Anti-corruption programme MZ SR

Resort anti-corruption programme of the Ministry of Health of the Slovak Republic (updated on 30 June 2026)

Article 1

Introduction

The new version of the Resort Anti-Corruption Programme of the Ministry of Health of the Slovak Republic 2026 (hereinafter referred to as the "RBC' or "Resort Anti-Corruption Programme') was drawn up in accordance with Resolution No 31/2026 of the Government of the Slovak Republic of 21 January 2026 (hereinafter referred to as the "Resolution of the Government of the Slovak Republic'), on the proposal of the Slovak Republic's National Anti-Corruption Strategy for the years 2026 2029 (hereinafter referred to as the "National Anti-Corruption Strategy of the Slovak Republic').

In point B.4. of the Order of the Government of the Slovak Republic, members of the Government of the Slovak Republic and presidents of other central government bodies are required to adopt, on the basis of an assessment and evaluation of corrupt risks, a Resort anti-corruption programme which will include specific anti-corruption system measures and make it publicly available on its website.

Point B.5. of the Order of the Government of the Slovak Republic obliges members of the Government of the Slovak Republic and the Presidents of other central government bodies to evaluate the performance of the tasks arising from the Resort Anti-corruption Programme and to update this programme.

by 30 June each year for the preceding calendar year

This Resort Anti-Corruption Programme is a follow-up to the previous Resort Anti-Corruption Programme of the Ministry of Health of the Slovak Republic 2025, the approved National Anti-Corruption Strategy of the Slovak Republic and its development takes into account the information provided on corruption risks at the Ministry of Health of the Slovak Republic (hereinafter referred to as the Ministry of Health) (hereinafter referred to as the Ministry of Health) and the role of the RBC is to create a fully-fledged working environment with a culture of anti-corruption behaviour, to reduce the scope for the emergence of corrupt behaviour while increasing the effectiveness and effectiveness of the prevention of corruption.

Article 2

Definitions

For the purpose of the implementation of the anti-corruption programme, the terms and definitions used in the National Anti-corruption Strategy of the Slovak Republic are used. https://www.bojanticorruption.gov.sk/ resolution-government/?csrt=18255851901373764595 and used by the State Security and Corruption Prevention Department of the Slovak Government in published material.

Integration means the property of a person who is consistently reflected in honest, honest, impartial and credible conduct in accordance with generally accepted values, ethical principles, standards and rules. The degree of integrity of the individual, the public authority and the whole system of institutions shall be assessed according to external expressions and conduct in accordance with declared values and principles. In this sense, the relationship between integrity and the trend towards corruption is indirectly proportional. It should be pointed out that the term "integrity" is not identical to the term "integrity" which is demonstrated under the relevant legislation of the Slovak Republic by an extract/depreciation from the criminal record.

Corruptionis the abuse of power or position for the benefit of others. Such a definition is based on the United Nations Convention against Corruption1. Similarly, the European Commission (EC) uses the general definition of corruption in the context of the European Structural and Investment Funds (ESIF) as a misuse of (public) status for personal benefit2. This underlines that corruption payments or transactions help many other types of fraud, such as false invoicing, fictitious expenditure or non-compliance with contractual specifications.

The fight against corruption requires a society-wide approach, a prerequisite for cooperation between the public and private sectors, as well as academics, civil society organisations and businesses. Public sector cooperation should not circumvent local authorities, which should be one of the key partners in implementing anti-corruption measures.

Although at the time of drawing up this document the concept of corruption itself is not defined as a term in Slovak law, § 328 to § 336d of Act No. 300/2005 Coll. Criminal law as amended (hereinafter referred to as "the Criminal Law") mentions the types of proceedings relating to corruption or bribery. The term corruption is therefore of generic importance in this document, which includes not only all the types of proceedings mentioned above, but also any other conduct detrimental to the public interest. General corruption can be seen as a misuse of public status for personal benefit. In addition to offences that may be subsumed under the corruption area defined under the offences referred to in the specific section of the Criminal Code in the broader sense, it also includes the abuse of power, power, influence or position, inciting such abuse, clientelism, family labour, protection, blackmail, conflict of interest, illegal lobbying, giving and receiving undue benefits without providing counter-service and misappropriation of public resources. Misuse of the jurisdiction of a public office holder within the meaning of Article 326 of the Criminal Code is, in substance, also a corruption, as well as criminal offences committed in connection with public procurement and public auction3 and machination in connection with insolvency and settlement proceedings.4.

The main negative impact of corruption is the weakening of citizens' confidence in the rule of law. A co-product of corruption is also the inefficient distribution of public funds, distortion of competition and excess costs for business, which have been shown to slow down the country's economic growth, which does not lead to the sustainable development of society. From a sociological point of view, these negative phenomena exacerbate social inequalities and undermine the principle of equal opportunities. At the same time, they may threaten both internal and external security of the State. Corruption is an obstacle to sustainable economic growth, diverting resources from productive results, weakening the efficiency of public spending and increasing social inequalities.

The risk of corruption means the existence of an opportunity, likelihood or possibility of corruption and the costs of such corruption. It also includes causes, scope or conditions that facilitate the emergence of a situation favourable to bribery, corruption, corruption or behaviour. This is a warning signal, for example, that power or status may or might be misused for the benefit of others.

Anti-corruption prevention (hereinafter referred to as "the prevention of corruption') means systematic procedures for:

1. (a) identifying and eliminating causes, opportunities and conditions favourable to the emergence and existence of corruption;
2. (b) reducing and eliminating corruption risks;
3. c) reducing the likelihood or possibility of corruption;
4. (d) deterring persons from committing corruption offences;
5. e) Strengthening the culture of ethics, integrity and anti-corruption awareness.

Resort bodies means any public authority, ministry, self-governing body, office, specialised agency, legal person established by law, commercial company with State ownership, as well as a legal person of which one of the founding parties or founder is a public authority.

Public integrity means consistent compliance of the procedure with common ethical values, principles and standards in order to promote and prioritise public interest over private public sector interests. In the context of the activities of public authorities, it is also understood as honesty, honesty, impartiality, respect for dignity, decency, correctness, transparency and credibility in the exercise of official duties and delegated powers. There is no doubt that there is an indirect proportional relationship between public integrity and corruption.

Public sector include legislative, executive, administrative and judicial authorities and their public officials appointed or elected, paid or unpaid, in a permanent or temporary position at central and sub-national level. This may also include public organisations, public undertakings and public-private partnerships and their employees, as well as employees and entities providing public services to which a contract may be concluded, or may be financed from private sources in some countries.

Conflict of interest in our legal order occurs quite often, as a rule, when legal rules impose an obligation to refrain from "which could lead to a conflict of interest," this term often appears together with the word "in particular." The Public Procurement Act links this concept to a conflict of interest where a personal interest may be regarded as a threat to the impartiality and independence of public procurement. As defined by the Organisation for Economic Cooperation and Development "The conflict of interests means a conflict between a public office and the private interests of a public office holder where a public office holder has private interests which could unduly affect the performance of his duties and duties."
Transparency International defines this term as a situation in which an individual or entity working for, be it government, trade, media or civil society organisation, is confronted with a choice between the duties and requirements of his/her position and his/her own private interests.

Public interest the interest in sustainable and sustainable improvement is understood in accordance with the rule of law and generally recognised ethical and moral principles, quality of life, living conditions and well-being of all or most citizens. However, the public interest as a subject of concerted efforts is not seen as a will to the detriment of other persons, but as a legitimate claim in which the situation of others will not deteriorate and the clear and certain criteria of democracy and the rule of law are respected.

Personal interest understood interest "which brings equity or other benefits' for the benefit of anyone having jurisdiction or having a close relationship with him. In the general definition of close persons we understand not only persons close to the civil code but also others who have a broader relationship than relatives.

Inheritable liability ' means the obligation of persons to be held accountable for the demonstrable consequences of their actions which have an adverse effect on the fight against corruption and the prevention of corruption.

Raising awareness of corruption means an interactive communication process to improve the capacity to perceive and understand the context of corruption, its manifestations, ways and consequences, as well as the development of competences, skills, motivation and attitudes necessary to activate anti-corruption behaviour.

Anti-corruption coordinator, is an employee of MZ SR whose position is created in accordance with task No. B.2 of the Government of the Slovak Republic. The anti-corruption coordinator ensures the functioning of the Ministry's anti-corruption system, assists the heads of staff in promoting anti-corruption measures, coordinates anti-corruption prevention activities, including the corruption risk management process, and provides expert consultations in the field concerned within his scope.

Article 3

Corruption risk management

The assessment of corrupt risks, as part of their management, shall include a set of activities and mechanisms which determine the likelihood of the occurrence of, or the likelihood of, corruption itself occurring. However, the assessment of corrupt risks is not a one-off or an end in itself. It's a continuous process. The measures taken to mitigate and eliminate corruption risks need to be continuously monitored, evaluated and improved to achieve the desired effect.

An organisation which is unable to reduce or eliminate the corruption risks to which it is exposed causes problems not only for itself but also for other organisations outside its scope. The aim of MZ SR is to effectively manage corrupt risks to eliminate or minimise potential corruption risks to the level at which the Ministry is able to manage them.

Corruption risk management is an essential part of the Ministry's activity and covers all its processes. It falls within the remit of Ministry's heads of staff and staff at all levels of management who identify existing corruption risks, map and evaluate their degree of relevance. The process results in the compilation of the current integrated risk and opportunity register, including corruption risks, for the relevant period. The risk register shall be reviewed on a regular basis, at least once a year, with a view to including updating the procedures for eliminating corruption risks, or identifying new corruption risks5.

Article 4

Purpose, objectives and background of the Ministry's APC

The Department's Resort Anti-Corruption Programme was designed to improve anti-corruption prevention and the fight against corruption, i.e. by identifying corrupt risks and causes of corruption to prevent the emergence of new conditions, opportunities and situations for corrupt behaviour in the Resort. In doing so, it takes into account the specificities of the Ministry as a central government body or the context of its competence and competence. The context of the anti-corruption strategy of the Slovak Republic shows that anti-corruption prevention is simpler and less costly than detection, investigation, prosecution of corruption and enforcement, but at the same time it must be effective and effective.

The purpose of this Ministry's ARP is therefore to create an environment that:

1. a) increase citizens' confidence in the honest and credible exercise of public authority;
2. b) raise awareness of corruption;
3. c) activate anti-corruption behaviour and conduct of employees and improve the reporting conditions for suspected corruption and the possibility of protecting whistle-blowers;
4. d) stresses the protection of the public interest and the refusal of corrupt behaviour and action at all organisational levels;
5. e) apply rigorously the inferible responsibility for corruption;
6. (f) create conditions to prevent abuse of power, influence and position, clientelism and nepotism.

To achieve these objectives it is necessary to create appropriate institutional, legal, technical and social conditions and to apply the principle of zero tolerance for corruption. In the context of this principle, acts of corruption and the risks that could give rise to corruption or create room or opportunity to commit should not be undermined or overlooked.

Corruption and antisocial behaviour whistleblowers must not create guilt and petty corruption offenders a sense of collective innocence. The notifier shall be assured that his notification of suspicion of corruption, corruption or conduct remains confidential and shall not be subject to retaliation.

The integrity and credibility of the Ministry on whose behalf the decision is issued must not be called into question when making a decision on its own merits. Any reduction in transparency in the decision-making processes of public authorities is unacceptable. In this context, it is also necessary to remove from decision-making all discretionary elements that could create room for corrupt behaviour. The integrity or credibility of the authority on whose behalf the decision is issued shall not be called into question when making its own decision on its own merits. There is also a need for strong accountability for creating space, opportunities and conditions for corruption, as well as for the emergence and existence of corruption schemes and networks (the so-called 'carousel corruption').

The anti-corruption coordinator of MZ SR is responsible for preparing and submitting an update of the Resort Anti-corruption Programme for approval to the Minister of Health of the Slovak Republic.

Article 5

Sectoral anti-corruption programme measures updated on 30 June 2026

In order to improve the system for managing corrupt risks and subsequently addressing vulnerabilities and ministry processes exposed to non-ethical or unlawful behaviour, it is necessary to identify those risks, to assess the degree of their frequency and severity of their impact on activities, objectives and credibility, or the Ministry's reputation, to analyse their causes, to take and monitor the implementation of corrective measures to reduce or eliminate them.

The corruption risk management system also includes an application for the management of corruption risks by the Office of the Government of the Slovak Republic, which will provide information on corruption risks to the Ministry's senior staff and enable monitoring of compliance with the relevant measures. To this end, regular assessment and assessment of corruption risks will be carried out and corrective action taken.

The basis for the analysis of corrupt risks is an internal management act which serves to identify and manage these risks effectively. It shall also include a list of processes, procedures and activities exposed to corruption, together with the determination of time limits and responsible persons for decision-making and performance as part of this internal management act.

Within the framework of the corruption risk management system, the Ministry will evaluate the suitability and effectiveness of existing management activities in order to eliminate corruption risks and to eliminate the conditions allowing corruption. Following an assessment of corrupt risks, the type and level of anti-corruption management activities to be applied to the corresponding category of corruption risk shall be determined, assessing whether existing management activities are sufficiently effective. They shall be adjusted as necessary.

Ministry staff may report suspected corruption and suspicion of other antisocial activities via e-mail address Corruption@health.gov.sk or protipolcinnost@health.gov.sk, by post as well as personally orally in the record of the person responsible at the Office of the Director of the Control, Supervision and Complaints Service. The inspection, surveillance and complaint service will provide the anti-corruption coordinator every six months with a list of submissions received concerning the reporting of suspected corruption. In this context, it is necessary to ensure protection for whistle-blowers who have brought to the attention of corruption or other anti-social behaviour or conduct. The support and protection of whistle-blowers is included in a system of procedures, rules and internal management acts which guarantees an impartial assessment of the conduct vis-à-vis the staff member, which may be considered to be retaliation for having notified such proceedings.

The principle of protection of notifiers is that procedures and rules/internal rules are designed to guarantee the support and protection of whistle-blowers who, in good faith, warn of the emergence of corrupt risks, possible corruption or other anti-social behaviour or unethical behaviour. The protection of whistleblowers shall include the application of a system of rules and procedures for the impartial assessment of conduct against a staff member who may be considered retaliatory for having reported suspicions of corruption or other anti-social or non-ethical conduct. The burden of proof shall lie with the person who has proposed or applied the sanction. The very existence of legislation to sanction corruption is not enough to reduce corruption.

Decree No 400/2019 of the Government Office of the Slovak Republic Z.z., which issues the Code of Conduct of the State employee and the Code of Conduct of the Ministry of Public Works Employees defines and supports the required standards of conduct and conduct of employees in relation to the public, partners and co-workers. It is a summary of the fundamental values and principles of honest and ethical behaviour, creating the basis for public trust in public administration.

The training activities of Ministry staff on corruption prevention will focus on strengthening the honest conduct and conduct of all Ministry staff. They will include the adaptation process of newly recruited employees when they enter employment, as well as ongoing training of employees and heads of staff of the Ministry. The aim is to achieve increased workers' initiative to identify areas and opportunities allowing for the emergence and existence of corruption risks, to increase the number of proposals to minimise or eliminate corruption risks, including when addressing ethical issues.

The Ministry identifies and evaluates the risks arising from possible or existing internal and external conflicts of interest. All staff of the Ministry shall be required to notify any actual or potential conflict of interest, such as family, financial or other connection, which may or might affect directly or indirectly the performance of their work and the performance of their duties to their superior. Rules on the resolution of conflicts of interest should help to specify situations where employees may be able to facilitate or prevent the conduct of a corruption transaction. A conflict of interests may also be closely linked to the involvement of a risk trading partner or employee in a project or transaction, resulting in collusion, unjustified cost increases, poor quality projects, etc.

Article 6

Monitoring, evaluation and updating of the Resort Anti-corruption Programme

The purpose of monitoring the Resort Anti-Corruption Programme is to find out how successful the implementation of anti-corruption measures and the level of improvements achieved in the Slovak Republic are.

Monitoring through the anti-corruption coordinator shall collect on an ongoing basis data and information on the state of implementation of the measures by stakeholders, such as organisational units and subordinate organisations of the Ministry. In order to ensure smooth monitoring and proper evaluation of the Resort Anti-Corruption Programme, the cooperation and synergy of all organizational units and subordinate organisations of MZ SR is essential.

In particular, the information provided by the organizational services of MZ SR and its subordinate organisations is taken into account in the monitoring and evaluation of the situation.

Media information, evaluation reports and surveys of international and national organisations, the business sector and non-governmental organisations will allow an objective and unbiased view of the implementation of the Resort Anti-corruption Programme.

In the evaluation, it is recommended to take into account all the above sources of information with a prior examination of their objectivity. At the same time, the identified weaknesses (weak points) which adversely affect the ability to identify, mitigate and, where appropriate, eliminate corruption risks are also taken into account. At the same time, the causes of non-compliance or insufficient implementation of measures are identified, indicating what improvements have been made and setting recommendations for the next period.

Article 7

Final provisions

Corruption and fraud can be seen in many ways. MZ SR applies zero tolerance policy against corruption and fraud and has in place a reliable control system designed to prevent corruption and fraud as far as possible and to ensure that they are detected and corrected when they occur. All relevant procedures and strategies support the management of MZ SR, which will actively and continuously review and update it.

The Resort Anti-Corruption Programme shall be an open document and shall be deemed to be up-to-date if necessary and to be able to identify deficiencies or new facts. The anti-corruption coordinator, in coordination with the departments of the Ministry and subordinate organisations, will propose possible amendments to individual measures, solutions to problems and ways to eliminate obstacles to slowing down or preventing the implementation of the Resort Anti-corruption Programme. The summary evaluation is carried out by the anti-corruption coordinator once a year in the last calendar year and submitted to the Slovak Government Office no later than 30 June of the following year.

This Resort Anti-corruption Programme shall enter into force on 30 June 2026.

Corruption@health.gov.sk

And the authentic form:

Ministry of Health - do not open
Control, Supervision and Complaints Unit
Limba 2
P.O. BOX 52
837 52 Bratislava 37

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1 Article 15 et seq. the United Nations Convention against Corruption.
2 EC document - Fraud risk assessment and effective and proportionate anti-fraud measures, European Structural and Investment Funds - Guidelines for Member States and bodies involved in the programme, 16.06.2014, European Commission, EGESIF 14-0021-00 (https://ec.europa.eu/sfc/sites/sfc2014/files/sfc-files/guidance fraud risk assessment en.pdf).
3 § 266 to 268 of the Criminal Code.
4 § 241 of the Criminal Code.
5 Methodological Recommendation on Corruption Risk Management issued by the Corruption Prevention Department of the Office of the Government of the Slovak Republic approved on 25.06.2025