Photo credits: Transparency International
A comprehensive study by Adina Dudau, Alvise Favotto, Georgios Kominis, Denisse Rodriguez-Olivari from the University of Glasgow – Adam Smith Business School examines organizational Integrity Management Systems (IMS) across five sectors at high risk of corruption: defence, critical infrastructure, healthcare, professional sport, and banking.
The report was produced under the Work Package 4 and adopts a meso-level analytical lens, focusing on organizational practices that enable or constrain integrity breaches. Through detailed case studies, the researchers explore how imbalances between systems emerge, the challenges of navigating regulatory ecosystems, and where organizations test the boundaries of integrity.
From the Leonardo bribery investigations and the UK Post Office Horizon IT scandal to procurement irregularities at Novartis Hellas and AML failures in Operation Clean Hands and Nordea Bank, this report reveals how formal compliance regimes can conceal deep-seated systemic flaws. The analysis consistently finds symbolic belief systems, ambiguous boundary rules, misaligned diagnostic metrics, and a pervasive absence of interactive mechanisms.
The cross-case analysis reveals consistent failures across four key IMS elements:
- Belief Integrity Management Systems: Often visible but symbolic, proving unreliable at disciplining day-to-day decisions under pressure
- Boundary Integrity Management Systems: Expanded policy sets (codes, due diligence, certifications) that leave grey zones around agents, political intermediaries, and data integrity
- Diagnostic Integrity Management Systems: Commercial KPIs routinely outrank integrity-critical indicators (i.e. privileged access events, unresolved incidents, third-party red flags)
- Interactive Integrity Management Systems: Oversight forums designed to challenge prevailing narratives proved weakest across all cases, with substantive challenge only occurring in response to external litigation
The D4.1 report demonstrates that policy on paper proves insufficient when belief and boundary IMS suppress doubt, diagnostics are blinkered, and interactivity ritualized. Post-scandal reforms often over-concentrate on boundary and diagnostic levers while neglecting learning-oriented beliefs and interactive IMS.
The report provides a practical blueprint that treats procurement as a public-private bridge, reinforces whistleblowing as an early warning system, and hardwires transparency into financial and contracting flows. The recommendations transcend limited approaches like ISO 37001 certification and call for intentional design of holistic IMS as the central task for converting integrity from policy aspiration to operational capability in high-risk sectors.