Shadow Report for Sustainable Development Goals 16.4, 16.5, 16.6 & 16.10

The information gathered in the Shadow Report for Sustainable Development Goals 16.4, 16.5, 16.6 & 16.10 (hereinafter referred to as “the Report”) has been used as an input into two processes. 

* At the global level, this information has been used at the High-Level Political Forum in July 2018, which serves as the central United Nations platform for the follow-up and review of the Sustainable Development Goals (hereinafter referred to as “SDGs”). As part of its advocacy plan against corruption, Transparency International has initiated voluntary reviews on the aforementioned SDGs, in order to complement national voluntary reviews submitted in the forum by the states. This initiative has enabled SDG’s monitoring to go beyond the remit of governments, so at to include civil society and other stakeholders, which are able to provide a more independent and objective look on the SDGs implementation progress. This is of crucial importance, since the official assessment of progress made towards the SDG targets relied on data generated by government agencies, particularly national statistics offices. The reliability and credibility of official data may be open to question for two reasons. First, in some settings, national statistics offices may simply be overwhelmed by the task of producing data for 169 targets. Second, politically sensitive targets, such as those related to corruption and governance, require that governments assess their own efficacy. Given the challenges described above, independent analysis is vital to complement and scrutinise official government progress reports related to SDGs 16.4, 16.5, 16.6 and 16.10.

* At a national level, the information generated enabled Transparency International Greece (hereinafter referred to as “TI-G”) to conduct an independent appraisal of Greece’s progress in fighting corruption, tackling illicit financial flows, and improving transparency and access to information, against the targets set for the Greek state though the Agenda 2030 for Sustainable Development. 


High-Level Political Forum of United Nations, Greek state, civil society, international and national organizations fighting against corruption, journalists.

2018  on going 

The Report reviews progress against SDG Goal 16,  that focuses on sustainable governance and anti- corruption fight. The Report mainly focuses on the policy areas linked to the following Goal’s 16 targets: i) 16.4 on illicit financial flows, ii) 16.5 on bribery and corruption, iii) 16.6 on transparent and accountable institutions, and iv) 16.10 on access to information. The particularity of the Report lays on its main goal, which is the provision of an independent appraisal of Greece’s anti-corruption efforts in the context of the SDGs. To do so, the Report covers a broad range of issues related to a robust anti-corruption framework and it identifies areas where the Greek anti-corruption system leaves room for improvement. However, it is worth mentioning that extracting of information was a challenging task due to the multi-dimensional nature of SDG targets, data availability and perceived credibility of data generated by government agencies. 

A questionnaire provided by Transparency International, which covers the de jure legal framework and the de facto situation linked to the aforementioned targets served as the tool to extract the Report’s data.  The originality of the questionnaire is that it aims at providing a rounded overview in a way that goes beyond the narrow understanding of corruption captured by the official global indicators. This is why, when a score is provided each policy area was assessed against three sources of information. 

First, relevant information has been extracted from national legislation, reports as well as press releases of the Greek ministries and public administration. Second, relevant country data from assessments and indices produced by civil society groups and international organisations was considered. Country reports from international organisations, such as the Organisation for Economic Cooperation and Development (OECD), the Financial Action Task Force (FATF), the United Nations (UN) have been used. Third, articles published in the press and information from civil society and other organizations have also served as a source. Based on the aforementioned data there was a scored evaluation of the Greece’s de jure legal and institutional framework. Also, researchers conducted a qualitative appraisal of the country’s de facto efforts to tackle corruption. In this way, TI-G was able to extract pertinent data to monitor national anti-corruption progress. 


TI-G has cooperated with Transparency International – Secretariat and has been financially supported by Transparency International-Spain and its Action Grant fund, in order to conduct the research and publish the Report.

The Report has been published by TI-G. 

Researcher of the Report is Ms Eleni Kloukinioti, Lawyer and TI-G’s Researcher.

Legal reviewer of the Report is Ms  Εleni Kalogeraki, Lawyer 

Editorial reviewer of the Report is Ms  Piyi Yiatra, Office Supervisor of TI-G. 

Ms Leondiou Evelina, Ms Exarchou Giolena and Ms Fotopoulou Katerina, students of the University of Athens – Faculty of Law and interns of TI-G, have made voluntary research contribution into the Report. 


The Research was conducted in Greece during May - June 2018 and its output has been promoted ever since.

The Research and its results can be found here: 

TI-G presented the research in various conferences and seminars. Some of them can be found in the following links: 

A scorecard with the results of the Report can be found here:


The Report is a reminder towards the state and the civil society on the importance of an anti-corruption strategy as well as a clear proposal indicating the policy areas, which have to be improved. In particular, the Report propose:

  1. that for the reduction of illicit financial flows under SDG 16 target 16.4 the Greek state should:

    • actively investigate and prosecute cases of money laundering, drug trafficking and other forms of organised crime;

    • create a registry of beneficial ownership;

    • follow up on the EU legislation, by incorporating on time all the EU Directives and the measures proposed;

    • strengthen mechanisms for asset recovery; και 

    • record the results of its actions in relation to recovery and return of stolen assets and make them public.

  2. that for the reduction of corruption and bribery in all their forms under SDG 16 target 16.5, the Greek state should:

    • pass a law regulating lobbying of political actors, in line with international standards;

    • monitor the implementation of legal framework concerning the financing of political parties; and

    • monitor the implementation of legal framework concerning interest declarations and income as well as asset disclosures and code of conduct of public officials.

  3. that for effective, accountable and transparent institutions at all levels under SDG 16  target 16.6, the Greek state should:  

    • pass a standalone whistleblower protection law that is in line with international standards; 

    • adopt internal monitoring structures in all ministries, departments, bodies and Local Authorities; and

    • develop a training policy to support long-term anti-corruption strategic planning and capacity development for the public sector. 

  4. that for ensuring public access to information and protect fundamental freedoms, under SDG 16 target 16.10 the Greek state should:

    • support, protect and promote investigative journalism and civil society activists; and

    • take appropriate measures in order to deal effectively with Greek bureaucracy, in order to ensure people’s access to information;

The Report strengthened TI-G’s capacity to carry out and maximise the effectiveness of its advocacy to influence national, regional or global development policy and practice. The Report was a unique opportunity for TI-G to raise a voice for tackling corruption in Greece and counter regional and international conservative lobbies slowing down or countering the adoption and the implementation of progressive texts and/or policies towards the fight against corruption. For instance, the findings on the whistleblowing legislation enabled TI-G to present the Greek whistleblowing framework (or its absence, if we want to be more accurate) to the advocacy meetings of Transparency International in Brussels, pushing for the adoption of the EU Directive for the protection of whistleblowers. 

At the same time, the Report can be related to other advocacy activities of TI-G where the results of Research has been used as indicators of the need of the improved into legislation. Such advocacy activities can be briefly summarized into TI-G’s conferences on whistleblowing and lobbying. 

Moreover, the methodology of the Report as well as its results enabled TI-G to set the ground for its future advocacy activities in order to boost changes into the open governance and whistleblowing regulatory framework.