1. Openness To, and Restrictions Upon, Foreign Investment
Policies Towards Foreign Direct Investment
The GOI has publicly stated its commitment to attract foreign investment, particularly given Iraq’s current fiscal challenges and the massive reconstruction needs in areas previously held by ISIS. In February 2018, the GOI partnered with the World Bank and the Kuwaiti government to host the Kuwait International Conference for the Reconstruction of Iraq, which was partially aimed at attracting private sector investment. The GOI has made little progress on commitments made at the conference to reform processes and regulations that hinder investment.
In December 2015, the GOI passed an amended National Investment Law (NIL) that improves investment terms for foreign investors, allows them to purchase land in Iraq for certain projects, and speeds up the investment license process. In 2015, Iraq also joined the International Convention on the Settlement of Investment Disputes between States and Nations of Other States (ICSID).
Nevertheless, foreign investors continue to encounter bureaucratic challenges, corruption, and a weak banking sector which make it difficult to successfully conclude investment deals. The IKR financial sector is still recovering from years of financial instability in the IKR and the Central Bank of Iraq’s sanctions against the IKR financial system immediately following the Kurdistan independence referendum in September 2017.
Recently, the GOI has been exploring financing options to pay for large-scale development projects rather than relying on its previous practice of funding investments entirely from current annual budget outlays. According to the NIL, the GOI reserves the right to screen foreign direct investment. The U.S. Department of State is not aware of instances where this screening process has impeded foreign investments in Iraq.
The IKR has its own investment law and regulations. The KRG is working to put the business registration process and procedures online. The KRG is open to public-private partnerships and is interested in modern, long-term financing, as demonstrated by the KRG’s oil and gas sector contracts that increase production.
According to Iraqi law, a foreign investor is entitled to make investments in Iraq on terms no less favorable than those applicable to an Iraqi investor, and the amount of foreign participation is not limited. However, Iraq’s NIL limits foreign direct and indirect ownership of most natural resources, particularly the extraction and processing of any natural resources. It does allow foreign ownership of land to be used for residential projects and co-ownership of land to be used for industrial projects when an Iraqi partner is participating.
Iraq’s 2006 Investment Law Number 13 called for the establishment of a National Investment Commission (NIC) and Provisional Investment Commissions in each of the provinces. The NIC, launched in 2007, is a cabinet-level organization which provides policy recommendations as well as support to current and potential investors in Iraq. The NIC’s “One Stop Shop” is intended to guide investors through the investment process, though investors have reported challenges using the NIC’s services. The NIC can also grant investment licenses and facilitate visa and residency permit issuances for business travelers.
Limits on Foreign Control and Right to Private Ownership and Establishment
According to National Investment Regulation No. 2 of 2009, if an investment license is granted to a project, at least 50 percent of the project’s workers must be Iraqi nationals. The amended NIL also states that investors should give priority to Iraqi citizens before hiring non-Iraqi workers. As a result of popular protests in the summer of 2015, the GOI has applied pressure on foreign companies to hire more local employees. In order to generate non-oil revenues, the GOI has also encouraged foreign companies to partner with local industries and purchase Iraqi-made products. The GOI generally favors SOEs and state-controlled banks in competitions for government tenders and investment. This preference discriminates against both local and foreign investors.
Other Investment Policy Reviews
In the past three years, the GOI has not conducted any investment policy reviews through the Organization for Economic Cooperation and Development (OECD), the World Trade Organization (WTO) or the United Nations Conference on Trade and Development (UNCTAD).
Foreign investors interested in establishing an office in Iraq or bidding on a public tender are required to register as a foreign business with the Ministry of Trade’s Companies Registration Department. Investors who will do business only in the IKR can register with the Kurdistan Regional Government directly. Companies that will do business in both the IKR and greater Iraq must register with the Ministry of Trade.
Under the NIL, the NIC and the Provincial Investment Commissions (PICs) are intended to be one-stop shops that can provide information, sign contracts, and facilitate registration for new foreign and domestic investors. The NIC offers investor facilitation services on transactions including work permit applications, visa approval letters, customs procedures, and business registration. Investors can request these services through the NIC website: . However, the National and Provincial Investment Commissions struggle to operate amid unclear lines of authority, budget constraints, and an absence of regulations and standard operating procedures. The Investment Commissions still generally lack the authority to intercede when investors encounter bureaucratic obstacles with other Iraqi ministries.
In order to incorporate a company in Iraq, an investor must obtain a statement from an Iraqi bank showing a minimum capital deposit. All investors must also apply for an investment license from the appropriate national, regional, or provincial investment commission. Companies are required to register with the General Commission for Taxation and register employees for social security (if applicable). Companies that provide security are also required to register with the Ministry of the Interior. It takes an average of 26 days to start a business in Iraq, according to the 2018 World Bank Ease of Doing Business report; online procedures accounted for only 0.5 days of that time.
The National Investment Commission does not exclude businesses from taking advantage of its services based on the number of employees or the size of the investment project. The commission can also connect investments by micro-, small-, and medium-sized enterprises (MSMEs) with the appropriate provincial investment council.
The Kurdistan Board of Investment (KIB) manages a streamlined investment licensing process in the IKR whose policy is to acknowledge receipt of the license request within 30 days of the initial license application; however, the licensing process can take from three to six months and may involve more than one KRG ministry or entity, depending on the sector of investment. Despite bureaucratic hurdles, on the whole, the KIB investment framework seems to work well. Because of oversaturated commercial and residential real estate markets, the KIB has moved away from approving licenses in these sectors. Businesses report some difficulties establishing local connections, obtaining qualified staff, and meeting import regulations. However, the KIB receives high marks for being helpful in resolving problems. Additional information is available at the KIB’s website: .
Iraq does not restrict domestic investors from investing abroad.
2. Bilateral Investment Agreements and Taxation Treaties
Iraq does not have a Bilateral Investment Treaty (BIT) or a bilateral taxation treaty with the United States. The United States and Iraq signed an Agreement for Economic and Technical Cooperation on July 11, 2005 and it entered into force December 18, 2013. The U.S.-Iraq Strategic Framework Agreement (SFA) (available at the following website: ) provides intergovernmental forums to address impediments to investment and trade. There was a bilateral Higher Coordinating Committee (HCC) meeting on January 28, 2018 under the auspices of the SFA. At the HCC both sides committed to reinvigorate the Trade and Investment Framework (TIFA) process and to the formation of two bilateral working groups: 1) to simplify Iraq’s visa and residency permit process and 2) to resolve commercial disputes between American companies and the Government of Iraq. The existing TIFA between the governments of Iraq and the United States entered into force in 2013 and the inaugural TIFA Council meeting took place in March 2014 in Washington, D.C. The TIFA provides a framework for dialogue to increase trade and investment cooperation between the two countries.
Iraq is a signatory to investor protection agreements or memorandums of understanding with 35 bilateral partners and nine multilateral groupings. The agreements include arrangements within the Arab League, as well as arrangements with Afghanistan, Armenia, Bangladesh, France, Germany, India, Iran, Japan, Jordan, Kuwait, Mauritania, the Republic of Korea, Sri Lanka, Syria, Tunisia, Turkey, the United Kingdom, Vietnam, and Yemen.
Iraq currently has bilateral investment treaties with Armenia, France, Germany, Japan, Jordan, and Kuwait. Only the BITs with Japan and Kuwait are in force. Iraq’s investment agreements include general provisions on promoting and protecting investments, including clauses on profit repatriation, access to arbitration and dispute settlements, fair expropriation rules, and compensation for losses. However, the Iraqi government’s ability and willingness to enforce such provisions remains untested.
Iraq joined the Greater Arab Free Trade Area (GAFTA) in 1998 to better integrate economically with other Middle Eastern countries. However, Iraq withdrew from GAFTA on November 17, 2016, choosing instead to implement tariffs on all the goods coming into the country.
U.S. companies have raised concerns about the Ministry of Finance Tax Commission’s use of the “deemed tax” method to calculate corporate taxes, which can be disadvantageous for firms generating less than 20percent profit, the standard percentage applied to every company, regardless of the firm’s actual profit. U.S. investors also complain about the application of the social tax, equivalent to 5percent of employees’ pay and a 12 percent employer contribution, to third country national employees who do not participate in or benefit from the Iraqi health or pension system, which the taxes are used to fund.
3. Legal Regime
Transparency of the Regulatory System
Iraq’s overall regulatory environment remains opaque. Investors that bid on public procurement contracts or seek to invest in major infrastructure projects report that corruption, unclear regulations, and bureaucratic bottlenecks are major challenges. The KRG rolled out procurement reform measures in 2016 that seek to address some of these issues, yet the efficacy of these measures remains unclear. Iraq’s commercial and civil laws generally fall short of international norms. There are few provisions regarding commercial competition. The NIL does not establish a full legal framework governing investment.
The absence of other laws in areas of interest to foreign investors also creates ambiguity. Iraq’s Legislative Action Plan for the Implementation of WTO Agreements – the legislative “road map” for Iraq’s eventual WTO accession – requires competition and consumer protection laws that are critical for leveling the business playing field. The Council of Representatives passed a Competition Law and a Consumer Protection Law in 2010; however, the Competition and Consumer Protection Commissions authorized by these laws have yet to be formed. Without these Commissions, investors do not have recourse against potential unfair business practices such as bid rigging or abuse of a dominant position in the market.
The way in which the Iraqi government promulgates regulations can be opaque and lends itself to arbitrary application. Regulations imposing duties on citizens or private businesses are required to be published in the official government gazette. However, there is no corresponding requirement for the publication of internal ministerial regulations. This loophole allows bureaucrats to create internal requirements or procedures with little or no oversight, which can result in additional burdens for investors and other businesspersons.
Regulations exist at both the national and the provincial level. National regulations are the most relevant to foreign businesses. Lack of regulatory coordination between GOI ministries and national and provincial authorities can result in conflicting regulations, which makes it difficult for investors and business people to easily and accurately interpret the regulatory environment.
Publicly listed companies are governed by the Interim Law on Securities and Markets (Coalition Provisional Authority Order Number 74) which is consistent with international norms; however, enforcement of this law is often not effective. Accounting, legal, and regulatory procedures are opaque, inconsistent, and generally do not meet international standards. Draft bills, including investment laws, are not available for public comment.
The GOI encourages private sector associations but private sector associations are generally not influential, given the dominant role of SOEs in Iraq’s economy.
The promulgation of new regulations with little advance notice and requirements related to investment guarantees have also slowed projects. While the Kurdistan Region Investment Law (KRIL) of 2006 does not stipulate that a local partner is necessary to acquire an investment license, government officials sometimes encourage this practice.
International Regulatory Considerations
Iraq is not a member of the WTO and is not a signatory to the Trade Facilitation Agreement (TFA).
Legal System and Judicial Independence
Iraq has a civil law system, although Iraqi commercial jurisprudence is relatively underdeveloped. During decades of war and sanctions, Iraqi courts became isolated from developments in international commercial transactions. Investors report that corruption and bureaucratic bottlenecks are significant problems. As trade with foreign parties increases, Iraqi courts have seen a significant increase in complex commercial cases. Contracts should be enforceable under Iraqi law. In practice, however, honoring contracts and contract enforcement remains a challenge due to unclear regulations, lack of decision-making authority, and rampant corruption.
Laws and Regulations on Foreign Direct Investment
Iraq is a signatory to the League of Arab States Convention on Commercial Arbitration (1987) and the Riyadh Convention on Judicial Cooperation (1983). Iraq formally joined the ICSID Convention on December 17, 2015, and on February 18, 2017, Iraq joined the Investor-State Dispute Settlement (ISDS) process agreement between investors and states.
Competition and Anti-Trust Laws
The Council of Representatives passed a Competition Law and a Consumer Protection Law in 2010. However, the Competition and Consumer Protection Commissions authorized by these laws have yet to be formed. Later, the NIL was intended to promote fair competition and “competitive capacities” in the local market. However, the NIL did not include provisions related to the competition legislation. Investors note that the prominent role of SOEs in Iraq and corruption issues undermine the competitive landscape.
Expropriation and Compensation
Article 23 of the Iraqi Constitution prohibits expropriation, unless done for the purpose of public benefit and in return for just compensation. The Constitution stipulates that expropriation may be regulated by law, but specific legislation regarding expropriation has not been drafted. Article 9 of the amended NIL also guarantees non-seizure or nationalization of any investment project covered by the provisions of this law, except in cases where a final judicial judgment has been reached. It prohibits expropriation of an investment project, except in cases of public benefit and with fair compensation. Iraq’s Commercial Court is charged with resolving expropriation cases. Over the past six years, there have not been any government actions or shifts in government policy that would indicate possible expropriations in the foreseeable future.
In the IKR, if the KIB determines that investors are using land awarded under investment licenses for purposes other than those outlined in the license, it can impose fines and potentially confiscate the land. Article 17 of the IKR investment law outlines an investor’s arbitration rights, which fall under the civil court system. Arbitration clauses should be written into local contracts in order to facilitate enforcement in the event of a dispute.
ICSID Convention and New York Convention
Iraq is considering, but has not yet signed or ratified, the convention on Recognition and Enforcement of Foreign Arbitral Awards (1958 New York Convention) and the ad hoc arbitration rules and procedures established by the UN Commission on International Trade Law (UNCITRAL Model Law). The enforcement of arbitral awards must comply with the special requirements set forth in current Iraqi civil procedure law and other related laws.
Investor-State Dispute Settlement
In November 2010, Iraq’s Higher Judicial Council established the First Commercial Court of Iraq, a court of specialized jurisdiction for disputes involving foreign investors as part of a national strategy to improve Iraq’s investment climate. This court began hearing cases in January 2011. In 2017, a Higher Judicial Council survey of the 16 federal courts of appeals that heard Iraq’s commercial cases showed that 1,565 commercial cases had been filed and 83percent of those cases had been completed. Given that all of Iraq’s ministries are located in the capital, and the vast majority of commercial cases involve a foreign party and an Iraqi government agency, the Baghdad Commercial Court reviews far more commercial cases than the general jurisdiction courts in the surrounding provinces. In 2017, 982 commercial cases were filed with Baghdad’s Commercial Court, representing 63percent of the total commercial cases filed. In the IKR, commercial disputes are handled through the civil court system.
International Commercial Arbitration and Foreign Courts
Iraq is a signatory to the League of Arab States Convention on Commercial Arbitration (1987) and the Riyadh Convention on Judicial Cooperation (1983). Iraq formally joined the International Convention on the Settlement of Investment Disputes between States and Nationals of Other States (ICSID) on December 17, 2015, and on February 18, 2017, Iraq joined Investor-state Dispute Settlement (ISDS) process agreement between investors and states.
Under Iraqi law, an Iraqi debtor may file for bankruptcy, and an Iraqi creditor may file for liquidation of the debtor. Bankruptcy is not criminalized. The Iraqi Companies Law regulates the process for liquidation of legal entities. Nevertheless, the mechanism for resolving insolvency remains opaque. Out of 190 countries, Iraq rankslast, tied with 22 other countries at 168 in the category of Resolving Insolvency, according to the World Bank’s 2018 Doing Business Report ( ).
7. State-Owned Enterprises
State-owned enterprises (SOEs) are active across all sectors in Iraq. GOI ministries currently own and operate over 192 SOEs, a legacy of the state planning system. Many Iraqi SOEs are unproductive, and the GOI’s continued support of unprofitable entities places a substantial fiscal burden on Iraq. These firms employ over half a million Iraqis, many of whom are underemployed. The degree to which SOEs compete with private companies varies by sector; SOEs face the most competition in the market for consumer goods. The GOI has expressed a commitment to reforming the SOEs and taking steps toward privatization as part of its international financing programs.
Law 22 of 1997 and the NIL provide the regulatory framework for the operations of SOEs and joint ventures between foreign companies and SOEs. Law 22 is complex, and several articles are ambiguous regarding the rights and privileges that SOEs enjoy. Article 15.3 of Law 22 allows Iraqi SOEs to engage in partnership agreements or joint ventures with foreign companies. However, the lack of clarifying regulations has created difficulty in implementation. Ministries have faced challenges in reviewing partnership agreements without sufficient criteria to determine if the agreements would be effective or successful. When parent ministries wish to initiate a partnership for an SOE under their purview, they generally advertise the tender on their ministry’s website. Partnerships are negotiated on a case-by-case basis, and the minister’s approval is required. The Ministry of Industry and Minerals (MIM), which oversees the largest number of Iraq’s SOEs, received the Council of Ministers’ approval in 2013 to institute the following requirements for partnerships: 1) change the required minimum duration to three years; 2) add a requirement that the foreign company register a company office in Iraq; and 3) add a requirement that the foreign company participate in the production of goods.
According to the Prime Minister’s Advisory Council, foreign companies have faced challenges in partnerships because the GOI has at times cut subsidies to the SOE after partnerships were formed, the employment policies and salary decisions were dictated by the parent ministry, and gaps between the GOI’s official policy and practices affected their bottom line. In addition, the MIM has often required that the foreign investor pay all SOE employees’ salaries regardless of whether they are working on the agreed project.
GOI entities are required to give preferential treatment to SOEs under multiple laws. A 2009 Council of Ministers’ decision requires all Iraqi government agencies to procure goods from SOEs unless the SOE cannot fulfill the quality and quantity requirements of the tender. A Board of Supreme Audit decision requires government agencies to award SOEs tenders if the SOE’s bid is no more than 10percent higher than other bids. Furthermore, some GOI entities, including the MIM, have also issued their own internal regulations requiring tenders to select Iraqi SOEs, unless the Iraqi SOE states that it cannot fulfill the order. Sometimes a foreign firm must form a partnership with an Iraqi firm to fulfill tenders promulgated by SOEs.
As of 2017, state-owned banks had provided SOEs with approximately $11 billion USD in loans in order to finance salaries since 2003, although many SOEs that received these loans were unable to repay; SOEs also receive research and development subsidies. Under Article 16 of the 2008 Regulations for Implementing Government Contracts (Law No. 1), SOEs are exempt from bid bond and performance bond requirements. While the Iraqi budget outlines the funds that the SOEs will receive, both for operational costs as well as for salary payments, the SOEs do not always receive the exact figure allocated. As a result of years of sanctions and war, most of these SOEs suffer from sclerotic management and dependence on GOI contracts. Many of them are not commercially viable due to bloated payrolls and obsolete equipment, although some have adapted and are producing goods for the domestic market.
In 2015, the MIM developed a plan to restructure its 59 SOEs. Under the proposed plan, the MIM would rate SOEs based on their profitability and degree of government dependence. Unprofitable SOEs that are unable to cover payroll obligations would be sold or shut down. However, no action to implement this plan has been undertaken. Article 14 of the 2017 Federal General Budget Law expanded the potential role of private investment in SOE reform, giving governorates the mandate to expand partnerships with the private sector “as much as possible” with approval of the governorate’s council.
Iraq is not party to the Government Procurement Agreement within the framework of the WTO.
Articles 20-25 of Law 22 specify the selection process of an SOE’s Board of Directors. The law includes provisions to introduce a degree of autonomy. For example, it requires that the minister’s sole appointment to the Board of Directors receive the approval of an “Opinion Board.” Nevertheless, in practice, the majority of board members have close personal and political connections to the parent ministry’s leadership.
SOEs do not adhere to OECD Guidelines. Iraq does not have a centralized ownership entity that exercises ownership rights for each of the SOEs. SOEs are required to seek their parent ministry’s approval for certain categories of financial decisions and operation expansions. However, in practice, SOEs defer to the parent ministry for the vast majority of decisions. SOEs submit financial reports to their parent ministry’s audit departments and the Board of Supreme Audit. These reports are not published and sometimes exclude salary expenses.
The GOI has repeatedly announced that it plans to reorganize failing SOEs across multiple sectors. Additionally, the GOI is eager to modernize Iraq’s financial and banking institutions. There are, however, no concrete timelines for these initiatives, and entrenched patronage networks tying SOEs to ministries remain a stumbling block. Presumably, foreign investors would have an opportunity to invest in privatization projects. The IMF Stand-By Arrangement requires the Government of Iraq to conduct an audit of state-owned banks and the World Bank’s Development Policy Loan requires Iraq to audit SOEs.
Iraq ranked 169 out of 180 on Transparency International’s 2017 Corruption Perception Index. Public corruption is considered by Iraqi officials to be a major obstacle to the development of Iraq’s economy and to political stability. Perceptions of corruption are pervasive in government procurement, in the awarding of licenses or concessions, dispute settlement, and Iraq’s customs regime.
Targeting corruption has been a key element of Prime Minister Abadi’s reform agenda, and public protests throughout the country continue to call for the removal of corrupt officials. The Prime Minister formed a committee in January 2015 to approve and coordinate anti-corruption efforts. The committee includes the Commission of Integrity (COI) Acting Commissioner, the Minister of Finance, the Minister of Planning, the President of the Board of Supreme Audit, and the Council of Ministers Secretary General. In 2016, Prime Minister Abadi dismissed Minister of Trade Malas Abdulkareem for corruption and for not showing up to work at the Ministry for more than 30 days. The parliament also questioned Minister of Defense Khalid Al-Obaidi, dismissing him on corruption allegations on August 25, 2016. Minister of Finance Hoshyar Zebari was also dismissed on September 21, 2016 after being accused of corruption. None of these officials was prosecuted for corruption, and there was speculation that the dismissals were otherwise motivated. Anticorruption laws apply to all citizens of Iraq, but investors assert that some government officials and their family members are frequently involved in corrupt practices without scrutiny. According to UNDP data, 95 percent of bribery incidents go unreported.
While large-scale investment opportunities exist in Iraq, particularly for sophisticated investors, corruption remains a significant impediment to conducting business, and foreign investors can expect to contend with corruption in many forms, and at almost any level. While the GOI has moved toward greater effectiveness in reducing opportunities for procurement corruption in sectors such as electricity, oil, and gas, credible reports of corruption in government procurement are widespread, with examples ranging from bribery and kickbacks to awards involving companies connected to political leaders. Investors may come under pressure to take on well-connected local partners to avoid systemic bureaucratic hurdles to doing business. Similarly, there are credible reports of corruption involving large-scale problems with government payrolls, ranging from “ghost” employees and salary skimming to nepotism and patronage in personnel decisions. Moving goods into and out of the country continues to be difficult, and bribery of port officials is commonplace; Iraq ranks 179 out of 190 countries in the category of “Trading Across Borders” in the World Bank’s 2018 Doing Business report.
U.S. firms frequently identify corruption as a significant obstacle to foreign direct investment, particularly in government contracts and procurement, as well a performance requirements and performance bonds.
There are three principal institutions specifically designated to address the problem of corruption in Iraq. CPA Order 57 established Inspectors General (IGs) for each of Iraq’s ministries. Similar to the role of IGs in the U.S. government, these offices are responsible for inspections, audits, and investigations within their ministries. The Commission of Integrity (COI), initially established under the Coalition Provisional Authority (CPA), is an independent government agency responsible for pursuing anti-corruption investigations, upholding enforcement of laws, and preventing crime. The COI investigates government corruption allegations and refers completed cases to the Iraqi judiciary. COI Law No. 30, passed in 2011, updated the CPA provisions by granting the COI broader responsibilities and jurisdiction through three newly created directorates: asset recovery, research and studies, and the Anti-Corruption Academy.
The Board of Supreme Audit (BSA), established in 1927, is an analogue to the U.S. government’s General Accountability Office. It is a financially and administratively independent body that derives its authority from Law 31 of 2011 – the Law of the Board of Supreme Audit. It is charged with fiscal and regulatory oversight of all publicly-funded bodies in Iraq and auditing all federal revenues, including any revenues received from the IKR.
None of these organizations is perceived as an effective check on public corruption.
Neither the COI nor the IGs have effective jurisdiction within the IKR. The Kurdistan Board of Supreme Audit audits regional revenues with Iraqi Kurdistan Parliament (IKP) and GOI oversight. The IKP passed the Commission on Public Integrity (Law Number 3) in 2011, which established a regional Commission of Integrity (KCOI) that began its work in late 2013. The IKP passed an amendment to the law in May 2014 that gave the KCOI increased jurisdiction over other branches of government, and made the KCOI responsible for investigating money laundering. The Commission launched an initiative in early 2014 to collect financial declaration forms from public officials at the director general-level and above. They received a 95 percent response rate and have begun to check the disclosure documents against other public records. According to the KCOI 2017 Annual Report, 372 cases were reported or referred to the KCOI from different sources such as the Prosecutor’s office, KRG Intelligence, the KCOI Hot Line, and IKR media outlets. The KCOI settled 33 cases in 2017 with 15 ending in sentencing and 18 dismissed.
Iraq is a party but not a signatory to the UN Anticorruption Convention. Iraq is not a party to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.
Resources to Report Corruption
According to Iraqi law, any person or legal entity has the right to submit corruption-related complaints to the COI or the inspector general of the GOI ministry or body engaging in corruption.
Commission for Integrity
Department of Complaints and Reports