without recognising with gratitude the strong political will of the Prime Minister Mitchell and the Governor-General of Grenada who inaugurated the Association in May 2015. The effectiveness of the Association is based on the “collective ownership” by its members, and the trust and confidence that member countries have in the Commonwealth Secretariat to work on this important agenda for dealing with corruption. This partnership brokered by the Commonwealth Secretariat has led to the institutionalisation of annual meetings of the Heads of Integrity Commissions and Anti-Corruption Bodies – These annual meetings of Heads of ACBs act as a focal point for the Association, providing a forum for Heads to peer-review each country anti-corruption reports and shared transferable experiences and peer learning. As members, we have traversed through a 5-year journey of developing impactful results. The journey started in 2015 with the Association’s meeting held in Grenada, Trinidad and Tobago in 2016, Jamaica in 2017, Turks and Caicos in 2018. This year the Heads of Integrity Commissions and Anti-Corruption Bodies in Commonwealth Caribbean is meeting here in this beautiful Cayman Islands. While we acknowledge a positive profile achieved by the Association, challenges persist. Much work that lies ahead of us include the pressing need to address issues such as illicit financial flows, unexplained wealth, etc. Since corruption has international dimension and cross border crimes, we need concerted efforts to address the menace. That’s why this Association meetings have provided practical platforms for members by pooling together the means, experience and resolve to address Anti-Corruption challenges. There is also an urgent call on Governments to strengthen and resource Integrity Commissions and anti-Corruption Bodies to make them fit for purpose to combat complex and sophisticated corrupt practices of the 21st Century. In terms of the Conference overview, the conference programme is in for parts - these are the opening ceremony, 3-day technical sessions, sight-seeing and AGM. The opening ceremony sets the tone for the conference as we receive a welcome message from Mrs. Rosie Whittaker-Myles, Chairman, Commission for Standards in Public Life, Remarks by Mr. Dirk


PAGE | 42

Harrison, Chairman, Commonwealth Caribbean Association of Integrity Commission and AntiCorruption Bodies, key note address by the special guest of honour, the Commonwealth SecretaryGeneral, the Rt Hon. Patricia Scotland, QC and then the opening proclamation of the conference by His Excellency the Governor, Martyn Roper, OBE. The technical sessions are where the conference business is conducted. These comprise of the country and expert presentations, group discussions and networking during in and out of sessions. All work and no fun makes Jack a gloomy person, so there will be one day sight-seeing to the Stingray, Sandbar & Rum Point Beach Adventure. I must also mention there will a welcome cocktail and closing dinner. The AGM is the final part of the Conference where the Heads of ICs and ACBs will issue the conference Communique, select the country to host the next conference, and new Chairperson for the Association. WHO is this person? He is African, American, Asian, Australian, Caribbean, Canadian, Chinese, European, Nordic, and from the Pacific… He or She can be of any nationality, creed or race…he/she is:A PIMP: - Uses other people without any care and sucks the life and spirit out of anyone that can assist him or her in his or her achieving a personal gain or advantage. IGNORANT: he or she has no feeling or care for any other person(s). He/she “ignores” his/her fellowhuman being. MANIPULATIVE: He or she manipulates persons, environments and dynamics for his /her sole advantage. MISANTHROPIC: he or she has to dislike other person…. he or she is the only one that counts. PARASITIC: he or she “feeds” on other people’s talents, labour and intellect…he or she sucks out the spirit of his/her follow human being. CONCEITED: he or she believes himself and herself to be superior, smarter than you and I because after all he or she “has found a way to cheat the system”…and that is a high mark of superiority in the mind of this “rogue”! A HYPOCRITE: - he or she is the ultimate hypocrite who practices hypocrisy- he or she display trust by holding a position of trust well-knowing that he or she practices distrust at the highest end of the scale. A LIAR: - he or she is a liar….He or she cannot be anything else than practicing corruption….most of all he or she is a liar to himself or herself… AN OPPORTUNIST: - He or she can “sniff” an opportunity when one presents itself. If no opportunity presents itself, he or she creates one! GREEDY: - there is no limit to his or her greed- even when he or she has achieved sufficient selfenrichment to everyone’s detriment, he or she wants more….


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ARROGANT: - he or she is utterly arrogant….and often incensed at being suspected of corruption…..and displays complete superiority when practicing his or her unlawful acts. This is the person who causes over one trillion us dollars per year in damage to society by sucking out every economy where he or she operates…. For every anti-corruption fighter - this is the photo that you should have on your office notice board…to remind you that this is the person you must stop…..and remember once you succeed to send him to confinement...he or she will manage to corrupt his/her new environment. This is the universal corrupt person… keep watching him/her…!!! Dr Roger Koranteng Interim Adviser and Head, Public Sector Governance Commonwealth Secretariat


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DAY 1: James Lager – Fight Less, Design More: Reducing corruption with behavioural ethics

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June 2019

Fight Less, Design More Reducing corruption with behavioral ethics James M. Lager, JD, MSOD Adjunct Professor Robert H. Smith School of Business University of Maryland, USA

Deputy Ethics Counselor* US Government Accountability Office

*The opinions here do not represent GAO’s institutional views

5th Annual CCAICACB Conference Grand Cayman Island

Myths about corruption

PAGE | 44b

Good guys are ethical, bad guys are corrupt



Real people are neither good or bad, black or white. We’re grey

Myths about corruption and behavior

PAGE | 44c

Good motives lead to good conduct and bad motives lead to corrupt conduct We overestimate how much behavior is caused by character, intentions or abilities Ordinary people commit evil by responding to their circumstances in ways they feel are righteous. Not just who but what is responsible. (Zimbardo: The Lucifer Effect)

Bernie Madoff

Myths about corruption and behavior

PAGE | 44d

(More‌) Good motives lead to good conduct and bad motives lead to bad corruption We underestimate the power of context to weaken the relationship between actions and intentions (Ross 1977)

Retirement savings

Exercise more Eat healthy The road to Hell is paved‌

Milgram experiments

People with good motives do bad things, and often think they are right

Myths about corruption and behavior

PAGE | 44e

Offenders use cost-benefit analysis before acting

If the bat and ball cost $1.10, And the bat cost $1.00 more than the ball, How much does the ball cost? 10 cents!

x + (x + 1.00) = $1.10 2x + 1.00 = $1.10 2x = .10 x = .05

Myths about corruption and behavior Ethical reasoning leads to ethical behavior

Plato (Phaedrus); Katha Upanishad

“Knowing something is wrong...and the explaining why, are completely separate processes.” Jonathan Haidt Moral Dumbfounding We know things are wrong, but can’t always explain why.

PAGE | 44f

Myths about corruption and behavior

PAGE | 44g

Ethical reasoning drives ethical behavior

Ethical judgment by intuition and emotion (elephant) is automatic Conscious reasoning (rider) to justify the judgment follows Riders think they are in control, but the emotional elephant is strong Motivation is tied to our automatic emotional thinking It’s really hard to steer a determined elephant

PAGE | 44h

Unconscious bias leads to corrupt acts Motivated Reasoning (I don’t like it, so it can’t be true) The right answer is known in advance • • •

Is human behavior causing climate change? Should most members of a planning authority (zoning) be builders? Is it Cricket?

We have Blind Spots Bounded ethicality: People often don’t see ethical issues because of systematic and predictable ethical blind spots

Should-self and Want-self

PAGE | 44i

Unconscious bias leads to corrupt acts Most ethical problems stem not from people seeking to enrich themselves, but from unconscious bias. • We believe we are more ethical than others • We have an illusion of objectivity. We can put aside self-interest – but they can’t! 92% of Americans are satisfied with their own character

Confirmation bias assures us that we really are right! “I will look at any additional evidence to confirm the opinion to which I have already come.” Lord Molson

PAGE | 44j

Unconscious bias leads to corrupt acts Overconfidence “Human minds are overconfidence machines.” David Brooks 93% of US drivers believe they are better than average 94% of college professors think they are above average Almost all newlyweds predict their marriages will last until “death do us part.”

Overconfident executives are more likely to commit financial reporting fraud. (Libby & Rennekamp 2012)

Tackle unconscious bias by examining the ethical system

Good Grades!

Sonner, B. S. (2000). A is for “adjunct”: Examining grade inflation in higher education. Journal of Education for Business, 76(1), 5-8.

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Systems factors that encourage corruption POOR PERFORMANCE MEASURES ď ą A compensation system that rewards bank employees for the number of new accounts they open begs for fraud.

ď ą A compensation system that rewards government officials to meet performance goals based on a single metric begs for fraud.

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Systems factors that encourage corruption Stress and Deadline Pressure More misconduct when people are tired or pressed for action. No Segregation or Rotation of Duties Lack of internal controls facilitates corrupt behavior. Goals Gone Wild! Stretch goals beg for stretching the truth and measure management.

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Systems factors that encourage corruption Short-term orientation Focusing on immediate goals (quarterly profits) leads to measure management  a long-term focus creates more value, and makes gaming the numbers ineffective

“Business” frame predominates Narrow cost-benefit and profit focus crowds-out broader ethics concerns  ethical fading, moral disengagement

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Common Anticorruption Efforts

Codes of Conduct

No evidence Codes affect behavior

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Common Anticorruption Efforts Threatening Punishment

Evidence unclear that punishment works

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Common Anticorruption Efforts

The threat of being caught deters! Suggests: Audits and inspections

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Common Anticorruption Efforts Ethics Training

Bernie Madoff

Immanuel Kant 17th Century Philosopher

Scant evidence ethics training changes behavior No evidence ethics training makes long-term change

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Common Anticorruption Efforts We Need Better Laws!

Strategy: Attend to ethical culture

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Ethical culture correlates with ethical behavior

Strategy: Remove impediments to ethical culture

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Strategy: Ethical nudges and ideas Sign at the top!

Internal controls Avoid Diffusion of Responsibility

Properly align rewards Don’t rely on personal integrity or the criminal law while your systems encourage unethical behavior.

Promote the shared values of your organization

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Strategy: Ethical design principles Make it easy to do the right thing. • Removing obstacles is often the more effective approach • Reward good process not just good outcomes

Attend to risk with a systems view • Identify opportunities for unethical behavior and address them with systems and incentives • Imagine how a tired, stressed, or person with weak selfcontrol would react in that situation

Deal with the elephant in the room • Corruption comes from automatic thinking, not cold costbenefit calculation • Persuade the elephant with emotional appeals Honor, integrity, reputation

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Prevent corruption by shaping the path

The law and policy should not have to work so hard. “Ethics is not a belief problem, it’s a design problem.” Prof. Nick Epley, University of Chicago

Conscious reasoning, pleas to behave, and threats

Selected References (with gratitude to these and other scholars)              

PAGE | 44y

Ariely, D. (2008). Predictably irrational: the hidden forces that shape our decisions. New York. NY, EtatsUnis: HarperCollins Publishers. Bazerman, M. H., & Tenbrunsel, A. E. (2011). Blind spots: Why we fail to do what's right and what to do about it. Princeton University Press. Epley, N. (2014). Mindwise: Why we misunderstand what others think, believe, feel, and want. Vintage. Haidt, J. (2001). The emotional dog and its rational tail: A social intuitionist approach to moral judgment. Psychological Review, 108, 814–834 Haidt, J. (2012). The righteous mind: Why good people are divided by politics and religion. Vintage. Haidt, J., Bjorklund, F., & Murphy, S. (2000). Moral dumbfounding: When intuition finds no reason. Unpublished manuscript, University of Virginia. Kahneman, D. (2011). Thinking, fast and slow. Macmillan. Kouchaki, M., Smith-Crowe, K., Brief, A. P., & Sousa, C. (2013). Seeing green: Mere exposure to money triggers a business decision frame and unethical outcomes. Organizational Behavior and Human Decision Processes, 121(1), 53-61. Ordóñez, L. D., Schweitzer, M. E., Galinsky, A. D., & Bazerman, M. H. (2009). Goals gone wild: The systematic side effects of overprescribing goal setting. The Academy of Management Perspectives, 23(1), 6-16. Ross, L. (1977). The intuitive psychologist and his shortcomings: Distortions in the attribution process. In Advances in experimental social psychology (Vol. 10, pp. 173-220). Academic Press. Soltes, E. (2016). Why they do it: inside the mind of the white-collar criminal. PublicAffairs. Shu, L. L., Mazar, N., Gino, F., Ariely, D., & Bazerman, M. H. (2012). Signing at the beginning makes ethics salient and decreases dishonest self-reports in comparison to signing at the end. Proceedings of the National Academy of Sciences, 109(38), 15197-15200. Thaler, R. H. H., and Cass R. Sunstein. 2009. Nudge: Improving decisions about health, wealth, and happiness. Penquin. Zimbardo, P. 2007. The Lucifer Effect: Understanding How Good People Turn Evil. Random House.


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DAY 2: Stacy de la Torre – The Jakarta Principles: Commentary for Anti-Corruption Agencies

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The Jakarta Principles: Moving from vision to reality. by Stacy de la Torre, Regional Anti-Corruption Advisor, UNODC

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• Primary rules: Primary rules are rules, or laws, that govern general societal conduct. Thus, primary rules construct legal obligations and consequences when they are disobeyed. (Rules of conduct) • Secondary rules: Secondary rules confer the power to change, modify, or enforce primary (and secondary) rules. (The latter are rules of adjudication.)

Jakarta Principles

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Summary of Jakarta Principles

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Institutional Status




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HR Authority

Adecuate and reliable resources

Financial Autonomy

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Ethical Conduct


Public reporting

Public Communication

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Jakarta principles are like a house of cards

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Steps towards the implementation of the Jakarta Principles • Panel on ACAs at the 15th IACC in Brasilia (Nov. 2012) • Adoption of the Jakarta Principles in Jakarta, Indonesia (Nov. 2012) • Panama Declaration by the International Association of AntiCorruption Authorities (Nov. 2013)

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Steps towards the implementation of the Jakarta Principles • Conference of States Parties to the UNCAC, Resolution 5/4 (2013)

• Conference of States Parties to the UNCAC, Resolution 7/5 (2017)

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Steps towards the implementation of the Jakarta Principles • Legislations adopted in Burkina Faso (2015), Niger (2016) and elsewhere, aligning with the Jakarta Principles • Transparency International’s Report on ACAs in Asia (2017) • Special Event in the side-lines of the 7th CoSP in 2017

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Steps towards the implementation of the Jakarta Principles • Constitution of the Association of Anti-Corruption Authorities in Africa (AAACA) (Sept. 2013)

• Constitution of the Network of National Anti-Corruption Authorities in West Africa (NACIWA) (June 2015) – Preambule:

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Next step? • Adoption of the Colombo Commentary – a.k.a the “CoCo” • Hopefully, like a coconut it will drift to other shores.

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Thank you for your attention


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DAY 2: Trevor Munroe – Transforming words into action: The Petrojam scandal and citizen engagement in Jamaica

PAGE | 46a


Salutations. May I thank Sheenah Hislop for her kind words of introduction and also express my sincere appreciation to the Commonwealth Secretariat to Roger in particular and to the team from Commission for Standards in Public Life as especially Rosie for inviting me to participate, to learn from and to once again make a presentation. In listening to the country presentations I want to express appreciation to colleagues staying the course. I thought I would share with you my reflections and experience in relation to the Conference Theme “Transforming Words Into Action” and relate it to an issue that has dominated Jamaica’s governance over the past year. In a word, my central argument, reinforced by the Petrojam scandal in Jamaica is: in a situation of endemic corruption, heightened citizen engagement is critical for transforming 1

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words into action but equal, requires enormous effort by anti-corruption leaders in public bodies as well as in civil society especially in a period of relative public passivity – both to support the Commission in any quest for additional resources as well as to defend it against push back from powerful interests. NB Stacy’s recall of Indonesian experience – Dominica Commission/Government at loggerheads non-compliance/non-functioning public media outcry.

In relation to our theme, I am concerned with “words” from two different sources which have to be transformed into action. The first source is “words” from political leadership and the second is statements from anti-corruption bodies. Let us deal with each in turn. “Words” of Political Leaders Political Leaders, as you know, seek to outdo one another in commitments to deal with corruption. For example, in Trinidad & Tobago, the Manifesto of the People’s National Movement in 2015 declared “Corruption will not be shielded or protected by a PNM Government”. In 2016, the Manifesto of the Jamaica Labour Party led by our current Prime Minister, Andrew Holness, committed to “bring an end to rampant corruption” and beyond that promised “swift and appropriate sanctions for 2

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breaches of anti-corruption laws”. And so it has been pledges by political leaders in responding to public concerns re corruption.

In 2018, the LIMA Commitment

supported by the Heads of Government in the OAS, called for public filing of financial disclosure statements by public officials where appropriate. To his credit, at his inauguration as Prime Minister, on February 26, 2016, Prime Minister Holness recognised that “there is only so much trust that…statements of commitment can buy…the Jamaican people want to see action…trust requires the actualisation of commitments.” One year subsequently, there was, to use in the Prime Minister’s words, some “actualisation”; the Integrity Commission Bill was laid in the House of Representatives with the further Prime Ministerial pledge “we commit to bold and decisive actions to eradicate corruption by the necessary passing of legislation”.

The law, that is, the Integrity Commission Act, came into being on February 22, 2018. It represented an important “action” in transforming those words. However, the action was weaker than the words had promised. A major deficiency is the inclusion of Section 53 (3) which requires that “until the tabling in Parliament of a report…all matters under investigation…shall be kept confidential and no


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report or public statement shall be made by the Commission” in relation to that matter. Not surprisingly, surveys of public opinion suggest that when actions fall short of commitment this contributes to the growth of negative perceptions amongst the public. Eight months after the passage of the Act, an October 2018 national poll in Jamaica conducted by the respected Don Anderson organization revealed the following in response to the question “Thinking of three years ago compared to now, would you say that there is more, less, about the same level of corruption as three years ago? 59.7% of the population said more and within that overall sample, the youth between 18 and 24 have the highest negative opinion, namely 63.3% and women far exceeded men 66% to 52%.”

It is very likely that similar opinion in other territories with the possible exceptions of Grenada, Barbados and Bahamas would have sustained the perceptions of corruption in the Caribbean eight years before when 52.5% believed the politically connected criminals go free. Then in Jamaica 52.7% of Jamaicans believed that “powerful criminals go free” and 57.8% that “politically connected criminals go free” (source: Caribbean Human Development Report January 25, 2012). It is worth recalling that the comparable numbers for Trinidad and Tobago was 61.6% re


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powerful criminals and 70.2% re powerfully connected criminals. Clearly on the face of it far more is needed to transform the words of political leaders into the action that “people want to see”, to use Prime Minister Holness’ phrase, and thereby arrest declining trust and confidence in institutions of governance.

“Words” of Anti-Corruption Bodies What about the words of Anti-Corruption Bodies and Integrity Commissions? Let us recall our commitment as recorded in the communique from our Fourth Annual Conference in Turks & Caicos last year. We agreed then, among other things, “that Integrity Commissions and Anti-Corruption Bodies should further intensify their public education and citizens’ engagement and initiatives…in particular continue the deeper mobilisation with…civil society organizations and religious bodies…”. This commitment, of course, reflected one of the principles of the Jakarta Statement which urged Anti-Corruption Agencies to “communicate and engage with the public regularly in order to ensure public confidence…”. Part of the clear mandate from Jakarta was to “tackle corruption through…awareness raising…”.

Even prior to Jakarta, the United Nations Convention Against

Corruption, in Article 13, obliged signatory states to promote “active participation


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of individual groups” and to engage the society and the people in the combat of corruption. As I hope to demonstrate in reviewing the Petrojam case, we in civil society have taken these mandates seriously and have tried to “put our money where our mouth is”. I note in the country reports, despite constraints, some effort to include in the report on how far we have transformed our 2018 words in the Turks & Caicos Islands, into actions in the months that have preceded this Conference. Suffice it for me, as a friend and long standing advocate of Jamaica’s Integrity Commission, to point to one fact: the first “official press conference” of Jamaica’s Integrity Commission was held on the Thirteenth of May 2019, that is one year two months and 22 days after the Commission came into effect. No doubt there are explanatory factors and extenuating circumstances having to do with preoccupation with the complexity of merging three legacy agencies into one. No doubt you shall also review those circumstances and encourage the commitment to have hereafter regular interactions with the media.

Petrojam “Scandal” Against this background I now wish to turn to the Petrojam case study. First of all, Petrojam is a limited liability company, incorporated in October 1982 as a wholly


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owned subsidiary of the Petroleum Corporation of Jamaica (PCJ). The company operates the only petroleum refinery in Jamaica, processing crude oil into various finished products including liquefied petroleum gas, asphalt and unleaded gasoline. Crude supplies are sourced primarily from Venezuela and finished products imported mainly from Trinidad and Tobago. In terms of revenue Petrojam is by far the largest public body in Jamaica, with projected revenues in 2018/2019 of 1.3 Billion US Dollars. Ironically, the company has as one of its core values “integrity” which, it explains, commits the entity to “operate to the highest ethical standard” and to “be honest, frank and transparent with others”.

On May 22, 2018 in his

presentation to the Sectoral Debate, the Opposition Spokesman on Science and Technology “called on the new Integrity Commission and the Auditor General to urgently examine the operations of the state owned oil refinery Petrojam” (Gleaner, May 23, 2018). He claimed that what was happening at the state owned agency reminded him of “the wild, wild west” including wide spread nepotism and irregularities of all kinds.

Arising from what the Auditor General described as “public concern”, that office commenced and completed field work between June and September 2018. The


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Report was published in December 2018. The report confirmed “In awarding contracts, Petrojam frequently contravened the terms of procurement law…explicit acts of nepotism…could not account for $5.2 Billion” in unaccountable losses, made sponsorships and engaged consultants in breach of relevant policy. This continued a practise detected by previous reports across administrations.

Unlike previous

reports of past Auditor Generals and similar “scandals” Petrojam has not been a seven-day wonder. I am indebted to my colleague, Jeanette Calder, Executive Director of the Jamaica Accountability Meter Project (JAMP) for her recalling some of these seven-day wonders stretching over fifty years: 1967 – “Auditor General’s Report Tabled in House: Financial Irregularities Losses Shown” 1978 – No Accounts Ever from Regional Hospital Boards; 1984 – Auditor General Dissatisfied with National Accounts; 1991 – Grim Conditions at Bellevue:

Neglect, Demoralisation, Petty

Corruption Citing; 2001 – Ministries Guilty of Poor Financial Control; 2011 – Private Sector Groups Call for Sanctions for JDIP Breaches;


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2017 – Government Department Spends 76 Million Dollars on Rent Without Moving In. These are but a sample of Auditor General’s Reports which arose and disappeared in short order with little or no consequential action. The one outstanding exception related to the Farm Work Programme in relation to which an Auditor General’s Report of 1990 found irregularities: subsequent investigations led to the charging, prosecution and incarceration of the then Minister of Labour. That was the last such occasion, almost thirty years ago.

In relation to Petrojam, I remind us that the issue arose twelve days before our Fourth Annual Conference and remains alive today, one year thereafter. Secondly, there has been some transformation of words into action, albeit limited and incomplete:  The entire Board, the General Manager and senior staff were required to resign;  The Minister of Energy, Science and Technology was compelled to resign;  The Government, through the Prime Minister, responded to pressure by making a number of policy changes and disclosures earlier resisted in Parliament. For example, on the third of July, The Cabinet announced that 9

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“public bodies will be prohibited from entering into sole-source retainer contracts without the prior approval of Cabinet…the Ministry of Finance has been tasked with developing uniform regulations for public bodies…it will be a requirement that all donations be disclosed with details to include the amount, the receiving entity, the purpose of the donation and connected party consideration with the Management, Board of Directors or the Minister”. Actions yet to be completed and disclosed include the results of the investigations being carried out by the Integrity Commission and the Major Organised Crime Anti-Corruption Agency.

Main Lesson My submission is that it is Citizen Engagement alongside transparent Parliamentary oversight (the proceedings of the PAAC are televised live and clips uniformly make the nightly news) that has so far achieved some advance and it is citizen engagement that needs to be sustained, broadened and deepened if further advances are to be made.

To sustain, deepen and broaden citizen engagement is particularly 10

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challenging in the current Jamaican and, I dare say, Caribbean context. That context incorporates a complex contradiction. On the one hand surveys indicate that the people themselves believe they “can make a difference in the fight against corruption”. The Latin American and Caribbean Global Corruption Barometer 2017 revealed that 73%, 58%, 89% of the people respectively in Jamaica, Trinidad and Tobago, and Bahamas feel they can make a difference.

At the same time however and on the other hand, data in Jamaica confirms a downward trend on all indicators of participation – in community groups and organizations, including religious organizations, to say nothing of electoral participation which saw the lowest voter percentage turnout in over seventy years in the 2016 Jamaican general election. Consistent with this trend, the 2017 LAPOP Report indicated that Jamaica had the lowest level of protests of the twenty odd countries surveyed in the Western Hemisphere. Hence, extraordinary effort is required to move the needle of citizen engagement essential to drive and to defend sustained action by Integrity Commissions and Anti-Corruption Bodies. Data relating to engagement on Petrojam confirms this effort.


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First the traditional media, in the first week of the Petrojam scandal coming to public attention, there was one reference in the national newspapers. This gradually grew until in the fifth week following the initial exposure, there were 28 items of news, columns, letters to the editor and editorials in The Gleaner and The Observer. In week six, that had grown to 36, an average of five per day. Interestingly, in the week following, on July third, the Prime Minister felt compelled to relieve Minister Wheatley of the Energy Portfolio, but retained in Cabinet with other portfolio responsibilities. Print media attention continued in weeks seven, eight and nine. In the week between July eighth and fourteen, there were 48 items, that is, seven per day in the two national newspapers.

The electronic media was little different. In the sixty-one days of the months of June and July 2018, there were forty-two items of news, current affairs discussions and interviews in which, in my capacity as Executive Director of National Integrity Action, I took part. Social media commentary, while generally not focussed on public affairs, nevertheless reflected and sustained interest in the Petrojam scandal. The following are typical:


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June 24, 2018 – Andrew Wheatley should be fired. I cannot believe unno in power two years and unno do more corruption than PNP in 18 years. Shameful! Shameful! June 24, 2018 – Send them to prison. Set example Mr. Prime Minister. July 3, 2018 – Good job. The PM has exercised his authority and is dealing with the situation, something I have never seen from a PNP Government (on Wheatley being relieved of the Energy portfolio) July 19, 2018 – The prisons should be filled with these corrupt politicians, policemen and women and others from every nook and cranny of the island. July 30, 2018 (On the announcement of Wheatley’s resignation) – What took you so long, having seen your credibility shattered?? Resignation, yes. Fine!!! We need those fat career politicians to pay back with their own money the tax dollars which they have fleeced us. Accountability!!!

Underlying and contributing to this media attention were the weekly exposures in the meetings of the PAAC and the effort of National Integrity Action to initiate and sustain a broad coalition of civil society and private sector groups. This effort begun with a statement on June 28, 2018 in which NIA insisted “that either Minister


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Wheatley tenders his resignation forthwith or the Prime Minister asks him for his resignation”. This was followed by a meeting, requested by NIA, between NIA and the Umbrella Groups of Churches on July 5 “to consult on the question of integrity and good corporate governance on the obvious erosion of public trust which has become a feature in the Jamaican society over the years”. Both organizations then joined “in seeking separate meetings with the Honourable Prime Minister, Leader of the Opposition and the Private Sector Organization of Jamaica to address the long standing deficit of public trust which has been further damaged by the Petrojam situation”. This was followed by a meeting of the NIA and the JUGC with the PSOJ, the Jamaica Chamber of Commerce and the Jamaica Manufacturers and Exporters Association. Arising from that meeting the five organizations together met with the Leader of the Opposition first, and thereafter with the Prime Minister on July 31, 2018. Minister Wheatley resigned on July 30, 2018. In a joint public statement arising from the July 31 meeting, the Prime Minister agreed to “ensure that the investigative agencies (MOCA, Integrity Commission) are given adequate budgets”.


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Over and above and surrounding media interests and partnership building relating to Petrojam, NIA sustained citizen awareness building with significant advertising on commercial spots in the media. Between May 28, 2018 and April 2019, there were 1,977 spots on TV/cable channels; 1,565 on radio; 182 in the cinema totally 3,724, as well as strategically placed billboards urging citizens to “do the right thing”. Over this twelve month period the cost – approximately US$300,000.

I conclude that the “transformation of words into action”, in the Jamaican and Caribbean context, requires that we renew and implement the commitment of the Fourth Annual Conference to “further intensify public education and citizen engagement and initiatives”. Otherwise, we too like the politicians, shall fall victim to the people’s distrust and lack of confidence in authority and our governance arrangements.

Professor Trevor Munroe, CD, DPhil (Oxon) Executive Director National Integrity Action



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DAY 3: Dr. Roger Koranteng – Coordination Mechanisms for Inter-Agency Cooperation in Combating Corruption

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Coordination Mechanisms for Inter-Agency Cooperation in Combatting Corruption By Dr Roger Koranteng Adviser and Head, Public Sector Governance Commonwealth Secretariat, London, UK

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Introduction • This presentation covers issues related to cooperation between agencies that are responsible – directly or indirectly - for fighting corruption.

• And highlights practical ways in which cooperation between various agencies involved in dealing with corruption can be enhanced. • Moreover, it identifies ways in which multi-agency approach can be as an effective way of addressing corruption using all available tools at the disposal of the anti-corruption agency

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• The success of Anti-Corruption Commissions (ACCs) strongly relies on the effectiveness and cooperation of many other complementary institutions such as the public prosecutor, the ombudsman, the auditor general, Procurement regulator, Police and aw enforcement Agencies, Financial Intelligence Units, the courts, etc whose contribution and interaction play a crucial role. • Yet, experience worldwide indicates that in most countries, cross-agency coordination remains weak or inexistent. • Law enforcement agencies are often not well connected and integrated, due to their wide diversity, overlapping mandates, competing agendas, various levels of independence from political interference and a general institutional lack of clarity.

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Jurisdictional Reach • Fighting corruption and related activities can be complex and resource consuming. The corruption cases may entailed sophisticated schemes with multiple actors and are further complicated by their multi-jurisdictional reach. • Combating corruption and the laundering of the proceeds of corruption cannot be undertaken by a single agency acting in isolation, no matter how competent this agency and its staff may be. • It is important to note that depending on a jurisdiction’s legal and criminal justice history, will have jurisdiction over the predicate crime of corruption. • And it is precisely because, this jurisdiction may be in a single or very few agencies, that, it is essential that, there is cooperation in combating corruption.

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Domestic Cooperation • By domestic cooperation, we mean that relevant government agencies responsible for combating corruption interact with each at both the policy and operational levels.

• The interaction should be in the form of exchanging of information, cooperating on cross cutting agency investigations, exchange of staff in order to share their expertise with another agency, and generally, participation in inter-agency fora on a frequent and ongoing basis

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Why the Need for Cooperation? • Take the case of a contract between a government and private sector players for the supply of equipment for hydroelectric development; installation of an airport radar; and passport equipment. • These types of large government projects would typically fall within the portfolio of several ministries and as the cases above illustrate, intelligence that would lead to the detection of corruption activities may potentially come from a variety of sources. • However, unless anti-corruption agencies establish continuous surveillance over public officials, and/or private sector players involved in these projects, it is difficult to catch corrupt officials committing corrupt acts and private individuals corrupting them.

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Why the Need for Cooperation? • Therefore, detecting corruption would entail looking into circumstances where these officials, or corrupters, are the most vulnerable, that is, when receiving cash or other assets, when placing these assets in safe havens or in their attempts to legitimize these assets. • These transactions undertaken with illegal proceeds necessarily will leave traces as they are recorded in different databases. • Say a car is bought with illegal proceeds, some government agency will undoubtedly have maintained a trace of the transaction: matriculation of the vehicle, the information is out there, but transforming this data into intelligence that can further be exploited, linked to criminal activity and produced as evidence in a prosecution, • requires the collaborative efforts from key national stakeholders.

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Why the Need for Cooperation? • Thus combating corruption requires participation from all sectors of government and the private sector. • In order to effectively combat corruption governments have established specialized anti-corruption agencies, however, these agencies will need to work in concert with other institutions, whether for referral of potential criminal activity, occurring suspicious activities or in order to collect evidence and build a strong corruption case.

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Agencies Directly Involved in Detecting Corruption Activities • The following institutions would invariably play a role in tackling the problem of corruption. • Depending on the jurisdiction, each plays a specific role according to the legislative mandate given. • But regardless of the divergence of responsibilities, there is an overlap in the work done particularly on the ultimate objective, i.e. combat corruption. • The Audit Office, the Public Prosecutors Office, Integrity Commissions, the Anti-Corruption Agency: the Police/Investigative Agencies, Office of the Ombudsman, Judiciary, etc.

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Avenues for cooperating (or models of cooperation) • They are numerous ways in which a jurisdiction can establish modalities for ensuring to the extent practically possible, cooperation and coordination among the relevant agencies . • • Jurisdictions can adopt anyone of the following modalities: • • • •

Task Force; Coordinating Council or Committee; Memorandum of Understanding; and Interagency Sharing of Intelligence.

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Task Force • A taskforce is a body formed expressly for the purpose of addressing a particular problem. • The task force would be responsible for formulating a set of solutions to the problems and pick the most practical solution to each problem, as determined by some set of standards such as the law, regulations, rules and institutional mandates. • Such a task force can be either permanent or temporary body. It can be permanent with respect to a problem like combating financial crime generally and money laundering in particular. • Temporary could a body set up to address a specific issue such as for example human trafficking, illegal logging or diamond smuggling.

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Coordinating Council • Some jurisdictions establish under the anti-corruption laws a high level body responsible to set policy in the fight against corruption and crime.

• Tasked with coordinating and making sure that the public institutions fulfil their responsibilities and undertake actions under their mandate. • It is an inter-agency body that is dedicated to marshalling the resources of the government as well as demonstrating political commitment at the highest level of government.

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Memorandum of Understanding • Where, for whatever reason, may be turf wars, or some bureaucratic reason, a multi-agency body cannot be created, one option is to create a forum or coalition that is joined together by way of a memorandum of understanding. • The memorandum of understanding may provide for modalities of exchange of information – at the operational level – among the agencies; • share experiences; • exchange of information, • providing logistical or operational support; and • generally address and mitigate any coordination problems.

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Inter-Agency Sharing of Intelligence • One of the key methods of addressing corruption and money laundering is to have accurate, comprehensive and timely intelligence from relevant bodies that feeds into the investigation and prosecution of corruption. • Consequently, inter-agency sharing of strategic intelligence is essential. Agencies such as the FIU; the Criminal Investigations Department of the Police; the Audit Institution office; the National Intelligence Service; the Anti-Corruption Agencies themselves; and other relevant intelligence gathering agencies, should have a forum where intelligence can be shared and coordinated.

• For example, the Indian government in its anti-corruption strategy suggested that an inter-agency task force be established for purposes of sharing intelligence.

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Establishing Effective Cross-Agency Cooperation • In order to establish effective cross-agency cooperation, the agency in charge of coordinating and monitoring the implementation of the anti-corruption policies should have: • Sufficient authority, • Resources, • Capacity, and • Political backing to perform its mandate and compel line ministries to implement measures and report on progress.

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Political and Operational Attention from the Design Stage Many coordination efforts have failed because of initial design flaws. • Sufficient political and operational attention should be given to the coordination of anticorruption efforts from the onset, • with coordination issues considered from the design stage of anticorruption policy making, and • integrated in the overall anti-corruption architecture.

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Strong Leadership and Political Determination • Securing support and collaboration from other agencies usually implies positioning the anti-corruption institution at a point of maximum influence. • The overall responsibility for coordination needs to be assigned to a high level political authority or a lead figure, usually in the Office of the Prime Minister or a State Minister with the view to providing the requisite political leverage to deal with powerful line ministries and other public agencies. • Others have recommended locating the lead agency at the maximum point of influence to give it the necessary political backing and visibility to allow it to take leadership in promoting coordination and if need be, compelling other institutions to cooperate.

Clear Mandate and Lines of Responsibility

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For effective cooperation, the establishment of specialised anti-corruption bodies should relate to what’s already in place and their respective roles and mandates clearly defined and well understood. This implies understanding where and how the various mandates and responsibilities meet and interact.

Respective institutions should be given clear lines of responsibility, especially with regard to who should deal with particular cases of corruption. Clear rules of engagement should also guide the interaction and collaboration between the various institutions involved.

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Legal Obligation to Cooperate Some countries such as Hong Kong and Singapore impose stringent legal duties of cooperation on government and the public, compelling them by law to support the Anti-Corruption Agency’s work. Malaysia follows same patterns with 16 deputy public prosecutors being assigned by the Attorney General’s office to work on AntiCorruption Agency’s cases. Whatever the solution, there should be a framework of control to ensure effective enforcement of collaboration.

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Cooperation as a Long-Term Process • Effective cooperation of anti-corruption efforts is a long-term process that requires times and resources allocated to trust building efforts. • While ad-hoc cooperation on specific cases can contribute to this process, it is recommended to approach coordination as a long term and ongoing process and

• Establish the necessary structures to facilitate effective long term cooperation in the form of regular interagency forums that allows exchange of information, discussions, etc.

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Appropriate Coordinating Committees or Structures • Where coordination remains challenging, special committees or institutions may be established to address cross-agency cooperation. • They can be composed of representatives from the executive, judiciary, legislature, and civil servants in key departments (such as customs, procurements, revenue collection and law enforcement and from local governments). • They can also include members from civil society such as business representatives, NGOs, religious leaders, etc. • In all cases, they need to have sufficient power, resource and capacity to deal with powerful ministries.

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Information and Communication Strategy By nature, cross-cutting reforms depend on good communication and information sharing between all implementing agencies and the public, including access and dissemination of supporting anti-corruption policies and documents. Recent developments in information technology open new opportunities in this field as well as provide innovative tools to promote effective data and information sharing across agencies, such as the development of crossagency databases, computerised case-management tracking systems, etc. At another level, a proactive strategy of systematic information sharing between agencies may help build trust relationships and foster longer term cooperation.

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Conclusion • In conclusion, memorandums of understanding are one way in which to implement laws authorizing or organizing exchange of information. • Cooperation among domestic agencies is essential given the complex nature of financial crimes even where they do not cross borders. • Given the limited human expertise and financial resources, building interagency and cross sectoral partnership should be a critical component to achieving some measure of success in combating corruption.


Country Presentation: Antigua & Barbuda

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Fifth Annual CCAICACB Conference Topic Country Presentation – Antigua and Barbuda

Neil Coates


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Fifth Annual CCAICACB Conference

Factors that have restricted the overall operation and management of the Commission

 Lack of funding  Inadequate staffing  Ability to discharge its functions as provided by the Act  Deficiencies in the Integrity in Public Life Act


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Fifth Annual CCAICACB Conference

Status of the Antigua and Barbuda Integrity Commission

 2006 to 2014  2014 to June 2018 Appointed in October 2014 Initial effort to jump start the work of the Commission Set up database to record information for declarants Staffing issues resulting in Commission becoming non-functional in early 2016 until February 2018 • Second appointment in 2018 after two year of inaction and two Commissioners threatening to resign • 4th Annual Commonwealth Caribbean Association of Integrity Commissions & Anti-Corruption Bodies Conference held in June 2018 in Turks & Caicos • Prepared draft action plan • • • •


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Fifth Annual CCAICACB Conference

Status of the Antigua and Barbuda Integrity Commission..cont’d

 June 2018 to May 2019 • Approved action plan for 2018/19 on June 14, 2018. -Integrity Commission Action Plan 2018-2019 • Issued first press release on June 15, 2018 to advise the public on (1) the Asot Michael matter and plans to investigate the allegations and (2) to provide an overview of how the Commission will operate going forward in relation to our interaction with stakeholders and the public. Press Release June 15, 2019 • Initiated an aggressive search to fill the position of Secretary to the Commission, however, the salary being offered was totally inadequate and this completely handicapped the process. In addition, the Commission had no funds and therefore was restricted to the salary being offered by the Government. • Completed database for all declarations submitted and wrote to all ministries, departments and statutory bodies that are required to submit the names of persons required to file declarations in accordance with the IPL Act • Retained legal counsel for the purpose of obtaining an opinion on the ability of the Commissioners under subsection 12(1)(d) of the IPL Act to begin an investigation without first receiving a written complaint. Legal Opinion


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Fifth Annual CCAICACB Conference

Status of the Antigua and Barbuda Integrity Commission…cont’d

 June 2018 to May 2019 • Issued second press release on June 25, 2018 to advise the public that (1) there were grounds for an investigation into the Asot Michael matter (2) that the Government had agreed to provide funds to the Commission, (3) that the Commission had engaged legal counsel to advise the Commission on subsection 12 (1) (b & d) and (4) that based on the advice and opinion of legal counsel, the position of the Commission had changed and that an investigation could only be initiated if a written complaint was received in the proper form. Press Release June 25, 2018.docx • Prepared non-compliant listing of persons required to file declarations and anticipated placing first non-compliant listing in the official Gazette in September 2018, however this was not done until May 31, 2019 for a variety of reason. • Setting up standard weekly, monthly, quarterly and annual reporting guidelines/requirements for the office. • Prepared proposed amendments to the to the IPL Act dealing specifically with penalties for non compliance with the IPL Act Proposed amendments to the Integrity in Public Life Act.docx


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Fifth Annual CCAICACB Conference

Major Events in 2018/2019 • Changed the Commission’s interpretation of subsection 12(1)(d). • Completed database of all ministries, departments, statutory bodies and other persons that are required to submit the names of persons required to file declarations. • Completed database of all individuals in public life who are required to submit declarations annually. • Completed initial non-compliant listing of persons who had not filed declarations. • Completed draft amendments to the penalty provisions in the IPL Act.


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Fifth Annual CCAICACB Conference

The functions of the Commission as provided in the Integrity in Public Life Act (IPLA)are as follows Section 12(1) (a) to receive and retain all declarations filed with it under this Act; (b) to receive and investigate complaints regarding non-compliance with or contravention of any provisions of this Act or the Prevention of Corruption Act, 2004; (c) to make inquiries as it considers necessary in order to verify or determine the accuracy of a declaration filed under this Act; (d) to conduct investigation into any offence of corruption under the Prevention of Corruption Act, 2004 (PCA) if it is satisfied that there are grounds for an investigation; (e)To appoint where necessary Auditors to examine and verify the accuracy of the declarations filed under the Act or complaints of financial irregularities arising from breach of the code of conduct specified in the Second schedule; (f) To examine the practices and procedures of Statutory Corporations and Departments of Government to determine whether there are corrupt practices; (g) To advise Statutory Corporations and Departments of Government of any change in practice or procedures which may be necessary to eliminate corrupt practices; (h) To perform such other functions as is required by this Act.


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Fifth Annual CCAICACB Conference

Initiating an investigation under the IPLA and PCA • All complaints under the IPLA must be in writing for any investigation to be initiated • In regards to the Prevention of Corruption Act the IPLA provides that the Commission can initiate an investigation if it is satisfied that there are grounds for an investigation


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Fifth Annual CCAICACB Conference

Initiating an investigation under the IPLA and PCA post legal opinion

• All complaints under the IPLA must be in writing for any investigation to be initiated


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Fifth Annual CCAICACB Conference

Format of Complaints to the Commission • All complaints to Commission must be in writing and shall include the following:  Period within which the breach was committed.  Name and addresses of persons involved in the commission of the breach.  Evidence to support the complaint including documentary evidence and sworn statements.  Such other particulars as may be prescribed by Regulations. A person who makes a complaint shall not be liable in civil or criminal proceedings provided he proves that the complaint was made in good faith.


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Fifth Annual CCAICACB Conference

Interpretation of Sub-Section 12(1)(d)

• Legal opinions were obtained on the interpretation of sub-section 12(1)(d) and a request is in the process of being sent to the Attorney General to refer the matter to the Court of Appeal for interpretation pursuant to section 3(1)(b) of The Attorney General’s Reference (Constitutional Questions) Act, 2009 (No. 10 of 2009).


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Fifth Annual CCAICACB Conference

Statistical Data Declarations by persons in Public Life 2014




Total known declarants





Number of declaration filed





Percentage compliance





Number of declarants who have not filed





Total number of departments, statutory bodies etc. who have not submitted the names of persons required to file


Total number of department, statutory bodies etc. who have not submitted the names of persons required to file



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Fifth Annual CCAICACB Conference

Statistical Data - Complaints Filed

Number of complaints submitted


Number of investigations started


Number of investigations in progress


Number of investigation closed for any reason


Number of investigations forwarded to the appropriate authority for prosecution


Number of convictions



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Fifth Annual CCAICACB Conference

Penalties for Non-compliance


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Fifth Annual CCAICACB Conference

Existing Penalties •

Failure to make appropriate disclosures in declarations  A fine not exceeding $5,000 or to a term of imprisonment not exceeding 6 months on summary conviction.

Actions for failure to file a declaration  File a report in the Gazette and send a report to appropriate official as documented in section 20(1).  Failure to file a declaration will result in a fine not exceeding $10,000 or a term of imprisonment not exceeding 12 months on summary conviction.

Breach of the Code of Conduct  A breach of the code of conduct is an offence and is liable on summary conviction to a fine not exceeding $50,000 or to a term of imprisonment not exceeding 3 years of both fine and imprisonment.


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Fifth Annual CCAICACB Conference

Proposed Penalties •

Late filing penalty – A person who fails to file a declaration on or before the date by which the filing is required is liable to a penalty of $250.

Failure to file declarations – A person who fails to file a declaration is liable to a fine of $1,000 with an additional of $25 for each day or part thereof that the failure to file continues.

Failure to file complete declarations – A person who files an incomplete declaration will be liable to a penalty of $200 plus an additional penalty of $25 per day or part thereof that the failure continues, if after being notified by the Commission of the deficiency in the declaration in writing.

Failure to respond to request for information in a specified timeframe – A person who fails to respond to a written request from the Commission for information related to a declaration filed will be liable to a fine of $1,000 plus an additional fine of $25 for each day that the deficiency continues.


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Fifth Annual CCAICACB Conference

Proposed Penalties • Failure to provide listing of persons who are required to file declarations – A person who fails to submit the names of persons who are required to file a declaration with the Commission by the due date will be liable to a fine of $250 plus an additional penalty of $25 for each day or part thereof that the deficiency continues.


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Fifth Annual CCAICACB Conference

Other Proposed Amendments Proposal to require heads to submits names of persons required to file declarations •

All heads of governmental departments, commissions, diplomatic missions, statutory corporations, state institutions, boards deemed to be persons in public life as per schedule 1 of the Act shall provide a list of all persons in the department, commission, mission, corporation , state institution or board to file with the Commission a listing of all person who are required to file a declaration under this Act by January 31 of each calendar year.

Enforcement Provision •

Any person who is assessed a penalty by the Commission must pay such penalty within 30 days of receiving the notice of assessment of the penalty.

Where a penalty assessed is not paid within the stipulated period, the Commission shall write to the relevant authority requesting the withholding of the assessed penalties from the wages, salaries or compensation received by the individual.

the relevant authority shall withhold the assessed penalties from the wages, salary or compensation of the individual and transfer same to the Commission’s account.



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The End



Country Presentation: The Bahamas

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Country Presentation: Belize

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BELIZE: COUNTRY PRESENTATION 5th Annual Commonwealth Caribbean Association of Integrity Commissions & AntiCorruption Bodies (CCAICACB) Conference June 3rd, 2019 Grand Cayman Marriott Beach Resort Lord John Dalberg Acton said in 1887 in a letter to the Anglican Bishop Mandell Creighton, “Power tends to corrupt, and absolute power corrupts absolutely. Great men are almost always bad men……” To put this in milder terms, a person's sense of morality lessens as his or her power increases. This holds true to today in spite of the many advancements of mankind. In our small nation of Belize, the scourge of corruption is easily recognizable and has its roots embedded in both the public and private sectors. The Integrity Commission of Belize was established in the year 1994, but has been nonfunctional for most of its existence. The Commission was re-activated in the year 2017 after approximately 8 years of non-performance, but shortly after its re-activation saw the resignation of its then Chair in early January of 2018, with the Commission then going on a brief hiatus until August of 2018. As a part of the Government of Belize’s good governance agenda, it repealed the Prevention of Corruption in Public Life Act and replaced it with the Prevention of Corruption Act (hereinafter referred to as the “PCA”) which became law in the year 2007. The Integrity Commission comprises of seven members - a Chairperson and six (6) members appointed by His Excellency the Governor General in accordance with Section 3 of the PCA. Section 3 reads in part: “(1) There is established for the purposes of this Act, a body to be known as the Integrity Commission which shall consist of a Chairperson who shall be an attorney-at-law with not less than five years standing and six other members who shall be persons of integrity and high national standing.


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(2) Two members of the Commission shall be appointed by the Governor-General, acting in accordance with the advice of the Prime Minister given with the concurrence of the Leader of the Opposition and the other members of the Commission including the Chairperson shall be appointed by the Governor General acting in accordance with the advice of the Prime Minister given after consultation with the Leader of the Opposition.� The mandate of the Commission is to investigate corrupt activities by persons in public life and to ensure that those persons in public life (presently limited to members of the House of Representatives including the Speaker, Members of the Senate including the President of the Senate; and members of local authorities), remain compliant with their duty to file a declaration of financial affairs dating to the thirty-first of December of each year. These activities are specifically outlined in Section 4 of the PCA as follows: (a) to examine and retain all declarations filed with the Secretariat under this Act; (b) make such inquiries as it considers necessary in order to verify or determine the accuracy of the declarations filed under this Act; (c) investigate complaints regarding non-compliance with or breach of the provisions of this Act; and (d) perform such other functions as it is required by this Act to perform. Section 5 goes on to state: “In the exercise of its functions under this Act, the Commission is not subject to the direction or control of any other person or authority.� Though the Act refers to the independence of the Commission there are still internal issues which remain a challenge for the Commission as it continues to operate with only an Administrative Secretary and Office Assistant in a cramped space on the 3rd Floor of the National Assembly. It is the aim of the Commission to have its offices relocated to more


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spacious and suitable accommodations in the near future but budgetary and financial constraints are of concern. It is, nonetheless, the view of the Commission that the appointment of the appointment of an Accounting Officer will assist with the expeditious performance of the Commission’s tasks and objectives. The Commission engaged in rigorous discussions surrounding the appointment of a suitable individual to act as its Senior Accounts Clerk to assist with its accounting functions, now being performed by the Clerk of the National Assembly. Several applications have been received and the Commission intends on interviewing those persons in short order. This addition would certainly boost the Commission administrative functions as it strives to achieve the attainment of its statutory obligations. The Commission certainly realizes that competencies of its employees are a crucial part of the Commission’s productivity and on-going improvement. Other useful appointments for the better functioning of this Office, would include a Legal Advisor to the Commission and a Special Investigator, on an as needed basis. The Commission is at times in need of legal advice and any request to be made to the Attorney General’s Ministry could potentially lead to a conflict of interest situation. Despite that and in furtherance of the promotion of its good governance agenda and of great significance is the fact that Belize acceded to the United Nations Convention against Corruption (UNCAC) on December 12th, 2016 pledging to “assess the legal and institutional framework in Belize, with the aim of identifying and strengthening anti-corruption regimes in Belize”. The Government of Belize has reported that although our country is considered as a country with an “economy in transition, as such, any plans and programmes to combat corruption has to be measured in line with Belize’s capacity financially, technically and otherwise.”


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In this territory, we can assess some of the main risks of corruption as follows: (a) Lack of proper funding /resources - there is a lack of appreciation for the cost-benefits of a "clean" administration and of the fact that an effective Agency needs proper funding; (b) Person in Public life not providing full information on their financial affairs; (c) Policies, procedures, mechanisms for reporting are non-existent, unclear or not adequately enforced; (d) No standards or mechanisms are in place that would enable public servants or citizens to report to the Commission acts of corruption which have come to their attention during the performance of their public or private functions. This should be complemented by measures that protect public servants who report acts of corruption in good faith; (e) No sensitization campaign effected with the assistance of the AG’s Ministry and the Ministry of Public Service; (f) Supervision and performance management are inadequate; with those in power having high levels of discretion in their decision-making; and (g) Accepted ethical standards are lacking with the Belizean culture tolerable of rule breaking and short cuts. We are fully aware that the lack of responsible and accountable governance leads to corruption and which ultimately lends itself to social ills such as poverty, migration and political unrest, to name a few. In recognizing corruption as a worldwide phenomenon, strides must be made to combat it by fostering the necessary advancement and change. Time and time again our third world nations are ranked on the Corruption Perception Index based on varying indicators sighting us as highly corrupt or measurably corrupt and with these third world nations struggling for a better ranking, forcing us to take not only notice but also action.


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The following questions can now be posed – (1) Is Belize as a nation ready to start the fight against unethical behaviour? (2) Are we ready to eliminate and eradicate the poisonous and treacherous acts of illicit behaviour and gains that have infected our very social fibre? We say a resounding YES but the inevitable question is – How can this be achieved? In Belize, and since the re-activation of the Integrity Commission, persons in public life, have been compliant for the most part with the asset disclosure regime as per the Prevention of Corruption Act, but there is much more to be done. It is our hope that the Integrity Commission of Belize will be viewed as autonomous, promoting integrity, investigating and exposing corruption and misconduct in public administration. Notably, a Secretariat to the Commission has been established and there has been the enforcement of the collection of administrative fines of $100 per day for each day that a person in public life fails to file a declaration or give such information or explanation as required in filing with the Commission. In progressing this gargantuan feat of eradicating corruption, the Government of Belize through the Attorney General’s Ministry, is the designated and central authority for the United Nations Convention against Corruption. We must strive as a Commission to work hand in hand with other agencies to install and enforce preventative measures in this fight against corruption. The citizens of our nation too must take an active role and assume responsibility in empowering themselves to become fearless and to challenge each other to improve in thinking and behaviour. Educating one’s populace about anti-corruption in general and our laws in force may improve one’s decision making with the beginning of the change that we so desire. It must


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be recognized that holding our persons in public life accountable after an election is a part of our civic responsibility as they have been elected to lead and represent us. In promoting and facilitating inter-country cooperation (such as this event) and by developing a strong partnership with other nations we can together aid in preventing, detecting, punishing and eradicating corruption. Our Belize legislation particularly vests the Commission with broad powers of investigations including the power to summon and examine witnesses, to call for the production of books, plans and documents. Failure to disclose any information duly required by the Commission is punishable by a fine and imprisonment. As well, there is “whistle-blower� protection where a person makes a complaint to the Commission in good faith that is not frivolous or vexatious reasonably believing that the complaint made and allegations contained in it, are substantially true and in the circumstances, it is reasonable for him or her to make the complaint, he or she shall not be liable to any form of reprisal or any suit, whether civil or criminal. The accession to the Convention against corruption, the reactivation of our Integrity Commission is only the beginning, there is much more work to be done and everyone has their part to play. It is not a singular act nor can it be achieved with the wave of wand. With a view to prevent corruption using a cost benefit analysis, the expected cost of acting in a corrupt manner must be increased relatively to and optimally outweigh the expected benefit. In particular, the probability of liability or conviction and the corresponding penalty or punishment must be increased.



Country Presentation: Cayman Islands

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Cayman Islands

Commonwealth Caribbean Association of Integrity Commissions and Anti-Corruption Bodies Conference Grand Cayman, Cayman Islands 3 – 7 June 2019 Chairperson Mrs. Rosie Whittaker-Myles


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Cayman Islands Overview  The Cayman Islands  Grand Cayman  Cayman Brac  Little Cayman Image:

 260 sq km /100 sq mi (combined)  Population: 63,415 (2017)*  57% Caymanian  43% Non-Caymanian *Statistics provided by the Cayman Islands Economics and Statistics Office’s Compendium of Statistics 2017 (


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Cayman Islands Overview 

Discovered by Christopher Columbus in 1503.

Became British Territory (via Jamaica) in 1670.

Implemented its first constitution in 1959.

Officially became a direct dependency of Britain when Jamaica gained independence in 1962.

Legislation passed in 1966 to expand the banking/finance industry.

Category 4/5 Hurricane Ivan hit Cayman in September 2014, resulting in 95% of housing stock sustaining damage, with around 25% destroyed or damaged beyond repair.

CSPL established under current constitution, which came into effect in 2009.

Cayman’s telecommunication services, financial expertise and infrastructure rival those of large industrialized nations.



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Brief Introduction and Background  The Cayman Islands Constitution Order 2009 came into force on 6 November 2009, repealing and replacing the Cayman Islands (Constitution) Order 1972 as amended over the years.  The Commission for Standards in Public Life (the “Commission”) was established as an institution supporting democracy under the 2009 Constitution; a fulfilment of the 1999 White Paper requirements for the UK’s British Overseas Territories.  It reinforced the need to have regard for ethics and transparency as important elements of a democratic society and the necessary protection of the rights and freedoms of the people in the Cayman Islands.


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Constitutional Mandates for the Commission 117(9)(a) to assist in the setting of the highest standards of integrity and competence in public life in order to ensure the prevention of corruption or conflicts of interest; (b) to monitor standards of ethical conduct in the Legislative Assembly, the Cabinet, and on the part of public authorities and public officers; (c) to supervise the operation of registers of interest and to investigate breaches of established standards; (d) to review and establish procedures for awarding public contracts; (e) to review and establish procedures for appointing members to public authorities, and the terms of their appointment; (f) to recommend codes of conduct to prevent any Minister, public authority or public officer employing their power for any personal benefit or advantage, and to recommend legislation to provide appropriate sanctions; (g) to report to the Legislative Assembly at regular intervals, and at least every six months; and (h) to exercise such other functions as may be prescribed by a law enacted by the Legislature.


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Work since February 2018 

Tabled the Commission’s Fourteenth , Fifteenth and Sixteenth Reports which are now available on the Commission’s website;

Continued to follow-up with the Office of the Premier on a commencement date and regulations for the Standards in Public Life legislation;

Reviewed and discussed the Procurement Law, 2016, the Procurement Regulations, 2018 and the draft Procurement Code of Conduct;

Inspected the current Register of Interests (“ROI”) and met with the members of the Legislative Assembly’s ROI Committee to discuss their observations and questions arising from the ROI inspection ; followed-up with ROI Committee;

Continued to follow-up with the Cabinet Office on the status of the draft Ministerial Code of Conduct and the expected date for its finalisation and implementation;

Liaised with the Hon. Deputy Governor and the Hon. Leader of the Opposition and Chairman of the Public Accounts Committee (“PAC”) and requested further information regarding a news article entitled “PAC motion threatens CO with contempt”, in order to consider the matter;

Reviewed the Internal Audit Service’s (the “IAS”) report on the Commission’s concerns arising from the Gender Equality Tribunal’s (the “Tribunal”) ruling on the matter Atherley et al v H.M. Prison Service in order to provide feedback to the Ministry of Human Resources & Immigration; and

Discussed the United Nations Office on Drugs and Crime (“UNODC”) anti-corruption educational programme titled Education for Justice (“E4J”) and commenced outreach to various educational stakeholders in the Cayman Islands to explore the level of interest in implementing the programme. Facilitated the attendance of University Professor at a Specialist E4J Workshop in Colombia.



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Work since February 2018 Continued…  Attended a Data Protection Awareness Session facilitated by the Office of the Ombudsman;  Considered the Report of the Office of the Auditor General titled  "Fighting Corruption in the Cayman Islands". Attendance by the Chairman before the Public Accounts Committee in relation to the findings and recommendations of the Auditor General in respect of the Standards in Public Law; and  Presented and participated in a training workshop for Board Members and Members of Statutory Authorities facilitated by the Commissions Secretariat.


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Main Challenges Faced in Implementing Initiatives  Continued delay in securing a commencement date for the

Standards in Public Life Law, 2014 and the Standards in Public Life (Amendment) Law, 2016.  Continued delay in having approved drafting instructions for the Standards in Public Life Regulations.  Perceived lack of support for legislation from politicians, public authorities and board members of statutory boards as a result of the delay in commencing the Law.


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Results of the Innovation/Activities/Initiatives  Continued to consider matters related to conduct and conflicts of interest affecting the integrity of persons in public life.  Commenced its outreach to various educational stakeholders in the Cayman Islands to explore the level of interest in implementing the United Nations Office on Drugs and Crime (“UNODC”) anti-corruption educational programme titled Education for Justice (“E4J”).  Presentation to Sixth Form Students at High School.  Began planning of the Fifth Annual Commonwealth Caribbean Association of Integrity Commissions and Anti-Corruption Bodies (“CCAICACB”) Conference as the 2019 host country.


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Future Goals Our future goals as detailed in the Commission’s 2018 submission to the CCAICACB remain:  Advocate for the approval of Standards in Public Life Regulations, and the securing of a commencement date for the Standards in Public Life Law, 2014 and the Standards in Public Life (Amendment) Law, 2016.  See through the implementation of the Ministerial Code of Conduct.  Continue collaboration with schools to effect implementation of E4J into curriculum.  Continue to participate in any public relations opportunities, as well as in local and regional cooperation efforts where possible.


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Recommendations that could be Shared Our recommendations as detailed in the Commission’s 2018 submission to the CCAICACB remain:  Ensure the legislation is relevant to the particular jurisdiction in which it is to be implemented. The Legislation enacted in the Cayman Islands followed on from extensive research into the legislation of other jurisdictions and best practices.  Engage with a view to securing full participation of lay persons who serve on boards, statutory authorities, etc. who will be affected by legislation.  Seek “buy-in” or support from the government as a whole, both politicians and senior civil servants. This can be achieved through educational initiatives.  Allocate resources carefully to ensure support on an administrative level and for the purposes of investigations.  Continually seek to engage Ministers/Members of the Legislative Assembly and public officials.

In addition, the Commission recommends the following:

 Continue its outreach to secure agreement of schools to implement the UNODC’s E4J programme in primary, secondary and tertiary institutions.



Country Presentation: Dominica

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INTRODUCTION The newly appointed Integrity Commission of Dominica, under the Chairmanship of Stephenson Hyacinth is pleased to participate at another CCAICACB Conference. We extend very best wishes to all members of Integrity Commissions and other AntiCorruption Bodies in the Commonwealth Caribbean for a fruitful conference and for the further deepening of the relationship among our organizations. We are grateful for the continued financial and technical support of the Commonwealth Secretariat and for the leadership of Dr. Roger Koranteng.


BACKGROUND The Integrity in Public Life Act was passed in Dominica in 2003; the Commission became operational in September 2008. The Act of 2003 was amended in 2015. The main effect of the amendment was the dissolution of the former seven-member Commission, chaired by Julian Johnson from inception to 2015 and the reconstitution of the Commission as a three-member body, chaired by Dermot Southwell.


THE COMMISSION On July 25, 2018, Chairman Dermot Southwell passed away after a period of illness. His passing left two members on the Commission. Section 10(2) of the Act (amended) states that a quorum of the Commission is two; section 10(3) states that the proceedings of the Commission shall not be affected by any vacancy amongst the members or by any defect in the appointment of any member.

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That scenario was similar to the situation in 2016, when the failure of the Leader of the Opposition to nominate a third member to the Commission left it with two members. In the earlier case, the Commission met and operated normally. In the latter case, the Commission never met since neither of two remaining members was the Chairman. The Commission currently comprises three members who were appointed April and May 2019 by His Excellency the President in accordance with the Act:  Chairman Stephenson Hyacinth (nominated by the Prime Minister, after consultation with the Leader of the Opposition);  Commissioner Thomas Holmes (nominated by the Prime Minister)  Commissioner Cara Shillingford (nominated by the leader of the Opposition). It is very instructive that the appointment and subsequent operation of the Commission is so heavily dependent on the political machinery that exists


ACTIVITIES OF THE COMMISSION a. July 2018 to May 2019 The period was the aftermath of the passage of Hurricane Maria. Very few activities were completed, given an island nation in the midst of reconstruction. The Commission sought to meet with the Director of Public Prosecutions (DPP) to discuss the backlog of reports to her regarding persons who had failed to file. The DPP’s office was heavily impacted resulting in the loss of files, among other things, and that meeting never took place. The Commission was of the view that the successful youth education programme themed ‘Success without Integrity is Failure’ for secondary school students which was launched in 2016, could recommence in 2018. Alas this was not to be, since, schools were still operating on shift systems and the Commission’s office was in need of repair (more work still to be done).

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The list of persons in public life, over whom the Commission has jurisdiction, is dynamic and constantly changing. Persons in public life are to continue to file for TWO years following the demission of office of persons in public life and any person acting in the office of ppl for six months continuously becomes a ppl. The numbers for the past few years are as follows:

The functions of the Commission, according to the Act, are to: “(a) receive, examine and retain all declarations filed with it under this Act; (b) make such enquiries as it considers necessary in order to verify or determine the accuracy of any declarations filed under this Act; (c) without prejudice to the provisions of any other enactment, inquire into any allegation of bribery or act of corruption under this Act; (d) receive and investigate complaints regarding non-compliance with any provision of this Act; and (e) perform such other functions as is required under this Act.”

Regarding the first function, “(a) receive, examine and retain all declarations filed with it under this Act, each year, each person in public life makes declaration no later than March 31st of the following year. To facilitate the process, the Secretariat sends out, every January, Form 2, Guidelines for filling out Form 2 and a Calendar with informational highlights.

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Production of the 2018 Calendar was frustrated; the 2019 Calendar one, also themed: ‘Success without integrity is failure’ was sent to all persons in public life. It highlights aspects of the legislation and instructs persons in public life. The Calendar is also sent to all secondary schools and the State College. The examination of declarations is done with the ‘Adagio’ accounting software. Adagio produces a balance sheet for each person in public life. A comparative analysis provides the basis for clearance or for the issuance of a query. At the end of the process, compliance is gauged. The process for financial declarations as shown below was effectively on hold from step 3.








Report to IC

5. Decision and Action

Functions (c) and (d) remain very troubling ones. The burden of proof in these matters is the responsibility of the complainant. Section 32 of the Act gives the ‘complainee’ the right to institute legal proceedings against him (the complainant) if the Commission rejects the complaint that he brought.

Another matter that the Commission started to address was the Falling Rate of Compliance as illustrated in the following figure. The Commission held a working session to diagnose the issue and to brainstorm solutions. The outreach to ppl was heightened, and the Commission seriously advertised its new power (under the Amendment Act) to “extend the period in which a declaration may be filed”.

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Percentage compliance

86.62 84.30

83.25 80.20






Fig. 1 Compliance with the Act, Calendar years 2012 to 2016 (Table & Graph)

In 2017, Compliance rose to 85%. b. From May 2019 The two remaining members on the Commission ended their terms of office in February 2015 and the Secretariat continued to petition the Offices of President and Prime Minister for the appointment of a Commission to validate the work of the Secretariat.


CONCLUSION The Commission has already laid the framework for an engaging and active stint in office. This is a prayer for better times for our organizations, countries and people.


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Country Presentation: Grenada

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GRENADA COUNTRY REPORT June 2018 to May 2019

Office of the Integrity Commission & The Financial Intelligence Unit

(JUNE 2018 TO MAY 2019)

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OFFICE OF THE INTEGRITY COMMISSION AND THE FINANCIAL INTELLIGENCE UNIT GRENADA COUNTRY REPORT JUNE 2018 TO MAY 2019 FOR COMMONWEALTH CARIBBEAN ASSOCIATION OF INTEGRITY COMMISSIONS AND ANTI-CORRUPTION BODIES CONFERENCE INTRODUCTION During the period 2018 to 2019 the Office of the Integrity Commission (“Commission”) and the Financial Intelligence Unit (FIU) engaged in their respective areas of work. However, this last year saw collaborative efforts undertaken by both member organisations which were critical to their roles which required them together to tackle the challenges of corruption in Grenada’s anti-corruption sector. The Commission proceeded with its phased approach to its work, and despite prevailing budgetary constraints, was able to place emphasis on the creation and development of specific policies, procedures and protocols, which led to the enhancement of its work. We are happy to report that in recognition of its commitment to good practices established by the Commission in its work; it is earning the current title of “Best Practice” in the Caribbean by both regional and internationals experts. Both the Commission and the FIU are supported by a small dedicated group of professionals who are on a learning curve as Grenada implements its fledgling anti- corruption system. We have been extremely active in the quest to establish a robust National Anti-corruption System, therefore, good practices, policies or procedures have been deemed effective to strengthen public integrity in government. The aim to improve and update our methodologies determines our best practices. .

1|Page Grenada Country Report June 2018 – May 2019

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TRAINING AND DEVELOPMENT We have been receiving training and advice from some of the best subject matter experts that the world, region and nation have to offer. United Nations Office on Drugs and Crime In 2018, the first phase of training from the United Nations Organization on Drugs and Crime (UNODC) on the Development of a National Anti-corruption Strategy intended to implement the requirements of the UN Convention Against Corruption, was held in Grenada with the Stakeholders of our National Anticorruption Round Table Mechanism. The second phase of that exercise will continue in July 2019, in collaboration with the UNODC. Grenada has been blessed with training opportunities from UNODC and for this we are extremely grateful. Virtual Centre for Excellence Training Series – Senior Leadership and Management The Commonwealth Caribbean Association of Integrity Commissions and AntiCorruption Bodies (CCAICACB) June 2018 Communiqué stated that “The Association agreed to: a) Accept the offer of the Government of Grenada to provide facilities for capacity building programmes of the Association, in collaboration with the Government of India and the Commonwealth Secretariat;” . Unfortunately, Grenada has utilized existing national infrastructure through the resources of the Commission until the assignment of the agreed physical structure. The Commission launched its Virtual “Centre for Excellence Series” and held a successful Regional Senior Leadership and Management Training Programme, in collaboration with the Commonwealth Secretariat and Grenada’s Department of Public Administration. The focus of the Training was on global best practices for public sector management systems. The Lead facilitator was Dr. Roger Koranteng, Interim Advisor and Head of Public Sector Governance, Commonwealth Secretariat who covered several issues including; Conflict of Interest Management in keeping with International Best

2|Page Grenada Country Report June 2018 – May 2019

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Practices; Addressing Weaknesses in Organisational Governance; Ethics and Moral Conduct; and Global Trends in Anti-Corruption Deterrence. Dirk Harrison, Chairman of the CCAICACB presented on Procurement Matters and International Best Practices and Principles of Investigation, during which practical experiences were shared by Rohan Reid of the Major Organised Crime and Anti-Corruption Agency (MOCA) the delegate from Jamaica. Among local presenters were David Holukoff, Director of Grant Thornton, who reviewed the recent Corruption Perception Index published by Transparency International, and Inspector Raymond Lockiby from the Financial Intelligence Unit. He dealt with the issue of Threats and Vulnerabilities in Public Sector Management Systems. The regional delegates/participants were:- Guyana/Integrity Commission: Mr. Kumar Dorisami Chairman, Mrs. Rosemary Benjamin-Noble Commissioner, and Mrs. Amanda Jaisingh Secretary; Dominica/Integrity Commission Mrs. Palestrina Rolle-George Research Officer; St Lucia/Integrity Commission Ms. Jean Morille Secretary/CEO; and Jamaica/MOCA- Rohan Reid - Deputy Superintendent. Local participants included the Director of Public Prosecutions, the Attorney General, the Ombudsman, Department of Public Administration (DPA), the Permanent Secretaries, Chairpersons and Chief Executive Officers from Statutory Bodies, other Senior Public Officials, Civil Society Organisations and, Staff and Commissioners from the Office of the Integrity Commission. The four day Programme was delivered in Three Sessions: Session One for General Stakeholders, March 25 and 26, 2019, had fifty (50) participants; Session Two for Statutory Bodies, March 27, 2019, had fifty four (54) participants; and Session Three for the National Anti-Corruption Roundtable Mechanism, March 28, 2019, had thirty eight (38) participants. The regional participants attended all three Sessions.

3|Page Grenada Country Report June 2018 – May 2019

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Integrity Commission Grenada facilitates Sharing with Regional Colleagues During the half day sessions of the Senior Leadership Training the regional participants were invited to a sharing of information on the * Administrative and Operations Systems of the Integrity Commission Grenada. Two half day sessions were held at the Office of the Integrity Commission. Our structure, policies, procedures, practices and documents, were shared with our colleagues. Additionally, we focused on the Authority pf the Commission, Declaration and Compliance processes, Chain of Custody procedures, Investigations and Risk Management, Complaints, Educational Outreach Seminars and Activities. The participants were very receptive and pleased with what was shared and there were many questions during and after the sessions.

Grenada’s Chairperson attends 4th Gathering of the ParlAmericas Open Parliament Network Chairman Lady Anande Trotman-Joseph, was invited to showcase the work of Grenada’s Integrity Commission at the 4th Gathering of the ParlAmericas Open Parliament Network which was held in Quito, Ecuador from March 12 – 14, 2019. Lady Trotman-Joseph presented on “Strengthening Parliamentary Oversight to Promote Openness and Counter Corruption”. The presentation focused on: Key aspects of a public integrity regime;  Important provision within the law to regulate this issue;  Good practices, policies or procedures that have been deemed effective to strengthen public integrity in government;  Opportunities for parliamentary collaboration with civil society to support the effective implementation of relevant laws;  Recommendations for Parliament The Parliament Network noted with keen interest the implementation methodologies of Grenada’s Anti-corruption Regime and the initiatives and best practices undertaken by the Integrity Commission.

4|Page Grenada Country Report June 2018 – May 2019

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Commonwealth Anti-corruption Benchmarks Review Meeting Chairman Trotman-Joseph was invited along with other academia and international organisations across the Commonwealth to the Review Meeting in London, England from 15th – 16th May 2019. Chairman, was the only Caribbean academic, who was requested to facilitate a Session on “Regulation” The Session examined twenty-two (22) Benchmarks. The Commonwealth Anti-corruption Benchmarks are designed primarily to help governments and public sector bodies measure their anti-corruption laws, procedures, and actions against international anti-corruption good practices and implement appropriate improvements.

OUTREACH SEMINARS One of the Integrity Commission’s key mandates is reflected in the Integrity in Public Life Act (IPLA) No.24 of 2013, Section 12 (1) (h) and reads, “The Commission shall (h) carry out programmes of public education intended to foster an understanding of the standard of integrity”. In that regard, the programmes delivered were:-

Grenada Industrial Development Corporation The Commission conducted an Educational Outreach Programme for the Board of Directors, Management and Senior Staff of the Grenada Investment Development Corporation (GIDC). The Programme was geared towards raising awareness and promoting a keen understanding of the Commission’s operations, best practices and functions in keeping with its Integrity in Public Life (IPL) Act No. 24 of 2013 and the Prevention of Corruption Act No. 15 of 2007, as well as International AntiCorruption Frameworks (OAS Inter-American Convention Against Corruption, United Nations Convention Against Corruption) to which Grenada acceded. 5|Page Grenada Country Report June 2018 – May 2019

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Specific attention was made particularly to the managing of “Conflict of Interest” and “Gratification” as highlighted in the Code of Conduct (section 40 of the IPL Act) and the Prevention of Corruption Act, respectively. An Overview and General and Technical Functions of the Commission; Organizational Integrity; Code of Conduct and Best Practices in Public Life together with a Simulation Exercise were also shared by the presenters. Subsequently, the Corporation developed three Draft Policies (Conflict- ofInterest, Anti-Bribery and Fraud, and Code of Conduct) and invited the Commission to review same. The review was for the purpose of having the Policies finalized and subsequently implemented.

Customs and Excise Department The Commission conducted an Educational Outreach Programme for Junior Customs Officers of the Grenada Customs & Excise Division. The objectives of the Programme were to sensitize and share information on: The responsibilities of the Integrity Commission, the Integrity in Public Life Act No. 24 of 2013 and the Prevention of Corruption Act No. 15 of 2007;  The International Anti-Corruption Framework;  Declaration and Compliance Process;  How to Complete a Declaration Form;  What is Corruption and its Negative Effects;  The Difference Between Ethics and Integrity; and  Code of Conduct- Conflict of Interest, Gifts and Gratification. A total of twenty seven (27) participants were present at the Programme. Each participant received Integrity Commission Information Packs which consisted of a Brochure (contains the Code of Conduct), declaration form (used for “How to complete your declaration form” exercise), List of Relevant Anti-Corruption Legislation in Grenada and an Evaluation sheet.

6|Page Grenada Country Report June 2018 – May 2019

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Later on in the year, all twenty-seven Officers filed their Declaration of Assets, Liabilities and Income.

Physical Planning Unit The Office of the Integrity Commission conducted an Educational Outreach Programme for the Physical Planning Unit (Ministry of Finance) at the GCNA Building, Kirani James Boulevard, St. George. The Objectives of the programme were to sensitize and share information on: The responsibilities of the Integrity Commission, the Integrity in Public Life Act No. 24 of 2013 and the Prevention of Corruption Act No. 15 of 2007;  The International Anti-Corruption Framework;  Persons in Public Life vs a Public Officer;  Code of Conduct- Conflict of Interest, Gifts & Gratification;  Corruption and its Negative Effects;  The Difference Between Ethics and Integrity;  Declaration and Compliance Process; and  Risk Management This Programme was geared towards raising awareness and promoting a keen understanding of the Commission’s operations, best practices and functions in keeping with its Legislations and Conventions. Specific attention was placed on Managing “Conflict of Interest” and “Gratification” highlighted in the Code of Conduct (section 40 of the IPL Act) and the Prevention of Corruption Act, respectively. A total of thirteen (13) participants were present at the Programme, including the Permanent Secretary. Participants were furnished with Integrity Commission’s Information Packs.

7|Page Grenada Country Report June 2018 – May 2019

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LOGO AND MASCOT COMPETITIONS The Commission launched its Logo and Mascot Competition during the celebration of International Anti-corruption Day in December 2017. The registration period ended in July of 2018 and the winners were selected in August of the same year. In an effort to sensitise the students and teachers of secondary schools about the work of the Commission’s mandate in the area of anti-corruption, the distribution of prizes to the four winners was done at the respective secondary schools. The presentation of the Mascot and new Logo took place during the celebration of International Anti-corruption Day on December 7, 2018. The Commission’s new Logo was displayed on a Banner and the Mascot which was made, interacted with everyone present and was “a hit” with the students, especially the little ones. At present there is a naming of the Mascot competition for students of Primary Schools, the winner of that competition will be announced in July 2019.


8|Page Grenada Country Report June 2018 – May 2019

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INTERNATIONAL ANTI-CORRUPTION DAY CELEBRATIONS International Anti-corruption day was celebrated by Commission on December 7th 2018, for the second under the two year theme from 2017- “United Development, Peace and Security”. The official celebration is December 9, of each year. However, same on the closest week day.

the Office of the Integrity time in Grenada’s history, Against Corruption for date for the international the Commission celebrates

A new chapter in the life of the Commission was launched; The Commission’s Logo and Mascot which was the highlight of the Celebration. Over 150 persons attended the event and the range of students included primary school students ages seven (7) and upwards, and representatives from The Brownies Association from Beacon Learning Centre. At the secondary level representatives from the uniformed groups were in attendance: Cadet Corp and Boy Scouts Association. The winners of the Competitions and supporters from their schools also attended. This is a much looked forward to day in the calendar of activities of the Commission. INVESTIGATIONS The ‘Integrity Commission’s Questionnaire’ was adopted by the Commission and implemented. To date, the Investigations Questionnaire was sent to, and responses were received from, the following entities: Department of Customs  Housing Authority of Grenada  Ministry of Health  Ministry of Social Development and Housing  Marketing and National Importing Board  Grenada Solid Waste Management Authority Assessments of those responses to the Questionnaire were completed by the Investigations/ Compliance Officers, and reports and recommendations were 9|Page Grenada Country Report June 2018 – May 2019

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submitted to the Commission. Follow-up actions were initiated by the Commission based on the reports. The practices and procedures of these entities are under review.

Investigations Protocol An Investigations Protocol was adopted by the Commission, August 2018, and continues to be amended from time to time in a responsive way.

Complaints Form A Generic Complaints Form, was developed and subsequently adopted by the Commission as a standard Complaints Form. Marketing and National Importing Board (MNIB) Investigations Investigations into the operations of the Marketing and National Importing Board (MNIB) commenced formally on the 2nd August 2018. The investigations were in response to various media reports concerning certain issues related to the operations of MNIB. This was the first time that the Integrity Commission had undertaken an Investigation of this magnitude. In keeping with Section 12 (1) (f) (g) of the Integrity in Public Life Act (IPL), No. 24 of 2013, The Commission set up an Investigations Team and an Inquiry Team and engaged with its relevant key stakeholders, to deliver on the legal mandates of the Integrity in Public Life and the Prevention of Corruption Acts. At present the matter is before the Court, in that the former CEO of the MNIB has challenged the authority of the Commission to conduct the investigation into the MNIB. The hearing has been scheduled for 5th June 2019. The Integrity Commission Grenada must place on record its appreciation to CCAICACB for the training and development assistance provided by its former 10 | P a g e Grenada Country Report June 2018 – May 2019

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Chairman Mr. Eugene Otuonye QC of the Turks and Caicos and present Chairman Mr. Dirk Harrison of Jamaica.

FILING OF DECLARATIONS/GAZETTE NOTICE OF NON COMPLIANT DECLARANTS Two hundred and seven (207) declarants have filed their declarations for the period May 2018 to May 2019 in accordance with its mandate. Among the declarants filed are ALL Junior Customs Officers and seventy-nine Corporals and Sergeants of the Royal Grenada Police Force (RGPF). The IC has sought to deepen its compliance analysis especially following training that the staff was exposed to by UNODC on Auditing Asset Declarations. Seventeen (17) of the non-compliant declarants have been issued with Final Notices and one (1) non-compliant declarant is scheduled to be Gazetted and published in at least one (1) the weekly newspaper. A demon “How to Complete your Declaration Form” has been uploaded on the IC’s Website and the IC’s You Tube Channel; this assists persons with the completion of the Declaration Form.

NEW POLICIES AND PROCEDURES The Commission further developed/commenced items in the following areas:     

Gift Registry and management of Gifts received by Public Officials; Legal Systems Hub; Amendment of Declarations Form; Creation of Activity Summary Sheet for Declarants Personal Files; Creation of Declarations Email; Creation of Declarations Demo; 11 | P a g e

Grenada Country Report June 2018 – May 2019

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     

Creation of an Investigations Grid Creation of a Compliance Activity Process Grid Procedure for Handling Non-compliance ; Auto response acknowledgement email for extensions; New Format for Asset Registry; and Confidentiality Agreement for persons providing Consultancy Services.

12 | P a g e Grenada Country Report June 2018 – May 2019

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The Financial Intelligence Unit further developed within the last year: Operations Manual;  Strategic Analysis Standard Operating Procedures: and  A Tactical Targeting Analysis Standard Operating Procedures These procedures provided the requisite benchmark to guide their operations, improve efficiency and the quality of outputs. A number of successful money Laundering prosecutions, seizures and forfeitures were realized epitomizing the effectiveness of Grenada’s legislative and procedural regime.

Building Synergies An important strategy employed by the FIU was the strengthening of synergies and capacity building with other law enforcement agencies in the jurisdiction; this assisted in the decentralizing of money laundering investigative techniques and a greater understanding and efficiency during financial crime investigations. In fostering and strengthening our partnership with the integrity commission focus was placed on the relationship between corruption and money laundering.

Legislative Mandate As part of its legislative mandate, the FIU provided Anti-Money Laundering and Combating the Financing of Terrorism supervision to non-Bank and designated non-Financial Business and Professions (DNFBP). Our approach has been a collaborative in tandem with the Anti-Money Laundering and Combating of Financial Terrorism Commission (AML/CFT), Grenada Authority for the Regulation of financial Institutions (GARFIN) and the Integrity Commission, in an 13 | P a g e Grenada Country Report June 2018 – May 2019

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attempt to maximize expertise and reduce on the time spent on conducting inspections/investigations. The recent amendment of the Proceeds of Crime Act instructs reporting entities to register with the Commission for AML/CFT purposes. The data captured will assist to advise on the level of existing risk and will ensure the required resources be allocated to minimize vulnerability gaps.

National Risk Assessment The FIU leads the country’s National Risk Assessment process, utilizing the World Bank’s tool mechanism in an effort to identify, assess, and understand the money laundering and terrorist financing risks of the country. This provides the necessary action to remedy current and impending threats and vulnerabilities. A multi-sectorial working group encompassing both private and public sector representatives was created to manage the risk assessment process. The overwhelming response of our stakeholders contributed greatly to the success of the process thus far. In short order the results of the assessment would be analyzed and used to develop a national action plan a to be used as a road map to address Money Laundering and Terrorist Financing threats and vulnerabilities. A similar approach will be taken as part of Grenada’s preparation for its’ Mutual Evaluation process by the CFATF, a standards training workshop will be conducted in an effort to enhance country representatives understanding of the FATF standards on AML/CFT and the implementation of effective measures. Currently work has started on the technical questioner as a precursor to the impending evaluation. Commendation must be given to the Integrity Commission who played a leading facilitation role in this process. Central government has exhibited political will to fight cyber-criminal activity by providing additional infrastructure and the requisite legislative support to broaden the scope for practitioners and to allow for greater efficiency. The FIU is therefore optimistic that with this momentum greater success will be realized. 14 | P a g e Grenada Country Report June 2018 – May 2019

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Regional Security Systems Training The FIU in collaboration with The Regional Security System (RSS)- Asset Recovery Unit (ARU), Barbados held a four day training session from 9th July to 12th July 2018 at the Kirani James Athletic Stadium, St. George. RSS was created out of the need for a collective response to security threats, which were impacting on the stability of the region in the early 1970’s and 1980’s. There were three facilitators from the Asset Recovery Unit namely Mr. Grenville Williams who serves as Director, ARU of the RSS; Mr. Andrew Searles and Mr. Donald Sheckles RSS’s legal advisors. The topics covered were Asset Recovery, Money Laundering and Crypto Currency. The following participants attended the training: Members of the Royal Grenada Police Force (FIU, CID), Customs and Excise Department, , Inland Revenue Department, Airport Security, Anti Money Laundering Safety Commission and the Integrity Commission.

CONCLUSION The Commission and its Stakeholders, especially the FIU remains committed in the advancement of its National Anti-corruption regime. The outcome of the MNIB Investigation will definitely impact the work of the Commission. Both the IC and the FIU pledge to continue its collaborative approach towards the fight against corruption, in Grenada, Carriacou and Petite Martinique. The evolution of new and emerging technology continues to challenge the FIU and other law enforcement agencies to become much more creative in their approach to investigation. We take this opportunity to express our sincere thanks to the Executive and Members of the CCAICACB for ALL of its support this past year and we look 15 | P a g e Grenada Country Report June 2018 – May 2019

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forward to the continued sharing and exchanging of invaluable expertise, information and experiences as we forge ahead in the fight against corruption.

Grenada CCAICACB Report 2018

Office of the Integrity Commission Archibald Avenue PO BOX 90 St. George Grenada West Indies Website: Telephone: 1 (473) 439 9946 Financial Intelligence Unit Financial Complex The Carenage St. George Email: Website: Telephone: 1 (473) 435 2373 / 2374

16 | P a g e Grenada Country Report June 2018 – May 2019


Country Presentation: Guyana

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Title Page

The title of this Country Report is “The Integrity Commission of Guyana: Anti- Corruption Endeavours”

This Country paper was prepared by the Office of the Integrity Commission as a requirement for the Commonwealth Caribbean Association of Integrity Commissions and Anti-Corruption Bodies Conference in the Cayman Islands (3rd -7th June, 2019).


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Table of Contents Page Title Page


Introduction/Background of the Integrity Commission


Innovative Work/Initiatives Implemented


Results of the Executed Work Plan


Challenges and Lessons Learnt







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INTRODUCTION/BACKGROUND OF THE INTEGRITY COMMISSION The legislative framework of the Integrity Commission (“the Commission”) by virtue of the Integrity Commission Act, stipulates anti-corruption strategies to promote good conduct of public officers. This Act was promulgated on 24th September, 1997 with the sole purpose of securing the integrity of persons in public life.

Establishment of the Integrity Commission The Integrity Commission Act outlines the composition of the Commission. Accordingly there is provision for the appointments of: 

a Chairman; and

two (2) to four (4) Members of the Commission

Qualification and Appointment of Chairman to the Integrity Commission: The Appointment of a Chairman to the Commission entails the consideration of qualification: - as a Puisne Judge of the Supreme Court; - or any other suitable person The qualification and appointment for other members to the Commission presupposes presidential consideration. The selection of successful candidates exhibits their disciplinary capacity and experience in: - Law, Public Administration; Social Service; Finance; Accountancy; or any other discipline.

Process of Appointment  The Appointment Process of members to the Integrity Commission necessitates a Consultation Protocol. Appointment of the Members may be deemed complete where the Consultation Protocol ends.  The Consultation Protocol includes decision making input by the President and Leader of the Opposition.  Members may be elected for service of tenure in a temporary or permanent capacity. 1

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 After the completion of the Consultation Protocol the Publication Process ensues.

The names of those persons selected to be members of the Commission are required to be published in the Official Gazette and in a daily newspaper.

Staffing of the Commission There is provision for a Secretary to the Commission who functions as chief executive officer of the Commission, and oversees and manages the day – to- day work of the officers and staff the Commission’s secretariat.

Other professional staff may be recruited as the work of the Commission necessitates.

Reporting Process for Corruption: Part IV of the Act stipulates the reporting process for public officers in relation to their submission of declarations.

Stakeholder Agencies for Reporting Acts of Corruption: The Reporting Process provides for the reporting of varied acts of corruption. The Listed Offices below are stakeholder agencies: 

Guyana Police Force

Guyana Revenue Authority

Chambers of the Director of Public Prosecutions (DPP)

Audit Office of Guyana

Attorney General Chambers

The Commission’s Vision is: “Improved public confidence in the integrity of holders of public office.” The Commission’s Mission is: “Securing the integrity of persons in public life.” 2

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The Commission’s Objective is: “To secure the integrity of persons in public life through their compliance with the provisions of the Integrity Commission Act No. 20 of 1997.” The Secretariat’s Objective is: “To ensure the proper performance of the functions of the Commission.”

Reconstitution of the Integrity Commission The reconstitution of the Integrity Commission occurred on February 22, 2018 with the swearing in of appointees to the Commission, namely: 

Mr. Kumar Doraisami as Chairman

Pandit Rabindranath Persaud as a Commissioner

Mrs. Rosemary Benjamin-Noble as a Commissioner

The reconstituted Integrity Commission has tenure of three (3) years.


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INNOVATIVE WORK/INITIATIVES IMPLEMENTED Guided by a work plan, the following activities were executed: 

Recruitment of the full complement of staff based upon the revised organizational chart.

Training of members and employees in crucial areas to assist with implementation of the full operations of the Commission.

 Creating, obtaining, management and updating of a listing of persons in public life for 2018 per Schedule I of the Integrity Commission Act, thus creating an Inventory.

 Provision of each identified person in public life for 2018 with the authorized correspondence package for filing declarations with the Commission. This package included appropriate instructions to public officers in accordance with the law.  Reception, examination and filing of declaration forms.  Making requests, subsequent to examination of declarations, for further information, where applicable.  Conducting follow - up with defaulting declarants.  Responding to declarants’ and the general public’s queries, complaints and incoming mails.  Working with stakeholder agencies in the fight against corruption.

Other logistical and administrative activities continued such as ensuring maintenance of records including proper accounts and submission of annual financial statements to the Auditor General, correspondence, minutes of meetings and decisions. There was also focus on updating procedures relevant to the security and confidentiality of: 1. the Commission’s records; and 2.the Commission's Secretariat (building)

The Commission also embarked on a communications strategy through firstly updating the Commission’s website and commencing public awareness activities utilising print and other media and press conferences. The targets of this public awareness emphasis include: 1.

Public offices


Persons in public life


General public 4

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RESULTS OF THE EXECUTED WORK PLAN Appointments, Remuneration and Training In 2018, the Commission proposed and implemented a revised organizational structure. This proposed structure created new positions within the Commission. These positions, now finalized, facilitate the proper performance of the Commission's work and comprise: 

One Secretary

One Legal / Compliance Officer

Two Investigators

One Accountant

One Administrative Assistant

One Office Assistant/Driver

One Data Entry Clerk

Two Typist Clerk

One Cleaner

All positions were filled with the exception of Investigators. The salary structure at the Commission was reviewed. Payment under new salary scales and of non- taxable allowances became effective from 1st April, 2018. This was carried out to provide a reasonable and liveable remuneration package for persons employed in the foregoing positions, and to properly insulate the staff and ensure confidentiality due to the nature of the Commission’s work. Training has also played a crucial role for the efficient and effective functioning of the Commission. As a result, two (2) members and the Secretary benefited from a five (5) - day Senior Leadership and Management Training Programme in Grenada in March, 2019. In addition, other employees are currently receiving local training in areas that will assist with their everyday duties.


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Meetings  The Commission hosted over forty (40) informal meetings with persons in public life. Persons in Public Life originated from public offices and over thirty (30) meetings were held at other public offices. This facilitated the discussion of matters related to the work of the Commission.  There were fifteen (15) statutory meetings where important decisions were made in aiding the Commission to carry out its mandate. The decisions included agreements and discussions among members as highlighted in this report. Informal meetings, as required to expedite the work of the Commission, were held from time to time.  Monthly staff meetings are held among the Secretary and other staff members to ensure continued efficient execution of the work of the Commission.


A current budget of a relatively modest sum of forty-five million Guyana dollars [(G$45,000,000) – USD 208,000)] was approved to carry out the daily functions of the Commission. The Capital Budget awarded was two million five hundred thousand dollars [($2,500,000) – USD 11,300] to aid in the purchasing of equipment and furniture. Declarations  Throughout the year the Commission obtained lists of persons in public life. The ascertainment of these lists was guided by Schedule I of the Integrity Commission Act. The method of ascertaining the names and designations of declarants was: 

requesting letters sent to Public offices;

following up with telephone calls,

reminder letters sent to defaulting Public offices to submit their list,

notices in the media.

 The Commission created an Inventory from the public offices’ responses. Inventory updates accounted for approximately eighty-five per cent (85%) of names from Public Offices in 2018, and approximately fifty percent (50%) for 2019. The Public Offices’ 6

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responses flow from the Commission’s requests. This information renders the Inventory to be 100% complete.  Each public officer identified receives an authorized declaration from the Commission. The authorized form accompanies a covering letter with appropriate instructions. The documents are then delivered by hand or sent through bulk postage.  The Commission's Secretariat recorded the following statistics as at 10th May, 2019: 1. Postage of one thousand two hundred and ninety-nine (1299) cover letters with forms to Public Officers. 2. Seven hundred (700) declaration forms received, scanned and retained. 3. In November, 2018, review of declaration forms for the period 2018 commenced. To date, fifty-three (53) declarations forms for 2018 were reviewed, with forty-eight (48) requiring additional documents.  The placement of notices in the media. This informed non – compliant Persons in Public life of the extension date for submission of their declarations.  The Commission published the names of defaulting Public Officers. There were eight (8) publications. These included publications of names of separate public offices. Publications followed the method as specified by the Integrity Commission's Act: 

in the Official Gazette

in a daily newspaper

 Persons in public life may request assistance to complete declarations. The Commission's Secretariat acquiesces to such requests. The provision of assistance by the Commission may also be in other matters, as may be requested.

Complaints Part of the Commission’s mandate is to receive and investigate complaints. Two (2) complaints were received by the Commission’s Legal/Compliance Officer. These complaints were reviewed and responded to by the members of the Commission.

Review of Integrity Commission Act 1997 Reviewing of the Commission’s Act and Schedule 1 has commenced, with the intention of making recommendations to the Hon. Prime Minister for its strengthening. 7

PAGE | 54k

Website and Networking of Computers The Commission's website was updated as a means to inform the public, public offices and public officers of the work of the Commission. In addition, the computers at the Commission have a computerized network system. Security of the Commission’s building and documentation The Commission has placed a major emphasis in this area. The entire building that houses the Secretariat has a full alarm system, security cameras and a full - time physical guard. In addition, the Commission’s scanned declarations were backed up on a storage device that was stored off site. Reports and Financial Statements As a requirement by the Commission’s Act, the 2018 Presidential Report was submitted to the President and the Commission is in receipt of its 2015 Audited Financial Statement.


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CHALLENGES AND LESSONS LEARNT Challenges 1) There were no official investigations on declarations received. The Secretariat, however, requested additional documents from Declarants, as necessary. 2) There were both non-compliance and late compliance by some public offices. This was the experience gleaned from the submission process. The notices of reminders to public offices, as placed in the media, flowed from the Commission's request letters. Those letters were sent directly to public offices. The Commission’s inventory does not reflect a thorough number of Declarants for 2018 and 2019. 3) There were non-compliance and late compliance from persons in public life. Despite the media notices, declarants did not submit their declaration forms on time. 4) The Commission found that there was a need to clarify the status of declarants from public offices where discrepancies with previous lists submitted, were observed. This included the occupation of the declarant, and whether there was resignation, demise, retirement or dismissal from public office. 5) The filling of information in the Declaration Forms is required to be as at June 30 of each year. The Integrity Commission Act requires this. Yet, it remains the bane of most declarants. The statutory period is the element resulting in the most dissatisfaction for declarants. Declarants have requested that the statutory period be from January to December of each year. Some declaration forms exhibit the statutory period for January to December. This is the statutory prescriptive period. Thus, the Commission categorizes these declaration forms to be incorrectly filled. 6) Declarants fail to provide supporting documentation to their Declaration Form. Thus, their declarations fail to justify the accuracy of the information provided. 7) Preparation and submission of the Commission’s 2016, 2017 and 2018 Financial Statements to the Audit Office of Guyana was still being undertaken due to previous dearth of appropriate staff. 8) Failure to establish a robust Management Information System to store declarations. The current database lacks the capacity for the generation of investigative reports and a manual for its operation. As such the current officer is unable to operate it. 9

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LESSONS LEARNT 1. The Commission recognizes that it would not be able to fight corruption alone. Every stakeholder must be involved in this process. As such, the Commission is in the process of engaging other agencies in addition to those stipulated in its Act. 2. Full staff complement is important to carry out the full mandate of the Commission. (This should be achieved by June 30, 2019). 3. Training and procedural manuals are two (2) important features in carrying out the daily functions of the Commission. 4. Reviewing and investigating the accuracy of a declaration is crucial to secure the integrity of persons in public life. 5. The Commission needs to find solutions to have full compliance of public offices and public officers in fulfilling the mandate of the Commission.


PAGE | 54n

PROJECTIONS 1. The Commission's revision of its Persons in Public Life Database Management Information System. This revision is currently in progress. 2. Recruitment of full complement of staff based on the Organization chart. 3. Continued application of public awareness methodologies:     

placement of notices visits letters telephone calls to Public offices, persons in public life press conferences/briefings.

4. Making requests for 2019 declarants’ listings to the following agencies in order to update the Commission’s inventory: 

Parliament Office

all the relevant Government Ministries

Office of the Regional Democratic Councils


5. Provision of each identified person in public life for 2019 with the authorized form for declarations. A cover letter accompanies each Declaration Form. Cover Letters contain appropriate instructions as statutorily stipulated.


Receipt, examination, and filing of declaration forms, requests for further information. Follow up with defaulting public officers.

7. Investigating and resolving matters and complaints relating to the Commission and declarants. 8. Publishing the names of defaulting Persons in Public life. The placement of names in the Official Gazette or a daily newspaper serves to notify Public Officers. The publication acts as a deterrent for Public Officers to submit their declarations. The Commission explores every avenue statutorily provided. This includes legal action, where applicable. 9. Maintaining and updating a secure database (Persons in Public Life MIS) of declarations.


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10. Develop, implement, monitor and update an operations manual to serve as a guide in the daily operations of the Commission. 11. Maintenance of proper accounts. The preparation of 2015, 2016 and 2017 Annual Financial Statements and their submission to the Audit Office of Guyana. 12. Continue the day to day Administrative and Financial activities of the Commission. 13. Updating of the Commission’s website. 14. Reviewing of the Commission’s Act. 15. Continuous training of staff.


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CONCLUSION Overall, the Commission had a successful year. The work plan followed the Commission's legislative mandate. Most of the activities planned were completed. There were few major challenges. The Commission hopes to find solutions to these challenges and thus yield greater success in execution of its mandate going forward.



Country Presentation: Jamaica "Text not available"

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Country Presentation: Saint Lucia

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BRIEF OVERVIEW OFFICE OF INTEGRITY COMMISSION FOR 2018-2019 INTRODUCTION The Office of the Integrity Commission was established in accordance with Section 118(1) of the Constitution of Saint Lucia (hereinafter referred to as The Constitution) and is regulated by the Integrity in Public Life Act Cap1.19 of the Revised Edition of the Laws of Saint Lucia (hereinafter referred to as The Act).

The present Commissioners took the oath of office on 26th of April 2018. They are:  Pastor Sherwin Griffith, Chairman  Ms. Leandra Verneuil, Commissioner (Lawyer)  Mr. Linwall Nantonjames, Commissioner  Mr. Rupert Ellis, Commissioner  Mr. Cleophus Regobert, Commissioner (Accountant)

STAFF  Jean Morille, Secretary  Dianne St. Croix, Research Assistant

In an era where corruption has undermined and destroyed democracies, eroded governments’ ability to provide safe havens for their people, security, peace and in most cases basic necessities for their people’s survival, we continue to stand strong because embedded in our Constitution is this cardinal which has helped to fight this scourge...Corruption.

We must, however, ensure that the links of our anti-corruptive practices are strengthened and become that unbreakable chain for our island nation for the next forty years and beyond.

Saint Lucia Country Paper 2019

Page 1 of 11

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This cardinal I speak of is the Office of the Integrity Commission which was established by the Constitution of Saint Lucia Chapter 1.01 of the Revised Edition of the Laws of Saint Lucia and regulated by the Integrity in Public Life Act Chapter 1.19 of the Revised Edition of The Laws of Saint Lucia.

The activities of the Office commenced in 1998. These activities have been instrumental in making the public aware of the scourge of corruption and the negative effects such corruptive practices have on an island nation such as ours. Our people speak openly and question the integrity of persons in public life and seek accountability of persons in public life. Therefore, the Office of the Integrity Commission must assure our people that it can assist in allaying their concerns and be effective in doing so.

THE WORK AND RECOMMENDATIONS OF PAST COMMISSIONS [A REVIEW OF 2002-2014 REPORTS] The First Commission was appointed on February 26, 1998 and today the Integrity in Public Life Act Chapter 1.19 of The Revised Edition of the Laws of Saint Lucia is the legislation which gives life and breath to the Office of the Commission.

ACTIVITIES The Commissioners throughout the years have embarked on a series of activities primarily PUBLIC AWARENESS CAMPAIGNS. This awareness achieved by means of articles in local newspapers, comprehensive discussion programmes hosted by GIS (Government owned tv station) and the local media. Out of this campaign a Handbook 2005 was printed and distributed to the general public via Government institutions and libraries and later on memorandum entitled “Unsatisfactory Completion of Declaration Forms� to assist persons in public life to properly fill out their declaration forms prior to filing.

Saint Lucia Country Paper 2019

Page 2 of 11

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In 2010 conversations were held with an official of the World Bank, Washington regarding the Integrity Commission’s Rules on Financial Disclosure and Business Activities for Members of Parliament in Saint Lucia.

Under the Chairmanship of Pastor Sherwin Griffith in 2010, there was yet another public awareness campaign including an interview with a popular television personality Cecil Actille of DBS Television. In February 2010, there was discussion with respect to a suitable website for the Commission and Cyber Scripts International was contacted. The Prime Minister was written to by Commissioners with respect to the Website. The proposal and costing for the development of the website were forwarded to the PM’s office for urgent attention. That was the first attempt at obtaining a website by the Commission without success.

In 2011, the Commissioners held several weekly meetings with Attorney General, Solicitor General, Deputy Director of Legal Drafting and Commissioner of Police for proposed changes to the Act.

A workshop conference on Good Governance in collaboration with the Commonwealth Secretariat was held in Saint Lucia at the Coco Palm Resorts. This was attended by members of Integrity Commission, Ministers of Government, Permanent Secretaries, Principals of Schools, Police Officers and Senior Officer of Customs and the Inland Revenue.

In 2013/2014 further meetings were held with stakeholders the main objective was improving relations, advising on the work of the Commission and seeking assistance and support for work of the Commission. Discussions were held with the State’s Deputy Director of Legislative Drafting and the Attorney General.

CONCERNS Since 2002 to date according to the reports of various commissions the concerns of the Commission have been the same. Year after year reports state the very same concerns:Saint Lucia Country Paper 2019

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The Commission is described as having “no teeth” is a toothless tiger and other similar nomenclature.

The lackadaisical manner in which persons in public life take their statutory obligation

Failure in timely filing of declarations

Blatant refusal of declarants (especially Spouses) to provide supporting financial statements or additional documents

Budgetary restraints

Insufficient staff to properly investigate the declarations filed

No website to disseminate information

Failure of Government to amend legislation to provide for a proper secretariat and more investigative and prosecuting powers

Failure of the DPP to prosecute

Failure of the Police to investigate

Lack of respect for the office of the Integrity Commission by public officers including members of Parliament.

INTEGRITY COMMISSION 2018/2021 Being cognizant of the work of previous Commissions, the mission statement of this present Commission is to ensure that the legislation is amended, a proper secretariat or office be put in place and that a website be readily available to disseminate information to achieve the Integrity Commission’s mandate.

REASONS FOR AMENDMENT OF LEGISLATION STAFF OF THE COMMISSION/OFFICE OF THE COMMISSION The office of the Commission needs to be staffed by a proper secretariat, the current staffing is wholly inadequate and consists of an administrative assistant and an intake officer. It is proposed that the staff who is appointed by the Public Service Commission be so appointed on the advice of the Commissioners but become permanent upon appointment.

Saint Lucia Country Paper 2019

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To perform the duty and the tasks to efficiently execute the work of the Commission, the Commission should have the following persons: -

Executive Director


Legal Advisor (assigned from the Attorney General’s Office during the time of declaration)


Investigative Officer (preferably one who is highly skilled and experienced to conduct investigations relating to financial crimes)


Administrative Secretary


Senior Accounts Clerk


Any other personnel reasonably necessary to carry out the work of the Commission such as office assistant/cleaner.

The Regulations by the Minister of Justice (Section 48 of The Act) will define the duties of the office of the secretariat and its personnel.

The office must be set up and given a permanent location to ensure, confidentiality of all its documents and ensure that the office maintains a high degree of virtual excellence. The current location is not ideal.

MEMBERS OF THE COMMISSION The Chairperson plays a very important and significant role in such an esteemed office and therefore may be a retired judge or lawyer of more than 15 years standing or a citizen of good standing in the community. Other members may include a chartered accountant, other persons in the society who are citizens of good standing including a faith based minister.

DEFINITION OF PERSONS IN PUBLIC LIFE The present legislation at Schedule 1 needs to be amended to include the Chairperson/Deputy of Constituency Councils and Principals and Deputy of Secondary Schools, Director and Deputy Director of Information Services. Saint Lucia Country Paper 2019

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It is proposed that as it relates to Gifts section 28 be amended and the limit of $500.00 be removed.

It is proposed that Section 28 read as follows: - All Gifts received by persons in public life must be declared.

OTHER ANTI-CORRUPTION AGENCIES Further amendment to the legislation should give the Commission powers to make available to it: 

To form bonds with other anti-corruption agencies as indicated below,

Receive and share information if needed by the Commission for investigative purposes for clarification and verification from the Financial Intelligence Authority, Financial Regulatory Authority, Comptroller of Customs and Inland Revenue or other Anti-Money Laundering Agency including the Border Control Agency.

The information must be relevant to the investigation of a person in public life, his spouse or child.

Investigation prior to prosecution be done by an agency other than Police

Prosecution be carried out by an agency other than DPP

GENERAL BUDGET FOR THE COMMISSION The Commission at present has no security of tenure. It is proposed that the Budget should be prepared by the Executive Director with the Senior Accounts Clerk and approved by the Commissioners then sent to the Minister for Justice for inclusion in the Ministry’s annual estimates. Currently this is not the procedure followed.

It would be preferable that budget so prepared be approved upon presentation to the PM and the Director of Audit be responsible for auditing the accounts of the Office.

Saint Lucia Country Paper 2019

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WEBSITE It would be helpful for the Commission to have a website to disseminate information to the public and to allow public officers access to declaration forms. It may also be used for filings complaints.

AN ENTITY WITH NO ‘TEETH’ ‘TOOTHLESS TIGER’ From 2002 to date, all reports of the various Commissions thus far appear to suggest that the Commission had no powers to deal with persons who refused to or failed to file declarations. This continues to be the concern of this present Commission. It was observed: 

That the publishing of offenders in the Gazette was of no consequence.

That referral to the Director of Public Prosecutions for further action lead to no action not even a report or least communication from the DPP of what was done or not done in these circumstances.

That there has been no prosecution of defaulters for the past 16 years

Failure for further investigation of public officers by the Police Department

Public Servants who are permanently employed and required to file declarations, over the years have failed to or refused to file and such corruptive practices continue without penalties. Such officers retire and enjoy their pension and gratuity.

The graphical representation herein below will show the percentage of filing by the various heads of public officers to show comparison with members of parliament and permanent secretaries/deputy permanent secretaries. It appears that following a general election there is a decrease in filing of declarations by persons in public life.

The graphical representation also shows that no one has been prosecuted, investigated or fined for not having filed or not furnishing particulars in declarations.

Saint Lucia Country Paper 2019

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PERMANENT SECRETARIES 20 18 16 14 12 10 8 6 4 2 0 2004





Saint Lucia Country Paper 2019











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0 2004





Saint Lucia Country Paper 2019











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WORK OF COMMISSION TO DATE Since the first official meeting of the Commission on May 2, 2018: 

The Commission had meetings with Cabinet Secretary with respect to budget and funding for the work of the Commission

Ms. Vidal-Jules (Legislative Drafting) so that amendments to the current legislation can be recommended, these amendments are in keeping with the constitution.

The Chair and Accountant have travelled to Turks and Caicos to the 4th Annual Conference of Caribbean Integrity Commissions and Anti-Corruption Bodies.

Revised the Letters and Declaration forms to include a signed authorization letter by Declarant to Financial institution to further investigate or verify accounts if such investigation or verification is absolutely necessary.

Revised the Handbook

Commissioned the design of a Website for the filing of declarations on line; thus making it easier for persons to comply with their obligations in public life.

Reading the draft discussion of the Jakarta Principles for Anti-Corruption Agencies, to recommend changes to the legislation, in keeping with our mandate for the prevention, investigation and prosecution of corruption in public office.

A public education drive, with respect to Integrity and Anti-corruption for the awareness and to sensitize the public especially young persons under 16 and hence targeting the schools.

A proposal for a Website and Database

Proposal of an anti-corruption jingle

Senior Management Training in Grenada – Secretary, Office of the Commission (March 25 – 28, 2019)

Caribbean Financial Action Task Force (CFATF) Standards Training - Coordinated by: The National Anti-Money Laundering Oversight Committee (NAMLOC) April 8 – 10, 2019

Had a meeting with the Minister of Justice with a view of ensuring the amendment to the legislation and the drafting of regulations to ensure proper procedures for investigating and prosecuting offenders of The Act.

Saint Lucia Country Paper 2019

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A functioning website to disseminate information

Amendment of the legislation to be able to administer its own budget, secretariat and means of investigation and prosecution.

Saint Lucia Country Paper 2019

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Country Presentation: Turks & Caicos Islands

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Commonwealth Caribbean Association of Integrity Commission and Anti-Corruption Bodies (CCAICACB) 5th Annual Conference – Cayman Islands – June 2019

Turks and Caicos Islands (TCI) Integrity Commission Report for May 2018 to May 2019 _________________________________________________

In 2018/2019, the Integrity Commission of the TCI, despite its persisting resource challenges, continued to discharge, as best as it could, its mandates under the TCI Constitution and the Integrity Commission Ordinance.

Among these, were its very important anti-corruption compliance and investigation mandates, as well as its mandate to educate the country’s residents about the Commission’s vision, functions and objectives, and to assist those who offer themselves for public service to adhere to the principles of integrity and good governance in public office and, in so doing, to facilitate the sustained economic growth and development of the TCI. 1|Page

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Board of Commissioners and the Executive The Commission, during the year, welcomed new Commissioners, inclusive of a new Chairman, and a new Director, as it bade farewell to its long-serving Chairman, Sir David Simmons, in October 2018, and its former Director, Mr. Eugene Otuonye, QC, in July 2018. Sir David had served the Commission from the very outset of its establishment in 2010 and, former Director Eugene, from 2011.

The Commission’s new Chairman, the Hon. Mr. Justice Seymour Panton, who is the recently retired President of the Court of Appeal of Jamaica, assumed office in December 2018. Additionally, Commissioner Dr. the Revd. Samuel Goldstone Williams was appointed to the Board of Commissioners in November 2018.

Another of the Commission’s Commissioners, the Revd. Pedro Williams, who had served for three years, demitted office in March of this year. His successor, Mrs. Tremmaine Swann-Harvey, Esq, assumed office, effective May 20, 2019.

Greg Christie, who formerly served as Jamaica’s 4th Contractor General, was appointed as the Commission’s new Director, effective July 2018.


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The appointment of a new Chairman, following the end of Sir David Simmons’ substantive tenure, in early 2018, took longer than was anticipated. In consequence, there were matters that could not be embarked upon by the Commissioners until a substantive Chairman was appointed.

With the full 6-person complement of the Board of Commissioners now in place, the Commission is positioned to continue its normal and routine operations without difficulty.

Compliance The Commission’s one-person-staffed Compliance Department, under the able stewardship of Crystal Baksh, now Crystal Almonte, continued, throughout the year, to administer the discharge of its critical and formidable mandates. In November 2018, Crystal was elevated from her substantive position of Compliance Officer, to the position of Senior Compliance Officer (SCO). The vacant SCO position was publicly advertised, and several applicants were screened, shortlisted and interviewed.

As usual, and thanks to the positive attitude of Declarants in public life in the TCI, the Commission’s Compliance Unit enjoyed a relatively very good year with approximately 95% compliance amongst the country’s 180+ Declarants, who 3|Page

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were required to submit declarations during the period in question. The names of less than 10 non-complaint Declarants, each for 2017, and 2018, were referred, in compliance with the dictates of the law, on account of their failure to file their declarations on time.

There is still the lingering issue of the Unit not being notified of new employees in Government positions, who fall into the category of Declarants, or of those who have left the TCI Public Service and are required to file exit declarations.

With continued outreach, public notices, and meetings with Ministries and Heads of Departments, the Compliance Unit has been addressing the problem. Its objective is to ensure that all Declarants are properly notified of their responsibilities to the Commission, and to people of the TCI, and are fully compliant with the requirements of the law.

As always, all 21 Members of the TCI House of Assembly have been compliant in filing their two-year Declarations of Assets, Liabilities and Income, as well as their annual Statements of Registerable Interests and Gifts, on time.


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The Commission has recently hired a new Compliance Officer (CO) to fill the vacancy that was created when Ms. Almonte was promoted to the SCO position. The new CO will restore the Unit’s approved staff complement to two (2) persons.

This, however, will not alleviate the pre-existing backlog of declarations that is required, by law, to be subjected to interrogation, nor the new filings that have to be similarly processed. Additional human resources are desperately required, if the Commission is to effectively discharge this very important element of its mandates.

Additional resources are also required to upload the seven (7) years of historical asset declaration data, that remain on the Commission’s records, into our computerized system and, in so doing, to reduce the turn-around time that it takes for declaration clearance certificates to be issued.

Additionally, two of the Commission’s key corruptionprevention mandates, which fall to the Compliance Unit – (a) the mandate to examine the practices and procedures of public bodies in order to facilitate the discovery of corrupt practices; and (b) the mandate to instruct, advise and assist the management of public bodies of any change in practices or procedures which may be necessary to reduce the occurrence of corrupt acts – are, also, regrettably, not being 5|Page

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effectively discharged, due to a deficit of human resources. This also requires urgent address.

Investigations and Enforcement The Commission’s Investigation and Enforcement Unit was significantly bolstered with additional resources during the year. It moved from a two-person Unit, as at May 2018, to a current team Unit of four. The Unit is now composed of a Senior Investigative Officer (SIO), Mr. Richard Mills, an Investigative Officer, a Financial Investigative Officer, and an Intelligence Officer. A fifth officer – a Technical IT/Investigative Officer – is expected to be recruited shortly, and will expand the Unit to a five-person team.

The Commission’s Investigation and Enforcement Unit was very busy during the year, as there were several matters under investigation.

The Unit received sixteen (16) new reports during the year. These, along with an ongoing forty-five (45) or so, that were carried over from the previous year, demanded the full attention of the Unit.


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At any given point in time, the Unit will be actively working on twenty (20) to twenty-five (25) matters simultaneously. Despite the increase in its manpower complement, the demands and complexity of the Commission’s investigations are significant, and the fact is that the Unit is still understaffed and remains challenged to discharge its mandates, effectively, efficiently and with expedition.

It is worthy of note that the Unit continues to collaborate with local and overseas law enforcement agencies on a few matters. It has also secured funding to undertake a number of very serious matters, which could pose far-reaching adverse implications, for the TCI, if they are not urgently addressed. The matters were awaiting thorough investigation, but same was beyond the resource and technical capacities of the Unit.

The confidence that is reposed in the Commission, by those who report matters to it, has to be reinforced by its actions in effectively and efficiently dealing with same.

Our teams understand that this is the core of our functioning, if the Commission to be taken seriously. We do, however, explain to persons who have reported issues to the Commission, that budgetary constraints may result in us having to take more time than would be reasonably 7|Page

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expected, if we are to effectively address the matters that are at hand.

Some of our stakeholders do seem to understand this. However, when matters drag on for extended periods, it will inevitably lead to persons who will then doubt the Commission’s ability to do what it says it will do.

Expectations must be managed when the lack of resources inhibit an anti-corruption commission from discharging its functions efficiently and effectively, failing which its reputation, in the public’s eyes, and in the eyes of other stakeholders, will be negatively impacted.

The Commission currently has two matters before the courts. There is also at least one matter that is pending with the Office of the Director of Public Prosecutions.

One of the difficulties that we experience, being a part of a relatively small island community, in which residents are drawn from several nationalities, is that witnesses, while some may be forthcoming with information, the overwhelming majority are, nevertheless, extremely reluctant to appear in Court. 8|Page

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Our teams, having observed the outcomes of Commission matters, that have passed through the Courts over the past four years, are exploring alternative avenues for dealing with these challenges. We are, therefore, presently engaged in the process of implementing new strategies to tackle the issues that we have identified.

Public Education Mrs. McCartney Pierre, the Commission’s sole Public Education Officer, has continued the Commission’s outreach during the year to our very critical stakeholders – the wider community, but specifically our schools, public bodies, public officers, as well as the private sector.

The Commission’s annual High School Debate and Community College Speak Off Competitions were held in March of this year. This was in addition to the other usual outreach engagements that are routinely undertaken at schools, and at several public bodies.

Some of our planned visits, and scheduled programmes for radio and television broadcasts, were put on hold but should be re-instituted during the new Financial Year.


PAGE | 57j

As we had advised last year, the costs that are associated with executing these activities, across the islands, in what is essentially an archipelagic state, require significant funding that did not materialize in the past financial year.

The Unit has been preparing for the initiation of its 2nd Public Perception Corruption Survey, and its most recent engagements with the Police Department, Customs, and the Health Department, have been quite productive. All participants will complete the questionnaire on their perceptions of the levels of corruption in the TCI. The first survey began in 2014, and encompasses over 300 inputs. However, the data is to yet to be analyzed, collated and published.

The Unit’s introduction of Integrity Clubs, throughout TCI High Schools, is still being worked upon, as funding issues appear to make it difficult for personnel from the schools to commit to the undertaking. Among the Unit’s plans, is the objective of partnering with business persons, artists and professionals, who are drawn from the local communities, and to take them into the schools with us, during our engagements. This way, the students will have the opportunity to hear of their experiences, and how important adherence to principles of 10 | P a g e

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integrity has been throughout the development and growth of their careers.

Information Technology The Commission’s IT Specialist and Security Manager, Mr. Jovan Flemming, has consistently kept the Commission on the cutting edge of information and communications technologies with continuous upgrades to the Commission’s IT systems and licences. We are grateful to have someone of his calibre and expertise as a part of our team.

Looking Forward The Commission’s new Director, very early in his tenure, and after consultation with internal and external stakeholders, developed and submitted a 2-year organization restructuring and operational strategic plan. The plan was unanimously approved by the Commission’s Commissioners, for implementation.

In essence, a gap-analysis, between the mandates of the Commission, on the one hand, and the adequacy of its organizational structure and resources to efficiently and effectively discharge those mandates, on the other, was undertaken. 11 | P a g e

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A budget proposal, which reflected the resources that would be required to bridge the gap and effectively implement the plan, was submitted to the TCI Government. However, having regard to the Government’s own budgetary constraints, only some of the Commission’s requisitions were given favourable consideration for the current 2019/2020 Financial Year.

One of the allocations that was granted, was funding to enable the Commission to expand its office in Providenciales. Funding to facilitate the initial scoping of the requirements for the Commission’s implementation of the 2017 TCI Bribery Ordinance, that is patterned off the UK’s 2010 Bribery Act and the 2016 Bermuda Bribery Act, was also approved.

The Commission was also allocated funds to recruit a much needed Finance, Accounting and HR Manager, as well as an Administrative Assistant. Both will be based at the Commission’s expanded office in Providenciales.

As is clearly indicated in its Strategic Plan, the Commission requires additional staff, across its organization, to enhance its capacity to more effectively and efficiently discharge its several anti-corruption and good-governance mandates. Indeed, some of these mandates are not being currently discharged at all. 12 | P a g e

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However, the Commission recognizes the financial constraints that exist within the TCI Government, itself, and the competing demands that it faces for its limited funds.

The Commission will, therefore, in the current financial year, continue to do its best to maximize the return from its budgetary allocations in delivering upon the discharge of its several constitutional law and statutory mandates.

That said, the Commission will also, in the coming financial year, appeal again to the TCI Government and House of Assembly, for the additional resources that it needs to ensure that it operates at the level of effectiveness and efficiency that the architects of the TCI Constitution and Integrity Commission Ordinance had intended for it to operate.

Integrity Commission of the Turks and Caicos Islands May 2019; V.2

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Trinidad & Tobago - Jakarta Principles Analysis

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Paper by Mr. Justice Melville Baird on the Applicability of the Jakarta Principles to Trinidad and Tobago

Article 6 (1) of the United Nations Convention Against Corruption (UNCAC) requires each State Party acting in accordance with the fundamental principles of its legal system to ensure the existence of a body or bodies that would prevent corruption by e.g. implementing the policies referred to in Article 5 and increasing and disseminating knowledge about the prevention of corruption. Article 6 (2) provides for each State Party to grant the body or bodies referred to in 6 (1) the necessary independence in accordance with the fundamental principles of its legal system, to enable the body or bodies to carry out its or their functions effectively and free from undue influence. Additionally, the necessary material resources, staff and training for such staff should also be provided. Further, Article 36 requires each State Party, acting in accordance with the fundamental principles of its legal system, to ensure the existence of a body or bodies of persons specialized in combatting corruption through law enforcement. In November 2012, The United Nations Development Programme (UNDP) and United Nation Office on Drugs and Crime (UNODC) collaborated with the Corruption Eradication Commission (KPK) of Indonesia and hosted a meeting in Jakarta of current and former heads of anti-corruption agencies (ACAs), anti-corruption practitioners and experts to develop a set of standards that would guide the establishment and operations of anti-corruption bodies. At the conclusion of the 2012 meeting participants endorsed the The Jarkata Statement on Principles for Anti-Corruption Agencies; this set out the 16 Jakarta Principles which provided more detailed guidance on the UNCAC concept of “necessary independence”. At the seventh Conference of State Parties (COSP) in 2017 UNCAC Resolution 7/6 mandated the United Nations Office on Drugs and Crime (UNODC) to develop, amongst other things, guidance notes and technical tools on the implementation of Article 6 of the Convention. In May 2018, the Mauritius Communiqué, agreed to, at the “Regional Conference on Effectiveness of Anti-Corruption Agencies and Financial Intelligence Units in Fighting Corruption and Money Laundering in Africa” called for the development of indicators to assess and measure effectiveness that would guide ACAs and Financial Intelligence Units. In response to these requests, UNODC and UNDP convened an Expert Group Meeting (EGM) in July 2018 in Colombo and brought together some thirty international experts from around the world to develop a “Commentary on the Jakarta Statement on Principles for Anti-Corruption Agencies”. The Commentary was drafted to provide, 1

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inter alia, guidance on the sixteen principles enshrined in the Jakarta Statement and is intended to assist State Parties to better implement Articles 6 and 36 of UNCAC. Each of the sixteen principles is vitally important for the effectiveness of the ACAs. Trinidad and Tobago signed UNCAC on 11th December, 2003 and ratified it on 31st May, 2006. The thrust of this paper today is to demonstrate the manner in which Trinidad and Tobago, primarily through its Integrity Commission, is performing in the glare of the Jarkata Principles. The answers to the questions under “Self–assessment” appear under the heading “Comment” and are not necessarily in the order in which the questions were posited. Time is the enemy this morning and its hostility would preclude treatment of the other ACAs in Trinidad and Tobago. Principle 1 – Mandate “ACAs shall have clear mandates to tackle corruption through prevention, education, awareness raising, investigation and prosecution, either through one agency or multiple co-ordinated agencies”. Comment UNCAC Article 6 requires each State Party to establish a body to prevent corruption by such means as: (a) implementing the policies referred to in Article 5; and (b) increasing and disseminating knowledge about the prevention of corruption. In Trinidad and Tobago there are bodies established to prevent corruption; these bodies specialise in combatting corruption through law enforcement (Article 36). In Trinidad and Tobago the requirements of UNCAC are holistically met through a multiple agency approach. And although the single agency approach is seemingly the most well-known version of an ACA, our Constitution would have to be radically and extensively altered for us to achieve that result. The bodies that are mandated to target corruption are all given their mandates by law. These bodies are the:


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Integrity Commission mandated by the Integrity in Public Life Act (“the Act”) and the Prevention of Corruption Act.


Office of Procurement Regulation mandated by the Public Procurement and Disposal of Public Property Act.


Police Complaints Authority mandated by the Police Complaint Authority Act.


Financial Intelligence Unit of Trinidad and Tobago mandated by the Financial Intelligence Unit of Trinidad and Tobago Act.


Director of Public Prosecutions (DPP) mandated by the Proceeds of Crime Act.


Civil Asset Recovery and Management Agency mandated by the Civil Asset Recovery and Management and Unexplained Wealth Act, 2019

These bodies are all endowed with the “necessary independence” to discharge their mandates. Principle 2 - Collaboration “ACAs shall not operate in isolation. They shall foster good working relations with State Agencies, civil society, the private sector and other stakeholders, including international cooperation”. Comment At the present time there is no provision in the Act that would allow collaboration with other state agencies to tackle corruption. The Commission has suggested amendments to the Act that constitute a general overhaul of the Act. In the amendments we have included a provision for information sharing with other ACAs. The Acts of Parliament creating the ACAs with which information is to be shared however must be amended by Parliament to enable the receipt of information from the Integrity Commission. There is no provision in the Act requiring the Integrity Commission to collaborate with civil society, the private sector or international bodies, to tackle corruption. But this the Commission is advocating of its own motion.


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Principle 3 - Permanence “ACAs shall, in accordance with the basic legal principles of their countries, be established by proper and stable legal framework, such as the Constitution or a special law to ensure continuity of the ACA”. Comment Several ACAs, the Integrity Commission included, have been established by the Constitution; others are creatures of other statutes. Principle 4 – Appointment “ACA heads shall be appointed through a process that ensures his or her apolitical stance, impartiality, neutrality, integrity and competence”. Articles 6 and 36 both call for the necessary independence of ACAs, and this independence must be seen to begin from the top. The Act requires that the Chairman, Deputy Chairman and the three other Members of the Commission be persons of integrity and high standing. The Act also provides that the Chairman and other Members of the Commission shall be appointed by the President, after consultation with the Prime Minister and Leader of the Opposition. They are not publicly vetted. The law does not speak of minimum education or experience qualifications for the Chairman of the Integrity Commission; neither does it speak specifically of the Chairman being apolitical. By convention however the Chairman is usually a retired professional, e.g. a judge or manager and not an active member of any political party. We have suggested that a provision be included in the Act that would require the Chairman and Members of the Commission to be totally apolitical, that is to say, that they should not be or recently have been, a member of a political party, nor should they have been donors or patrons of any political party. Principle 5 – Continuity “In the event of suspension, dismissal, retirement or end of tenure, all powers of the ACA head shall be delegated by law to an appropriate official in the ACA within a reasonable period of time until appointment of the new ACA head”. 4

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Comment In the event of any of the aforementioned contingencies, the Deputy Chairman will automatically begin to exercise all powers of the absent Chairman until the appointment of a new Chairman; this would include presiding over the statutory meetings. Section 4 (6) of the Act provides that three Members of the Commission, of whom one shall be the Chairman or Deputy Chairman, shall constitute a quorum. There is no provision for a time limit for the post of Chairman to be left vacant.

Principle 6 – Removal “ACA heads shall have security of tenure and shall be removed only through a legally established procedure equivalent to the procedure for the removal of a key independent authority specially protected by law (such as the Chief Justice)”. Comment Section 8 (2) of the Act provides for the President to terminate the appointment of a member of the Commission if one or more of certain specific conditions have been satisfied, viz where that member is found to be of unsound mind; becomes bankrupt or compounds with creditors; is convicted of any offence which brings his office into disrepute; is guilty of misconduct in relation to his duties; misbehaves in office; fails to carry out any of his statutory duties or functions or is incapable, for whatever reason, of performing his duties and functions under the Act. The minimum fixed term of appointment for the Chairman under the Act is three years, and the process for his removal from office is not similar to that for the removal of the Chief Justice. The rules of natural justice however, would require that the Chairman be permitted to defend himself on an allegation for his removal. It would be a public hearing. Principle 7 – Ethical Conduct “ACAs shall adopt codes of conduct requiring the highest standards of ethical conduct from their staff and a strong compliance regime”. Comment


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When developing a Code of Conduct it is important to integrate some form of compliance regime, whether tied into an existing public service disciplinary system or a separate ACA specific internal disciplinary system. I am of opinion however that the Code of Conduct, though requiring a strong compliance regime, must not be criminalized. The Expert Group Meeting (EGM) convened by UNODC and UNDP in Colombo in 2018 spoke approvingly of the Bhutan Ethical Code of Conduct. The Bhutan Code provided penalties for breaches of the Code, where the breach was considered: i) minor; ii) minor but committed for the second time; iii) repeated breaches irrespective of their nature. In the three instances, disciplinary action is prescribed. The only reference made to criminal law was where it was stated that if any breach of the Code was punishable by a heavier penalty under another law, then that law should apply. Part IV of the Act, sections 23 to 31 deal with Code of Conduct in respect of persons in public life and persons exercising public function. The Office of Procurement Regulation is in the process of drafting a Code of Conduct that would include and be applicable to, the staff of the Commission. The members of the Commission are not covered by a Code of Conduct. stricto sensu, but section 8 (2) of the Act provides for sanctions where a member of the Commission is found liable for unethical conduct. I reiterate my stand against the notion that the Code of Conduct must be criminalized. Principle 8 – Immunity “ACA heads and employees shall have immunity from civil and criminal proceedings for acts committed within the performance of their mandate. ACA heads and employees shall be protected from malicious civil and criminal proceedings”. Comment Section 39 of the Act exempts the members of the Commission from personal liability in the discharge of the functions of the Commission under the Act unless it is shown that they acted recklessly or in bad faith. This cloak of immunity is also being sought for persons legitimately performing any function under the Act provided it is not done recklessly or in bad faith. The Act does not provide specific protection to members of the Commission and employees of the Commission from malicious civil and criminal proceedings; protection however is in-built in the civil and criminal law of Trinidad and Tobago.


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Principle 9 – Remuneration “ACA employees shall be remunerated at a level that would allow for the employment of sufficient number of qualified staff”. Comment Section 9 (1) and (4) of the Act respectively provide for the salaries and allowances of the Chairman and other Members of the Commission to be determined by the Salaries Review Commission and that their salaries and allowances should be a direct charge on the Consolidated Fund. Section 9 (3) of the Act provides for the staff of the Commission to be public officers appointed in accordance with section 121 of the Constitution (this section of the Constitution deals with the appointment of Public Officers). Apart from the staff of the Commission being public officers, the staff could also include contract officers. And the salaries of both the public and the contract officers are determined by the Chief Personnel Officer. Section 9 (5) of the Act authorises the Commission to appoint and employ, on such terms and conditions as it thinks fit, any other officers and employees as it thinks necessary for the proper carrying out of its functions under the Act. They are regarded as employees for service and should be distinguished from employees on a contract of employment. The salaries of the latter is determined by the Chief Personnel Officer. Principle 10 – Authority over Human Resources “ACAs shall have the power to recruit and dismiss their own staff according to internal, clear and transparent procedures”. Comment The provisions under section 9 (3) (4) and (5) of the Act referred to under Principle 9 are reiterated here. The termination of service of public officers comes under the purview of the Public Service Commission governed by the Public Service Regulations. The termination of officers on contract is the responsibility of the Chief Personnel Officer and is governed by the terms and conditions of their contracts. The termination of employees for service is addressed by the organisation that employs them applying the terms and conditions of their contract for service. 7

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Principle 11 - Adequate and Reliable Resources “ACAs shall have sufficient financial resources to carry out their tasks, taking into account the country’s budgetary resources, population, size and land area. ACAs shall be entitled to timely, planned, reliable and adequate resources for the gradual capacity development and improvement of the ACAs operation and fulfilment of their mandate”. Comment Principles 9, 10 and 12 are relevant. The Integrity Commission receives its funding predictably when the budget cycle is completed but there is no guaranteed minimum budget. Head 37 is the budget line for the Integrity Commission and the current budget needs augmenting to ensure that the Commission can effectively discharge its mandate. Over the past three years the budget of the Commission has been stable. Principle 12 – Financial Autonomy “ACAs shall receive a budgetary allocation over which ACAs have full management and control without prejudice to the appropriate accounting standards and auditing requirements”. Comment Viewed from the stand point of the financial infrastructure the Integrity Commission does not enjoy financial autonomy. Principles 9, 10 and 11 are relevant. Principle 13 – Internal Accountability Principle 7 (Ethical Conduct) is relevant. “ACAs shall develop and establish clear rules and standard operating procedures including monitoring and disciplinary mechanisms to minimize any misconduct and abuse of power by ACAs”.


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Comment The Act does not require the members of the Commission or staff to complete asset declarations and conflict of interest forms. However, a Code of Conduct that will be applicable to all government departments is at the present time being drafted by the Office of Procurement Regulation; that code would require members of the staff of the Commission to complete conflict of interest forms. The Act provides for the President to terminate the appointment of a member of the Commission, on the grounds inter alia, that the member has become bankrupt or compounds with his creditors; is convicted of any offence which brings his office into disrepute; is guilty of misconduct in relation to his duties; misbehaves in office and fails to carry out any of the duties or functions conferred on him under the Act. Members of staff who are public officers fall under the Public Service Commission; the Head of the Public Service Commission’s Secretariat is the Director of Personnel Administration and he initiates disciplinary action against public officers. Contract officers fall under the Chief Personnel Officer and disciplinary action would be taken by the Department in which the contract officer is working. These disciplinary processes allow for public and contract officers to have a right to reply and a right of appeal. The Act identifies and delineates the powers of the Commission; it also sets out parameters for the Investigators of the Commission. One of the requirements for the appointment of Investigators is that they must have served as police officers in the police service up to, at least, the level of Inspector, they must have investigative skills and are to be guided in their investigations by the Judges Rules. The Commission has no prosecutorial powers. Principle 14 – External Accountability “ACAs shall strictly adhere to the rule of law and be accountable to mechanisms established to prevent any abuse of power”. Comment The Integrity Commission is not subject to oversight by a cross-party Parliamentary Committee, neither is it subject to any other form of external oversight. The Integrity Commission is an independent body and takes direction from no one and no body.


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Principle 7 (Ethical Conduct); Principle 9 (Authority over Human Resources); Principle 12 (Financial Autonomy); and Principle 13 (Internal Accountability) are relevant.

Principle 15 – Public Reporting “ACAs shall formally report at least annually on their activities to the public”. Comment Section 10 of the Act provides for the Commission, not later than 31st March, to make a report to Parliament of its activities in the preceding year. Principle 16 – Public Communication and Engagement “ACAs shall communicate and engage with the public regularly in order to ensure public confidence in its independence, fairness and effectiveness”. Comment The Commission engages with the public by means of various projects launched during the year. The public speeches of the Chairman on anti-corruption are given to the media as a matter of course. The Commission also has a website and it is updated with reports and news.

Conclusion Notwithstanding the fact that the Integrity Commission figured to a remarkable degree in the consideration of the Jarkata Principles, I can asseverate that the comments made in respect of each principle could, generally speaking, apply mutatis mutandis to the other ACAs of Trinidad and Tobago. It is therefore with sentiments of unbounded pride and profound satisfaction that I can say that Trinidad and Tobago in its legislation against corruption is acting according to the spirit and philosophy of the UNCAC. Be it admitted that in a few instances Parliamentary intervention would be necessary, and that might take some time, but in the main, Trinidad and Tobago can walk in lockstep with the other members of UNCAC as we deal corruption its final quietus, vanquishing a common enemy and achieving a common good. 10


Cayman Islands - Jakarta Principles Analysis

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Draft Commentary on the Jakarta Principles

Cayman Islands Legislation

1. Mandate Establishing of body/bodies to prevent corruption through implementing policies increasing and disseminating knowledge about the prevention of corruption;

Section 117 (9) CI Constitution –sets out the Commission’s functions. Functions constitute clear mandate for corruption prevention. See, too section 5 SPL Law.

Investigative powers but no prosecutorial powers. Ensure the existence of one or more bodies specializing in combating corruption through law enforcement Must have necessary independence to discharge mandates

Though silent on the issues of education and awareness, these are vital for the fulfillment of its role. Mandate given to Anti-Corruption Commission – section 3 to administer the AC Law (2019 R); powers, duties and functions are set out under s4. ACC has authority to investigate through investigating officers – s 3C AC Law and powers of arrest - s3D ACL In addition, RCIPS, has authority to investigate and prosecute corruption Offences (Criminal Procedure Code (“CPC”) and Penal Code (“PC:”)

2. Collaboration

Fostering of good working relations s22 and 24 SPL allow for collaboration with the RCIPS and the DPP upon satisfaction after inquiry that a breach of Law or offence committed.

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Otherwise, no direct mention of collaboration; however, given the mandate of the Commission – s117 CI Constitution as set out under s5 SPL Law, there is scope for the Commission to collaborate with other government departments/statutory authorities, etc. S8 CI Constitution – Commission is not subject to direction/control of any other person/authority. SPL Law is not in effect with the result that there have been no investigations conducted under the Law. Nonetheless, where inquiries have been made into certain matters arising in the public forum, relevant authorities have responded accordingly. ACC – s 4(2) and 4(5) provide the legal framework for collaboration with other bodies including overseas agencies.



Must be established by proper and stable legal framework, e.g., the Constitution or a special law

The Commission is established under s117 CI Constitution as one of the institutions supporting democracy. S121 (5) CI Constitution also requires the enactment of a law for giving effect to the establishment and maintenance by the Commission of a Register of Interests.

The SPL Law was passed by Members of the Legislative Assembly in 2014 and amended in 2016 but to date has not been brought into effect. The ACC is not a creature of the CI Constitution but is firmly established by the ACL. Based on its work as reported, the ACC is effective in executing its mandate.



Process of appointment of AC heads to ensure his/her apolitical stance, impartiality neutrality, integrity and competence

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s117 (1) – (5) CI Constitution as set out under s4 (1)-(3) SPL Law: persons of “high integrity and with experience in public or private sector”; comprising 1 Accountant (Chartered/Certified) with 10 yrs experience; legal practitioner 10 years practice in Commonwealth.

Appointment by Governor after consultation with the Premier and Leader of Opposition. Excluded – member of LA, holder of public Office or having held public office in the 3 preceding years; held office in a political party in 5 preceding years; non-Caymanian. Appointment by Governor.

ACL – Schedule (s 1-4) for qualifications Previously, there was no public call for ACC or SPL Commission. This process is now being rolled out for the first time.

5. Continuity Requirement for delegation by Law of powers of ACA head to appropriate official in the ACA within reasonable time in event of suspension, dismissal, resignation, retirement or end of tenure – pending appointment of new head

s117(9)(7) CI Constitution allows Governor to appoint member where vacancy arises. In that case, newly appointed member serves until expiration of term. s4(4) SPL Law reflects same.

No specific provision for replacement of Chairman/head.

Powers granted to Commission; not exclusively to the Chairman. No automatic delegation of powers in absence of Chairman. No maximum timeframe in Law/Constitution for any post to remain vacant. s8 Schedule to ACL – addresses vacancies.

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No specific provision for replacement of Chairman/head of ACL. S4 Schedule allows for members present and forming quorum to elect person to preside in absence of Chairman.

No maximum timeframe in Law for any post to remain vacant.

6. Removal ACA Heads to have security of tenure; removal only through legally established procedure for removal of key independent authority (e.g., Chief Justice).

s117(6) CI Constitution and s4(3) SPL Law treat vacancies and removal from office arising from:term expiry; absences from 3 consecutive meetings without Governor’s approval; resignation of member; removal from office by Governor for inability to discharge functions of Office (arising from infirmity of body or mind or any other cause) or misbehavior; or if nominated for election to LA (with consent); or if appointment to public office.

Term of appointment is 4 years s117(6)(a) CI Constitution. S4(3) SPL Law. No provision for Chairman/member defending its position against removal. No established process for removal. ACL Schedule s 6- allows for resignation of member; s7- revocation of appointment after consultation with the AG. Term of Office – 3 years or less s1(2) Schedule for Chairman; same term provided in s2 of Schedule for members.

7. Ethical Conduct ACA’s to adopt codes of conduct requiring highest standards of ethical conduct from staff and strong compliance regime No specific codes established for Commission. Schedule 2 SPL Law sets out “Principles to be adhered to”, i.e., Nolan Principles.

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8. Immunity ACA heads and employees to have immunity from civil and criminal proceedings for acts committed within the performance of their mandate; to be protected from malicious civil and criminal proceedings. s34 SPL Law – no liability for damages for the Commission or any of its members for act/ omission in the discharge of functions under the Law, unless “shown that act or omission was in bad faith”. ACL – s14 and 15 Schedule – similar provision as under s34 SPL, except in s14, reference made in addition to “purported discharge” of functions and s15 provides indemnity by the Commission to its members

9. Remuneration

ACA employees to be remunerated at level to allow employment of sufficient number of qualified staff

Remuneration of “staff” is dealt with by s7 SPL Law. s7(1) speaks to “allowances” of Commission members – set by Governor. S7(2) speaks to the provision by Government of “adequate staff” for the prompt discharge or duties. Currently, Commissions Secretariat comprises a Manager; 2 assistants and 1 executive secretarial post holder. The Secretariat services 5 Commissions. The Commission has no direct involvement with budget. S7(3) expenses incurred by Commission, members and staff are to paid from the revenue of the CI.

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S19 SPL allows the Commission to appoint an “investigating officer” to conduct an inquiry into alleged/suspected breaches of the Law. The issue of funding/budgeting will become more critical for the Commission in the event of an investigation when the Law comes into effect. ACL – s10 Schedule – remuneration of Commission to be paid from revenue of CI. Sections 3A and 3B of the ACL allow the Governor to employ staff and to approve secondment of public officers (including investigators) to ACC. Section 4 - the ACC’s manager, with the approval of the ACC has the power to employ experts/consultants at remuneration to be approved by Governor and paid from revenue of CI.

10. Authority over HR ACAs to have power to recruit and dismiss staff according to clear and transparent procedures

Commissions Secretariat comprises Government employees who are subject to Public Service Management Law and Personnel Regulations. Other than set out above, the CSPL has no other power/control over staff. No specific procedures set out under Law. 11. Adequate and Reliable Resources ACAs to have sufficient financial resources to carry out tasks, taking into account country’s budgetary resources, population size and land area. To be entitled to timely, planned, reliable and adequate resources for the gradual capacity development and improvement of the ACA’s operations and fulfillment of mandates. Save for the provision of s7 SPL Law there are no other provisions dealing with resources for the SPL Commission. Currently, budget exists for all Commissions which rely on the resources of the Secretariat. Budget cycle is now 2 years.

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[Self-assessment questions-?]

12. Financial Autonomy ACAs to receive budgetary allocation over which ACAs have full management and control without prejudice to appropriate accounting standards and accounting requirements.

Currently, the Manager Commissions Secretariat handles budgetary matters. Commissions Secretariat is required to comply with national accounting and audit requirements (and international?)

13. Internal Accountability ACAs to develop and establish clear rules and standard operating procedures, including monitoring and disciplinary mechanisms, to minimize misconduct and abuse of power by ACAs

No specific rules and standard operating procedures established by Commission to self-regulate itself. s16(2) SPL Law – prosecution under this Law can only be instituted with written consent of DPP.

S21SPL Law – Person in public life must be given reasonable time and opportunity to make representations in person or by attorney prior to Commission concluding that the person has breached Law. S22 SPL – where Commission finds breach of Law or commission of an offence, to refer the matter forthwith to RCIPS and DPP.

ACL – s17 and s 18 establish procedure for disclosure of members’ interests and s19 allows the ACC to regulate its own procedures.

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14. External Accountability ACAs to strictly adhere to rule of law and be accountable to mechanisms established to prevent abuse of power s18- 25 SPL deal with Powers of Investigation. Commission has power to require production of “books, records, accounts, reports, data, stored electronically or otherwise or any other documents relating to the functions of any public or private body”; to require persons in public life to answer questions; to verify declarations; cause witnesses to be summoned and examined on oath, etc.

As indicated above, however, in cases of breach/commission of an offence, matters are referred to RCIPS and the DPP with “certified copy of declaration in question and a report” of Commissions’ findings. ACC – has powers under section 4 ACL to, inter alia, detect and investigate corruption and other offences. It also has powers of search and seizure. The office of the DPP prosecutes. The Governor has oversight of the ACC.

15. Public Reporting ACCs to formally report to Public at least once per Annum

s117(9)(g) – the CSPL is required to report twice annually (at least). s 5((1)(g) SPL Law –reflects this requirement and s8(1) speaks to the manner in which reporting shall take place and be deemed to be in the public domain. S9 ACL – the ACC is required to report to the Governor once annually; however, s8 ACL restricts the provision of information. S53 ACL – requires the production of an annual Report within each month of each financial year by the AG and the Deputy Governor on the enforcement of the ACL which is to be tabled before the LA.

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16. Public Communication and Engagement ACAs to communicate and engage with public regularly to ensure public confidence in its independence, fairness and effectiveness Due to the delay in commencement in the SPL L, the Commission has not been as actively engaged with the public as desired for optimum effectiveness. The Commission has, however, over the past year, been actively involved in introducing the UNODC’s Education for Justice Programme E4J; to universities, primary and secondary schools. The Commission has also participated over the past year in a training workshop for Board Members and members of statutory authorities.

The SPL Commission has a website which is frequently updated and which contains minutes of all Commission meetings. The Chairman for the Commission also appeared before the Public Accounts Committee to respond to questions regarding the findings of the Auditor General in her Report released in January 2019 titled “Fighting Corruption in the Cayman Islands”.


Saint Lucia - Jakarta Principles Analysis

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May 2019


Office of Integrity Commission SAINT LUCIA

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INTRODUCTION Members of the Integrity Commission have perused the draft Jakarta Principles and members conclude and agree that for Saint Lucia to properly implement the sixteen principles would indeed be a challenge, implementation being dependent on adequate and reliable resources. Principle 11, the penultimate principle suggests that Anti-Corruption Agencies (ACAs) shall have sufficient financial resources to carry out their tasks, taking into account the country’s budgetary resources, population size and land area. While Article 6 of the United Nations Convention Against Corruption (UNCAC) requires that ACAs should have the necessary material resources necessary to carry out their functions, article 36 suggests that the relevant ACA should have the appropriate …resources to carry out their tasks.” It goes without saying THAT without financial capacity ACA is unable to carry out the tasks effectively and efficiently. Saint Lucia is an independent island nation celebrating this year, 40 years of independence. It is 238 square miles and HAS a population of 150,000+/-. Its main source of income is from agriculture and tourism. It has no other natural resource such as minerals, oil etc. ITS Gross Domestic Product (GDP) (purchasing power) – USD$9547.30. For the island nation the latest corruption index as of May 2019 is 55 – Corruption index is based on how corrupt the public sector is perceived to be. A country’s score indicates the perceived level of public sector corruption on a scale of 0(Highly corrupt) to 100 (very clean). Saint Lucia’s Corruption index between the period, 2010-2014 was 71, its highest on record. Having regard to the above information, one can clearly see the need to improve and to put more measures in place to reverse the index score towards 100. Most of the measures needed will require financial as well as adequate human resources.

Office of Integrity Commission, Saint Lucia

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ANALYSIS OF JAKARTA PRINCIPLES: A COMPARISON WITH SAINT LUCIA LEGISLATION An assessment of the Jakarta principles as it relates to Saint Lucia is as follows: PRINCIPLE 1 – MANDATE ACAs shall have clear mandates to tackle corruption through prevention, education, awareness raising, investigation and prosecution either through one or multiple coordinated agencies. Saint Lucia has more than one body with a clear mandate for tackling corruption namely: The Office of the Integrity Commission: - the office is established by the Constitution to ensure anti-corruption in persons holding public office with powers to verify, investigate and prosecute pursuant to the filing of declarations of such persons. The Integrity in public Life Act Chapter 1.19 of The Revised Edition of The Laws of Saint Lucia (hereinafter referred to as The Act) regulates the procedure by which the members and the office operate. The Office of the Ombudsman: - established by the constitution to protect its citizens from abuse of administrative power. The Financial Regulatory Services Authority (FSRA) established by legislation: THE Financial Services Regulatory Authority Act Chapter of the Revised Edition of the Laws of Saint Lucia supervises, licenses and regulates the financial sector by ensuring best practices of all financial institutions including insurance companies. Financial Intelligence Authority WAS established by the Financial Intelligence Authority Act Chapter 12.23 of The Revised Edition of the Laws of Saint Lucia and continues its operations under the Money Laundering (Prevention) Act Chapter 12.20 and Proceeds of Crime Act Chapter 3.05 and Mutual Assistance in Criminal Matters Act Chapter 3.03. It is responsible for receiving and analysing suspicious transactions and investigation of money laundering and other serious financial crimes and the dissemination of information to THE Police and Director of Public Prosecution (DPP), Comptrollers of Inland Revenue Department and Customs & Excise Department. This authority advises, assists and educates financial institutions and other businesses in their obligation to detect and report suspicious activities in their

Office of Integrity Commission, Saint Lucia

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operations, prevent and deter money laundering, financing of terrorism and other related crimes. The Department of Customs & Excise, Management & Control Act is to certify the compliance of goods into and out of the country are lawful and comply with the laws of the country failing which, there is the power to seize, search, investigate and prosecute. Each of these bodies has most of these core mandates and all bodies have at one time or other embarked on education and awareness programmes. Each of these bodies has limited independence to carry out ITS function; however their independence is limited by financial constraints. The ability to properly investigate relies on the assistance of the police force and prosecution is through the office of the DPP in all cases. A single agency approach may be a better financially viable approach than having numerous agencies with a similar agenda. However, with other agencies in place to assist with investigation it may be more prudent to have in place an independent prosecuting agency which may assist in effectively curbing corruption. PRINCIPLE 2 - COLLABORATION ACAs shall not operate in isolation, they shall foster good working relations with state agencies, civil society, the private sector and other stake holders, including international cooperation. The Office of the Integrity Commission at present collaborates with the office of the DPP, Public Service Commission and the Police to assist with prosecution and investigation where there is good reason to do so. There is no obligation to partner with other State Agencies. It is the recommendation of this Commission that the legislation be amended to include such cooperation with FIA, FSRA Customs, Inland Revenue and international agencies to facilitate better research and investigative means for effective prosecution.

Office of Integrity Commission, Saint Lucia

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The office of the FIA however fosters good working relations with state agencies such as the FSRA, Police and Customs as well as private entities in particular financial institutions and external agencies. PRINCIPLE 3 - PERMANENCE ACAs shall in accordance with the basic legal principles of their countries, be established by proper stable legal framework such as the Constitution or special law to ensure continuity of the ACA. The office of the Integrity Commission: Section 118 of the Constitution Act and the Parliamentary Commissioner /Ombudsman: Section 110 of the Constitution Act are enshrined in our Constitution, hence there is no concern as it relates to continuity. However, the Integrity in Public Life Act regulates its powers and procedure of the Office of the Integrity Commission. The Act therefore if used, limits the powers of the ACA and in its present form needs amendments to give it the force necessary to be more effective in both investigating and prosecuting. PRINCIPLE 4 - APPOINTMENT ACAs heads shall be appointed through a process that ensures his or her political stance, impartiality, neutrality, integrity and competence. In Saint Lucia the Constitution expressly states that in the performance of its function, the Commission is not subject to the control or direction of any person or authority which suggests Its neutrality and apolitical nature: Section 8 For this reason, the term of the Office must not end with the election of a new government no matter the political party; however, THERE appears to be the trend suggesting some political influence. With respect to impartiality and neutrality: There is some form of consultation procedure rather than a vetting in the manner suggested by the Principles. The ACA head’s and the members’ are appointed by means of cross party consultation rather than vetting. Office of Integrity Commission, Saint Lucia

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With respect to integrity over the years’ moral standing and integrity appear to have been the main ethos above education, experience and qualifications thus the Chairperson of the Office of the Integrity Commission has been a man of ‘religion’. With respect to competence the law simply requires that one of the members be a lawyer and a chartered or certified accountant and that the member not a senator or member of the House of Assembly or at any time during the 3 years prior to his or her appointment, a public servant: Section 3. PRINCIPLE 5 - CONTINUITY In the event of suspension, dismissal, resignation, retirement or end of tenure, all powers of the ACA head shall be delegated by law to an appropriate official in the ACA within a reasonable period of time until the appointment of the new ACA head. The Act is silent on continuity with respect to the resignation of the Head or any member in that regard. However, the Act Section 3(1) states that the Office shall consist of a Chairperson and not less than 2 or more than 4 other members, in practice, there is a Deputy Chairperson appointed by members who would sit for the Chairperson in his/her absence until another is appointed. As long as the Office consists of a Chair and at least two members, the work is unhampered. PRINCIPLE 6 - REMOVAL ACA heads shall have security of tenure and shall be removed only through a legally established procedure equivalent to the procedure for the removal of a key independent authority specially protected by law (such as the Chief Justice). The Chair of the Office of the Integrity Commission receives a stipend from the consolidated fund and is appointed for a term of three years. The Office does not have its own budget nor does it have the responsibility for its own budget and finance. There is no security of tenure and the Chairperson and members receive a stipend for attending meetings of the Commission save that the Chairperson receives a ‘retainer’. Office of Integrity Commission, Saint Lucia

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Removal such as resignation, revocation or death is done in accordance with a procedure Section 4, 5, 6 of The Act. There is no time limit maximum or otherwise for the post of the Chairperson to be left vacant. There are no Regulations in place governing the working, procedure or discipline of head/members of the Office or the effective implementation of the Integrity in Public Life Act since the legislation was enacted in 1998. PRINCIPLE 7 – ETHICAL CONDUCT ACAs shall adopt codes of conduct requiring the highest standards of ethical conduct from their staff and a strong compliance regime. There is no written Code of Conduct at present. There are no Regulations in place with respect to the code of conduct or practice and procedure of the Staff or members of the Commission. However, Staff are to adhere to the principles of confidentiality and secrecy and are to take such oaths upon appointment to the Office. PRINCIPLE 8 - IMMUNITY ACA heads and employees shall have immunity from civil and criminal proceedings for acts committed within the performance of their mandate. ACA heads and employees shall be protected from malicious civil and criminal proceedings. Section 43 of the Act gives immunity to the Commission and Staff and states as follows: Subject to Section 10 no action shall lie against the commission, its staff or any person acting under the direction of the Commission, for anything done or omitted to be done in good faith and its administration or discharge of any functions, duties or powers under this Act. PRINCIPLE 9 - REMUNERATION ACA employees shall be remunerated at a level that ALLOWS for the employment of a sufficient number of qualified staff.

Office of Integrity Commission, Saint Lucia

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In Saint Lucia the Act at Section 38 addresses staff of Commission as follows: (1) The Commission shall be provided with a staff adequate for the prompt and efficient discharge of its function under the Act. (2) The Staff of the Commission shall be public officers appointed in accordance with Section 86 of the constitution. The staff consists of two persons, A Secretary and a Research Assistant. There are no legal officers, investigators, accountants or persons needed to allow the commission to perform its work effectively and efficiently. The remuneration of the staff is dictated by the Public Service Commission PSC. At present the Secretary runs the Office rather efficiently with her limited resources, however she is not paid for her qualifications and the type and quality of work that she performs. She is very knowledgeable not just about the workings of the Public Service but more importantly the work of the Office of the Commission. There are recommendations for adequate staff: That the Commission have control of its own budget and be accountable to the Director of audit. That the Commission be consulted with respect to the appointment of Staff. That the Commission have adequate staffing to include an administrative head, legal officer, specialist investigators, forensic accountant and other personnel to assist the Commission in the effective discharge of its function and to regain public trust and to show that corruption is effectively tackled. PRINCIPLE 10 - AUTHORITY OVER HUMAN RESOURCES ACAs shall have the power to recruit and dismiss their own staff according to internal clear and transparent procedures.

Office of Integrity Commission, Saint Lucia

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As stated in the discussion above as it relates to Principle 9, the Staff is appointed by the Public Service Commission (PSC) and the Commission has no control whatsoever. All appointments and dismissals are through the Office of the PSC. The laws for the disciplining of staff are general and not specific to the Office and the work of the Commission. PRINCIPLE 11 – ADEQUATE AND RELIABLE RESOURCES ACAs shall have sufficient financial resources to carry out their tasks, taking into account the country’s budgetary resources, size, population and land area. ACAs shall be entitled to timely, planned reliable and adequate resources for the gradual capacity development and improvement of the ACA’s operations and fulfilment of the ACA’s mandate. The Commission does not receive its funding early enough and has no idea what its funding is and gets whatever funding that is allocated by the office of the Prime Minister through the Cabinet Secretary. Recently it was pointed out that the Minister of Justice is the person with the responsibility to give effect to the implementation of the Act. Thus the Minister was invited to a meeting with the Commission and it is hoped that the Minister will ensure recommendations will be realised. Therefore, there will be gradual improvement of the Office and tackling corruption will be more efficient and effective. PRINCIPLE 12 - FINANCIAL AUTONOMY ACAs shall receive a budgetary allocation over which ACAs have full management and control without prejudice to the appropriate accounting standards and auditing requirements. As discussed previously, the Commission has no control over its budget and therefore does not have operational flexibility as envisaged by the principle. This coupled with the fact that the Commission does not have the Staff for investigating and is dependent on the police and without proper investigation procedures, there can be no prosecution. These are two areas where the work of the Commission is severely inadequate or non-existent.

Office of Integrity Commission, Saint Lucia

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PRINCIPLE 13 - INTERNAL ACCOUNTABILITY ACAs shall develop and establish clear rules and standard operating procedures, including monitoring and disciplinary mechanisms, to minimize any misconduct and abuse of power by ACAs. As stated earlier in Principle 7 and elsewhere there is no regulation in place, so compliance with rules and monitoring of staff IS not in place. The Staff Code of Conduct is regulated by the Public Service Staff Orders which speaks to disciplinary matters. PRINICPLE 14 - EXTERNAL ACCOUNTABILITY ACAs shall strictly adhere to the rule of law and be accountable to mechanisms established to prevent any abuse of power. There is no oversight body or cross party parliamentary committee or oversight mechanism in place for addressing complaints of misconduct and/or abuse of power by ACAs. PRINCIPLE 15 - PUBLIC REPORTING ACAs shall formally report at least annually on their activities to the public. Section 37 of the Act states: (1) Subject to subsection (3) the Commission shall as soon as possible but not later than 2 months after the end of each financial year, make a report to Parliament of its activities in the preceding year and the report shall be tabled in the house of Assembly and the Senate not later than 3 months after receiving the report. (2) The report under subsection (1) shall not disclose the particulars of any Declaration filed with the Commission. (3) The Commission shall make its first report to Parliament not later than one month after the end of its first year of operation and the report shall be tabled within 3 months of its submission to Parliament. A tabling of the report at Parliament suggests that the report becomes public knowledge. MOST Parliamentary proceedings are televised. Office of Integrity Commission, Saint Lucia

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PRINCIPLE 16 - PUBLIC COMMUNICATION AND ENGAGEMENT ACAs shall communicate and engage with the public regularly in order to ensure public confidence in its independence, fairness and effectiveness. THE dissemination of Handbooks (revised 2018) about the office of the Integrity Commission and a campaign of awareness in schools and tertiary institutions on THE island will assist in ensuring better public awareness and support in the future. It is recommended that a public survey, if finances allow, should be undertaken in the later part of this year to assess the public’s views in order to identify critical areas requiring preventative and investigative attention as was done by participating countries Ukraine and Armenia. It is hoped that with new level of public awareness persons especially the youth, and other persons with information will come forward and assist the Commission with its work. Communication and public engagement ARE key in improving the operations of the Commission. CONCLUSION We end by stating that the Jakarta principles and this self-assessment has assisted in bringing to the forefront our inadequacies in tackling corruption. These inadequacies appear to be the cry of Commissions prior to this current one. We are hoping that in ensuring that, the Minister of Justice who is now engaged in discussions with this commission, that the funds will be allocated FOR proper and effective work in tackling corruption of persons in the public arena, but more importantly that the Integrity in Public Life Act will be amended to give ‘teeth’ to the work of the Commission as we continue our journey together as a Sovereign nation. We understand that the world is now a global community in the age of instantaneous communication. Small nation states like ours are in need and compete for assistance from friendly governments as well as non-governmental institutions (ngos) and in order to ensure

Office of Integrity Commission, Saint Lucia

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this invaluable assistance, our integrity is the most valuable tool. To this end we are committed to improving our methods of preventing corruption.

we would like to thank you for giving us this opportunity for self-assessment and for offering recommendations which indeed will ensure positive steps in our journey together.

Office of Integrity Commission Hewannorra House Trou Garnier Pointe Seraphine Castries, Saint Lucia

Office of Integrity Commission, Saint Lucia

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Annual General Meeting Minutes

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COMMONWEALTH CARIBBEAN ASSOCIATION OF INTEGRITY COMMISSIONS & ANTI-CORRUPTION BODIES ANNUAL GENERAL MEETING – 7 JUNE 2019 GRAND CAYMAN MARRIOTT BEACH RESORT, CAYMAN ISLANDS MINUTES PRESENT: Mr. Dirk Harrison, Chairman Mrs. Rosie Whittaker-Myles, Vice-Chairman Mr. Cleophas Regobert, Treasurer Mr. Justice (Ret’d.) Melville Baird, Country Representative Ms. Helen Ambo, Country Representative Dr. Roger Koranteng Mr. Neil Coates Mr. Radford Hill Mr. Stephenson Hyacinth Mr. Robert Robinson Mr. Tafawa Pierre Mr. Kumar Doraisami Mrs. Rosemary Noble Colonel Daniel Pryce Ms. Jean Morille Mr. Greg Christie Canon Mark Kendall Ms. Jasmine Pascal

Jamaica Cayman Islands St. Lucia Trinidad & Tobago Dominica Commonwealth Secretariat Antigua & Barbuda Antigua & Barbuda Dominica Grenada Grenada Guyana Guyana Jamaica St. Lucia Turks & Caicos Turks & Caicos Trinidad & Tobago

APOLOGIES: Ms. Deshawn Arzu Torres, Country Representative Ms. Joy Powell, Secretary Lady Anande Trotman-Joseph Mr. Eugene Otuonye, QC

Belize Jamaica Grenada, Past Chair Immediate Past Chair

1. Call to Order The meeting was called to order at 9:45 am. Representatives (Mr. Franklyn Williams and Ms. Deirdre Clarke-Maycock) from the Bahamas indicated that having attended the Conference for the first time and therefore not being formal Page | 1

PAGE | 61b

members of the Association expressed their gratitude for the invitation and indicated that having seen the value of being a part of this Association, they would make the case to their Government upon their return home to formally become members. That said, they indicated that they would not remain in attendance for the duration of the meeting. The Chairman informed the Bahamas group that they were welcome to remain at the meeting on observer status. 2. Prayer Canon Mark Kendall led the Members in prayer earlier in the morning and this prayer was extended to cover the meeting. 3. Chairman’s Welcome and Opening Remarks The Chairman formally welcomed Members to the 2019 Annual General Meeting of the CCAICACB. He extended his thanks to the Cayman Islands Government, specifically the team headed by the Chairman of the Commission for Standards in Public Life, the Commissions Secretariat, the Commonwealth Secretariat andDr. Roger Koranteng, along with other agencies which supported the 2019 Conference such as the International Narcotics and Law Enforcement Office (US Embassy, Kingston) and, members for their attendance and participation. 4. Consideration of Reports a. Chairman’s Report The Chairman noted the great strides that have been made since the inception of the CCAICACB at the Grenada conference in 2015. Since the Immediate Past Chair left his post last year, the current Chairman has had various engagements. This included attending a conference in 2018 in Colombo, Sri Lanka where the draft Commentary on the Jakarta Principles was obtained. This document was shared with the Executive Committee Members and was reviewed for the Association by Justice Baird. Though this document is not yet public, it is being mentioned due to its great utility for anti-corruption work; for that reason, we extended an invitation to the UNODC to attend the Conference and speak on this document for the benefit of all members and participants. The Chairman stated that the Association members will now have benchmarks from the Commonwealth Secretariat and from the Jakarta Principles and urged members to use these documents to guide their respective bodies. The Chairman notes that the Integrity Commission of Grenada is leading the way amongst the Commonwealth Caribbean integrity institutions in conducting training exercises at their Centre of Excellence. He attended one such exercise in Grenada to mark International Anti-Corruption Day (9 Dec 2018). Additionally, he was invited in March 2019 by the Chairman of the Grenada Integrity Commission and provided the requested assistance in training conducted there. The Deputy Chairman for Grenada’s Integrity Commission, Mr. Robinson, was asked to convey the Association’s gratitude to the

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Grenada’s Chairman, Lady Anande Trotman-Joseph, and to request on behalf of the Association that invitations to training opportunities continue to be extended. The Chairman noted that the Chairman for Guyana’s Integrity Commission had also reached out to him in March for assistance and he shared with him a template used in investigations. For the first time in the history of the Association a Treasurer’s Report has been produced. The production of this Report shows the advancement of the CCAICACB. The Chairman gave an overview of those administrative procedures which have taken place in order to formalise the registration of the Association and open a bank account in Grenada He expressed thanks to Grenada’s Integrity Commission and to Ms. Metard, Q.C. who drafted the By-Laws for the Association and assisted in seeing through the process and stated that he now has hard copies of the By Laws for signatures once the resolution to ratify the documents has been passed. He noted the continued reduction of financial support by the Commonwealth Secretariat. The Executive agreed to work during the year to increase membership in the Association and this has been successful as additional countries have become aware of the Association and this year 5 representatives of Bahamas were in attendance. Other countries such as St. Kitts have shown an interest in attending the Conference but due to financial restraints they were unable to attend. The thwarting of the work of various commissions has been noted as a trend (for example, the reduction of membership in Dominica from 7 persons to 3), and commissions must remain vigilant and supportive of one another in their common goals. The Chairman welcomed and thanked Colonel Pryce of Jamaica as a new member, and Stephenson Hyacinth of Dominica as newly appointed Chairman of Dominica Integrity Commission. Condolences were extended to Dominica’s Commission on the passing of their past Commissioner. He further thanked Helen Ambo of Dominica for her persistent and stellar work whilst awaiting membership appointments. Radford Hill of Antigua & Barbuda was welcomed back after a period of absence. Missing today is Deshawn Arzu Torres of Belize, who had attended the first 3 days of the conference and the Chairman thanked Belize for their input. The Vice-Chair of CCAICACB added for the record that included in the activities of the Association over the past year was the participation of the Chairman and Lady Anande Trotman-Joseph of Grenada in a television interview which was broadcast to 200,000 viewers.

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Following from that the Commonwealth Secretariat representative requested that commissions utilize the media as the Commonwealth Secretariat will compile this information and consolidate it to be re-distributed to member countries and for archival purposes. He recommended that press releases are issued by delegates through their individual bodies upon their return home about this conference through the Conference Communique. This recommendation was reinforced by the delegate from Grenada who suggested that press releases be issued to all newspapers. The recommendation was accepted. The delegate from Turks & Caicos suggested that the Association reaches out to Barbados, St. Vincent, Montserrat and BVI with a view to having them join the Association and securing their attendance at the next Conference. The Chairman agreed that we needed to increase members; however, the cost consideration must also be factored in. b. Treasurer’s Report The Treasurer indicated that as no dues are being collected at the moment there is not a financial statement for review. He further confirmed that the bank account has not yet been opened but expects that the final administrative arrangements will be made within the next few months. The Treasurer indicated that the Executive Committee which is due to be elected during the course of this meeting will have two decisions to make in the immediate future – the development of both a strategic plan (with both short and long-term objectives of the Association) and a budget (for the remainder of 2019 and a budget for 2020). The Treasurer indicated that the objectives to be included in a strategic plan include: i. ensuring the maximum number of members to the Association in order to increase the amount of dues able to be collected; ii. creating and approving monthly and yearly budgets to cover the remainder of 2019 and 2020; iii. appointing a Secretary for note-taking and other administrative matters; iv. agreeing an allocation of monies to be put towards training for both Executive and wider membership; v. setting up a website for the Association; vi. establishing a headquarters for the Association; and vii. considering how the weaning of funding from the Commonwealth Secretariat will affect the work of the Association over the years to come. It is estimated that the 2019 dues will amount to approximately USD$11k to work with for the rest of the year. In 2020 the Treasurer estimates that the Association will need an Page | 4

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additional USD$32k to meet the objectives of the Association though this would not include the costs associated with hosting the Conference. Members can expect to receive invoices from the Treasurer in the next month for the 2019 dues. Payments should be made as expeditiously as possible. Dr. Koranteng suggested that the Executive consider sourcing funding for the Association from other governments or entities. Mention was made of the Ombudsman’s Association which obtains sponsorship from donor bodies. Sponsorship could also come from the EU and from similar institutions. This should be explored once we have a budget in place. Discussions were also held surrounding an increase, over time, of the amount of dues; and whether the Constitution should be amended in regards to increasing dues. The Treasurer ultimately recommended that the Association proceed with issuing invoices (in the next month) for fees in the amount currently contained in the Constitution and the incoming Executive can consider the further financial needs of the Association and how best to meet those needs. It was pointed out that the increase of fees required an amendment to the Association’s Constitution which required notice unless all members in attendance were willing to indicate that they were waiving their right to insist on the application of the Constitutional provision. It was agreed that this matter would be put over to a Special General Meeting to be convened following notice. 5. Matters for Consideration a. The Constitution of the CCAICACB Members were provided with hard copies of the CCAICACB Constitution for their ease of reference during the meeting. The Chairman also outlined the need to give one month’s notice in order to make any changes to the Constitution as provided for in Articles 13 and17. i. Membership Forms and Dues The Chairman requested for members to take back to their home countries the membership forms provided to them and have them completed and returned to the CCAICACB electronically as a matter of urgency. A discussion ensued about whether membership forms with signatures are legally necessary, and whether there should be different requirements for pre-existing members and new members, and individual members versus member organisations. Discussions also ensued as to whether ratification of membership applications/submissions was required. It was proposed that the initial version of the form is used for the time being and this was agreed. It was further agreed that the currency for dues would be formally clarified. Page | 5

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ii. Appointment of Executive Committee Members A discussion took place to clarify whether persons appointed to the Executive were appointed in their personal capacity or as a representative of their Country i.e. if a Member from Jamaica is appointed Chairman but can no longer serve in that capacity, should a new election take place to replace him/her or should a new Member from the same country (i.e. Jamaica) be appointed. It was agreed that persons appointed to the positions of Chairman, Vice Chairman, Treasurer, and Secretary should be appointed as individuals and therefore new elections should take place should persons no longer be able to serve in any of those capacities. Discussions also ensued as to whether Association Members should be appointed to these positions from the same country. In regards to those appointed as Country Representatives, it was agreed that an individual from the same country could replace that individual (as opposed to new elections being held). A question was asked by a delegate as to whether the four individual appointments, Chairman, Deputy Chairman, Secretary and Treasurer could all come from the same country and it was agreed that this, and other matters raised would need to be addressed fully at a Special General Meeting. iii. Resignation/Removal of Officers of the Executive Committee This matter was not discussed and was adjourned to a Special General Meeting. iv. Formation of Non-Profit/Charitable Company – Opinion The Chairman indicated that in order to finalise the administrative arrangements to open the Association’s bank account, Members needed to agree and ratify a resolution to form a non-profit/charitable company. It is noted that the relevant forms/documents have been drafted in accordance with the legislation of Grenada and signed by the Chairman of the Grenada Integrity Commission; as it had been agreed by the Executive to open the bank account in Grenada. Members will be provided with copies of the Articles of Incorporation filed on 29 May, 2019 however the Chairman read into the record Article 5 which mirrors the Objectives set out in Article 4 of the Constitution

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It is further noted that a number of documents have been appended to the Articles of Incorporation including by-laws, comprising the entirety of the Constitution of the Association. These documents will also be circulated to all Members. The Chairman made reference to the checks and balance put in place regarding signatures on the Association’s account to be set up with FCIB. The agreement and ratification of the Articles of Incorporation were moved by the Chairman and seconded by the Treasurer. v. Appointment of Auditor The appointment of the Auditor will be set as an agenda item at the upcoming Special General Meeting. 6. Model Legislation The Model Legislation has been finalised and will be provided to all Members for review. This should be uploaded to members’ websites. 7. Communique arising out of the 5th Annual Conference Members reviewed the draft Communique and agreed minor amendments. The adoption of the Communique (with amendments) was proposed by Canon Mark Kendall and Mr. Radford Hill seconded the motion. 8. Election of Members to the Executive Committee Chairman recognized the Proxy held by Ms. Jean Morille (St. Lucia) for Belize. Elections were held for newly appointed executive committee: For the post of Treasurer, Canon Mark Kendall (TCI) proposed Cleophas Regobert (St. Lucia). It was seconded by Rosie Whittaker-Myles (Cayman Islands). For the post of Chairman, Cleophas Regobert (St. Lucia) proposed Dirk Harrison (Jamaica). It was seconded by Canon Mark Kendall (TCI). For the post of Vice-Chairperson, Rosie Whittaker-Myles (Cayman Islands) proposed Justice Melville Baird (Trinidad & Tobago). It was seconded by Colonel Daniel Pryce. For the post of Secretary, Greg Christie (TCI) proposed Helen Ambo (Dominica). It was seconded by Mr. Justice (Ret’d) Melville Baird. For country representation, Helen Ambo (Dominica) proposed Canon Mark Kendall (TCI). It was seconded by Jean Morille (St. Lucia). Page | 7

PAGE | 61h

For country representation, Robert Robinson (Grenada) proposed Lady Anande Trotman-Joseph (Grenada). It was seconded by Cleophas Regobert (St. Lucia). For country representation, Rosie Whittaker-Myles (Cayman Islands) proposed Kumar Doraisami (Guyana). It was seconded by Helen Ambo (Dominica). Post


Association Member Country


Mr. Dirk Harrison



Mr. Justice (Ret’d) Melville Baird

Trinidad & Tobago


Ms. Helen Ambo



Mr. Cleophas Regobert

St. Lucia


Canon Mark Kendall

Turks & Caicos Islands


Lady Anande Trotman-Joseph



Mr. Kumar Doraisami


Immediate Past Chairperson

Mr. Eugene Otuonye, QC

Turks & Caicos Islands



the Dr. Roger Koranteng


Commonwealth Secretariat 9. Hosting of 2020 Conference Members accepted the tentative offer of St. Lucia to host the Sixth Annual Regional Conference in 2020. 10. Any Other Business The Chairman gave notice of intention pursuant to Article 17 of the Constitution to hold a Special General Meeting in respect of making amendments the Constitution. The following items were identified for review at that meeting: 1. Article 7(3) 2. Composition of Executive - to ensure broad representation of members 3. Whether Chairman and Secretary to come from same country 4. Effect of removal from office in territory of postholder who holds individual office on Executive 5. Past Chairman’s role as part of Executive and the impact of resignation after serving 1 year of the 2 year term in office 6. Annual Membership Fees 7. Resignation and Removal of Officers

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Mr. Tafawa Pierre of Grenada thanked the Chairman of the CCAICACB for his professionalism and leadership. 11. Blessing Canon Mark Kendall blessed the delegates and wished them safe journeys home. 12. Adjournment The meeting was adjourned at 2:20pm.

_______________________________ Dirk Harrison Chairman Commonwealth Caribbean Association of Integrity Commissions and Anti-Corruption Bodies

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CCAICACB 2019 Conference Communique

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PAGE | 62a

COMMONWEALTH CARIBBEAN ASSOCIATION OF INTEGRITY COMMISSIONS & ANTI-CORRUPTION BODIES CONFERENCE COMMUNIQUE We, the Commonwealth Caribbean Association of Integrity Commissions and Anti-Corruption Bodies (“the Association”), meeting at our Fifth Annual Regional Conference convened under the auspices of the Commonwealth Secretariat and hosted by the Cayman Islands Commission for Standards in Public Life from 3 – 7 June 2019, at the Grand Cayman Marriott Beach Resort, under the theme: "Transforming Words into Action: Revitalising the Fight Against Corruption”;

NOTING with deep gratitude the invaluable support and warm hospitality provided by the Commission for Standards in Public Life, the Cayman Islands Government and the people of the Cayman Islands;

RECOGNISING with much appreciation the presence of the Rt. Honourable Patricia Scotland, Q.C., Commonwealth Secretary-General, her participation and delivery of the key note address wherein she reinforced the Commonwealth Secretariat’s collective determination to eradicate corruption through the development of research, capacity-building and networking;

THANKING His Excellency the Governor Martyn Roper, OBE for declaring the conference open whilst affirming the commitment of the Cayman Islands Government to good governance by the continued development and implementation of relevant policies in the civil service and the strengthening of its integrity bodies;

APPLAUDING the stellar work of Dr Roger Koranteng, Interim Adviser and Head, Public Sector Governance, Commonwealth Secretariat, resulting in his winning the 2018 Sheik Tamim Bin Hamad Al Thani International Anti-Corruption Excellence Award;

COMMENDING and thanking the Commonwealth Secretariat for its leadership, guidance, and financial assistance over the past five years and anticipating this continued support;

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REAFFIRMING the need to continue to use this regional conference as a platform for the sharing of information, best practices and strategies for combating corruption and the promotion of good governance;

EXPRESSING gratitude to the outgoing 2017/19 Executive Committee under the leadership initially of Mr. Eugene Otuonye, QC followed by Mr. Dirk Harrison;

HAVING extensively considered the theme of the conference and its programme content through the full exchange of the views of all delegates, facilitators and participants;

AGREE and ADOPT the following resolutions as actions to be taken by the Association:

a. continue to reiterate the need for regional integrity commissions and anti-corruption bodies to maintain their

independence, impartiality and professionalism, to further enhance their

effectiveness; b. make relevant recommendations to our Governments with a view to modernising, enacting and bringing into operation relevant legislation to continuously combat corruption; c. continue our calls on Member Governments to provide adequate financial, technical, and other resources (human or otherwise) to the Integrity Commissions and Anti-Corruption Bodies and greater autonomy in the use of those resources; d. encourage Member Governments to promote, encourage and support the work of each Member Country and the Association as a whole; e. invite CARICOM and other internationally recognised organisations to include on their agenda discussions related to anti-corruption efforts, integrity building, and the work of the Member Countries; f.

call upon Commonwealth Heads of Government Meeting (CHOGM) to include the issue of AntiCorruption as a side event at its meeting to be held in Rwanda in 2020 as well as part of its agenda and communique of that meeting;

g. network with a wide range of stakeholders in the fight against corruption to strengthen and establish relationships and to promote collaboration and capacity building locally, regionally and internationally; h. engage Directors of Public Prosecutions to establish and/or enhance lines of communication and

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working relationships to strengthen anti-corruption work in the region; i.

organise, attend, and/or participate in conferences, collaborative opportunities, training and capacity-building programmes, and similar educational events;


assist with the creation of standard written operating procedures for the investigation of acts of corruption;

k. develop, implement, review and update codes of conduct, to reduce conflicts of interest and promote an ethical culture within the Association and our organisations; l.

adopt effective and relevant organisational risk management strategies and information gathering techniques;

m. harness and put to maximum and innovative use, all resources available whilst continually seeking to engage the Commonwealth Secretariat and other bodies for the provision of additional resources and opportunities for capacity building; n. seek the technical assistance and support of the Commonwealth Secretariat in undertaking research to quantify the real cost of corruption; o. explore the possibility of securing financial and budgetary support for the Association from international development partners, especially those who have a vested interest in anticorruption; p. intensify public education opportunities through engagement, surveys, data gathering, presentations, publications, and the media; q. mobilise youth to understand the importance of integrity and ethics and the causes and effects of corruption on our society and their lives directly through the use of tools such as the UNODC’s Education for Justice Programme (E4J); and r.

promote the work of each Member Country through the use of internet platforms such as dedicated websites.

Having due regard to the diverse experiences of Member Country Delegates it was further agreed that we should continue to: a. pursue the development and implementation of regional anti-corruption model legislation in keeping with the requirements of the UNCAC and the constitutional and legislative frameworks of each respective Member Country in order to work towards the achievement of a reduction and eventual eradication of corruption in the Commonwealth Caribbean; b. support each Member Country in its anti-corruption and integrity work within the unique

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context of each Country; and c. encourage each Member Country to evaluate the framework for its respective bodies through the use of the Commonwealth (Secretariat) Anti-Corruption Benchmarks and the Jakarta Principles.

Following the Association Executive Meeting the Association further agreed: a. to accept the tentative offer of St. Lucia to host the Sixth Annual Regional Conference in 2020; b. that the newly elected 2019/20 Executive Committee of the Association shall be: Post


Association Member Country


Mr. Dirk Harrison



Mr. Justice (Ret’d) Melville Baird

Trinidad & Tobago


Ms. Helen Ambo



Mr. Cleophas Regobert

St. Lucia


Canon Mark Kendall

Turks & Caicos Islands


Lady Anande Trotman-Joseph



Mr. Kumar Doraisami


Immediate Past Chairperson

Mr. Eugene Otuonye, QC

Turks & Caicos Islands



the Dr. Roger Koranteng


Commonwealth Secretariat

Dated this 7th day of June 2019 at Grand Cayman.

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Conference Evaluation Results

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Evaluation Results Overall rating of the conference: Excellent


Whether delegates feel they can apply what they learned in the conference to their respective countries:







To Some Extent






Whether the objectives/expectations of the conference were met: Yes




Assessment of the conference logistics and content:

Benchmark countries, as selected by delegates: Grenada


Turks & Caicos


Cayman Islands




Trinidad & Tobago 13%













What is your general assessment of the way logistics were organised? # of responses Excellent 13 • great planning and 5 execution • suitable/ comfortable location • not enough time for the sessions • great team work of CSPL secretariat


• issues with PA system • nutritious food



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Adequate Poor

1 0

What is your assessment of the programme content? What would you like to have seen included in the sessions? Excellent 15 • Practical exercises. • The programme was adequate (no overkill or overemphasis). • Technology options for the automatic of the collection of statutory declarations, processing (recording) of information therein; and the initial analysis of comparative/historic information on previous declarations. • As time goes on more time needs to be afforded delegates to present papers and speak to laws. Sharing of Laws is critical to conferences. • Probably a little more interaction with resource people. • For the country presentation there should be a requirement that each territory provide certain standard statistical data and highlight changes (major) since last conference in relation to. • The content fitted adequately with this year's theme. • The framework by which a dollar value can be placed on the cost of corruption.



• [Should] Include a taste of Cayman history and culture. • At least one practical case and the particular of that investigation.

Adequate Poor Blank

0 0 1

• All delegates should have an exchange criteria at the conference to share their country's Annual Report which will be reflective of the actual work done and areas of sharing or development.

In your opinion were the objectives and expectations of the conference met? Yes 20 No 0 • • • • • • •

Yes! The sessions were very informative. Yes, however we need the entire commonwealth Caribbean represented. Yes, time was however the enemy in discussions. Information sharing is key to the fight against corruption. Yes in general. I believe the business of the association was dealt with. Yes. Very detailed. Overwhelmingly, yes! An excellent forum for learning what other countries are doing and how their legislation is structured • They were largely met. • Yes my expectation were met, however, I think we should consider including in the annual report a comparative data sheet of specific provision in the various legislations and share this information between territories. • I agree that the objectives were met as the networking and country presentations/sharing in fact exceeded my presentations.

Can all the critical areas presented and discussed, giving you a clear understanding of Integrity Commissions and Anti-Corruption Bodies, be applied in your country? Yes 14 • Sessions provided opportunities for critical review and reflection on the practices and

PAGE | 63c

operation of our Integrity in Public Office Commission. • Grateful for where we are relative to the region. Aware of where we need to go. • Need more legislation. • Implementation would only be more effective when all ICs and ACB heads are full time employees • Ideally • However, I was not clear on the definition of an "anti-corruption bodies"; it would be good to have a clear definition because it can be defined both widely and narrowly. • We are in the process of enacting a revised ACA so issues discussed can be applied.

To Some Extent


• Lack of legislative enforcement is [illegible] - need interagency cooperation would be something we expect to be improved. • The sharing of legislations and or written practices and procedures can be shared to assist. • Inter-agency collaboration; review of the legislation to amend it for greater effectiveness; better structure of the IC to operate more efficiently. • We are currently battling with the political will and lack of resources in our territory. This will therefore limit or restrict our efforts to some extent.



What are your take-aways from the Conference? • Critical review of over operation and implement strategies to ensure effectiveness • The means for cooperation when dealing with corruption • The lack of resources seen to be a common issue for all the Integrity Commissions or AntiCorruption Commissions • Greater need to optimise the good will and camaraderie • Need for information sharing. Establishing a website to include information from all member countries. • Modernisation and reform is urgent. Importance of Jakarta Principles. • Information on [illegible] ACA. • The need for the Government to support the Integrity Commission as this could be instrumental in T&T getting a more favourable perception index marking • The importance of Gov't support and greater standardisation of administration across ICs and ACBs - sharing is central • There is some momentum in this area - must continue • Many. I think the variance across the territories in terms of progress on the anti-corruption agenda. And that we need to consider the specific enhancements for our territory where other jurisdictions are further in their fight. • The need for all inter cont. agencies to work together to achieve greater success. • There are possibilities for more intimate information sharing and collaboration. • I have a better idea on how far reaching corruption is in obtaining good, transparent governance. • We can push the commission a step further along the way of more complete fulfilment of its mandate - critique the legislation, before more engaging with stakeholders and do more education activities. • The adoption of Jakarta Principles. • The participatory level is very good and this trend should be continues and expanded. I think that lack territory presentation should be very structured and should provide a specific set of information and data. • The need to join CCAICACB and need to ensure commission is equipped. • The promotion of good governance should be our overarching reach. Public education and awareness should be at the forefront of our fight against corruption. • Do what you can with limited resources networking and coordination and to save on cost and to maximise available resources.

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What is your overall rating of the Conference? Excellent 13 • This has been my first meeting and have learnt a lot. Great experience. • As at question 1 (one shortfall was the time allocated for the various programmes/subjects) • Rating enhanced by presence of commonwealth secretary general. Hers should have been the keynote address - and listed as such. • The information and knowledge share have broadened understanding of how much more needs to be done. • Accommodation was excellent! • Compliments to the organising team and to the ladies who assisted at all the sessions; excellent resource persons



• Conference attempted to cover relevant topics and achieved this very well - particularly the need to put words into action - agencies as well as governments. • Conference was a little loaded in terms of time set for different subject areas.

Adequate Poor What follow-up action(s) or suggestions would you like the Commonwealth Secretariat to do after the Conference? • Development of a generic instrument to access corruption and people in public life. • Encourage members to keep the Secretariat and members of achievements and legislation and important achievements. • Pressure needs to be brought on regional governments to strengthen the ACAs and ICs. • Technical support, ascertain needs and provide. • Capacity building • Countries that have useful modern anti-corruption legislation - links would be welcome • Encourage governments to legislate to allow ACA to function effectively • Provide training to the integrity commission of T&T in corporate governance and public procurement. • Provide training to integrity commission of Trinidad and Tobago. Corporate governance and public procurement. • Appoint rapporteurs to deal directly with Gov’ts (? Illegible) • A comparative table of the state of each territory IC; that is updated and amended in advance of the conference. It should be in a standard format; and I believe that information was provided in each territory report; but its best summarised and should not therefore result in substantially more effort on behalf of participants. • (1) Follow-up between commonwealth secretariat and deputy governor. (2) Assistance/guidance of commonwealth secretariat in identifying a way to quantify cost of corruption. • There should be an opportunity to bring investigative authorities together - Grenada • Making the secretariat more visible to countries in the Caribbean (Bahamas) • Possibly, meet the new IC one on one and help them to discuss/meet with the Executive in the valve of a well-functioning commission to the island • Engage the governments with a view of them adopting/subscribing to the Jakarta Principles • At next conference the topics should not be so comprehensive. Too much topics on one day to provide contact information for all our sister countries/participants so that we can continue to liaise and obtain the necessary support. • Continued financial support to ensure the gains to date are not wasted.

Select one or two countries you would like to benchmark after the Conference? Grenada 8 • To observe their process in assessing persons in public office

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Turks & Caicos


• Compact system



• Merging all ACAs into one organisation, to observe their process in assessing persons in public office

Cayman Islands Trinidad & Tobago

5 4

• Outreach programme, aspects of legislation

Singapore None

1 1

• None in particular - they all seem to have significant deficits

Please give your overall impression of the conference • • • • • • • • • • • • • • •

• •

• • •

Excellent! Great organisation and time management. As at question 1 (one shortfall was the time allocated for the various programmes/subjects) Very good. Excellent, greater incorporation of practical exercises [is needed]. Beneficial. Have a clear perspective of the anti-corruption efforts in the region. Well-organised. Great agenda and variety of facilitators. Well done! Well organised and informative. The conference was well organised. The conference was well organised and delivered! Excellent Excellent networking opportunity. Overall, conference was very well organised. Presentations were excellent and participation was good. Generally the conference was well put together and met the overall objectives. Great content. Knowledgeable presenters. Overall, an excellent production. The growing camaraderie serves to assist and strengthen Commissioners in their role and allows each organisation to be informed by its peers. Take a bow, Cayman. There is clearly a comprehensive understanding of the issues affecting Anti-corruption Agencies and hence the programme was geared at improving the impact of the agencies. The conference was well organised and home the involvement and time allocated for country presentations should be expanded and be made more structured. Allow countries to really discuss the issues and innovation happening in each territory and allow feedback. Expand the presentation time and Q&A. Reduce outside presentations. Well received I am walking away with critical information for implementation in my IC. This conference met its objectives and provided an opportunity for best practice.


Evaluation Form 2019

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PAGE | 64a Commonwealth Secretariat



1. What is your general assessment of the way logistics were organised? □ Excellent

□ Good

□ Adequate

□ Poor



2. What is your assessment of the programme content? □ Excellent (complete, well balanced) □ Adequate (needs major adjustment)

□ Good (some modifications needed) □ Poor (needs re-structuring)

Comments: (what would you like to have seen included in the sessions)

______________________________________________________________________________ ______________________________________________________________________________

3. In your opinion were the objectives and expectations of the Conference met? Comments:___________________________________________________________________


4. Can all the critical areas presented and discussed, giving you a clear understanding of Integrity Commissions and Anti-Corruption Bodies, be applied in your country? □ Yes

□ No

□ To Some Extent



PAGE | 64b Commonwealth Secretariat


5. What are you take-aways from the Conference? Comments:___________________________________________________________________

______________________________________________________________________________ ______________________________________________________________________________

6. What is your overall rating of the Conference? □ Excellent

□ Good

□ Adequate

□ Poor



7. What follow-up action(s) or suggestions would you like the Commonwealth Secretariat to do after the Conference? Comments:___________________________________________________________________

______________________________________________________________________________ ______________________________________________________________________________

8. Select one or two countries you would like to benchmark after the Conference? Comments:___________________________________________________________________

______________________________________________________________________________ ______________________________________________________________________________ 9. Please give your overall impression of the Conference. Comments:___________________________________________________________________

______________________________________________________________________________ ______________________________________________________________________________

Many thanks for taking time to provide your feedback.


Directory of Regional Anti-Corruption Agencies

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PAGE | 65a

Name of Agency/Body

Anti-Corruption Agencies/Financial Intelligence Entities Head of Address Email Agency/Body

Contact Number

Antigua Office of National Drug and Money Laundering Control Policy


Lt Col. Edward H. Croft

Financial Services Regulatory Commission


Ms Brenda Sheppard

Royal Antigua Police Force

Acting Commissioner of Police

Mr Atlee Rodney

Integrity Commission

Chairman of Integrity Commission

Mr Radford Hill


Mr Myles LaRoda

Integrity Commission


Ms Deshawn Arzu Torres

Integrity Commission


Ms Lisbeth Novelo

Royal Cayman Islands Police Service

Commissioner of Police

Mr Derek Byrne

Anti-corruption Commission Cayman


Mr Richard Coles

Camp Blizard P.O. Box W827 St. Georges Antigua Royal Palm Place Friar’s Hill Road St. John’s Antigua Police Headquarters, American Road, St. John’s, Antigua

Long Street St. John’s Antigua

+1 (258) 562-3255/6/7 +1 (268) 460-7390/91

+1 (268) 481-3300

+1 (268) 462- 0125

+1 (268) 562-5515

Bahamas Public Disclosure Office

Belize integritycommissionbze@gmai; Deshawn@mybelizeattorney.c om

Cayman Islands P.O. Box 909 Grand Cayman KY1-1103, Cayman Islands 2nd Floor Artemis House, 67 Fort Street,


+1 (345) 244-2900 +1 (345) 949-4222


+1 (345) 244-3685

PAGE | 65b


Financial Reporting Authority


Mr R. J. Berry

Commission for Standards in Public Life


Mrs Rosie Whittaker-Myles


Integrity Commission of Dominica

Mr Dermot Southwell

Assistant Superintendent of Police

Financial Intelligence Unit

Mr McKelson Ferrol

Commissioner of Police

Major General

Counter Terrorism & Organised Crime Investigation Branch (CTOC) Financial Investigations Division (FID) Integrity Commission

Senior Superintendent of Police

Major Organised Crime & Anti-Corruption Agency (MOCA) National Integrity Action (NIA)

P.O. Box 391, Grand Cayman, KY1-1106, Cayman Islands 133 Elgin Ave., 4th Floor Government Admin. Building, P.O. Box 1054, Grand Cayman KY1-1102, Cayman Islands 2nd Floor Artemis House, 67 Fort Street, P.O. Box 391, Grand Cayman, KY1-1106, Cayman Islands financialreportingauthority@g

+1 (345) 945-6267


+1 (345) 244-3685

Commissions Building 30 Cross Street Roseau Commonwealth of Dominica 47 Field's Lane Roseau Commonwealth of Dominica


+1 (767) 266-3436/3494

+1 (767) 266 3349

Mr Antony Anderson, CD, ADC, JP ACP Fitz Bailey

101-103 Old Hope Road, Kingston 6

Shop 68 Ocean Boulevard, Kingston, Jamaica


+1 (876) 927-4421 +1 (876) 927-4939 +1 (876) 922-7052

Mr Robin Sykes

1 Shalimar Avenue, Kingston 3

+1 (876) 928-5141

16 Oxford Road, Kingston 5; 45-47 Barbados Avenue, Kgn. 5 7th Floor NCB Towers, 2 Oxford Road, Kingston 5

Director General

Hon Mr Justice (Ret'd) Karl Harrison Colonel Desmond Edwards

Executive Director

Professor Trevor Munroe

2 Holborn Road, Kingston 10

+1 (876)926-2288 +1 (876)929-6460 +1 (876)906-584 +1 (876)948-9181 +1 (876)906-6318 +1 (876) 906 4371



Chief Technical Director Chairman

2 jm

PAGE | 65c Office of the Director of Public Prosecutions


Miss Paula Llewellyn, CD, QC

King Street, Kingston;

+1 (876) 922-6321-5

Revenue Protection Division (RPD)

Principal Director/ Commissioner (Acting)

Mr Cranston G. Morgan

1 Shalimar Avenue, Kingston 3

+1 (876) 928-0256 +1 (876) 967-3933 +1 (876) 967-3504

Tax Administration Jamaica (TAJ) Auditor General’s Department

Commissioner General Auditor General

Mr Ainsley Powell

PCJ Building (4th floor), 36 Trafalgar Road, Kingston 10 Auditor General’s Department 40 Knutsford Boulevard Kingston 5 Jamaica W.I.

+1 (876) 922-5905 m

+1 (876) 926-8309

Trinidad and Tobago Police Service

Commissioner of Police

Mr Stephen Williams (Ag. Commissioner)

Corner Sackville and Edward Streets, Port of Spain, Trinidad

Anti-Corruption Investigations Bureau

Senior Superintendent of Police. Director

Mr William Nurse (Ag Senior Superintendent)

No. 3 Independence Square South, Port of Spain, Trinidad and Tobago

+1 (868) 623-8429 +1 (868) 612-0102 +1 (868) 627-6120 +1 (868) 627-0735 +1 (868) 223-2242

Mr David West

+1 (868) 226-4722 +1 (868) 627-4383

Integrity Commission


Mr Justice (Ret’d) Melville Baird


+1 (868) 624-5415 +1 (868) 624-4736

Director of Public Prosecutions

Director of Public Prosecutions

Mr Roger Gaspard, Senior Counsel

+1 (868) 225-4377 +1 (868) 623-7532

Financial Intelligence Unit


Ms Suzanne Francois

Level 24, Tower D, Waterfront Complex, No. 1 Wrightson Road, Port of Spain, Trinidad and Tobago Level 14, Tower D, Waterfront Complex, No 1 Wrightson Road, Port of Spain, Trinidad and Tobago Winsure Building, No. 24-28 Richmond Street, Port of Spain, Trinidad and Tobago Level 25, Tower D, Waterfront Complex, No 1 Wrightson Road, Port of Spain, Trinidad and Tobago

+1 (868) 625-8351

Integrity Commission


Lady Anande Trotman-Joseph

Integrity Commission, Archibald Avenue, St. George's

+1 (473) 439-9212

Ministry of Legal Affairs

Attorney General &

Sir Lawrence A. Joseph

Ministry of Legal Affairs, H.A. Blaize


Mrs Pamela Monroe Ellis

Trinidad & Tobago

Police Complaints Authority



+1 (473) 435-2962

PAGE | 65d

Office of the Director of Public Prosecutions Police Headquarters

Chair of Anti-Money Laundering and Combating Terrorism Financing Commission Director of Public Prosecutions

Mr Christopher Nelson

Commissioner of Police (Ag) Head

Mr Edvin Martin

Accountant General Division, Ministry of Finance Office of the Ombudsman

Accountant General

Ms Quinta Charles


Ms Allison Audain-Miller

Transparency Action Grenada


Ms Dawn De Coteau

Audit Department

Director of Audit (Ag)

Mr Francis Hosten

Procurement Unit Ministry of Finance

Chief Procurement Officer

Mr Terrance Victor

Integrity Commission And Anti-Corruption Bodies Of Guyana


Mr Kumar Doraisami

State Asset Recovery Agency


Dr. Clive Thomas

Financial Intelligence Unit

Superintendent Tafawa Pierre

Street, St. George's

Office of the Director of Public Prosecutions, Church Street, St. George's Police Headquarters, Fort George, St. George's Financial Intelligence Unit, Financial Complex, Carenage, St. George's

christophernelson81@gmail.c om

+1 (473) 435-5566

+1 (473) 440-3499

+1 (473) 435-2374

Accountant General Division, Ministry of Finance, Financial Complex, Carenage, St. George's Office of the Ombudsman, Public Workers Union Building, Tanteen, St. George's Transparency Action Grenada c/o Law Office of Evette John Cherry Hill, St George’s Audit Department, Mt. Wheldale, St. George's Procurement Unit, Ministry of Finance, Financial Complex, Carenage, St. George's

+1 (473) 440-2294

+1 (473) 435-9315

+1 (473) 457-5855

+1 (473) 440-2264

+1 (473) 440-2731

74, Church Road & Fifth Avenue, Subryanville Georgetown Guyana c/o Ministry of the Presidency, Shiv Chanderpaul Drive, Bourda, Georgetown Guyana

integrity_commission@yahoo. com

+1 (592) 227-3576

+1 (592) 227-7017



PAGE | 65e Financial Intelligence Unit


Mr Matthew Langevine

Financial Intelligence Unit, Main & Urqhuart Streets, North Cummingsburg, Georgetown Guyana Camp Road, Eve Leary, Georgetown Office of the Commissioner, Guyana Police Force Headquarters, Eve Leary, Georgetown Guyana

+1 (592) 223-7234

Special Organised Crime Unit

Head of Special Organised Crime Unit

Mr Leslie James - Assistant Commissioner of Police

+1 (592) 225-3084 +1 (592) 225-3079

Guyana Police Force

Commissioner (ag)

Mr David Ramnarine (Assistant Commissioner) y

+1 (592) 226-2487/8


Mr Damien Kelsick Attorney-at-law

Kelsick & Wilson

+1 (869) 465-2440 +1 (869) 465-2645


Pastor Sherwin Griffith


Ms Jean Morille

+1 (758) 452-4093 +1 (758) 468-2187 +1 (758) 484-7008 +1 (758) 451-7479

Permanent Secretary Ministry of Home Affairs, Justice and National Security Financial Services Regulator Authority

Permanent Secretary

Mrs Elizabeth Bailey

+1 (758) 468-3600/15 Fax: +1 (758) 456-0228


Mr John Calixt Leon

+1 (758) 468-2990 +1 (758) 468-2999 Fax: +1 (758) 451-7655

Director of Public Prosecution


Mr Daarsrean Greene

+1 (758) 468-3017 +1 (758) 468-3008 Fax:

Attorney General

Attorney General

Mr Stephen Julien

Hewannorra House Trou Garnier Pointe Seraphine Castries Saint Lucia 1st Floor, Sir Stanislaus James Bldg The Waterfront Castries Saint Lucia 6th Floor Francis Compton Bldg. The Waterfront Castries Saint Lucia Hebah Centre Cnr. Micoud & Bourbon St. Castries Saint Lucia 2nd Floor Francis Compton Bldg. The Waterfront Castries

+1 (758) 468-3200 Fax: +1 (758) 458-1131

Saint Kitts & Nevis St. Kitts-Nevis Integrity Commission

Saint Lucia Integrity Commission


PAGE | 65f

Commissioner of Police

Financial Intelligence Authority

Mr Severin Monchery


Mr Paul Thompson

Turks and Caicos Islands Integrity Commission


Mr Greg Christie

Director of Public Prosecution Office

Director Public Prosecution

Ms Jillian Williams

Elections Office


Mr Dudley Lewis

Complaints Commission

Complaints Commissioner

Mr Paul Harvey

Human Rights Commission

Human Rights Commissioner

Ms Sabrina Green

National Audit Department

Chief Auditor

Anand Heeraman

Royal Turks and Caicos Islands Police Force


James Smith

Financial Intelligence Agency


Mr Dwayne Baker

Saint Lucia Police Head Quarters Bridge Street Castries Saint Lucia No.3 Mongiroud Street Castries Saint Lucia

+1 (758) 456-3702

+1 (758) 451-7126

Director@integritycommission .tc

+1 (649) 946-1941 +1 (649) 941-7841 +1 (649) 338-3331

+1 (649) 338-3292 +1 (649) 338-4295 +1 (649) 338-4295

+1 (649) 338-2301

Complaintscommission@gov.t c

+1 (649) 338-2927

+1 (649) 941-5343

+1 (649) 338-7663

+1 (649) 941-4448

+1 (649) 941-7691

Turks & Caicos Islands Franklyn Missick’s Building, Church Folly, Grand Turk, Turks and Caicos Islands, TKCA 1ZZ Rialeigh House, Gracebay Plaza Leeward Highway, Providenciales, Turks and Caicos Islands Southbase Grand Turk, Turks and Caicos Islands Tony Clarke’s Building Waterloo Rd Grand Turk Turks and Caicos Islands Cabot House, Suite C 104 Providenciales, Turks and Caicos Islands Level #3, RBC Bank Building, Leeward Highway, Providenciales, Turks and Caicos Islands Police Headquarters Bld 26A, old airport road Providenciales 201 & 202 Cabot House Leeward Hwy. Providenciales Turks and Caicos Islands


PAGE | 65g Attorney General’s Chambers

Hon Attorney General

Rhondalee BraithwaiteKnowles

Waterloo Plaza, Waterloo Road, Grand Turk, Turks and Caicos Islands

+1 (649) 338-3282

Patricia Janet Scotland

Marlborough House Pall Mall London SW1Y 5HX United Kingdom

+44 (0) 20 7747 6500 Fax: +44 (0) 20 7930 0827

Commonwealth Secretariat – UK Commonwealth Secretary General

The Rt Hon The Baroness Scotland of Asthal QC



PAGE | 66

Biographies Commonwealth Representatives The Rt Hon Patricia Scotland QC The Rt Hon Patricia Scotland QC took office as Secretary-General of the Commonwealth in April 2016. The Commonwealth is a family of 53 independent sovereign states, and home to 2.4 billion people. Building on the Commonwealth Advantage of shared inheritances, and similarities of law and administration, its members are committed to creating a more inclusive, sustainable, and resilient future for all. The people and institutions of the Commonwealth work together through a broad range of intergovernmental, civil society, cultural and professional organisations committed to the shared values and principles of the Commonwealth Charter that cherish equality of opportunity and celebrate diversity. In a career of firsts, Patricia Scotland is the first woman to hold the post of Secretary-General. Born in Dominica, she moved to the UK at an early age and was brought up in a large close-knit Caribbean family where she was taught the importance of hard work, education, pride in her heritage and the obligation to give back to the region of her birth and to the society in which she was raised. This ethos has guided her throughout her dynamic career in law, politics and public service. A lawyer by profession, she became the first black and youngest woman ever to be appointed Queen's Counsel. She is the only woman since the post was created in 1315 to be Attorney General for England and Wales. She was also Attorney General for Northern Ireland. Appointed to the House of Lords as Baroness Scotland of Asthal, she is Alderman for Bishopsgate Ward in the City of London and Chancellor of the University of Greenwich.

Dr Roger Koranteng Dr. Roger Koranteng is the Adviser and Head, Public Sector Governance, for the Commonwealth Secretariat, making him the principal specialist responsible for the Public Sector Governance and Anti-corruption at the Commonwealth Secretariat. His responsibilities include the governance, anticorruption, and democratic and oversight institutions in all the 53 commonwealth countries. Having established the vibrant Association of Anti-Corruption Agencies in Commonwealth Africa and the Caribbean, he conceived, midwifed and operationalised the Commonwealth Africa AntiCorruption Centre in Botswana as a partnership between the Commonwealth Secretariat and Botswana Government. He also partnered with Grenada Integrity Commission and Department of Public Administration to establish a Regional Training Centre of Excellence in Grenada. Based on his impactful work over the years, Roger has been chosen as a winner of the 2018 Sheik Tamim Bin Hamad Al Thani International Anti-Corruption Excellence Award. Dr Koranteng holds a PhD (Public Policy) from University of Birmingham, UK; an MA (Public Policy & Administration) from the Institute of Social Studies, the Hague, Netherlands; a Post-Graduate Diploma in Public Administration from GIMPA, Ghana; a Post-Graduate Diploma in Environmental Studies from the University of Oslo, Norway; and a BA (Hons.) from the University of Ghana, Legon. Dr Koranteng has published extensively on Governance and Anti-Corruption and has taken numerous assignments around the world. He has also worked as a facilitator and lecturer. Â


PAGE | 67

Biographies Speakers Stacy de la Torre Stacy de la Torre serves as the UNODC Regional Anti-Corruption Advisor covering Central America and the Caribbean with projects in over twelve countries in the region focused on corruption prevention, detection, prosecution and asset recovery. Prior to joining the United Nations, Ms. de la Torre worked as a prosecutor for the U.S. Department of Justice (DOJ) investigating and prosecuting cases of corruption, narcotics trafficking and money laundering. She served for more than 10 years as the DOJ Attaché in Central America and as the Senior Legal Advisor and Attaché at the U.S. Embassy in Mexico City. Ms. de la Torre also served as the DOJ Legal Advisor in Nairobi, Kenya, as a prosecutor at the UN International Criminal Tribunal for the Former Yugoslavia and as the Senior Legal Advisor to the UN International Independent Investigation Commission in Beirut, Lebanon and The Hague, Netherlands.

James Lager Jim Lager is the Deputy Ethics Counselor to the United States Government Accountability Office (GAO), and advises GAO on conflicts of interest, ethics, personal and organizational independence, and manages GAO’s ethics and “notice of interests” programs. Jim has substantial experience as a labour and employment lawyer, representing private and government clients in trial and appellate courts, and as an investigator in various contexts, including serving as a lead congressional investigator examining violation of US campaign laws. Jim is also an Adjunct Professor at the University of Maryland’s Robert H. Smith School of Business where he teaches ethics to graduate students, and a collaborator to, a non-profit organization that makes the world's best research available and accessible to anyone interested in improving ethical culture and behaviour. A frequent speaker on behavioural ethics, Jim’s publications include “Professionalism and Ethical Leadership from the General Counsel's Suite” (2016), "Governments Demand Compliance, Ethics Demands Leadership” (2010), and "Overcoming Cultures of Compliance to Reduce Corruption and Achieve Ethics in Government" (2009). His essay: "Have a Problem with Compliance?" was awarded the H. George Frederickson Best Article Award by the American Society for Public Administration. Jim received a Juris Doctorate from American University in Washington DC, and a Master’s of Science in Organization Development from American University/NTL Institute for Applied Behavioural Science.

Professor Trevor Munroe Professor Trevor Munroe is the Executive Director of National Integrity Action,

Jamaica’s Chapter of Transparency International and since 2012 has been appointed an Individual Member of TI, one of only 30 globally and the only such from the Caribbean. He has produced National Integrity System country studies of Jamaica, the Caribbean, and the Turks & Caicos Islands. Professor Munroe has a distinguished record as an academic, in civil society advocacy and in public service.


PAGE | 68

As an academic, he has authored or co-authored 9 books on Caribbean democratic governance and received many awards. These include the Vice Chancellor’s Award for Excellence, the Mona Principal’s Award for research, 2 Fulbright Fellowships taken up at Harvard University in the United States and an Honorary Doctorate in Social Sciences from Florida International University, the first person from the English speaking Caribbean to receive such as award. After gaining a First Class Honours Degree and a Masters in Government from UWI, Dr Munroe was awarded the Jamaican Rhodes Scholarship and attained his PhD in Political Science from Oxford University. In September 2013 Professor Munroe was the only person from the Caribbean invited to speak at the 110th Anniversary of the Rhodes Scholarships, celebrated at Oxford University. More recently, Professor Munroe was the only person from civil society organizations in the Caribbean invited by the European Union Ambassador to the United States to speak at the first ever EU and the Americas Conference held in Miami, Florida from November 15 – 16, 2018. As a civil society advocate, Professor Munroe was instrumental as founder/co-founder of the Citizens Action for Free and Fair Elections (CAFFE), University and Allied Workers Union (UAWU), and the award-winning radio current development programmes. He has delivered keynote presentations in the Bahamas, Bermuda, Cayman, Guyana, Trinidad & Tobago, among other CARICOM States. In the sphere of public service, Professor Munroe, on the nomination of then Prime Minister Patterson, served in Jamaica’s Senate for 10 years, championing legislation for greater transparency, accountability and good governance. He also served on the Executive of the Confederation of Trade Unions and the private sectors’ Think Tank in the 1990s. He has served as consultant to the USAID, UKDFID, the UNDP, UNESCO, the OAS, the Carter Centre and many other international bodies. He is currently a member of the Council of the “Partnership for a Prosperous Jamaica”, previously called “The Partnership for Jamaica”, now chaired by The Most Honourable Andrew Holness, ON, MP, and previously chaired by former Prime Minister, Portia 2 Simpson Miller. Previously, he served on Jamaica’s National Security Council on the invitation of then Prime Minister Golding. In Jamaica’s 2015 National Honours, Professor Munroe was awarded the Order of Distinction, Commander Class (C.D.). He is married to Ingrid, President and CEO of Excel Insurance Brokers of which he is also the chairman. His two children, Tarik and Kinshasa, each hold Masters Degrees in Human Resource Development.

Panellists and Moderators RJ Berry RJ Berry has been the Director of the Financial Reporting Authority since August 2016. Prior to that he was Head of Compliance at the Cayman Islands Monetary Authority (CIMA) for 12 years, and also served as Deputy Head for 2 years. Mr. Berry also has 9 years of Private Banking and Investment Dealing experience, having worked for CIBC Bank & Trust Company (Cayman) Limited, Barclays Bank & Trust (Cayman) limited and Bank Vontobel Cayman prior to joining CIMA.


PAGE | 69

Mr. Berry has a Bachelor of Business Administration, and is a Certified Anti-Money Laundering Specialist. He also holds the Canadian Securities Certificate and Series 7 Equivalency.

Derek Byrne Appointed on the 1st. November 2016 Commissioner Byrne is responsible for the organizational effectiveness and governance of the Royal Cayman Islands Police Service. Previous to this appointment, Commissioner Byrne served for 36 years with Ireland’s National Police Service, An Garda Siochana. In 2007 he was appointed to the rank of Assistant Commissioner and for the period 2008 to 2016 he served as Assistant Commissioner with responsibility for Special Crime Operations. In that role he had strategic, business and operational lead for serious and organised crime and international criminal investigations undertaken in that jurisdiction. Commissioner Byrne holds an M.A. in Violence, Terrorism and Security received from Queens University, Belfast, Northern Ireland (2017). He holds a B.A. (Hons) degree in Police Management and has completed the Strategic Command Course at Bramshill Police Training College, U.K. and the National Executive Leadership Programme (NEI) for world police leaders at the FBI National Academy, Quantico, Virginia, USA.

Whycliffe 'Dave' Cameron Whycliffe “Dave” Cameron was born on April 8th, 1970. Graduated from Kingston College in 1989. Dave Cameron earned the Douglas Forrest Scholarship (Sponsored by Frank Rance) for Hotel Management in 1989, to pursue studies at the University of the West Indies—Nassau Campus, where he earned a Bachelor’s Degree, with First Class Honours. In 1998 he graduated from the University of the West Indies with a Master’s of Science Degree in Computer-based Management Information Systems. Over the years, he has worked his way up in Finance to today being Founder and CEO of Infiniti Capital Jamaica Ltd. An Experienced Leader skilled in Negotiation, Budgeting, Business Planning, Operations and Sports Management. Strong business development professional and well-rounded individual with a demonstrated history of performance in the Financial Industry. Over 20 years of experience having worked with Dehring, Bunting and Golding in 1995 and being elevated to Vice President Treasury, Trading and Asset Management at Manufacturers Merchant Bank Limited in 2003 where he oversaw AUM of over $21B with an equity of over $1B at the time. Spent 3 years at Sterling Asset Management Ltd 2010-2013 and was instrumental in assisting the firm to double their capital in the 3 years and launch the Sterling Investments Ltd which is currently listed on the Jamaica Stock Exchange. A member of the then, West Indies Cricket Board, now Cricket West Indies, since 2002 and during that time have served in various capacities before heading the organization in 2013 to 2019. In 2013 we took over the leadership of West Indies Cricket that had an accumulated deficit of USD$5.8m and transformed it into a professional organization. Cricketers were now being employed and developed full time across the region and we had administrators employed in supporting roles. The result was the best individual ranking of most our players in decades which had started to translate into positive team results on the field. Dave Cameron is an avid sportsman and enjoys squash and golf. He is married to Connie Cameron, with whom he has 4 children.


PAGE | 70

Sophia Harris Sophia-Ann Harris (nee Solomon), the founder of the firm Solomon Harris now part of Bedell Cristin, is a graduate of the Cayman Islands Law School and has a degree from the University of Liverpool, England. She received an award from the Chamber of Commerce and the Cayman Islands Bar Association for scholarly achievements. Sophia was trained and practised with Hunter & Hunter (now Appleby) before leaving to establish Solomon Harris in 1997. The award-winning firm, Solomon Harris, has been consistently ranked as one of the top independent firms in the Cayman Islands and held an office in Zurich, Switzerland for over 6 years. Sophia’s specialties include banking, hedge funds and unit trusts, corporate and commercial law, trusts, immigration and all aspects of local licensing law. She is a well recognised corporate and immigration attorney and is listed in Lawyer Monthly’s ‘Leading Lawyer 100’ in the category of Banking and Finance for 2012. Sophia is also a full member of STEP. Sophia served as the Chairwoman of the Immigration Appeals Tribunal from October, 2009 to September, 2013. She was Chairwoman for the Immigration Department’s Business Staffing Plan Board for 2 years and sat on the Immigration Review Team for 2007 to 2008 and 2013. Sophia has also served on the Board of Governors for the University College of the Cayman Islands and also served on the Board of Directors for the Special Economic Zones Authority from 2014 to 2016. Sophia is a past Chairwoman of the Board of Directors of the Butterfield Bank (Cayman) Limited and continues to sit on its Board of Directors. Sophia is a current member of the Cayman Islands Anti-Corruption Commission by appointment of H.E. the Governor of the Cayman Islands. Sophia is a council member of the Cayman Islands Law Society and has sat as a council member of the Caymanian Bar Association. She is a Past President of the Rotary Club of Grand Cayman, serving as the first female president in the Cayman Islands and is a past Assistant Governor for the Rotary Clubs within the Cayman Islands. She is a Past President of the Chamber of Commerce and during her term with the Chamber she has addressed the United Nations on a number of occasions including the United Nations General Assembly on constitutional matters for the Cayman Islands.

Wavell Hinds He was born on New Cross Road, Fletcher's Land, Downtown Kingston, Kingston, Jamaica. The second of five children for his parents. He grew up in Portsmouth, Portmore, St. Catherine and attended the Rehoboth Basic School in 1979 then on to Independence City All Age (now Primary) in 1983, before advancing to Camperdown High School after sitting and passing the Common Entrance Examination in 1988. While at Camperdown he participated in cricket and football at the U14, U16 and U19 levels in both sports. He was named captain at all levels in cricket (Junior Colts, Colts and Sunlight Cup) and in football (U14, Colts and Manning Cup). While at Camperdown he also become a member of Kensington Cricket Club (1990) and played Minor, Junior and Senior Cup cricket. He captained the Minor Cup Team in 1991 and 1992 and was named captain of the Senior Cup Team from 2002 to 2009. He's presently still active and is the Junior Cup captain. As a strong community man, he started represented Portsmouth in community cricket in 1988 in the Portmore Cricket League and it still an active member of the today. He's also the Ambassador for the Portmore Cricket League a position he has held since 2004.


PAGE | 71

Through his outstanding performances at the high school and club levels he was selected to represent the Jamaica U19 Team (1994-96) for which he was named vice captain in '95 and captain in '96 respectively. His performances for the Jamaica U19 team also earned me a place on the West Indies U19 in 1995 to Pakistan and Bangladesh and 1996 Home Series as well. He made his First Class debut for the Jamaica Senior Men's Cricket Team in 1996. He matriculated to the University of Technology from Camperdown High School six (6th) form in September 1996 and took a leave of absence in September of 1997 to pursue his professional career in cricket. He immediately made the West Indies 'A' Team to tour South Africa in 1997 and in 1998 to tour Bangladesh and India. He made his One Day International (ODI) debut in 1999 in Singapore versus India and his Test debut in 2000 versus Zimbabwe in Trinidad and Tobago. He was a member of the West Indies Champions Trophy champion team in 2004 in England. Additionally, he's a member of numerous champion teams for Jamaica in Regional Cricket namely, 1999 One Day champions, 2000, 2002, 2005, 2008, 2009, 2010 and 2011 4Day Regional champions. He had the distinct honour of leading the Jamaica Team between 2005 to 2007. He represented the West Indies from 1999 to 2010 scoring five (5) centuries and fourteen (14) half centuries and five (5) Test centuries and fourteen (14) half centuries in both ODI and Test cricket respectively. He also represented Jamaica from 1996 to 2011 scoring numerous centuries and half centuries before he retired in April of 2011. During his professional career he also represented Derbyshire County Cricket Club in England between in 2008 and 2009. After retiring from professional cricket in 2011, he immediately got enrolled at The University of the West Indies Mona Campus pursing a Bachelor of Arts degree in Media and Communication (2011-14) for which he graduated with honours. In 2016, he again got enrolled at The University of the West Indies, this time at the Open Campus, where he successfully pursued his master's degree in Management Studies with specialization in Human Resource Management.

Adam Huckle Adam is a member of the Maples Group's Financial Services Regulation and Dispute Resolution & Insolvency teams, and regularly represents retail and investment banks, trustees, investment funds and other financial institutions. He has a broad range of litigation experience, with an emphasis on complex, multi-jurisdictional matters involving banking, finance, investment funds, company law and trusts disputes. Adam's regulatory practice has a particular focus on economic sanctions, but also includes advising on anti-corruption and bribery, cross border conduct of business, duties of confidentiality, licensing, record retention and information exchange. He regularly appears in the Grand Court and Court of Appeal of the Cayman Islands, and has authored a number of chapters and articles for journals such as International Corporate Rescue, Global Legal Insights, International Corporate Legal Guides and Practical Law, including with respect to anti-corruption, bribery and other financial crime. Adam joined the Maples Group in 2011 from Hogan Lovells International LLP in London, UK, where he was an associate in the Investment Banking, Funds Litigation and Dispute Resolution group. During his time there Adam was seconded to Group Litigation at Barclays Plc in London, UK. BAR ADMISSIONS 2007 – Admitted as a solicitor of the Senior Courts of England and Wales (not practising) 2011 – Admitted as an attorney-at-law in the Cayman Islands EDUCATION BPP, UK, Legal Practice Course (Distinction), 2005 BPP, UK, Graduate Diploma in Law (Commendation), 2004 University of Bristol, UK, BA (Hons) First Class, English Literature, 2003


PAGE | 72

Candia James-Malcolm Ms Candia James-Malcolm is the Assistant Director of Public Prosecutions in the Cayman Islands. Ms James-Malcolm received her Bachelor of Laws from the London School of Economics and Political Science in 2000. Thereafter she pursued the Bar Vocational Course at the Inns of Court School of Law as a member of the Honourable Society of Lincoln’s Inn. She was admitted to the Bar of England and Wales in 2001. She returned to her native Trinidad and Tobago and was admitted to the Bar in Trinidad and Tobago in 2002. She joined the Office of the Director of Public Prosecutions in Trinidad and Tobago in 2002 and remained there until 2008 whereupon she joined the Ministry of National Security as Legal Adviser. Ms James-Malcolm joined the Office of the Director of Public Prosecutions in November 2009 as Crown Counsel. She was appointed as Senior Crown Counsel in January 2017 and then as Assistant Director in July 2018. She is currently acting in the role of Deputy Director of Public Prosecutions. She prosecutes a wide range of serious and complex matters in the Summary Court, Grand Court and the Court of Appeal of the Cayman Islands.

Nick Kedney Nick is a Forensic Partner in the Financial Advisory practice, and leads the Discovery & Forensic Technology service line for Deloitte in the Caribbean and Bermuda. He specializes in the investigation of international commercial fraud, corruption, money laundering and asset recovery. He serves clients throughout the Caribbean and Bermuda region. Nick has over 20 years’ experience in large scale & complex forensic/fraud investigation, asset recovery and Discovery work; He has extensive experience of serious and complex multijurisdictional fraud litigation. Specific experience includes: Leading complex and high value forensic investigations into fraud and corruption, involving large volumes of transactional and communication data in industries such as financial services and petrochemicals; Providing litigation support on financially complex and highly contentious cases; Providing technology consulting services to law enforcement and regulatory agencies; Expertise in data analytics, visual investigative and network analytics and the deployment of analytics in forensic investigations; Investigation of offshore trust and corporate structures, international business corporations and bearer securities used to launder, conceal and protect misappropriated assets. Business intelligence investigations, including the deployment of sophisticated open source, internet and social media research techniques to identify assets and beneficial ownership Asset-tracing and recovery actions. Academic Credentials: University of Wales, Bachelor of Arts; University College London, Master of Science; College of Law, England & Wales, Post Graduate Diploma in Law Professional Credentials: Barrister, England & Wales (Non-practising); Certified Fraud Examiner (CFE)


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Cheryl Ann Neblett Miss Cheryl Neblett is the First Legislative Counsel of the Government of the Cayman Islands, a country where she has lived and worked since 1995. Miss Neblett is an attorney-at-law of more than 30 years call, having been called to the Bar in Barbados in October 1988. She is a graduate of the Faculty of Law of UWI and the Hugh Wooding Law School. Miss Neblett holds an Upper Second Class Honours Bachelor of Laws degree, a Legal Education Certificate, a Master’s in Public Law and Legislative Drafting and an Executive Certificate in Global Leadership. Prior to being First Legislative Counsel Miss Neblett was the first Director of the Law Reform Commission of the Cayman Islands, a post which Ms. Neblett held for 12 years. Miss Neblett continues to work for the Commission as a Legislative Counsel of the Portfolio of Legal Affairs and she is a contributor to the Law Review of the Truman Bodden Law School of the Cayman Islands. She is also currently a member of the Working Group for National Maritime Strategy and III Code Compliance and a member of a Maritime Strategy sub-committee on the regulation of domestic commercial vessels. Miss Neblett is an overseas member of the Bar Association of Barbados, a member of the Institute of Public Administration of Canada, the Commonwealth Association of Legislative Counsel and the Commonwealth Lawyers’ Association. While in the Legislative Drafting Department and in the Law Reform Commission Miss Neblett has drafted legislation and, in some cases, discussion and issue papers, relating to a wide range of matters including financial and financial services legislation, pensions, immigration, customs and border control, family law reform, health insurance, contingency fee agreements, arbitration, criminal law, anti-corruption, protection of whistle-blowers, plea deals, terrorism, anti-proliferation, timeshares, strata titles and residential tenancies, to name a few.

Steven Richardson Steven Richardson is currently the lead investigator for the International Cricket Council’s AntiCorruption Unit. He is responsible for coordinating investigations into corruption and match fixing in international cricket and for coordinating investigations in domestic cricket where they cross jurisdictions. In his role he has dealt with players, coaches and other Participants for corrupting cricket while also interviewing and disrupting corruptors threatening the integrity of the game. As well as investigating media stings alleging corruption in cricket he recently completed a 5 month spell in Sri Lanka to combat corruption in Sri Lanka cricket and support the local cricket board. Prior to working in cricket Steve was a senior detective in London’s Metropolitan Police where he led a murder team investigating 40 murders. He also led teams that investigated serious and organized crime from drug trafficking to international firearms smuggling.

Hector Robinson QC Hector Robinson QC is the Cayman Islands Litigation Practice Group Head for international offshore law firm, Mourant. He has more than 28 years' experience as a civil and commercial litigator and was appointed Queen's Counsel in February 2017. He is recognised as a thought leader, trusted adviser and first port of call for many local and international clients and intermediaries. He regularly appears as an advocate before the Cayman Islands Grand Court and Court of Appeal.


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Hector's work is now primarily focused on advising and representing trustees, settlors and beneficiaries in complex cross-border trust and estate disputes. His practice also covers regulatory investigations, fraud and asset tracing, receiverships, contentious property disputes and crossborder employment advice. He speaks regularly at professional conferences and seminars and has written articles published in prestigious and widely read publications such as Solicitors Journal, New Law Journal and PLC. He has, on a number of occasions, been accepted and relied on as an expert on Cayman Islands law by United States state and federal courts. Hector is the Chairman of the Cayman Islands Law Reform Commission and a member of the Chairmanship Panel of the Disciplinary Tribunal of the Cayman Islands Institute of Professional Accountants. Following a long career as a competitive club cricketer, Hector is now the President of Cayman Cricket, the national governing body for cricket in the Cayman Islands.

Sean Theron Sean has more than 15 years of experience with data analysis, forensic investigations, fraud investigations, the development of complex technology and eDiscovery solutions as well as cybersecurity. Experience includes addressing multimillion dollar disputes on matters including valuation support, financial misstatements, corruption, intellectual property, embezzlement, fraud and employee termination. Sean joined KPMG in 2017 as the Principal for E-Discovery and Foresnic Technology Services for KPMG Cayman Islands. Sean is also responsible for E-Discovery and Forensic Technology Services for the KPMG Islands Group. Sean has performed more than 500 collections to date. Sean was the co-lead on the largest forensic Electronically Stored Information (“ESI”) project in the Caribbean, which involved circa 2,700 pieces of media equating to 370 TBs of data. Sean has authored and co-authored numerous submissions to court and provided expert testimony in court, as well as authoring a number of though-leadership pieces. Software experience includes: Database and Analytics – Relativity; Summation; Concordance; Prediscovery Law; and Forensics – Encase; FTK; FTK Imager; Encase; X-Ways; Paladin; Macquisition; Nuix; RoboCopy; Rsync; Oxygen forensics Suite. Sector experience – funds, insurance, financial services, industrial services, government.

Sue Winspear Sue Winspear started as the Auditor General of the Cayman Islands in July 2016. Prior to that Sue, was Executive Leader Local Services with the UK’s National Audit Office from January 2014. Sue was a NAO executive board member and part of the senior leadership team and held specific responsibility for the NAO’s work on local government, education and health as well as communications and external relations.


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Between 2009 and 2014, Sue was a UK Senior Civil Servant being Director General Civil Service Reform in the Cabinet Office, Director General Finance & Corporate Services in the Department for Communities and Local Government and before that in the Department for Education. Sue’s earlier career was in English Local Government where she held several Board level roles. Sue is an Executive Committee Member for CAROSAI (Caribbean Region of Supreme Audit Institutions) and represents CAROSAI at INTOSAI’s (the International Organization of Supreme Audit Institutions) Capacity Building Committee. Prior to leaving the UK, Sue was an elected member of CIPFA Council and she has held numerous honorary roles over the years, notably being elected the first female President of the Society of Municipal Treasurers in 2005/06.

Delegates Helen Ambo Ms. Ambo has been the Secretary of the Integrity Commission of Dominica since 2010, and has supervised the transition of the Commission from a seven member to a three member one. She is qualified in Business Administration and Paralegal Studies and is a teacher by vocation.

Justice (Ret'd) Melville Baird Justice Melville Baird had a legal career. He practiced as a Barrister-of Law and was then appointed Magistrate of Trinidad & Tobago. Later Promoted to Senior Magistrate, he was thereafter appointed Chief Magistrate of Trinidad & Tobago. Justice Baird was then appointed High Court Judge of the Supreme Court, and on his retirement was appointed International Judge by the General Assembly of the United Nations. He presided at the International Criminal Tribunal for the former Yugoslavia in The Hague, for seven years. There he tried cases of war crimes, crimes against humanity and genocide committed during the war in Bosnia and the war in Kosovo. On his retirement as International Judge, Justice Baird returned to Trinidad and was subsequently appointed Chairman of the Integrity Commission, a position he currently holds.

Rosemary Benjamin-Noble Rosemary Benjamin-Noble was appointed as a member of the Commission in February, 2018, and is a West Indian trained Attorney-at-Law. She currently holds the position of Senior Manager, Legal & Compliance at Citizens Bank Guyana Inc. Mrs. Rosemary Benjamin- Noble possesses a Master's Degree in International Education. She currently serves as the Deputy Chairperson on the Rights of the Child Commission, and supports the endeavours of organizations which focus on the betterment of women and children. She has served in various capacities in other organisations.

Greg Christie Greg Christie is the Director of the Turks and Caicos Islands Integrity Commission. He is a former Contractor General of Jamaica and the former UK-DFID-supported Consultant and Principal Advisor to Transparency International’s Jamaica arm, NIA.


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An Attorney by profession, Mr. Christie was previously a Country Director, and the Global Commodities Business Unit Vice President and Assistant General Counsel for the Kaiser Aluminum and Chemical Corporation, with which he worked for 13 years. He has also served for 10 years as a University of the West Indies Law Director and Lecturer in Corporate, Insurance, Criminal and International law, and for 3 years as a Tutor in Insurance, Banking, Credit and Securities Law at Trinidad’s Hugh Wooding Law School. Mr. Christie has consulted with the UN-ECLAC and Air Jamaica, among other institutions, in governance, anticorruption, and international commercial law.

Mr. Christie is the holder of the LL.B. Degree from the UWI, the LL.M. Degree in Corporate, Insurance, Air and Space Law, and Law of the Sea, from the University of London, and the L.E.C. from the Hugh Wooding Law School. He holds business executive development certifications and has completed programmes at the Haas Business School, University of California at Berkeley, and the Darden Business School, University of Virginia. Mr. Christie has also received Anti-Corruption, Governance and Law Enforcement training in Singapore, and from the Commonwealth Secretariat, the U.S. State Department, Scotland Yard, UN-ODC, and the Regional Anti-Corruption Academy for Latin America and the Caribbean. He has participated in and/or made presentations at leading Anti-Corruption, Governance and Law-Enforcement events in Europe, Asia, Latin America, UK, the USA and the Caribbean. Mr. Christie is a Jamaica Government and UWI Post-Graduate Law Scholar. He has worked, studied and/or resided in 9 Caribbean countries, the United States, England and Ghana.

Deirdre Clarke-Maycock Deirdre Clarke-Maycock I am a Counsel and Attorney-at-Law in the Office of the Attorney General, where I have been engaged since 2004. During my tenure with the Attorney General’s Office, I have served as the Registrar of The Court of Appeal and the Registrar General of The Bahamas with responsibilities for the Companies, Intellectual Property, Deeds and Documents and the Birth Registries. I am the holder of a Bachelor of Law from the University of the West Indies and my Masters in International Maritime Law from the International Maritime Law Institute. Interest/Activities: Member of the Bahamas Bar Association Member of St. Anne’s Anglican Church Women (ACW) Public Relations Officer, Bahamas Heart Association Reading, traveling and meeting people

Neil Coates Neil Coates is a Director with Grant Thornton with more than +20 years of professional experience in assurance, tax, advisory and insolvency services. He has overall responsibility for Tax and Advisory services in Antigua and Barbuda, and Tax services in St. Kitts and Nevis. Tax services include but are not limited to the filing of tax returns, review and analysis of tax assessments from the Tax Authorities, preparation of tax responses, tax planning, tax defence and other advisory services. In terms of Advisory services, his main expertise and experience is in the areas of Due Diligence and Insolvency. He has been involved in several due diligence assignments across the hospitality and service sectors, most recently for a transaction exceeding US$80m. Over the last 15 years he has also managed a number of insolvencies in Antigua. His insolvency expertise extends across various entities and industries including both offshore (IBCs) and local financial institutions.


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He is considered to be one of Antigua’s foremost technical tax advisors based on his expansive knowledge of tax legislation and local tax planning practices. As such has influenced Government policy decisions related to personal income tax implementation in Antigua and Barbuda in 2005, the Antigua and Barbuda Sales Tax in 2007 and the Unincorporated Business Tax Act 2016 and subsequent amendments.

Neil is a member of the Institute of Chartered Accountants of Antigua and Barbuda and currently serves as the Treasurer and Vice-Chairman. Education background & professional membership: B.Comm (Distinction) – McGill University, Quebec, Canada – 1994 Certified General Accountants’ Association of Canada in 1995 American Institute of Certified Public Accountants 1997 Member of the Institute of Chartered Accountants of the Eastern Caribbean

Deirdre Clarke-Maycock Deirdre Clarke-Maycock I am a Counsel and Attorney-at-Law in the Office of the Attorney General, where I have been engaged since 2004. During my tenure with the Attorney General’s Office, I have served as the Registrar of The Court of Appeal and the Registrar General of The Bahamas with responsibilities for the Companies, Intellectual Property, Deeds and Documents and the Birth Registries. I am the holder of a Bachelor of Law from the University of the West Indies and my Masters in International Maritime Law from the International Maritime Law Institute. Interest/Activities: Member of the Bahamas Bar Association Member of St. Anne’s Anglican Church Women (ACW) Public Relations Officer, Bahamas Heart Association Reading, traveling and meeting people

Kumar Doraisami The appointed Chairman of the Integrity Commission began his tenure on February 22, 2018. His professional experience includes, but is not limited to, holding tenure of services as a former Magistrate, a retired Land Court Judge and a West Indian trained Attorney-at-Law. He is currently in private practice. Mr. Doraisami’s formal training includes but is not limited to: a three (3) year Diploma in Metallurgy and Materials Engineering Technology, a Bachelor of Science Degree from York University, Bachelor of Laws Degree and Certificate of Legal Education (Hugh Wooding Law School).

Dirk Harrison Dirk Harrison is currently the acting head of the Corruption Prosecution Division of the Integrity Commission. Prior to that, he was appointed Contractor General of Jamaica by the Governor General of Jamaica, His Excellency the Most Honourable Sir Patrick Allen, on 25th February, 2013, where he performed the duties from March 1, 2013 to February 22, 2018.


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As the Independent Commissioner of the Office of the Contractor General of Jamaica, Mr. Harrison was entrusted with the exclusive statutory authority, on behalf of Parliament, to monitor and to investigate the award and termination of all Government contracts, licences and permits, with a view to ensuring probity, propriety, accountability, competition and transparency in the Jamaica public sector procurement, contract award and licensing processes. He was vested with extensive statutory quasi-judicial powers of investigation, enquiry, search, discovery and subpoena.

Prior to his appointment as Contractor General, Mr. Harrison, who is a Caribbean trained lawyer, was employed as a Deputy Director of Public Prosecutions at the Office of the Director of Public Prosecutions (Jamaica) with special responsibilities for the Anti-corruption Unit, Coroners Unit, the Environment Law Unit and he is one of the Government Experts for Jamaica for the implementation of the United Nations Convention Against Corruption Review Mechanism (UNCAC). Whilst at the Office of the DPP, Mr. Harrison also held positions as a part-time Lecturer at the Justice Training Institute of the Ministry of Justice and previously tutored at the Norman Manley Law School in Advocacy. Before joining the Office of the Director of Public Prosecutions, Mr. Harrison worked as a Clerk of Courts in the Parish of St. Mary. Mr. Harrison has had extensive training in the fight against Fraud and Corruption, as well as Judicial and Prosecutorial Enhancement training. Mr. Harrison is a graduate of Jamaica College and a former student of Excelsior Community College. He is the holder of a B.A. in History (Hons.) and a LL.B. (Hons.) Degree from the UWI and the C.L.E. legal professional qualification from the Norman Manley Law School. Mr. Harrison has resided and worked professionally in Jamaica for 18 years and has been admitted as an attorney-at-law to practice in Jamaica. Mr. Harrison is married to Diahann Gordon-Harrison, Children’s Advocate of Jamaica, with four beautiful children, Dirk, Liam, Milan and Bree.

Radford Hill Mr. Radford Hill is the Senior Partner in the Firm of Hill & Hill of Long Street in the City of Saint John’s in the State of Antigua and Barbuda in the Caribbean. The Firm was established in 1984 as a Partnership between himself and his wife Cecile Hill.

Mr. Hill obtained a BA Degree from the University of the West Indies in 1974. In 1975, Mr. Hill migrated to London, England to continue his studies in law and was admitted into the Honourable Society of Lincoln’s Inn. Upon completion of his studies at the Bar, he was called to the Degree of an Utter Barrister in 1978. In 1979, Mr. Hill returned to Antigua and was admitted to practice at the Eastern Caribbean Supreme Court and has been in practice ever since. During that time, Mr. Hill has gained extensive experience in the field of commercial, corporate and investment Hill & Hill Attorneys-At-Law Notaries Public 2 law, banking, employment law and insurance. In addition he has advised a number of international corporate clients particularly in relation to the provision of offshore services. Mr. Hill has held a number of public appointments in Antigua and Barbuda including Chairman of the Industrial Development Board, President of the Industrial Court, Attorney General and Minister of Justice and Legal Affairs, additional Magistrate, a member of the Constitutional Review


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Commission and was a member of the Task Force appointed by the Government to advise on the feasibility of a Citizenship by Investment Programme for Antigua and Barbuda and was instrumental in creating the legislative and institutional framework for the programme. In July, 2016, Mr. Hill was elected President of the Local Licensed Agents Association of Citizenship by Investment Program. On the 6th of October, 2014 he was appointed Chairman of the Integrity Commission by His Excellency the Governor-General of Antigua and Barbuda. He has held a number of directorships including Director of Finance and Development Company Ltd and the Hadeed Group of Companies. He is also a former Director for the regional airline service LIAT. Mr. Hill writes and speaks fluent French. Mr. Hill is married with three (3) children Arianne, Andre and Alexis.

Eugene Otuonye QC Eugene Otuonye is the Director of Public Prosecutions of TCI. He is Nigerian and Caribbean trained Attorney - at - Law with more than 30 years of extensive legal practice in the public and private sectors in Nigeria and across the Commonwealth Caribbean. He has been a Queen’s Counsel since 2006. Prior to his current appointment as DPP of TCI in January 2019, Mr. Otuonye, served as the first substantive Director of the Turks and Caicos Islands (TCI) Integrity Commission from July 2011 until he demitted office on 30th of June 2018. He is also the immediate past Chairman of the regional anti-corruption body – the Commonwealth Caribbean Association of Integrity Commissions and Anti-Corruption Bodies. He demitted this office also in June 2018. Prior to these recent appointments, and in the period between 2004 and July 2011, Mr. Otuonye served as the Deputy Attorney General of TCI; the Attorney General of Monserrat; the Chairman of the TCI Public Service Commission and a member of the Advisory Council during the UK’s interim direct administration of the Turks and Caicos Islands. Mr. Otuonye is a member of the International Bar Association and a Fellow of the Society of Advanced Legal Studies, IALS, University of London, among other Bar and Professional Associations. Mr. Otuonye is married to Vivian, a Guidance Counsellor, and they have three adult males.

Tafawa Pierre Superintendent Tafawa Pierre has over twenty seven (27) years of experience as a Police Officer with the Royal Grenada Police Force (RGPF). Throughout his career he received extensive training locally, regionally and internationally in general police work, criminal investigation, financial crimes investigation and instructional techniques. In 2008, Mr. Pierre formed part of the team that was responsible for preparing Grenada for the examination by the Caribbean Financial Action Task Force (CFATF). He also attended the First Annual Conference of International Association of Anti-Corruption Authorities in Beijing, China, where he presented on special investigative techniques. In 2009 he served as Officer Second In-charge and Divisional Commander for the Eastern and Western Division respectively of the Royal Grenada Police Force (RGPF).


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Between 2010 and 2012, Mr. Pierre was the Commandant of the RGPF Police Training School and was selected to chair the Practice Committee of the Regional Security Services (RSS) Training Institute, Barbados. In 2013 he served as Staff Officer In-Charge of Training, Regional Security Services (RSS), Barbados. At present, Mr. Pierre is the Head of the Financial Intelligence Unit (FIU) Grenada, a member of the Anti-Money Laundering (AML/CFT) Commission Committee and represents Grenada at several meetings and forums.

Cleophas Regobert Mr. Regobert is a certified accountant by profession and has been in private practice for the past 35 years. He became a member of the Integrity Commission of St. Lucia in March 2018. Mr. Regobert has served as president of St. Lucia Save the Children Fund (Lusave), as president of the Kiwanis Club of Castries, St. Lucia, as vice president of the Institute of Chartered Accountants of St. Lucia, and as chairman of St. Lucia National Lottery. He has and continues to serve on the Board of Directors of several companies and served as a member of the Public Utilities Commission of St. Lucia. Mr. Regobert played squash and cricket, and is married with three daughters.

Robert Robinson Mr. Robert Robinson has had a long and illustrious career in the Public Service in Grenada and Trinidad that spans over thirty years. He served as a member of the Federation of the West Indies Civil Service in Trinidad, the Windward Islands Civil Service, headed by the Governor of the Windward Islands based in Grenada and the Grenada Civil Service. He was also a Director with the Employers Consultative Association of Trinidad and Tobago. As a result of his expertise he was appointed as the Labour Adviser with the Government of Grenada and up to present is an Industrial Relations Consultant. Mr. Robinson is an active and engaging person; this is evident in his extra-curricular activities. He served for ten (10) years in the following organisations:Treasure and subsequently President of the Grenada Civil Service Association (now named the Public Workers Union) Circuit Steward, Grenada Circuit of the Methodist Church in the Caribbean and the Americas Secretary, Grenada Cricket Association Mr. Robert Robinson was one of the founding members of the Office of the Integrity Commission Grenada from its inception. Currently, he serves as the Commission’s Deputy Chairman. He was also a member of the inaugural Executive of the Commonwealth Caribbean Association of Integrity Commissions and Anti-corruption Bodies (CCAICACB) for two terms. Mr. Robinson is married, and has three children and grandchildren.


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Deshawn Arzu Torres Deshawn D. Torres was born and raised in Belize. She obtained her Bachelor of Laws (LL.B) (Hons) from the Cayman Islands Law School (University of Liverpool) in 2003 and completed the Bar Vocational Course at the Manchester Metropolitan University in the United Kingdom in 2004. She is a founding partner at Mckoy Torres LLP in Belize where her main practice areas are contract, real estate, marital and family law with her having a keen interest in matrimonial and family law dispute resolution. Whilst Mrs. Torres has extensive litigation experience, she firmly believes that parties and their children benefit immensely when settlements can be arrived at without court intervention. As an arbitrator and certified family law mediator, she understands the needs of the parties and strategizes for an outcome that is favourable and in the best interest of all concerned. Before starting her own practice, she worked as a litigator at Youngs Law Firm for 10 years where she represented individuals and companies in personal injury, real estate, matrimonial and property disputes and also advised and represented major oil retailers, and corporations in the areas of labour and contractual disputes. She currently chairs the Integrity Commission of Belize, co-chairs the Social Security (Appeals) Tribunal and is a Director of the National Bank of Belize. She is a former Member of the Board of Trustees of the Association of Concerned Belizeans, Liquor Licensing Board (Belize District), and Trade Licensing Board (Belize District). Mrs. Torres is active in various community based organizations committed to leadership and the empowerment of women.

Rosie Whittaker-Myles Mrs. Whittaker-Myles is an attorney-at-law in private practice. She is a former partner in Charles Adams Ritchie & Duckworth’s litigation team and has over 17 years’ experience in civil and commercial litigation. Her wide range of expertise includes personal injury, employment, immigration, compulsory acquisition of land, trusts, wills, probate, (both contentious and noncontentious) and family law matters. She is a past Council Member for the Caymanian Bar Association. Mrs. Whittaker-Myles served as Chairperson of the Adoption Board and provided pro bono services for adoptions in the Cayman Islands for more than 13 years. She is a Legal Befriender, providing pro bono legal advice on all areas of Cayman Islands law, and serves as legal advisor to the National Council for Persons with Disabilities. Effective 1 February 2015 Mrs. Whittaker-Myles was appointed as Chairman of the Commission for Standards in Public Life for a four year term after which her appointment was renewed until 31 December 2019.

Franklyn Williams Personal Date of Birth: 28/01/67 Nationality: Bahamian Marital Status: Married


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Employment and Professional Experience November 2015 – To Present Office of The Attorney General Deputy Director of Legal Affairs Chair, Civil Litigation Division, Supervision of Legal Officers 2007 – 2015 Office of The Attorney General Deputy Director of Public Prosecutions 1999 – 2006 Office of The Judiciary Deputy Chief Stipendiary and Circuit Magistrate 1994 – 1995 Royal Bahamas Police Force Legal Advisor, Internal Legal Advisory Unit 1993 Office of The Attorney General Assistant Counsel Certification and Training 2007 Certificate United States Patent and Trademark Office Global Intellectual Property Academy 1998 Master of Laws (International and European Legal Studies) University of Durham(United Kingdom) 1997 Certificate in Portuguese Certificate in German Grosvenor Academy 1994 Certificate in Conversational Creole The College of The Bahamas 1992 Legal Education Certificate Council of Legal Education, West Indies 1990 Bachelor of Laws The University of The West Indies 1985 Associate of Arts History The College of The Bahamas Additional Professional Experience 2008 – 2015 Mechanism for Follow-Up of The InterAmerican Convention Against Corruption (MESICIC) Lead Expert/Examiner, Bahamas. 2012 – 2015 Conference of State Parties, United Nations Convention against Corruption (UNCAC) Representative/Examiner, Bahamas.


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Acknowledgements This conference would not have been able to take place were it not for the dedication, hard work and volunteerism of the following individuals and entities, for which our sincerest thanks are offered. His Excellency, Mr Martyn Roper OBE, Governor of the Cayman Islands. The Rt Hon The Baroness Patricia Scotland QC, Secretary General of the Commonwealth. Dr Roger Koranteng, Commonwealth Secretariat. Mr Dirk Harrison, CCAICACB Executive Chairman. Mrs Rosie Whittaker-Myles, Chairman, CI Commission for Standards in Public Life. Ms Jamie Ebanks, Spark! School of Performing Arts. Reverend Mary Graham, St George’s Anglican Church. Cayman Islands Cadet Corps. The Cayman Islands Government. The Members of the CI Commission for Standards in Public Life. The Staff of the Commissions Secretariat. The Staff of the Office of the Governor and Government House. Electronic documents from the conference and other related material can be found online on the CSPL website:

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