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Anti-corruption procedures

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The Swiss-Polish Cooperation Programme delivers the programmes indicated by the minister of health and the minister of labour and social policy, submitted in the non-contest procedure. The Implementing bodies derive in most cases from the public finance sector and include also budgetary units, which decreases the corruption risk. To tackle corruption, the formal assessment of applications was performed by two employees of the Intermediate Body, whereas content-related assessment was performed by the experts, who signed the declaration of impartiality and confidentiality prior to verification.

Within the monitoring process of the delivered projects, the Intermediate Body audits the reporting documents. The audit is performed by two employees. Also the visits aimed at monitoring of the projects delivery is performed by at least two persons. The four eyes principle aims at double verification of correctness of the submitted documents, verification of projects delivery and elimination of corruption risk.

The meetings with the representatives of the Implementing bodies or any other external entities organized in the Ministry of Health are attended by at least two persons from the Intermediate Body.

Preventing corruption in the projects is ensured by verification of public procurement documentation performed by the Implementing bodies / Partners / final beneficiaries. Verification consists in checking the compliance of the performed proceedings with the programming documents and the Public Procurement Law Act, with particular focus on equal treatment of the contractors and fair competition principle. In addition, pursuant to the Framework agreement between the Government of the Republic of Poland and the Swiss Federal Council, to increase transparency and counteract corruption, tender documentation contains the ‚anti-corruption clause’, template of which constitutes the Appendix to the Co-financing Agreement. In addition, the activities related to the public procurement proceeding, and in the case of appointing a tender committee – the committee meetings – may be attended by the representatives of the Swiss party or the National Coordination Body (Ministry of Regional Development) acting as the observers.

In the case of purchases below EUR 14 thousand, both the Intermediate Body and the Implementing bodies / Partners / beneficiaries are obliged to comply with the Guidelines of the Minister of Regional Development on awarding the procurement contracts within the Swiss-Polish Cooperation Programme, to which the provisions of the Act of 29 January, 2004 – Public Procurement Law do not apply, describing the procedures for awarding and documenting the completed procurement contracts. The Guidelines emphasize that the Employer is obliged to ensure that the project expenditures (regardless of the procurement contract value) are purposeful, cost-effective and enable timely delivery of tasks. The Employer must also comply with the principle of achieving best results from the given expenditure and with the competitiveness, equal treatment and transparency principles.

The Intermediate Body for the Healthcare and Child Care Priority implemented within the Financial Mechanism of the European Economic Area and the Norwegian Financial Mechanism 2004 – 2009 and PL07 Programme Operator Development and better adaptation of healthcare to demographic and epidemiological trends implemented within the Financial Mechanism of the European Economic Area and the Norwegian Financial Mechanism 2009 – 2014 and PL13 Programme Reducing social inequalities in health implemented within the Norwegian Financial Mechanism 2009 – 2014.

Delivery of tasks related to collection and assessment of applications submitted within the contest for co-financing the projects from the Norwegian and the European Economic Area funds and carrying-out the proceedings in the field of public procurements awarding (among others on selecting the contractors of the operations of the Bilateral Cooperation Fund and promotional activities and expert reports) are the areas of particular corruption risk.

To counteract corruption – when collecting applications for the programmes implemented within the Financial Mechanism of the European Economic Area and the Norwegian Financial Mechanism 2009-2014, each person performing formal and content-related assessment is obliged to sign declaration of impartiality and confidentiality of assessment of a given application. The assessment is issued by at least 2 persons (four eyes principle), and the assessment charts are verified by the secretary of the Assessment Team. Similar solution was introduced to the application assessment procedure in the priority area Healthcare and Child Care within the Financial Mechanism of the European Economic Area and the Norwegian Financial Mechanism 2004-2009. With regard to counteracting the corruption, when conducting public procurement proceedings (among others concerning the selection of the contractors of the Bilateral Cooperation Fund activities at the level of operational programmes, proceedings on promotional activities and expert reports) the provisions of the Public Procurement Law Act are applied.

In addition, the descriptions of the positions of the employees responsible for direct supervision over the projects implemented within the abovementioned programmes contain information about corruption risk.

Counteracting corruption at the level of projects implemented within the abovementioned programmes are ensured by the Programme Operator via the project monitoring system and system for non-compliance detection, reporting and correcting. On-site controls and controls upon project completion are performed by the Control Team composed of at least two persons (four eyes principle) pursuant to the Control and Management System Descriptions for the programmes co-financed from the funds of the Financial Mechanism of the European Economic Area and the Norwegian Financial Mechanism 2009-2014 and to the Procedure of Financial Management and Control of the Intermediate Body of the Healthcare and Child Care Priority within the Financial Mechanism of the European Economic Area and the Norwegian Financial Mechanism 2004-2009.

To summarize, the existing anti-corruption mechanisms referring to individual tasks eliminate the risk of occurrence of corruption-related events. The fact that to this moment no such phenomena have been reported is worth emphasizing.

Information on the anti-corruption procedures applied in the individual programmes delivered within the European funds.

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Ministry of Health

The Ministry of Health is an office of government administration serving the Minister of Health.

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