Strategy 2026–2028 to Combat Corruption in Senior Executive Positions in Monaco (GRECO 5th evaluation round)

The 2026–2028 Anti-Corruption Strategy for senior executive positions in the Principality of Monaco, accompanied by an operational action plan, implements the recommendations of the Council of Europe’s Group of States against Corruption (GRECO) as part of the 5th evaluation round on the theme of "Prevention of corruption and promotion of integrity within central governments (senior executive positions) and law enforcement agencies" (GrecoEval5Rep(2023)8). (Government press release of 1 June 2026)

See in addition our publications:

• GRECO • Developments in the fight against corruption in Monaco (2024-2026)
• Principles and rules governing the ethics, professional conduct and compliance of members of the Government (Sovereign Order 9.931 of 15 June 2023)

SUMMARY

Objectives of the Strategy and Operational Action Plan 2026–2028

The 2026–2028 Anti-Corruption Strategy for senior executive positions has five objectives:

1. To extend ethical oversight;
2. To consolidate a culture of integrity among public decision-makers;
3. To enhance the transparency of activities falling within the remit of executive functions;
4. TO create a legal framework to protect “whistleblowers”; See our publication Bill No. 987 relating to the protection of whistleblowers in the labour relations context
5. To enhance transparency in public procurement and prevent, within the framework of procedures, the risks of conflicts of interest.

The implementation of a three-year action plan (2026–2028) setting out the actions to be taken by the relevant departments and authorities will enable these objectives to be achieved. A table (V. Operational Action Plan 2026–2028) details the responsible parties, deadlines and monitoring indicators for all the measures and actions identified under the strategy.

At the end of the 2026–2028 period, a general review will be carried out to assess the impact of the Strategy and outline future prospects.

Scope

The scope of public office covered:

• ministerial posts: Minister of State and Government Advisers-Ministers;
• senior non-ministerial executive posts: Secretary-General of the Government and his Deputy, Chief of Staff to the Minister of State, Director-General of a ministerial department;
• Justice: Secretary of State for Justice;
• Prince’s Palace: Secretary of State, members of the Prince’s Cabinet, Advisers or Special Advisers, Administrator of the Crown’s Assets.

IN DETAIL

1. Extending ethical oversight

New responsibilities will be assigned to the ethical oversight bodies (the Ethics Committee - "Comité d'éthique" established under the Minister of State by Sovereign Order No. 9.931 of 15 June 2023, its Chair, and the Chair of the Higher Commission of Auditors - "Commission Supérieure des Comptes").

→ Strengthen the monitoring of declarations of private interests and previous activities to prevent conflicts of interest upon taking office and during the course of their duties:

• Extension of the declaration obligations, previously applicable only to Government Ministers, to all persons holding senior executive positions.
• Establishment of an integrity check to ensure that disclosure obligations are properly fulfilled, to verify the formal correctness of the declaration, and to assess whether the declarant is in a situation that could constitute an actual, potential or apparent conflict of interest.
• For members of the Government and the Secretary of State for Justice, declarations of interests will be made public in respect of information where disclosure to the public does not unduly infringe upon the right to respect for private and family life.

→ Extending ethical oversight to the end of a person’s term of office:

• Prevention of conflicts of interest in the event of a career change or transition for all individuals holding senior executive positions.
• New mechanism governing the mobility of public officials who are to pursue their careers in the private sector: submission to the Ethics Committee of a detailed description of their future activity (within two years of leaving public office), which will issue an opinion on compatibility or incompatibility, which may be made public in the event of non-compliance with this opinion by the declarant.

→ Strengthening the scrutiny of financial interests:

• Extension of the scrutiny of financial interests by the President of the Higher Commission of Auditors, previously applicable only to members of the Government, to all persons holding senior executive positions.
• The scrutiny of asset declarations will now go beyond formal checks to ensure the accuracy and completeness of the information provided, with a view to identifying any omissions or changes in assets that cannot be adequately explained by the officeholder.

→ Ensure that the Ethics Committee and the President of the Higher Audit Commission have the necessary resources to carry out their duties:

• Allocation of human, material and financial resources.

2. Strengthen a culture of integrity among public decision-makers

In addition to promoting clear ethical standards, this involves implementing a robust awareness-raising policy, training initiatives (both initial and ongoing), personalised advice, and the widespread adoption of ethical rules governing high-risk situations during the performance of duties (rules on recusal, acceptance of gifts, and holding multiple posts).

→ Training senior executives in professional conduct and ethics:

• All senior executives must undertake compulsory initial training (workshops and role-play exercises) upon taking up their post, and be provided with a guide to best practice (made publicly available).
• Followed by regular training in professional conduct and ethics, at least once a year.

→ Establish a permanent ethics counsel:

• Appointment of an ethics officer to provide confidential advice on ethical matters to members of the Government, the Secretary of State for Justice and certain senior civil servants within the Government administration.
• Chair of the Ethics Committee for staff of the Sovereign House.

→ Ensuring the management of conflicts of interest whilst performing official duties:

• Extending the rules and mechanisms for managing conflicts of interest, previously applicable only to members of the Government, to all senior public officials.
• In the event of actual, potential or apparent conflicts of interest, the person concerned must recuse themselves from handling the matter or refrain from taking part in the decision-making process.

→ Strengthening regulations on the acceptance of gifts and benefits:

• The general duty of constant vigilance, previously applicable only to members of the Government, is extended to all persons holding senior executive positions.
• The Ethics Committee is tasked with monitoring the proper maintenance of records of gifts and benefits received.

→ Clarify the rules on conflicts of interest applicable to members of the Government and the Secretary of State for Justice:

• Introduction of new rules on holding multiple posts applicable to members of the Government and the Secretary of State for Justice: a ban on carrying out any other paid activity (public or private) whilst in office.
• Exceptions may be made where the secondary activity is of an educational (e.g. teaching), artistic, literary, sporting or cultural nature.

3. Enhancing transparency in executive functions

The aim is to improve public access to information regarding government action, specifically concerning the publication of staff movements, the conditions under which legislative and regulatory standards are adopted, and communication with the press.

→ Making individual decisions on public sector employment accessible:

• Publication of appointments, designations and promotions to public sector posts: civil servants (already subject to publication of the Sovereign Order of Appointment in the Journal de Monaco) and staff on fixed-term contracts (to date, published via "real-time" updates to the official directory).
• In particular, publication on the Government’s website https://www.gouv.mc/ of new appointments to the Civil Service, changes and terminations of service.

→ Publication of the Council of State’s ("Conseil d'État") opinions:

• Publication of the Council of State’s opinions in the Journal de Monaco and on https://legimonaco.mc/
• Ensuring a better understanding of the legal, technical and political foundations that guided the drafting and adoption of laws and regulatory texts.

→ Inform the public about meetings between senior executives and lobbyists and influential third parties:

• Creation and publication of general digital registers for the relevant individuals within the Prince’s Government, the Directorate of Judicial Services and the Sovereign House, to ensure the traceability of lobbying activities and to strengthen the impartiality of public decisions taken in the context of legislative or regulatory work.
• Under the supervision of the Ethics Committee, mandatory registration in these registers will specify, for each reported meeting, the identity of the persons met and/or represented, the date and place of the meeting, the position advocated, and the draft text concerned.

→ Enhancing dialogue between members of the Government and the Secretary of State for Justice with the press:

• Regularly organising joint press conferences (Minister of State and Government Ministers) to provide a cross-cutting update on the Government’s agenda and priorities; Thematic meetings with the press (depending on the subject, involving the Minister of State or the relevant Minister(s)) to explore issues, timetables and expected impacts in greater depth, and to make public policy more accessible to the general public.
• Presentation by the Secretary of State for Justice of the year’s review and plans for the coming year in the presence of the media, at least once a year on the occasion of the opening of the judicial year; Throughout the year, interviews or press conferences addressing specific or topical issues relating to justice; improved access to justice ensured via social media, a dedicated website and the publication of information materials explaining how the justice system works, its activities and current projects.

4. Establishing a protective legal framework for "whistleblowers"

The aim is to establish a secure framework enabling anyone with knowledge of facts that may constitute offences, breaches or serious malpractice to report them without risking reprisals.

• Adoption in 2026 of Bill No. 987 on the protection of whistleblowers in the context of employment relationships (tabled in the Public Session of 3 April 2019 and currently under consideration by the Legislation Committee), which aims to establish a general framework for the protection of whistleblowers in both the public and private sectors.

5. Enhancing transparency in public procurement

This involves updating Sovereign Order No. 7.264 of 20 December 2018 regulating public procurement by the State, with regard to the procedures leading to the award of contracts and the implementing provisions laid down by ministerial order, in accordance with the enhanced transparency requirements recommended by GRECO and drawing on the key principles of public procurement enshrined in the United Nations Convention against Corruption of 31 October 2003 (not ratified by Monaco).

→ Strengthening publicity at the start of the procedure:

• Introduction of the principle of publicity for public service and supply contracts, involving the publication of a notice (in the Journal de Monaco or any other publication medium), setting out the details contained in the call for tenders.
• Introduction of new deadlines to improve the management of the procedure’s timetable.

→ Increase information provision during the procedure:

• Regulatory changes: introduction of a principle of prioritisation and weighting of objective award criteria; discontinuation of the practice of opening tenders in the presence of bidders; systematic communication of the grounds on which the Administration based its decision to reject a tender; obligation to publish a contract award notice for all contracts exceeding €200,000 excluding VAT (excl. VAT), including in particular the name of the successful tenderer.
  

→ Extending transparency to companies in which the State holds a majority stake:

• The State shall be subject to public procurement regulations when purchasing supplies, services or works from companies in which it holds a majority stake.
• Compliance by the State, within the framework of good governance of these companies, with the rules on transparency and competitive tendering for the award of certain contracts with third parties (contracts necessary to specifically meet needs of general interest of a non-industrial or non-commercial nature, and for the provision of a service to the public through the operation of networks).

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