Exploring Local Integrity Management in the Valencian Community: A Mixed-Methods Study

86 Abstract This article focuses on a pilot study of integrity management systems in the Spanish regional state of Valencia. The Valencian Community was a relevant case because it was one of the foci of corruption in Spain during the first two decades of the 2000s. The results were obtained from 65 valid responses to a survey of municipal political and administrative officials. The results were processed using MAXQDA2024 software. An analysis of the main views expressed and the policies adopted led to the grouping of cases into four clusters (obtained using the Jaccard similarity index). Municipalities were ranked based on the development of policies and visions regarding integrity. The main findings are that there is an increasing appreciation of integrity management policies, and that legislation is the predominant shaping element. Some of the informants highlight these policies in changing organizational culture and increasing professionalism. The size of municipalities and whether applications were made for European funding were found to be highly influential factors in the development of public integrity policies. This study confirms the relationship between policy development and the implementation of legislative measures. This could also help to study integrity policies in local governments in future studies. Keywords: public policy, local government, anti-corruption, integrity management, institutional performance. EXPLORING LOCAL INTEGRITY MANAGEMENT IN THE VALENCIAN COMMUNITY: A MIXED-METHODS STUDY *1 Gonzalo PARDO-BENEYTO María Ángeles ABELLÁN-LÓPEZ Juli Antoni AGUADO-HERNÁNDEZ Gonzalo PARDO-BENEYTO (corresponding author) Assistant Professor, Department of Constitutional Law, Political and Administrative Sciences, Faculty of Law, University of València, València, Spain E-mail: [email protected] ORCID ID: 0000-0001-7142-1740 María Ángeles ABELLÁN-LÓPEZ Associate Professor, University Institute of Creativity and Educational Innovations (IUCIE), University of València, València, Spain E-mail: [email protected] ORCID ID: 0000-0002-6553-0227 Juli Antoni AGUADO-HERNÁNDEZ Associate Professor, Inter-university Institute for Local Development, University of València, València, Spain E-mail: [email protected] ORCID ID: 0000-0001-7823-848X * Acknowledgement: This article is part of the project titled “Integrity management systems at the local level in the Valencian Community (2015-2022): diagnosis, challenges, and experiences (GESINLOC)”, reference number CIGE/2022/127. The project, obtained through competitive bidding, was subsidized by the Conselleria d’Educació, Universitats i Ocupació de la Generalitat Valenciana. DOI: 10.24193/tras.76E.6 Published First Online: 10/27/2025 Transylvanian Review of Administrative Sciences, No. 76 E/2025, pp. 86–106 87 1. Introduction This article examines the main policies adopted by 65 Valencian town and city councils during the period 2015-2023. It is based on the results obtained in a telephone survey carried out from November 1, 2023 to March 31, 2024. The importance of this study is justified by the role that corruption has played in recent years as a destabilizing element in liberal democracies (Mény, 2020). To generate legitimacy, public authorities have implemented measures to mitigate corruption in the public sphere (Suchman, 1995; Villoria, 2021a). Although corruption is a recurrent theme in social science literature, its study presents difficulties (Villoria and Jiménez, 2012). Consequently, some authors have decided to focus on the reverse side of this concept – namely, integrity (Huberts, 2014; Lawton, Van Der Wal and Huberts, 2015). There are few studies of integrity policies at the local level in Spain, as most of the related works have focused on corruption (for example: Garcia-Quesada and Jiménez, 2017; Jiménez, Villoria and García-Quesada, 2012; and Parrado, Dahlström and Lapuente, 2018). In the international literature, there are a variety of systematized studies focusing on local institutions (Ackim, Rugeiyamu and Msendo, 2024; Baljija and Rustemi, 2021; Huberts, Anechiarico and Six, 2008; Perlman, Reddick and Demir, 2023). The research question posed in this article is as follows: how and why are integrity management policies configured at the local level in Valencia? This question is answered through the generation of study categories of integrity management systems. The local level of the Valencian Community has been studied because it was affected by corruption cases in the first decades of the 21st century. Moreover, progress in the position of the European Quality of Government Index has been remarkable over the last ten years (Megias et al., 2024). 2. Theoretical framework 2.1. Isomorphism Several authors have highlighted the importance of the environment as an element that affects institutions and the adoption of innovations to improve legitimacy (Meyer and Rowan, 1977). DiMaggio and Powell (1983) determined that there is a series of macro-processes produced by coercion, professional practices (normative), or mimicry that generate modifications in the organization. These three types of isomorphism have been present in the changes in the modernization of the local level, with coercive isomorphism standing out above other types (Tolbert and Zucker, 1983). Likewise, dynamics are generated in which the characteristics of the organization itself are combined with the new innovations that occur over time (Tolbert and Zucker, 1996). The institutionalization of integrity measures in Spain and their construction at the local level have been spreading as regulations have been passed, which, in turn, were shaped by the EU (Jiménez Asensio, 2017). Hence, shaping the legal framework on which integrity policies have been built varies according to 88 the approval of new regulations. Thus, Law no. 19/2013 on transparency, access to public information, and good governance (Ley de Transparencia), for example, has been very important in shaping policies at the local level. The literature on transparency and good governance highlights the importance of regulations in implementing such measures. Coercive isomorphism is a crucial drive of the adoption of administrative modernization measures that transcend path dependence dynamics in Spain (Medir Tejado et al., 2021). Likewise, variability in terms of implementation stands out, and although legislation is a necessary condition for its emergence, other variables also affect the formation of these integrity management systems. According to Villoria (2021b), the literature highlights the need for, among other things, endogenous factors related to organization, the availability of funds, and sufficient trained personnel. Likewise, a push is needed from public authorities and public employees in charge (Medir Tejado et al., 2021). Proposition 1: Legislation alone does not seem to be sufficient to explain the widespread implementation of the integrity management system; thus, the vision of public officials tends to better explain its scope and formulation than legislation. 2.2. A preliminary definition of integrity Integrity is defined as the other side of the corruption coin. Both antagonistic concepts have evolved in parallel (Huberts, 2014). The term corruption was originally associated with a lack of virtue. However, during the French Revolution, this was associated with the reason. Today, corruption can be defined as the abuse of public power to promote private interest (Engels, 2019). This can be explained through individual (Avolio and Gardner, 2005; Heidenheimer, 2002), institutional (Acemoglu and Robinson, 2014; Dahlstrom and Lapuente, 2018; Della Porta and Vanucci, 1997; Parrado, Dahlström and Lapuente, 2018), and cultural approaches (Arellano-Gault and Lepore, 2011; De Sousa, 2008; Inglehart and Welzel, 2006), as well as from socio-economic and structural perspectives (Rothstein, 2011). Public integrity can be seen from various perspectives: individual, social, and institutional. Some authors focus on the morality of the individual and what they define in terms of right and wrong in relation to public management and decision-making (Plant, 2018; van Steden, 2020). Social conceptualizations are more global in character and based on values shared by society. Hence, there are authors who refer to the idea of the common good (Bhuiyan, 2011) or emphasize the general interest (Demmke, 2020). This understanding of integrity is related to the prevailing culture in a particular social system, which determines what is perceived as appropriate. Such a conceptualization considers the norms applied in a political community and is also based on informal and cultural rules (Arellano Gault, 2017). In addition, it can be seen how values change over time and affect public institutions differently. Elements such as social responsibility and the environment are recurrent values (Jørgensen and Bozeman, 2007). 89 From an institutional perspective, closely linked to the classical view of bureaucracy, integrity can be defined in terms of compliance with legality, neutrality, and administrative efficiency (Bozeman, 2009). This argument is based on minimizing the arbitrary power of public employees (Herzfeld, 2002; Papadopoulos, 1997; Seibel, 2020). The new public management (NPM) approach reflects a change in values, with efficiency added above other concepts. Thus, with the emergence of concepts such as managerialism, performance management, quality, privatization, or outsourcing, the instruments of Weberian control are dissolved and replaced by other instruments such as audits, evaluations, and management by objectives. However, the opening of key managerial positions was also advocated in favor of this efficiency (Menzel, 2015). From this perspective, these key positions in the organization were to foster ethical leadership by improving efficiency through the entrepreneur’s figure or the generation of public value (Moore, 1998; Osborne and Gaebler, 1994). In short, this article uses the term public integrity from a triple meaning: (1) a cluster virtue instilled in the individual that serves to overcome his possible moral deviations (Villoria, 2021a), (2) individual action that conforms to social and cultural conventions (Huberts, 2014), and (3) the quality of public institutions that aligns the action of institutions to prioritize public interests (OCDE, 2017). Proposition 2: The perception of integrity management policies is related to the breadth and level of Local Integrity System (LIS) development. It is understood that there will be several types of views. First, those who understand that integrity is transformative and generates improvement in the organization, human resources, and procedures within the institution. These views will be justified by arguments related to professionalization, cultural change, and general interest. Second, there are other types of managers who use integrity measures to obtain more resources; therefore, their arguments are efficiency-based. Third, there are those who only comply with the legal minimum to avoid punishment and who only consider a finalist vision of the fight against corruption. Finally, some do not comply with the legal minimum because they do not see a clear benefit. 2.3. Integrity management systems: definitions and previous work A local Integrity Management System can be defined as a set of policies and institutions that safeguard the integrity of a government. These focus on preventing corruption and generating ethical practices through value-based or institution-based measures (Huberts, 2014; Huberts, Anechiarico and Six, 2008; Rohr, 2017). The definition is in line with OECD (2020) recommendations in that it understands integrity as a coherent set of policies and infrastructures that are organized as a system and that consider the characteristics of the environment and the organization. The development of different instruments has been established over time. Without wishing to be exhaustive, several related concepts have been used historically by both 90 international organizations and specialized literature, including organizational integrity systems, integrity management frameworks, ethical infrastructures, pluralistic ethics management frameworks, ethical program models, national integrity systems, and local integrity systems. Although each concept focuses on a set of measures or the place where they are implemented, they have common elements (Huberts, Anechiarico and Six, 2008; Maesschalck, Hoekstra and van Montfort, 2024; Pope, 2000). Some attempts to operationalize such systems have been varied. For example, Pope (2000) found that the integrity of national integrity systems was based on institutional pillars such as the executive branch, legislature, judiciary, and media. The main idea of this author is that if one of the pillars of the system fails, corruption can cause the system to fail to serve general interests. From a local perspective, authors such as Huberts, Anechiarico and Six (2008) defined local integrity systems as an adaptation of Pope’s idea in which close cooperation is needed between the actors in a governance environment. All the systems mentioned previously were based on valueor institutional-based measures. Value-based measures change individuals’ values through non-coercive means that impact their value systems, whereas institutional-based measures focus on institutionalized coercion and impose control. However, the two dimensions work together and interrelate to generate synergies (Huberts, 2014; Rohr, 2017). Both types of instruments have led to different combinations of integrity-management systems. In conjunction with techniques based on a strategic approach, these have generated models to improve the integrity of public institutions. For example, OECD built a model based on commitment, responsibility, norms, society, leadership, merits and abilities, development of capabilities, openness, risk management, supervision, participation, and punishment. Hoekstra, Huberts and van Montfort (2023) generated an index for assessing local integrity management systems. Their approach identifies seven essential elements: (1) paying attention to integrity policies, (2) operationalization of integrity to measure implementation, (3) ethical leadership, (4) internal consistency, (5) checking whether the measures are comprehensive and measurable, (6) structures related to activities to improve policy outcomes, and (7) evaluation of a critical reflection. Another model to consider is The Public Integrity and Anti-Corruption Plan (PIPAC, for its initials in Spanish), which is an adaptation of the OECD’s integrity management model in which the focus is on the definition of integrity, management, monitoring, and the punitive system (De Bona, 2022). Other authors, such as Meza and Pérez-Chiqués (2024), determine the need to shape measures that consider the top-down approach with the bottom-up approach and that, in addition, have an internal or external character. Finally, Aldeguer-Cerdá, Abellán-López and Pardo-Beneyto, (2020) constructed a classification that was based on the duality between value-based and institution-based arrangements and included coercion and the integrity policy target. This was achieved using a functional classification proposed by Lowi (1972) and adapted to integrity management policies. The idea that some policies affect individual civil servants as well as institutions was also added. Integrity policies can be divided into four types of instruments: (1) ethical 91 policies, (2) openness policies, (3) deterrence/ empowerment policies, and (4) control policies. This theory enables an understanding of integrity policies and adds depth by going beyond the direct effects on morality and including an institutional component. 2.4. The development and classification of integrity policies According to this classification, integrity management policies can be grouped as follows: ‒Ethical policies focus on the individual and exert passive coercion as they seek to change institutional culture by improving personal values. They aim to have a set of principles that prevent behavior that is not aligned with social and institutional norms. ‒ Openness policies have an impact on the results of the institution’s actions, passively modifying its procedures. The organization is consequently immersed in an environment in which the institution is monitored and observed through the data provided. ‒Other types of policies to consider are deterrence and empowerment policies. These are located at the individual level and exert direct coercion on the individual. This coercion can become an incentive and reward, and in some way, the individual’s own characteristics. ‒Control policies have an impact on institutions. They are enforced by internal bodies and other independent external control institutions. Such measures create an institutional environment in which the autonomy of the organization is constrained by the actions of these actors. Table 1 lists the main measures that comprise each type of integrity policy group. These include mandatory measures (in bold) and those voluntarily present in local institutions. The latter are covered by the power of self-organization of local entities in Spain and Valencia (Sosa Wagner and Martín Mateo, 1999). It should also be noted that, in the Spanish system, the population mainly determines the resources available. This autonomy has also led to the uneven development of these policies. Technical reports on whistleblower protection (Tribunal de Cuentas, 2024) and studies on the implementation of transparency highlight the uneven development of Spanish municipalities, even when formally implemented (López-López, González-Quinzán and Mo-Groba, 2021; Valle Escolano, 2021). Proposition 3a: All other things being equal, the size of municipalities and resources are positively associated with the construction of transformational visions (which impact the organization, processes, positions, etc.), while municipalities with fewer resources tend to articulate more utilitarian, finalistic, or non-compliant visions. Proposition 3b: The most transformational visions have a variable distribution of instruments that combine ethical, openness, deterrent/ empowering, and control policies. Meanwhile, the most utilitarian visions focus on openness and control. Local governments with fewer resources will try to comply with legal obligations. 92 Table 1: Generating a classification of integrity policies Ethical policies Openness policies Code of ethics Ethics-code supporting infrastructure Courses and awareness-raising for public employees Courses and awareness-raising for elected officials Regulation of gift acceptance policy Actively published information Right of access to public information Big Data and open data Open agenda Open accounts Stakeholders register Citizen participation Environmental perspective in public procurement Social clauses in public procurement contracts Whistleblowing channel Deterrence and empowerment policies Control policies Disciplinary code Performance appraisal: monetary incentives Performance appraisal: non-monetary incentives Social clauses for the recruitment of staff Social clauses for obtaining grants Conflict of interest test Internal control External control Ethical climate survey Quality control Audits Algorithmic controls Citizen audit Red flags Risk management map Source: The authors 3. Methodology 3.1. Data collection The expert integrity informants were questioned through a survey on the measures adopted during the 2015–2023 period in their city councils. This period was chosen because regional legislation on transparency was implemented from 2015. The survey asked about measures taken on integrity and was addressed to local councils with a population of more than 5,000. The population of interest was 157 municipalities, and a total of 65 valid responses were obtained (41.4%). The survey was conducted between November 2023 and the end of March 2024. Responses were mostly obtained by telephone, although to increase the number of responses, the questionnaire was also sent to those respondents who requested a printed copy. Of the 65 participating municipalities, 35 are located in the province of Valencia, 19 in the province of Alicante, and 11 in the province of Castellón. Regarding population size, 18 municipalities have a population between 5,000 and 10,000, 19 between 10,001 and 25,000, and 21 between 25,001 and 50,000 inhabitants. To these must be added four municipalities between 50,001 and 100,000 inhabitants and two municipalities between 200,001 and 500,000. Only one municipality has more than 500,000 inhabitants. The profiles of the survey participants are shown in Figure 1. 93 Table 2: Survey questions Classificatory questions Type of respondent Municipality Province Causes What is your understanding of public integrity and anti-corruption policies? What motivates the adoption of these policies? What issues have affected your institution in implementing integrity management policies? Types of policies: Which of the following integrity policies are in place in your institution? Ethical policies Openness policies Deterrence/ empowering policies Control policies Other Have you applied for EU funding? If you have applied for European funds, have you approved an anti-fraud plan? Source: The authors Figure 1: Profile of the survey participants Source: The authors 3.2. Data processing The data was processed using mixed methods that combine quantitative and qualitative variables (using the MAXQDA2024 software). The question relating to the understanding and meaning of ethical policies was coded. Literal answers were used for the presentation of results. For the rest of the questionnaire, the answers were pre-treated by converting them into dichotomic variables. Finally, Jaccard’s similarity was used to generate clusters in function to how integrity management systems have developed (based on the perception of these measures and their 94 development through the adoption of policies). This approach measures similarity by considering the variables and codes that are similar in each document and dividing them by the sum of the similarities and those variables and codes that are either genuine or absent in a document. 4. Results and discussions To generate the clusters for analysis in the last part of the article, the motivations and visions of the respondents were combined with the type of policy implemented. Each cluster was reinforced with evidence obtained from the survey. Similarly, their conformation is linked to the corresponding theoretical framework. Table 3: Cluster composition Number (%) Cluster 1 Cluster 2 Cluster 3 Cluster 4 General Interest 0(0.0) 0(0.0) 2(16.7) 2(6.9) Professionalization 2(22.2) 2(13.3) 1(8.3) 10(34.5) Efficiency 0(0.0) 3(20.0) 6(50.0) 4(13.8) Legality 1(11.1) 7(46.7) 1(8.3) 11(37.9) Anticorruption 7(77.8) 4(26.7) 4(33.3) 7(24.1) Cultural change 0(0.0) 6(40.0) 0(0.0) 9(31.0) Institutional responsibility 0(0.0) 1(6.7) 0(0.0) 6(20.7) Others 0(0.0) 0(0.0) 0(0.0) 1(3.4) Code of ethics 2(22.2) 7(46.7) 5(41.7) 17(58.6) Deontological code 0(0.0) 1(6.7) 0(0.0) 6(20.7) Ethics infrastructures (codes) 3(33.3) 4(26.7) 3(25.0) 6(20.7) Public employees training 0(0.0) 0(0.0) 3(25.0) 18(62.1) Elected officials training 0(0.0) 4(26.7) 0(0.0) 6(20.7) Gift policy 1(11.1) 2(13.3) 2(16.7) 5(17.2) Others 0(0.0) 1(6.7) 1(8.3) 2(6.9) Proactive disclosure 7(77.8) 14(93.3) 11(91.7) 29(100.0) Right of access to public information 6(66.7) 12(80.0) 11(91.7) 29(100.0) Big Data and Open Data 0(0.0) 2(13.3) 0(0.0) 13(44.8) Published agendas 0(0.0) 4(26.7) 2(16.7) 17(58.6) Open accounts 0(0.0) 5(33.3) 0(0.0) 20(69.0) Lobby register 1(11.1) 0(0.0) 1(8.3) 9(31.0) Citizens’ participation 2(22.2) 6(40.0) 2(16.7) 23(79.3) Environmental perspective in public contracts 1(11.1) 2(13.3) 2(16.7) 11(37.9) Social clauses in public contracts 1(11.1) 4(26.7) 5(41.7) 19(65.5) Anti-fraud complaint mailbox 7(77.8) 11(73.3) 12(100.0) 26(89.7) Disciplinary code 0 (0.0) 0 (0.0) 1(8.3) 5 (17.2) Performance appraisal: monetary incentives 0 (0.0) 2 (13.3) 1(8.3) 3 (10.3) Performance appraisal: non-monetary incentives 0(0.0) 2(13.3) 1(8.3) 5(17.2) continued on next page 101 Table 4: Summary of cluster characteristics Classification Size Visions Policies Cluster I. Minimalist legal adoption (very low development) small Corruption Limited implementation of obligatory instruments: Openness policies - Active publication of information - Right to information - Fraud whistleblower protection Control policies - Internal and external controls Cluster II. Top-down modernization (low development) medium Legality Cultural change Openness policies - Active publication of information - Right to information - Whistleblowing channel Control policies - Internal and external controls Limited implementation Ethical policies - Codes of ethics Deterrence and empowerment policies - Ethical clauses in staff recruitment Cluster III. Efficiency vision (medium development) small-medium Efficiency Corruption Openness policies - Active publication of information - Right to information - Whistleblower mailbox Control policies - Internal and external controls - Conflict of interest tests - Risk maps Cluster IV. Complex model (high development) big Complex vision: professionalization, legality, and cultural change Openness policies - Active publication of information - Right to information - Whistleblower mailbox - Social clauses in public procurement contracts Control policies - Internal and external controls - Conflict of interest tests - Risk maps Ethical policies - Codes of ethics - Courses for public employees - Red flags Source: The authors 102 5. Conclusions This research has studied the main integrity management policies developed during the period 2015–2023 in the Valencia Region of Spain (Comunidad Valenciana). To this end, 65 valid responses to a telephone survey were used, and the results were processed using the MAXQDA 2024 software. Legislation is an essential element of implementation, but it is not sufficient on its own. In this sense, the role of those responsible helps to understand the broader scope of developing integrity management systems. Thus, professional leadership and vision are essential for policy design. The findings are consistent with Proposition 1. The perceptions of these officials are not uniform across all municipalities. There is a transformative view of integrity instruments in the organization that goes beyond the obligation to implement this type of policy and corresponds to highly developed municipalities in the region. This profile seeks an organization that functions better and avoids corruption. To achieve this vision, it is important to improve the organization and reinforce professionalism. This type of profile contrasts with a utilitarian one, which seeks to raise funds through the internalization of these types of policies and has an efficiency-oriented discourse; therefore, its development is less than that of the previous group. Thirdly, there are municipalities that only comply with legal obligations, and finally, others that have a simple vision of integrity policies and do not even comply with the minimum measures, which can be attributed to the characteristics of the municipality and the lack of greater awareness of the benefits of integrity. There is a negative cultural view combined with a finalist approach, while in the latter case, it is based solely on the latter perception. Therefore, the differentiation of visions is a fact that confirms Proposition 2. These visions impact the structure of integrity management systems. Transformational visions (Cluster IV) combine ethical, openness, deterrent/ empowering, and control policies more intensively. This is due to the vision of organizational improvement and the people who form it. As for the efficiency-oriented vision (Cluster III), efforts are focused mainly on openness and control policies, which is explained by a vision centered on the organization for the acquisition of resources. The development of municipalities that focus on legal compliance (Cluster II) involves advanced monitoring of policies required by law, but there is limited adoption of ethical policies. Finally, municipalities with limited implementation (Cluster I) adopt policies incompletely, even though they are required to do so by law. This is explained by the vision of those responsible, but also by having limited resources due to their size, which is detectable in clusters I, III, and IV but not in cluster II. Therefore, it can be said, to a limited extent, that resources are also important and influence the scope of integrity management systems. In this sense, it can be said that Propositions 3a and 3b are partially fulfilled. How can we achieve a greater reach in LIS? The solution to these problems involves implementing different measures. The main one would be to rethink the Spanish local government system and evaluate whether the size of the municipalities and resources are 103 sufficient at the current stage. However, this is unlikely to occur. Therefore, efforts should be redoubled to provide greater technical and financial support to municipalities that face more difficulties. Multilateral forums, such as federations of municipalities or provinces, should also be used to generate spaces for intermunicipal exchange and cooperation. Another way to address the problem, considering the results, is to make subsidies contingent on the implementation of integrity measures, thereby encouraging investment. Finally, there should be a flexible approach to the adoption of integrity measures that considers the evaluations of the public policies implemented and generates development itineraries to maximize resources and adapt them to the problems. 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