employees and to the public. Its observance will be mandatory and made a
condition of service. The code of ethics will include a disciplinary chapter
which specifies what constitutes misconduct, and the sanctions that apply.

5.8 Oversight and Accountability

The border agency will introduce a code of conduct specifying the duties of
all personnel. It provides a framework and guidelines covering areas such
as what constitutes a conflict of interest, its forms (incompatible functions
and activities, restriction on auxiliary activities, acceptance of gifts etc.),
how to avoid such conflicts, with whom to consult, reporting lines, and the
consequences of a breach. The code of conduct will be published. This is to
underline its importance in the eyes of border agency staff and to make
the public and partner organisations aware of the border agency’s anti-
corruption policy.

Continuous analysis of the threats and risks of corruption is mandatory as
is regular improvement of procedures to diminish the possibility for corrupt
practices. Transparent procedures with proper documentation will make it
possible to perform ex post analysis to verify suspected wrongdoing.
Procedures will be reviewed and updated at regular intervals.

5.9 Contingency

Contingency procedures for situations requiring urgent action (including
search and rescue) should be in place. The plans developed at central
level, and adjusted for regional and local needs, will clarify the division of
responsibilities in cases of imminent threats to national security (mass
influx of irregular migrants or refugees, terrorist activities etc.) or public
health (natural disasters, pandemic diseases, major accidents and fires in
the border zone etc.).

6. HUMAN RESOURCES AND TRAINING
6.1 Human Resources

The border agency will establish robust and specific personnel processes
for recruitment, retention, performance and assessment, promotion,
career development, training, transfer, severance, dismissal, retirement,
and remuneration and working conditions. These specific processes will be
complementary to each other and together form the border agency’s
Human Resources management system and policies. By introducing
regular audits and checks, the border agency ensures the fitness for
purpose of staff roles, grading, and pay scales within each function of the
agency. A centralised staff management database should be retained by
the Human Resources Department and made available on a need-to-know
basis to other administrative departments (e.g. finance, legal, training)
and line managers.

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Written and detailed post/job descriptions will be prepared by the Human
Resources Department for all types of employment, to describe the
minimum requirement of knowledge, skills, competences, and aptitudes
for any position. Objective and transparent written procedures and criteria
for staff selection, merit-based and non-discriminatory recruitment (based
on job-related skills and education), promotion, rotation, and termination
of employment are necessary. The required educational level and physical
suitability of new recruits will be tested, as well as ensuring that they meet
ethical standards and legal requirements (criminal/judicial records). Non-
discrimination based on sex, ethnicity, race or other protected
characteristics must be strictly forbidden and understood by all staff as a
violation of human rights.

The border agency will treat, with high priority, the overstaffing resulting
from merging the current administrations. The border agency will deploy
the necessary numbers of staff as a whole and for each individual location
in line with proposed organisation and risk analysis. Allocation of staff will
be made with clear written procedures. The border agency will implement
an open process of identification of the required numbers and categories
of staff (management, operational, administrative, specialists etc.). A
forecasting and planning system will be applied to predict any need for
new personnel.

The border agency will regulate a system of rotation within the agency,
regarding both duty station and tasks, either through voluntary or
obligatory rotation. Thus, border officers will be exposed to different tasks
and duties with the aim of increasing their knowledge and experience,
especially at the beginning of their career. The rotation system, together
with other measures, will also serve as an anti-corruption mechanism and
tool.

The border agency will monitor and evaluate its staff. The agency will
implement a career development system to collect and assess qualitative
data about the employee to examine her or his progression. A transparent
performance and merit-based promotion system will be applied to provide
a clear career path for motivated staff.

Border agency line mangers will regularly (e.g. annually) conduct
performance appraisal and review with staff, to enable a dialogue on
progression and give an opportunity to express their opinions and
expectations.

6.2 Training and Capacity Building

The border agency will elaborate and plan a training strategy document
consisting of key components such as assessment of educational needs,
content of training, target groups, methods of training, identification of
trainers, costs, training equipment, training venues, and evaluation. It will
also guarantee that the training strategy is regularly reviewed.

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The border agency will ensure that training policies and programmes are
based on a professional analysis of training needs at present and for future
priorities. It will be designed to provide individuals with the knowledge,
necessary skills, and attitudes to perform their jobs to a high professional
and clearly defined standard. Training programmes will provide the
opportunity for the integration of further training, and other external forms
of development. Line managers will play a key role, together with their
staff, in identifying training needs and proposing appropriate training
solutions.

Training should be a continuous element for all staff throughout their
careers (refresher, specialisation, and new skills/information training)
based on regularly updated curricula and training plans. It will provide for
basic and advanced theoretical and practical classroom-based learning as
well as on-the-job training, complemented by coaching and mentoring in
the field. Broad-based introductory training programmes for new recruits
(initial education) and subsequent training programmes addressing
specific job/individual requirements (continuing professional development)
will be introduced. Training opportunities must be equally accessible to all
staff, without discrimination.

A training entity will be established within the Human Resources
Department to coordinate training initiatives. The border agency will
operate a centralised training facility - the Border Security and
Management Academy - with sub-training centres suitably distributed
around the country. The Border Security and Management Academy will
graduate commissioned officers and in addition provide training in
different specialisations. The sub-training centres will ensure the initial
formation of non-commissioned officerss and provide basic training
programmes for the regular staff of the border agency. The academy and
its regional sub-training centres could also be the provider of training for
the new migration agency. The border agency will consider the benefit of
possible future inter-agency cooperation in common national training
programmes and facilities.

Training should be delivered mainly by certified full time trainers, who will
constantly sustain their knowledge and experience in their area of
expertise. For specialised training there might be a need to contract
external expertise to deliver training, for example in information
technology, forensic accounting etc. A train the trainer model will be
developed through which more internal trainers would be available, to
cascade knowledge down to the field level utilising a structured system of
presentations, demonstrations, and document sharing etc. The model will
strongly complement, encourage, and promote the skills and knowledge
acquired through central training courses.

Records of background skills and knowledge, individual training received,
and progress made will be maintained, regularly updated, and kept in the

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centralised staff management database. All training, whether internal or
external, will be properly and sufficiently evaluated to assess all-round
effectiveness (e.g. costs, improved job performance etc.) and identify and
address any changes that may be necessary.

The border agency (i.e. the training entity and the Border Security and
Management Academy (with its sub-training centres)) will develop a
curriculum on basic border management training. The IBM concept will be
an integral part of that programme. An advanced border management
training for managers will also be developed, including training on generic
management skills. Auxiliary training on topics such as computer and
language skills will be included either as part of basic courses or advanced
trainings, depending on the level of content. The agency will support
deployment of staff on special training courses organised by other
countries or international organisations. Training on human rights
obligations for border management authorities must be central to all
training, and a core element of the basic border management training
curriculum.

Specialised and advanced courses should be developed, e.g. for second-
line checks, crime intelligence, risk analysis and profiling, detection of
stolen vehicles, detection of forged and falsified travel documents,
detection of people hiding inside vehicles using state-of-the-art devices,
dog handlers, human rights, dealing with asylum seekers, detecting cases
of human trafficking etc. Specialised training would also apply to
administrative functions within the border agency, e.g. for procurement,
finances, and those operating specific technical equipment where
maintenance of staff skills is necessary.

The border agency at the local level should facilitate learning and
development for front-line staff. A dedicated period of time within regular
working hours should be reserved for training activities (e.g. presentations
by senior officers on new developments, online courses, familiarisation
with new technical equipment etc.). A system of tutor-officers or mentors
could be used to promote development of junior staff throughout the
organisation.

The border agency will ensure an inter-agency cooperation dimension
within the training programmes. Management and personnel training and
training systems will be coordinated with other law enforcement agencies,
especially with the police, migration, and customs administration. Joint
training activities will have a confidence-building and information
exchange function, and will result in more efficient use of resources. Inter-
agency training will be organised to familiarise staff with the organisational
structure, tasks, and activities of their counterparts, to raise general
awareness about the importance and benefits of inter-agency cooperation,
and to introduce participants to the other agencies at the border. For
example, joint training can be organized with other agencies on travel

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documents, visas, and residence permits; asylum and migration
legislation; code of conduct/ethics; foreign languages; use of equipment/IT
tools; detection and handling of irregular migrants; detection of trafficking
in human beings and smuggling of migrants; detection and processing of
forged documents; and detection and processing of stolen vehicles,
narcotics, weapons, explosives, and dangerous substances.

The border agency will ensure an international cooperation dimension
within the training programmes. Training events and workshops with
international participation, study visits, and exchange programmes will be
organised for border agency staff. These events increase knowledge and
understanding of practices in other countries and help to foster contacts
with partners. Counterparts from neighbouring countries will be invited to
training sessions of border agency staff, either at national, regional, or
local level (Border Security and Management Academy, sub-training
centres or BCPs).

The border agency will engage in organising specific training courses on
IBM in a multilateral context. This will allow officials from various border
services in neighbouring or other countries to learn about the concept of
Libyan IBM, as well as to share good practice and experiences. As a result,
it will increase knowledge and mutual understanding between countries.

The border agency will promote work towards cross-border and
regionalised training benchmarks and standards. The sharing of good
practices and standardisation of training curricula and material will be
encouraged.

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7 COMMUNICATION AND INFORMATION EXCHANGE
7.1 Intra-agency communication and information exchange

The border agency will take appropriate measures to regulate an efficient
and rapid flow of information and establish standard documentation within
the organisation. The system of communication and information exchange
of the border agency should be clearly stated in a regularly updated
manual or instruction, by describing the methods to be used (regular and
ad hoc meetings and reports, circulars/briefing notes, hard-copies or IT
system, radio etc.). Moreover, it will include the standard forms and
templates of the most frequently used documents, and the relevant data
protection measures to be employed to ensure security of information.

This is to be done in order to ensure the following needs:

«e the management and staff at central level has all necessary data
and information about the activities of the whole border agency, as
a basis for strategy formulation, resource planning, issuing
instructions, and for monitoring and controlling the work of the
border agency

«e the management and staff at regional and local levels have all
relevant and up-to-date instructions and information for properly
fulfilling their operational duties at the border and responding to
threats and emergencies in an appropriate way.

The border agency will regulate horizontal and vertical information flow at
and between all of its organisational levels, to ensure the appropriate
exchange of information between different individuals and entities.

The border agency will implement an IT system with electronic networks
between central, regional, and local levels with the following requirements:

«e Ensure automated communication and information exchange within
the border agency through a unified system, for example, through
database(s), intranet, and emails

« Provide for a system of collecting, processing, and distributing data
and information with real-time access for authorised users

« Allow for data flow management and identification of users based on
access rights and passwords

« Include a central alert/flagging system to notify of persons of
interest, notable changes in trends, or unauthorised use of the
system

«e Provide the possibility of creating statistical/analytical reports and
summaries

«e Ensure security and integrity of the system, e.g. through fire walls
and cryptography

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« Allow links to electronic border protection equipment (sensors,
radars, stationary thermal cameras, aerial surveillance system etc.)
where feasible

« Be interoperable with the IT systems of other relevant authorities
taking into account protection of personal data, if feasible.

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7.2 Inter-agency communication and information exchange

The border agency takes appropriate measures to regulate inter-agency
communication and information exchange by issuing relevant internal
guidance (rules or instruction) on what information is shared and
exchanged, how, and with whom. This is to be done to ensure security. In
addition, it will result in a system of communication that is based upon
rigorous processes rather than reliance on individual staff members who
may leave the border agency or rotate within the organisation thereby
hampering institutional memory.

The border agency ensures that the methods and formats of inter-agency
communication and information exchange are specified in inter-agency
agreements on cooperation at central, regional, and local level. Such
agreements should include the establishment (or formalisation) of contact
persons or focal points at the relevant levels and functions within each
agency.

Accordingly, the border agency should look to develop new IT systems or
upgrades existing systems, taking into consideration the following factors:

e Compatibility with other existing or planned systems and the
possibility of creating interfaces with other external databases

«e Security (data protection, access regulation)

e Accountability (records of access, usernames, etc.)

« Adaptability (adding/amending components/modules, users, etc.).

The border agency will consider the creation of joint systems with other
agencies (e.g. customs, migration agency, police), such as one overall
operating system with sub-modules allocated to each participating agency,
which would facilitate authorised information exchanges.

The border agency will also consider the creation of an inter-agency early
warning system. This could be through a system of contact points in
individual agencies or through the proposed IT solutions as outlined above.
Its purpose would be to exchange information that contains the first
indications of an extraordinary situation, which will facilitate a better and
more rapid response. The border agency should establish a horizontal and
vertical structure to rapidly inform other agencies, relying on and making
use of its own intra-agency systems as a basis for communication (see 7.1
above).

The border agency participates actively in both national and international
inter-agency working groups and fora. This participation should be
organised and carried out through the National Coordinator on Border
Security and Management and the Secretariat of the Steering Council.

7.3 International communication and information exchange

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In the light of the security challenges in the region, a radical change is
needed in cooperation mechanisms, bilaterally and multilaterally, with
neighbouring countries, countries of origin, and international
organisations.

The border agency will take appropriate measures to set up effective
external communication and information exchange mechanisms with
border agencies in other countries (especially in neighbouring countries).
This is to be done in order to create functional interfaces within Libya and
abroad. Regular meetings with border agencies from neighbouring
countries should address strategic issues, common planning, and the
evaluation of the respective border control systems. At the same time,
heads of local entities at the borders should maintain regular contact and
establish day-to-day working relations with their counterparts at an
operational level. The exchange of data and information at all levels needs
to be based on relevant agreements.

The border agency actively promotes the systematic exchange of
statistical data and appropriate national reports with the authorities of
neighbouring countries. Such reports could be exchanged on a monthly
basis and would allow for analysis and monitoring of the border situation in
the whole region.

As a part of its regular analysis of border checks and surveillance, the
border agency should include assessment of operational cooperation with
neighbouring countries. The results of that analysis should be utilised,
where necessary, to propose organisational changes with the aim of
improving border procedures, especially in terms of the facilitation of the
movement of persons and goods.

Membership of relevant international networks provides opportunities for
formal and informal communication and information exchange."
Furthermore, they facilitate the development of a contact network with
counterparts in other states and agencies. Accordingly, the border agency
will pursue opportunities to join and utilise all appropriate international
networks in the field of border security and management.

The border agency will promote the deployment or exchange of liaison
officers with countries identified as particularly relevant (neighbouring
countries or countries of origin of significant flows of migrants). This would
contribute to improved information exchange and coordination both at the
operational and the strategic level.

The border agency should explore suitable locations for common/shared
BCPs. In the absence of such BCPs, consideration will be given to
infrastructure at strategically relevant locations. For example, at particular

16 For example, the European Border and Coast Guard Agency (FRONTEX), the European

Fisheries Control Agency (EFA), the European Maritime Safety Agency (EMSA), European
Union Agency for Law Enforcement Cooperation (Europol), ICMPD, and IOM.

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BCPs, shared office space for staff from the border agency, other Libyan
agencies, and neighbouring countries, would facilitate operational
communication and exchange of information.

7.4 Communication and information exchange with other
stakeholders

Engagement with private sector stakeholders (e.g. airline, transport, and
courier industries) is important for effective border security and
management. This engagement (cooperation and communication) is
regulated by legislation or agreements.

The provision of easily understandable, accessible, and up-to-date
information to these stakeholders, as well as to the general public, is a
useful tool in this regard. The border agency should provide information on
issues relevant for crossing the state border. Information provided to
stakeholders and the public may be in the form of public notice boards at
BCPs or through brochures and posters. A public visibility mechanism,
principally through a border agency website, would further strengthen the
dissemination of relevant and useful information.

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