At today's session, the Council of the Agency for Prevention of Corruption adopted the Work Report of the APC for 2022, as well as the Report on the execution of the APC Budget for 2022.

It was assessed that the Agency continued to achieve measurable results in all areas of work, as evidenced by the data that all the goals outlined in the Work Plan were met, and in some areas they were exceeded.

The positive trend in the work of the Agency was carried over to 2022, which was practically the most effective in all segments since the establishment of the Agency.

In the area of ​​preventing conflicts of interest and restrictions in exercising public functions, the Agency, acting on all received requests, issued a total of 213 Opinions on the existence of conflicts of interest and restrictions in exercising public functions, by 14.5% more than the previous year and the most on an annual basis since establishment. Based on the given Opinions and the Agency's Decisions, 24 resignations of public officials were submitted.

Due to the proactive and preventive action of the Agency in the segment of reporting received gifts, sponsorships and donations, in 2022, 42% more donations were reported compared to the previous year, an increase in reported gifts was also recorded, and the number of reported sponsorships was higher as well.

In 2022, a total of 11,784 statements on income and assets were submitted to the Agency on various basis of submission, by 10.6% more compared to the previous year and the most since the beginning of work. The growth in the number of submitted statements is a consequence of the increase in the number of public officials, as well as the greater number of statements submitted by public officials upon termination of office. The work on checking the accuracy and completeness of the data in the statements was also intensified, so 59.6% more statements were checked compared to 2021, and significantly more compared to the previous years of Agency’s work.

The additional verification, the most complex type of control of income and assets of public officials, was fully completed, which refers to 20 high-ranking public officials, chosen in accordance with the degree of vulnerability of the area / function to corruption. In connection with the additional verification that began in the 3rd quarter of 2021, 12 procedures were completed and violations of the law were found in all of them. When it comes to monitoring the lifestyle of public officials, the Agency submitted one case to the Special State Prosecutor's Office in 2022.

Due to possible violations of the Law in this area during 2022, 43.4% more administrative procedures were initiated compared to the previous year. And the number of misdemeanor proceedings initiated in 2022 in this segment of APC work is significantly higher compared to the annual level of all previous years of work, which was primarily generated by intensive work and a proactive approach. With a non-selective approach, APC initiated misdemeanor proceedings against both former (519) and current public officials (534).

In the field of financing political entities and election campaigns, the Agency continued to implement activities in a planned and systematic manner with the aim of consistently monitoring the implementation of the LFPEEC and controlling the implementation and compliance with all prescribed prohibitions and limitations during the election campaigns for the local elections held in 2022.

In accordance with the adopted control plans and methodologies, despite the legal restrictions due to which it could not initiate misdemeanor proceedings in all cases in which irregularities were found, in 2022 the Agency initiated 67% more misdemeanor proceedings for violations of the LFPEEC compared to the previous five years of work altogether.

A high degree of implementation of the Agency's Work Plan for 2022 in the area of ​​adoption and implementation of integrity plans can be noted, bearing in mind the conducted activities and the high percentage of authorities that have fulfilled the obligations stipulated by law. Specifically, since the beginning of work, 98.9% of authorities have adopted an integrity plan and submitted it to the Agency, 99.1% of authorities have appointed an integrity manager, the questionnaire for assessing the efficiency and effectiveness of the integrity plan was filled out by 637 authorities, and 704 reports on implementation of integrity plan in 2021 were submitted.

In November 2022, the Agency, in cooperation with UNDP, developed a Methodology for assessing the application of anti-corruption measures in the judicial system, with the aim of improving the content and effects of the integrity plans of judicial bodies. The APC originally developed the Methodology for assessing the application of anti-corruption measures in 2021, applying it to two systems: state administration and social and child protection. It is planned that in the following period the Methodology will also be applied to authorities from the other seven sectors.

In 2022, the Agency continued its activities to amend the existing legal framework regarding the control of lobbying activities and further promoted the institute of lobbying by organizing new exams for potential lobbyists. Three calls for candidates to take the lobbying exam were announced and three exams were organized. In 2022, nine individuals passed the exam, four of whom were enrolled in the register of lobbyists. Currently, there are nine natural persons and one legal entity enrolled in the register of lobbyists. With the expert support of the Council of Europe, work was actively carried out on the drafting of the Draft Law on Lobbying and its accompanying by-laws.

In 2022, the Agency received 188 whistleblower reports, which is 32.4% more than in 2021 and the highest observed on an annual basis since the establishment of the Agency, which continues the trend of increasing the number of reports.

In 2022, 81 procedures based on whistleblower reports were concluded, of which five were found to involve a threat to the public interest. The Agency forwarded 12 whistleblower reports to the competent prosecutor's offices for further action and 34 to other competent authorities. For two reports forwarded to the competent prosecutor's offices in an earlier period, feedback was provided that an investigation had been initiated. Additionally, APC initiated nine proceedings ex officio due to suspicions of a threat to the public interest indicating the existence of corruption, and continued work on four ex officio proceedings from 2021. Six proceedings were concluded, and a threat to the public interest was found in all of them.

In 2022, the Agency received seven requests for whistleblower protection, and work continued on one protection request from 2021. Opinions were issued in two cases where damage was found to have occurred or there was a possibility of harm to the whistleblower.

The Agency demonstrated its commitment to the public interest by using regulatory analysis, and in that segment, it particularly intensified its work in 2022. In total, it analyzed 30 regulations, which is three times more than in the entire year of 2021 and more than in all previous years combined.

In 2022, three initiatives were sent to holders of executive and legislative power - two initiatives were proposed for the introduction of Preliminary Control of Corruption Risks (CPL Checklist) as mandatory in the procedure for drafting proposals for laws determined by the Government of Montenegro, as well as in the procedure for proposing laws by MPs independently or on behalf of six thousand voters; as well as the initiative for unifying the legal framework that regulates the most important issues of governance, supervision, real and potential conflicts of interest, and transparency of the work of public enterprises management bodies.

In cooperation with UNDP, the Agency has been actively working on improving the Methodology for Corruption Proofing in Montenegro, in order to determine areas at risk of corruption, especially the part of the Methodology related to the risk list, all aimed at facilitating a more objective identification of future legislation that will be subject to the Agency's analysis. From November 2022, the APC, in carrying out the anti-corruption assessment of the law, bases its opinions primarily on the innovative methodology for the analysis of regulations.

Intensive work has continued in the field of administrative proceedings, and in 2022, 444 administrative proceedings were initiated against public officials, which is 28.7% more than in 2021 and significantly higher than the annual levels of 2018, 2019, and 2020. The percentage of established legal violations is significantly higher in 2022 compared to the annual level of the previous four years of the APC work.

In 2022, the Administrative Court issued 48 judgments in proceedings related to lawsuits against the Agency's acts, in which 41 decisions were upheld and the lawsuits were dismissed as unfounded, 5 decisions were annulled and the case was returned for re-examination, and in 2 cases, the proceedings were suspended.

In 2022, due to violations of anti-corruption laws, the Agency submitted a total of 1,556 requests to competent misdemeanor courts for initiating misdemeanor proceedings, which is 34% more than in 2021 and significantly higher than the annual levels of previous years. This was primarily generated by a large number of initiated misdemeanor proceedings in the field of income and asset verification, but also by a significant increase in the number of initiated proceedings for violations of the LFPEEC. Sanctions were imposed in 92.6% of completed cases, and the total amount of fines imposed is 103,590€.

In 2022, special emphasis was placed on the intensive implementation of educational activities on various topics within the Agency's jurisdiction. It is important to note that this year, the Agency independently and in cooperation with other institutions organized a total of 29 trainings, the highest number on an annual basis since the establishment of this institution.

According to the results of the public opinion survey "Public attitudes towards corruption and familiarity with the work of APC", conducted by the Defacto Consultancy agency on behalf of the APC, the APC is ranked first among institutions in which citizens would have the most trust if they decide to report corruption. Cumulatively, 63.5% of respondents answered that they trust the work of the APC, while 68.5% of respondents answered that the Agency has contributed to the overall fight against corruption.

The APC continued to improve its public relations work. The Agency was intensively covered in the media during the past year, with a continued trend of significant improvement in its media image. For the first time since the institution's founding, there were more than a thousand positively-toned publications in a year, and their number exceeded the sum of the previous two years, surpassing the number of negative publications by two and a half times. Compared to earlier periods, the Agency better controlled its media presence, with the share of planned placements being higher than unplanned ones for the first time.

In the spirit of deepening inter-institutional cooperation and strengthening the systemic response to corruption, the Agency has maintained intense cooperation with state institutions. In order to further develop cooperation with the civil sector, which contributed to improving the accountability and reputation of the APC, Agency representatives worked intensively with representatives of the non-governmental sector.

The presented results of work are also a result of the application of all methodologies, projects and expert knowledge that the Agency continuously receives from international partners.

As part of the Project for the Fight against Economic Crime in Montenegro, APC, in cooperation with the Council of Europe, started a comprehensive analysis of the LPC, which is being carried out in three phases. With the support of UNDP in Montenegro, the Strategic Plan of APC 2022-2024 was adopted, while with the support of experts engaged within the II phase of the Horizontal Facility (Council of Europe and EU), the Communication Strategy of APC 2023-2025 was developed.

Thanks to the support of the US Embassy in Podgorica, the project "Implementation of ISO 9001:2015" started in the Agency in May 2022, which was successfully completed in November. The implementation of ISO standards will contribute to improving the quality of employees' work, motivation and coordination of work processes and their compliance with international standards.

The overall progress of the Agency in the past period has been noticed and supported by European partners.

In the latest report by the European Commission, published in October 2022, it is stated that " track record on prevention of corruption further improved, in particular due to the positive trend in the work of the Agency for Prevention of Corruption." The document also recognized the consistent proactivity of the Agency and the Council, as well as increased activities on the ground towards the public, media, and civil society, and emphasized that the capacity of the APC has been further strengthened, which has "produced improved performance and increased efforts to achieve tangible results."

In October 2022, the GRECO Evaluation Report for Montenegro was published as part of the 5th round of evaluation, in which it is stated that under the new management, the performance of APC has improved, as well as that "functioning is moving in the direction of greater independence, efficiency and a more proactive approach".

The Agency's budget for 2022 was EUR 1,809,298.00, of which EUR 1,507,360.53 (83.31%) was spent.