Transparency International Italy first proposed using integrity pacts (IPs) to oversee public procurements in seven large and midsized municipalities in 2000. In the same year, the Milan City Board and Council unanimously approved the use of IPs, and soon other municipalities in northern Italy followed.

In Italy, the integrity pact is intended as a formal contractual commitment between municipalities (or other contracting entities) and bidders, in which both parties refrain from corruption and collusion. Its clauses include:

• disclosure requirements for public authorities (data on the tendering and awarding process)
• disclosure requirements for bidders (payments in connection with the contract)
• dispute resolution mechanisms (arbitration rules of the municipality)
• sanctions for non-compliance (including the exclusion of companies from bids, cancellation of the contract, liability for damages)

Thus, in terms of contractual agreement, it includes all the relevant commitments of the original IP concept published by Transparency International in 2002. However, it differs from it by not providing for any formal monitoring role by civil society, mainly due to the additional costs this would imply. Nevertheless, TI Italy has played an essential role in supporting its technical implementation in Milan and elsewhere, monitoring its correct application and providing recommendations for its improvement.

Recorded positive impact of the use of IPs in Milan in the early 2000s resulted in the signing of a Memorandum of Understanding in October 2009 between TI Italy, the Anti-Corruption and Transparency Service (SAeT) and the National Association of Italian Municipalities (ANCI) for the further promotion of IPs in municipal procurement. This entailed TI Italy’s technical assistance in training procurement staff in municipal administrations and support in introducing IP clauses in tenders.

TI Italy monitored the use of IPs in Milan and recorded the positive impacts from 2002-2014 when they were applied to public contracts with a total value of €131 million. According to TI Italy’s assessment, a lack of compliance with the IP resulted in the cancellation of 453 tenders and the exclusion of 166 companies from bids. Moreover, it resulted in €2,76 million collected through sanctions procedures for non-compliance.

Over the years, the tool was progressively recognised in the Italian legal framework. According to both the Procurement Law and the 2012 Anti-Corruption Law, a bidding company must comply with the provision of an IP when contracting authorities (CAs) require them to sign it. Otherwise, a company can be excluded from the bid. In 2015, a decision by the newly created Italian Anti-Corruption Agency further encouraged public administrations at all levels to use the IP, though its inclusion is not mandatory.

According to a 2017 report, 70% of the 111 provincial capital cities in Italy adopted the integrity pact that year.

The latest Italian Anti-Corruption Strategy, adopted in November 2019, details the legality of IPs under Italian and European law and their usefulness. The strategy mentions the Integrity Pacts EU pilot project (see next section) as a best practice to be emulated by other Italian CAs. IP implementation has also been endorsed as part of Italy’s Open Government Partnership National Action Plan 2019-2020, with a recommendation for further use focusing on Sicily.

From 2016 to 2022, Italy took part in the implementation of the EU-wide programme to pilot the integrity pacts (IPs) to safeguard EU funds. Three civil society organisations – TI Italy, ActionAid Italia, and Amapola – monitored contracting projects in Sardinia, Lombardy, Calabria, and Sicily. The pilot has provided significant evidence about the added value of independent civil society monitoring in improving the quality of procurement planning, better value for money, citizen engagement, and business integrity.

In Sardinia, TI Italy monitored a 2,5 km extension of one light railway system line in Cagliari. The project, worth €22,5 million and managed by the Sardinian Regional Transport Company, was characterised by significant delays in the planning phase that upset the relationship between the contracting authority (CA) and the bidders. TI Italy mitigated the damage by conducting an in-depth assessment of the causes of delay and organising civic engagement initiatives to keep public interest high. It also helped the contracting authority develop an anti-corruption plan.

In Lombardy, TI Italy signed an IP with the Region of Lombardy to monitor a €1,95 million procurement of technical assistance to local government authorities to access and use funds from the European Social Fund for employment, education, and training. TI Italy’s monitoring work contributed to the clarification of an instance of suspected collusion in the submission of bids and helped the contractor to establish a modern, secure, and reliable whistleblowing channel as well as anti-corruption guidelines for its operations.

In Calabria, ActionAid Italia monitored the development of an archaeological park in Sybaris, worth €2 million and managed by the Regional Secretariat of Cultural Heritage and Landscape of the Calabria Region. The monitoring work from 2016 to 2021 contributed to revising and simplifying the contracting strategy to improve value for money and timeliness. Importantly, ActionAid also carried out a structured training programme in procurement monitoring for the affected community, which helped foster trust and engagement in the project.

In Sicily, the social enterprise Amapola entered into an agreement with the Madonie Community to monitor two projects for the procurement of IT equipment and educational services for high schools and energy efficiency interventions across different municipalities. Monitoring work in the first project, which ran from 2019 to 2021, helped to improve the quality and efficiency of the tendering procedure and, through civic monitoring workshops in affected schools, contributed to increased awareness and knowledge of public procurement among students.

The monitoring work in the second project on energy efficiency contributed to protecting the €4 million investment from significant corruption risks. After awarding the contract, the CA discovered that the technical director of the winning company had previously been convicted of environmental crimes. After its own background checks, Amapola found out that he was also involved in a corruption investigation related to a separate contracting procedure. The bidder had not disclosed this information, and the contract was eventually withdrawn.