12 Tools for Developing a Code of Ethics

The approval of a code of ethics is one of the essential preventive measures of the well-known “anti-fraud cycle” and also an obligation imposed by Law 1/2022, of 13 April, on Transparency and Good Governance of the Autonomous Community on all public administrations.

Within the framework of an agreement between the Generalitat Valenciana, the Provincial Councils, the Valencian Federation of Municipalities and Provinces, the University of Valencia and this Agency, on March 12, 2024, I gave the presentation “How to develop a code of ethics so that it is a true framework of public integrity”. And the truth is that few are, limiting themselves to being a “copy-paste” of the principles and duties already regulated and imposed by the regulations or the result of an assignment to private entities that ends with their delivery, without worrying about their operation.

I present here the document “12 tools to develop a code of ethics”[1] and I invite you to use it in your “homes” to develop your own code of ethics using this “toolkit” with  references, examples and guidelines to ensure that every public servant exercises the position or performs his or her functions without deviating from the general interest:

1.Legal references and key concepts of the code: count on our Code of Integrity of the Valencian Community[2], which summarizes and systematizes in a general and specific way (by areas of practice) the aspects related to integrity.

2.Support to establish specific reinforcement mechanisms in the areas of practice of municipal competence: consult our Manual “The exercise of public office with integrity” [3]to make use of keys, precautions and useful procedures for its design, and the models attached to our AVAF Guide “The Public Integrity Plan: roadmap and facilitating annexes”,  among others.

3.- Limits inherent to the nature of the code as an internal instrument of self-regulation, without being able to innovate sanctions, reserved to the Law.

4.- On the recipients of the code: both senior officials and public employees of any kind, with extension of provisions for contractors and other recipients of public funds. This is the case of our Code, approved by Director’s Resolution No. 82 of 10/02/2022.

5.- Guidelines for activating the participatory and public process of drafting the code that involves all the recipients of the code and best practices on the involvement of governing bodies.

Examples of principles and values for consideration by each institution, with additional materials and references.

7.The gift policy: general rule of non-acceptance, examples of courtesy uses and financial limits, forbidden gifts, record-keeping models, return policy, recourse to the OECD “GIFT” list.

8.- Elements of the code to detect, prevent and address risks contrary to integrity such as information leaks, conflicts of interest and lack of planning: regulations, examples of procedures, orientation questionnaire for their detection, practical situations of conflict of interest and irregularities, as well as mechanisms to be applied in the code and its extension to third parties (“two don’t argue if one doesn’t want to”). Possible use of the AVAF Visual Didactic Manual “Conflicts of Interest in the Key of Public Integrity”.

9.- Responsibilities for possible irregularities based on participation in decision-making processes. Guidelines and reference to the Code of Integrity cited above.

10.- Necessary provision for training in the code: the use of the AVAF’s YouTube channel.

11.- The ethics committee as an advisory body and receiver of complaints for non-compliance with the code. Examples of its functions and the regulation of the mailbox.

12.- The code as a living instrument: the need to monitor and update it to ensure its application. It’s not enough to “approve it and put it in the drawer.”

From the AVAF we hope that the document will be useful to advance in the important challenge of planning and managing public policies with integrity.

Do not hesitate to contact us if you have any questions at the following email: prevencion@antifraucv.es.

Irene Bravo Rey, Director of Prevention, Training and Documentation at the AVAF.

[1] https://www.antifraucv.es/wp-content/uploads/2024/03/12_herramientas_Codigo_Etico__.pdf

[2] https://www.antifraucv.es/codigo-de-integridad/

[3] https://www.antifraucv.es/recomendaciones-guias-y-manuales/

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The Valencian Anti-Fraud Agency delivers its 2023 Activity Report to the Corts Valencianes, highlighting its collaboration with justice and its international relevance

València, March 26, 2024.- The Valencian Anti-Fraud Agency has delivered the Activity Report for the year 2023 that took place at the Saló dels Espills de les Corts Valencianes, thus complying with the mandate contained in article 22 of Law 11/2016 on the creation of the Agency.

The director of the Agency, Joan Llinares, has handed over the two volumes of the Report, one in Valencian and the other in Spanish, to the president of Les Corts, Llanos Massó. The event was also attended by the Ombudsmen of all the parliamentary groups and the Bureau of Les Corts.

The Report includes the activity carried out by the Agency during 2023 in the area of training, prevention and documentation; the legal and whistleblower protection area; analysis and research; Administration, Recruitment, and Human Resources and Communication.

Among the highlights of the 2023 Report is the international recognition of the work carried out by the Agency, which has been highlighted in the exchanges carried out with the European Anti-Fraud Office (OLAF) and the Italian National Anti-Corruption Authority (ANAC) and the visits received by the Anti-Corruption Office of Georgia or the National Anti-Corruption Centre of the Republic of Moldova. She was also invited by the European Commission’s group of experts to explain how its complaint box works.

In 2023, the Agency participated in meetings and encounters with the European Anti-Corruption Partners (EPAC) network; the European Network of Anti-Corruption Contact Points (EAPCN); the Network of European Integrity Authorities and Whistleblowers (NEIWA) and the Network of Corruption Prevention Authorities (NCPA).

The second outstanding aspect of 2023 has been its intense collaboration with the judicial bodies, which has materialized with the signing of a Collaboration Agreement with the Attorney General’s Office or the provision of training by the Agency’s staff to the 61st promotion of access to the prosecutorial career.

The collaboration has also materialized with the participation of the Agency as a judicial expert in 8 legal proceedings; the preparation of 5 reports of judicial assistance and the presentation and testimony in oral trial in 2 of the proceedings.

You can access the following links:

  • Link to Executive Summary:


  • Link to the 2023 Activity Report:


The IES Antoni Llidó in Xàbia, new stop for the #DocuforumAVAF


Javea. – March 7, 2024

The Training Service of the Valencian Anti-Fraud Agency visits the town of Jávea, in the Marina Alta region, for the first time with #DocuforumAVAF.

The activity designed to publicize the work of the AVAF in the Valencian Community among 4th year ESO and high school students has visited the three provinces of the autonomous community since January 2024 with sessions in the towns of Algemesí and Vall d’ Uixó, which is now joined by Jávea in Alicante.

The Antoni Llidó Secondary Education Institute has been the first this school year in which two docuforums have been held on the same day. Pilar Moreno García, AVAF training technician, traveled to the town of Jávea on Thursday, March 7 for the occasion.

The activity was aimed at students in the 4th year of ESO and 1st year of high school studying the subjects of economics and business promotion, thanks to the collaboration of teacher Aina Moragues.

The protagonists of the learning experience have been 60 students and alumni in total, who after watching the documentary “Corruption: harmful organism” by Pandora Box TV in the classroom, shared their doubts and questions about the issues raised in the documentary to be . results by the AVAF technical training technician who visited their classrooms.

The protection conditions for informants regarding regulatory infractions offered by the AVAF, as well as the penalties imposed related to corruption crimes, were some of the questions posed by IES Antoni Llidó students.

With this new training action, the AVAF continues to contribute to the prevention of fraud and corruption through debate between students who will soon become full citizens.

If you are a university, high school or 4th year ESO teacher in the Valencian Community and are interested in having the training activity “Docuforum: Corruption, harmful organism” carried out in your classroom, do not hesitate to contact the training service of the Valencian Antifraud Agency through formacion@antifraucv.es