OFFICE OF GOVERNMENT ETHICS
COMMONWEALTH OF PUERTO RICO
A GENERAL OVERVIEW OF THE LAW OF GOVERNMENT ETHICS OF THE COMMONWEALTH OF PUERTO RICO
HIRAM R. MORALES LUGO, ESQ.
The Puerto Rico Government Ethics Act is Public Law No. 12, as amended, enacted on July 24, 1985. This law is a fundamental component of the policy initiatives that the Commonwealth of Puerto Rico has put into place to address the problem of governmental corruption. Other initiatives include the Independent Special Prosecutor Act, the Public Integrity Division and the Comptroller’s Affairs Office; the last two entities operate within the Justice Department.
The Government Ethics Act is the only measure originally drafted as to address the problem of corruption both through prevention and enforcement policies. The law has been deemed to be an example of progressive legislation, capable of integrating a public policy intended to guarantee the ethical-legal conduct of public servants and the administrative prosecutorial measures that take place in the absence of compliance with the established ethical standards.
To be sure, throughout its twenty years of history, the law has been amended significantly, in order to develop, expand and further clarify the rules that public employees’ and officials’ must acknowledge and comply with in the exercise of public functions, and in their private (regulated) affairs as well. In what follows, we provide a general overview of the basic organizational and operational architecture of the aforesaid Law and its main institutional component, the Office of Government Ethics of Puerto Rico (OEGPR).
The scope of the Government Ethics Law
The Puerto Rico Government Ethics Act applies to all the public servants of the Executive Branch of Government, which includes central government agencies, public corporations, municipalities, municipal corporations, and municipal consortia. Moreover, the Code of Ethics contained in the law sets forth specific restrictions in the affairs of former public servants from all three branches of government: Executive, Legislative and Judicial. According to the Law, the office of Government Ethics has jurisdiction over certain and specific Government officials in all three branches, as to the scrutiny and review of the financial reports they must submit. In the case of the Executive Branch, should a review of such documents reveal any irregularity, or should any conflicts of interest be ascertained, the Office will investigate, and following the due process, subsequently penalize the public servant in question. In the case of a financial report submitted by an official of the Legislative or Judicial branches, if an irregularity is found, the Office refers the matter to the appropriate committee, so that it may proceed according to its own Code of Ethics and applicable regulations. There are approximately 250,000 public servants to whom the Government Ethics law applies. Out of such a population, approximately 10,000 must submit financial reports.
Legal Objectives of the Law
The Puerto Rico Government Ethics Act has four essential purposes, predicated on of one fundamental objective, which is to restore the People’s trust in government.
• To promote and preserve the integrity of public servants and Government institutions.
This purpose grounds the responsibility to design plans and strategies geared toward producing the educational measures needed as to educate the public service in the understanding of the law, the prevention of corruption, and the development of the administrative and organizational performance of the men and women in charge of conducting public affairs. The educational strategies for both public servants and private citizens have long-term goals. To the extent that public servants acknowledge and learn the binding rules and laws applicable to their public and private affairs, they will be capable to make decisions and act according to the standards set to guarantee the optimal quality of public service. Although ignorance of the law does not exempt a person from compliance under the local legal order, the possession of relevant and effective knowledge allows for greater opportunities to understand, deliberate and conscientiously assume public responsibility.
• Guarantee respect for the law and obedience thereof
The State is responsible for the country’s social order and the citizens’ well-being. The implementation of a Code of Ethics for public servants offers the people a guarantee that those who are called upon to manage their patrimony will do so under high and honorable standards, thus ensuring excellent quality services.
• Prevent public servants, acting on behalf of the Government, from profiting out of the People’s patrimony.
- Chapter IV of the law provides for certain and specific functionaries to submit reports to the Office as to their personal finances. Through the reception and detailed review of these financial reports once every year, the Office monitors and verifies the public servants´ financial conduct, within the applicable administrative and constitutional framework.
• Prevent conflicts of interest on the part of public servants.
A conflict of interest is defined as a clash or contest between a public servant’s private interests versus the public interest. The Code of Ethics of the law seeks to protect the public interest by setting rules intended to inform effectively the conduct of public employees at all times, as to determine their relevant decisions and actions, to assure compliance with the established standards, the general well-being of society and the safekeeping of the optimal public interests.
The Outreach of the Law and the Prevention Program
As we have observed, the goal of the four purposes outlined above intend to restore the People’s trust in Government. In order to achieve this objective, the Office has four operational work areas or units: The Center for the Development of Ethical Thought (CDET) and the Legal Counseling Area, integrate the Prevention and Educational Program; the Financial Reports and Complaints Area, and the Investigative and Administrative Processing Area, conform the Audit and Enforcement program.
As we stated earlier, one of the purposes of the Government Ethics Act is to promote and preserve the integrity of the public servants and the government institutions of Puerto Rico. This purpose constitutes the foundation of the Prevention Program, the Office has designed in order to counter the problem of governmental corruption. Furthermore, Section 2.4(r) of the law specifically endows the Executive Director of the Office with the power and duty “to provide information and promote the dissemination and understanding of the ethical standards for the agencies, in order to inform the public and to educate and guide public servants and private citizens as to the normative standards of the Law and the functions of the Office and governmental ethics in general.”
Indeed, the Office has a duty to establish public policies and create programs that encourage ethical and moral conduct among the public servants. Section 2.4(a) of the Puerto Rico Government Ethics Act mandates the following:
1. The establishment of criteria for excellence, personal integrity, honesty, accountability, responsibility and truthfulness in public affairs, in order to inspire, foster, and restore the citizens’ trust in government institutions.
2. The commitment on the part of all public servants not to place personal interests above public interests, and to eliminate all practices of illegality, discrimination, fraud, or administrative mismanagement.
3. The continuous support and implementation of education, training programs and workshops to facilitate compliance with the merit system, and to achieve excellence and professionalism in public service.
All public servants are to conduct themselves with an attitude of respect, courtesy, and concern for the needs of the citizens beyond the officer or employee’s personal convenience.
To protect all confidential information to which a public servant has privileged access as part of his/her responsibilities.
Motivate all public servants to exercise the maximum discretion allowed, according to the criteria of excellence, and in so doing, to promote governmental efficiency and the optimal public interest.
The Office has a duty under the law to develop and implement a Prevention Program that reinforces moral and ethical principles, in order to establish a strategy that will insure the integrity of the public servants, and thus assure the good quality of the services rendered. Through the analysis of the legislative history of the Government Ethics Act, we find that it was conceived as a measure that would provide the mechanisms to promote the legal and integrity standards needed for the effective prevention of governmental corruption. Pursuant to this policy, the Administrative Bulletin of March 25, 1996, OE 1996-16, instructed all government agencies to create their own ethics committees. Thereafter, Public Law No. 157 amended the Law of Government Ethics as to include Art. 2.6. This norm specifies the role of the ethical committees in all the public organizations of the Executive Branch. The members of these pivotal workgroups include the agency’s Human Resources and Personnel Director, the Legal Division Director, the Internal Auditor, and the Liaison Officer, -who facilitates the communication between the committee and the Office- among others, that may be designated by the head of each agency. The inclusion and effective participation of high-ranking officials in the committees, guarantees the agency’s capability to motivate all the personnel, at all levels, to engage in activities and practices that promote optimal ethical behavior.
The ethics committees coordinate their activities according to the standards established by the Government Ethics Office, which directs and supervises the work plans said committees prepare according to the following objectives:
• To promote the dissemination and knowledge of the law and the various agencies’ codes of ethics among their public employees.
• To promote the proper work environment to achieve efficiency and excellence in the services they offer.
As we have explained earlier, the Office not only investigates and penalizes misconduct on the part of public officials and employees who act counter to their sworn duties and against public morality. The Office also has the tools, provided by the law and regulations, to encourage and foster good behavior and obedience of the laws on the part of public servants.
In the Office of Government Ethics, the CDET is the Area in charge of producing the academic educational framework for enhancing the ethical culture of the public service. This unit oversees compliance with a plan divided into three principal areas, all of them aimed at promoting the law and developing the potential of the public servants, based on knowledge of the law and the public service, academic research and publications, communication strategies, the design of courses, seminars and workshops, and the follow up of the work plans of all the ethics committees.
The Office of Government Ethics of Puerto Rico (OGEPR) has reassessed and developed its preventive measures through the instrumentation of educational initiatives geared to enhance the ethical culture of the public service of the Executive Branch of the Commonwealth of Puerto Rico. The (CDET) is an educational governmental entity, operating under the auspices of the OGE, and in charge of producing research on the ethical conditions of the public service, as well as designing interdisciplinary courses, seminars and workshops dedicated to the diffusion of government ethics, the development of public administration and the analysis and discussion of ethics in general.
The specifics of the aforesaid educational initiatives include, among others, traditional classroom type lectures; permanent television, radio and internet programming; periodical publications; several research initiatives that include comparative analyses on government ethics, law enforcement measures and empirical research on the ethical climates of all the governmental organizations of the public service. Moreover, the CDET produces an academic journal (Ethos Gubernamental). The first number was dedicated to the foundation and structure of the normative ethical discourse and its impact in contemporary public affairs. The second number was dedicated to the publication and analysis of the empirical research conducted by the Ethics Resource Center of Washington DC and the OGEPR, on the ethical conditions of the public service. The third number addressed the issue of ethics and policy in the contemporary world. The fourth number examines globalization, public health and governance, the ethical challenges posited by the development policies of the 21st century; it will be formally presented on March of 2007. During the five years of the instrumentation of the policies geared to advance the continuing education requirements contained in Art. 2.7, well over 790,118 employees and officials have taken courses or have been exposed to one or several of the educational frameworks offered by the CDET. The new curriculum of the CDET includes courses on normative aspects of the ethics code, ethics and strategic management, ethics and public service, ethics and human resources, supervision and leadership, the ethics of mediation, governmental values, fundamental rights and the workplace, governmental development, public decision making, quality of life, emotional intelligence and the workplace, administrative knowledge and the workplace, among many others.
The design and instrumentation of all these educational and academic initiatives are in tune with Public Law 13 of April 11 of 2001, which amended the Government Ethics Law of Puerto Rico, by including Art. 2.7. This normative disposition established the obligation of public servants to take 10 hours on public ethics, government ethics, ethics and the administration of public funds and property every two years, and by elevating the existing CDET of the OGEPR to the rank of law.
The Office publicizes the law and the services offered through the communications program. The CDET prepares the educational materials to be distributed in the courses, seminars and workshops. These materials are solicited by private individuals and groups as well. The Center works on the design of brochures, posters, newsletters and special announcements in relation to the standards of ethical conduct. Some of the pedagogical instruments of this program are:
• Conética Newsletter
This newsletter is published periodically, and reaches all agencies and municipalities. Each publication amounts to approximately 50,000 copies. The instrument plays a key role in keeping public servants up to date in the latest affairs of government ethics.
• Ethics Week
Every year, pursuant to a Governor’s Proclamation, the Office celebrates the Government Ethics Week. During this period, the CDEt, an the ethics committees of all public agencies, conduct high profile activities for the benefit of all public servants. Specific activities are held for upper and intermediate management, as well as for mayors and their representatives. To these ends, the Office organizes colloquia and forums on current topics dealing with government ethics, policy affairs, organizational, administrative and public development issues. And invites prominent and respectable Government representatives, community members and other professionals to speak and held workshops or discussant groups.
• Acknowledgment of Liaison Officers
Liaison officers are designated by their heads of agency upon request from the Office of Government Ethics’ Executive Director, to establish and coordinate relations in those areas in which we must have the collaboration of a contact person or group within said agency or municipality. Liaison officers have a relationship with the Office mainly in regards to facilitate the compliance by their agencies’ officials as to the timely submission of the financial reports, and the coordination of training or educational activities for the employees. These tasks, among many others, are part of the duties and responsibilities outlined in the applicable Circular Letters issued by the Office. This type of work is in addition to the specific responsibilities each public servant must comply with, and they receive no remuneration whatsoever for it. During the Government Ethics Week, the Office evaluates the performance of such unique officials, as to their contributions throughout the year, and conducts a special activity to acknowledge outstanding work. In so doing, the Office aims to motivate and promote the work of Liaison Officials who respond actively to their duties.
• Video Productions and Public Communication Programs
The Office produces relevant and competitive programming for the Puerto Rico Public Broadcasting Corporation. Programs dealing with contemporary ethical and axiological issues, and the identity, duties, rules and regulations of the Office, its services and standards of conduct. The programs are broadcasted the second Tuesday of each month. The video material is prepared and provided for agencies, universities and schools throughout Puerto Rico. Furthermore, it is a fundamental tool in the continuing education process of public servants, particularly those who due to their work schedule are unable to participate in the traditional course, seminar or workshops offered as prime educational alternatives.
Also, the Office pursues the production of informational spots to be shown every Sunday during the 9:00 p.m. newscast of the Public Broadcasting of Puerto Rico. These spots will offer information about the public policy established by this Office, on the basis of the experience acquired and the cases this Office has adjudicated.
• Web Page
Our Web Page, www.oegpr.net, is competitive and interactive, highly descriptive of all relevant initiatives, and constantly being reviewed as to keep it up to date. It offers information about the law, the Office and its services to all Internet users, and thus contributes to the constant flow of information. It includes spaces devoted to the detailed explanation of the services, analysis of relevant cases, opinions or resolutions. Likewise, users are able to communicate with the Office, and bring up their own particular issues and concerns.
Ethics Committees Program
The CDEt is in charge of coordinating the work plans and tasks submitted by the ethics committees of all agencies executive agencies, pursuant to Art. 2. 6 of the Law.
Currently, all central government agencies have created their own committees. As of this date there are 210 ethics committees, including those operating from the public corporations and municipalities.
Some of the activities included in the committees’ work plans are the following:
• Distribution of the Government Ethics law and its Regulations to new employees.
• Delivery to functionaries who cease their functions of the code
standards applicable to former public servants.
• Distribution of the informational materials on the law to all agency or municipality employee, and recording of the names of those who have received these materials.
• Coordination of informational sessions with the Office of Government Ethics, to offer these sessions to agency employees. Many agencies include these activities as part of their continuous personnel training throughout the year.
• Review of the agency’s internal regulations and control measure to keep them in harmony with the ethical conduct standards under the law.
• Verification that the agency or municipality is in compliance with the corrective action plans that must be submitted to the Office of the Comptroller of Puerto Rico, according to the recommendations made through the follow up interventions.
• Carry out special activities which communicate to the employees the agency’s mission and vision, and motivate them to act with diligence and efficiency.
The Office verifies compliance with the work plans submitted by the agencies, by reviewing the progress reports they must submit periodically. Moreover, the employees of the Center for the Development of Ethical Thought visit the agencies as a means of corroborating the work they have done, which is described in the progress reports.
The above is, in broad strokes, a description of the tasks conducted by the CDET of the Office of Government Ethics, engaged completely in the guidance and prevention program against corruption. Currently the CDET is organized in two areas –administrative and academic- eleven Ethics Technicians, one Training Technician, two Executive Secretaries and two administrative secretaries, carrying out these tasks under the supervision of two Assistant Directors. The latter are in charge of conducting the administrative and the academic affairs respectively. The Center also integrates a Division in charge of the registration processes associated with the obligation to comply with the continuing education requirements established in Art. 2.7., as well as the online education component of the CDET. This division is integrated by an Aid of the Executive Director, six employees in charge of registering and verifying pertinent data, and one secretary.
Section 2.4(n) of the Puerto Rico Government Ethics Act provides for the Office’s responsibility to establish an opinion service on specific matters or general issues on the law. The Office’s Legal Counseling Area is in charge of providing assistance to any request of opinion on the applicability of the law. At this time the Area has eight Legal Counsels, two Executive Secretaries, and one Administrative Secretary, under the supervision of a Principal Legal Counsel.
According to the Opinion and Consultations regulations (Regulations No. 5292 dated August 8, 1995) any executive agency or person may request a written opinion regarding a specific matter of his or her concern.
Furthermore, the Legal Counsel Area responds to all questions, doubts and information requests, by telephone or in person, so as to contribute effectively to the optimal quality of public ethical decision making. Nevertheless, only a written opinion signed by the Executive Director is considered a formal an official position of the Office.
The Director issues opinions about matters that are generally applicable, or which may interest a considerable group of individuals in the service. The same matter can also be dealt with through circular letters. In addition, opinions are rendered on specific matters brought to this Office for consultation, mainly those related to the conflict of interest provisions. There are a number of requirements that must be met in order to submit a request for an opinion. Every request must be addressed to the Executive Director and include the following:
• Full name, address, and telephone number of the person making the request. In the case of an executive agency, it must be signed by the head of the agency.
• Full name, address and telephone number of the authorized representative.
• It must be in writing and signed.
• A detailed narrative of the facts that give rise to the request.
• All the documents related to the request.
• In the case of an opinion requested by an executive agency, a legal brief explaining the official position.
Other tasks carried out by this work unit are:
• Preparing, for the Executive Director’s approval and promulgation, the regulations needed in relation to the law.
• The drafting of circular letters, memoranda, communications and other special requirements for the Executive Director’s consideration.
• Conducting legal research on judicial matters related to the law.
• Working on position papers concerning bills of law on which the Legislative Assembly requires the participation and analysis of the Office.
A Cursory look at the Audit and Enforcement Program
As we stated earlier, our Office has a ministerial duty to comply with a dual function of preventing governmental corruption. In addition to these measures implemented through the CDET, and the Legal Counseling Area, the Office has the power to investigate cases brought to the Office concerning possible violations to the Government Ethics Act. This function is exercised through the Office’s Complaint Area, which has attorneys who conduct the evaluation and formal investigation of the matters referred to them.
Any private citizen or public servant can ask the OGEPR to initiate an investigation about a possible violation to our charter law. That request can be made through a written sworn complaint, which must include all the facts that form the basis for the investigation request. Other sources of information and investigation are:
• the financial reports in which any irregularities or conflicts may be detected.
• the intervention of reports received from the Comptroller’s Office
• the reports from the Legislative Assembly’s Joint Commission on Comptroller’s Special Reports
• by the Executive Director’s own initiative (motu propio)
- confidential tips
news media reports
As previously stated, the Financial Reports Area is the other work unit related to the Audit and Enforcement program. That unit examines and studies the financial behavior of certain officials and employees within our Government who have an obligation to submit financial reports to our Office. As we pointed out in the beginning, the Office audits approximately 10,000. If any irregularity or conflict can be detected in the review process of any financial report, the Audit and Financial Reports Area refers the matter to the Complaints Area for the appropriate investigation. Nevertheless, the analysis conducted by this unit can also be considered a preventive measure, since any sign of a possible conflict of interest on the part of a functionary will lead to the appropriate warnings so as to put a stop to the situation immediately. Finally, we must underscore that the OGEPR maintains a close collaboration with all relevant and federal entities engaged in the prevention and prosecution of governmental corruption.
Fundamental Components in the Implementation of an Ethics Program
The organization entrusted with the delicate task of administering and enforcing
the ethical standards that must govern the behavior of public employees, must
first be recognized as a model and example of integrity. The procedures carried out, the actions taken and the decisions made representing the best interests of the people must be impeccably transparent. In the local experience, only then can the organizations engage in the public ethics agenda earn the respect and admiration of the public servants and society at large.
An Ethics Office cannot be seen as a public relations office for the government, trying to clean up its image only on the outside while overlooking matters of true substance. The ethics office leaders and directors must consciously undertake the responsibility of their position, understanding that the decisions made and the actions carried out respond solely to the people’s need to recover and maintain their trust in Government.
A Code of Ethics must be part of every day life for every public servant, it should not be one more document posted by a government agency’s doorway so everyone coming in sees it and assumes those who work there are ethical. The Code of Ethics and its standards must be made known to every public servant so as to prevent improper and criminal conduct.
Within a much broader plan, contemporary democratic governments are establishing ethics offices and bodies that reinforce the ethical principles and values universally acknowledged. Governments have recognized the need to strengthen the pillars of honesty, responsibility and commitment on the part of public servants so the people can be guaranteed fair treatment, security, the safeguarding of their general well-being, social order at all times, and guaranteed liberties for every citizen.
In the new century, the organizations in charge of managing the codes of ethics of the public service will be the leaders that set the guiding foundations for future generations.
For all of these reasons, it is all to fait to suggest that the creation of these governmental bodies becomes even more important, and that there are certain elements that become indispensable in order to achieve effectively these goals encompassed in the purpose of restoring and recovering the people’s trust in the work of their governments. In our judgment, those elements are:
• Complete administrative autonomy and fiscal independence
In the case of the Puerto Rico Government Ethics Act, provisions were made for our Office to adopt and approve its own internal regulations about personnel, accounting, and others. In this way, our Office is free from statutory obligations and legislation the general Government may approve to be managed by other bodies, which in turn are under the Office’s jurisdiction. By having our own regulations and being free from other bodies’ intervention, the Office is neither tied to nor compromised by any particular body that could, at some point in time, be the target of an investigation conducted by this Office.
Nevertheless, the Office is monitored by the Department of Justice and the Comptrollers Office. Also, the Office has the legal capacity to sue and be sued.
On the other hand, the Government Ethics Act states that, in order to assign funds, current expenses without revisions shall be included in the budget calculations made by the Governor. In this way, the necessary funds to conduct our tasks are secured, without revisions to those funds already committed. This insures our total fiscal independence. Concerning the financial resources we have at the Office for the new fiscal year (2006-2007), it reaches a total of $ 9,890,000. The Office continually performs need assessments, as to deal with the needs that merit immediate intervention.
• Rigorous and Zealous Process in the Selection of the Executive Director or the Office of Government Ethics
- The Puerto Rico Government ethics Act provides for a process to select candidates and the subsequent appointment of the official who will fill the position of Executive Director. According to the law, the Secretary of Justice must gather a panel of five former judges from the Supreme Court, so they may evaluate the candidates. The panel must submit a list of at least three candidates for the Governor’s consideration, within thirty days. Should they fail to meet this requirement on time, the Governor may then make the appointment himself.
The Governor submits the appointment to the Legislative Assembly, where the Senate Nominations Committee and a special commission from the House of Representatives pass judgment on the appointment and confirm or deny it. It is important to point out that the position of Executive Director for the Puerto Rico Office of Government Ethics is one of the few appointments in our country that requires confirmation from both legislative houses. Other positions that have the same requirement are the Comptroller and the OMBUDSMAN.
The Executive Director of this Office may not;
(a) Contribute money, directly or indirectly, to political parties or organizations,
(b) Campaign for or hold any position within a political party’s leadership or political organization, nor run for any elective public office.
(c) Participate or collaborate, directly or indirectly, in any political campaign of any kind.
(d) Influence on any decision by any government functionary, except when it is part of his/her official functions.
On the other hand, the Director can be removed only for the following reasons;
(a) Immoral, unlawful, or reprehensible conduct, or engaging in conduct specifically prohibited under the law as it concerns his/her position.
(b) Manifest incompetence or professional ineptitude in the performance of his/her duties and functions.
(c) Conviction for any felony or misdemeanor involving moral turpitude.
Manifest abuse of the authority or discretion conferred by this or other laws.
Forsaking his/her duties.
The Director may be removed from office due to physical or mental incapacity. Removal in this case will be deemed a voluntary resignation for all legal purposes and consequences thereto.
The Director can only be removed or severed from his/her position by bringing up formal charges before the Supreme Court, which will establish the procedure to be followed and will make the appropriate decisions in the matter.
We believe a highly rigorous process to appoint the Executive Director of the Government Ethics Office is necessary, since the position entails the delicate responsibility of promoting and preserving the integrity of our government’s public servants. That official becomes the principal role model of moral integrity for all public servants and the people at large, both on a professional and on a personal level. This way our law guarantees that the person designated to direct the Office of Government Ethics will be guided in his/her actions and decisions solely and strictly by these principles.
In order to achieve greater effectiveness as we meet the objectives contained in the law, the OGEPR has joined efforts with other government bodies with purposes similar to ours. This is how the concept of the Alliance Against Corruption came about, which brings together the Office of Government Ethics, the Comptrollers Office and the Department of Justice, as well as the Department of the Treasury and the Federal Bureau of Investigation. The OGEPR sustains collaboration agreements with each one of these agencies, in order to tend to those cases in which officials and employees act against the public interest. In order to maximize the agreements, the participating institutions have agreed to collaborate in the training of the relevant human resources, as well as in the exchange of information.
We can measure the level of effectiveness of the work done by this Office on the basis of the results obtained from the prevention and monitoring efforts. The effective dissemination of information about the law and the applicable regulations, increases significantly the number of requests for consultations, opinions, and complaints. Thus we may conclude that the prevention program has been effective in its purpose of advising public servants about the applicable standards and their duty to report any situation that could result in a violation of the Government Ethics Act.
Throughout its history, the Office has tended, until the month of November of 2006, 2,431 complaints, and has imposed a total of $1,408,000 in administrative fines. The power of the Executive Director of the Office of Government Ethics to impose administrative sanctions is one element that accelerates the steps required to process cases administratively when the law has been violated. This initiative has been beneficial, given the effect it has provoked on other public officials and employees, as to comply strictly with the standards imposed by the law.
Ultimately, the articulation of an effective public ethics program is proportional to the optimal balance between preventive and prosecutorial policies, articulated through a rigorous and exhaustive legal order, with the capacity to grow in time. Moreover, it requires institutional strength, an inclusive strategic vision, and a deep sense of commitment from all the human resources engaged in the project, as well as the acknowledgement and collaboration of society at large.