28. Memorandum submitted by Transparency
International (TI)
1. The focus of this submission is on the
potentially devastating impact of corruption in humanitarian response
to natural disasters and the need to reduce corruption risks through
robust accountability and transparency measures. TI believes that
corruption in humanitarian aid undermines the fundamental purpose
of humanitarian action. Its effects include the diversion of relief
supplies away from affected communities, inequitable distribution
of aid and sub-standard or inappropriately located infrastructure.
Such outcomes ignore the needs of the intended beneficiaries of
aid, often further marginalising those from the poorest sections
of society and deepening existing social conflicts. Tackling corruption
in humanitarian aid is key to ensuring effective and equitable
humanitarian assistance to those in greatest need.
2. Transparency International, the global
civil society organisation leading the fight against corruption,
brings people together in a powerful worldwide coalition to end
the devastating impact of corruption on men, women and children
around the world. TI's mission is to create change towards a world
free of corruption.
3. TI has worked to address the risk of
corruption in humanitarian response on several levels since the
2004 Indian Ocean Tsunami. TI national chapters in tsunami-affected
countries have sought to strengthen the accountability of national
relief and recovery operations through advocacy and capacity building
work. TI's International Secretariat, meanwhile, has helped bring
together key stakeholders at an experts meeting in Jakarta, Indonesia,
where representatives of affected countries identified measures
to protect tsunami aid from corruption (see Attachment One). TI
organised a similar meeting in Islamabad, Pakistan, to address
the risk of corruption following the severe South Asian earthquake
of October 2005 (see Attachment Two). At a global level, TI is
supporting the international humanitarian community's work to
increase transparency and accountability through its Programme
on Preventing Corruption in Humanitarian Assistance (see Attachment
Three). This programme involves the preparation of a "Tool
Box for Preventing Corruption in Humanitarian Assistance"
based on a risk-mapping exercise conducted in collaboration with
the Christian Michelsen Institute (CMI) and Overseas Development
Institute (ODI).
4. This submission is intended to share
with the IDC the lessons learned from TI's work in this area over
the past two years, particularly in relation to the 2004 Indian
Ocean Tsunami and 2005 South Asia Earthquake. It is divided into
two sections: the first section outlines a number of key recommendations
relating to corruption in humanitarian response to natural disasters
that we believe are relevant to the scope of this inquiry; the
second section responds to specific questions under consideration
by the inquiry, but which are not addressed in the key recommendations.
SECTION ONE: KEY
RECOMMENDATIONS
5. The following recommendations outline
some of the key steps that TI believes must be taken to minimise
the risk of corruption in humanitarian response to natural disasters.
Such measures will, however, only be effective if they are based
upon a serious determination among donors and humanitarian agencies
to openly address the problem of corruption. Though increased
political will is a nebulous and often difficult concept to promote,
concrete actions can be taken by donors and humanitarian agencies
to accept and address the risk of corruption. These include: speaking
openly about the issue at international and bilateral meetings;
honestly assessing the possible negative impacts of humanitarian
response in situations where corruption is prevalent; admitting
failures and seeking to identify lessons learned; piloting specific
anti-corruption measures in humanitarian response programmes;
and ensuring staff at all levels are aware of definitions of corruption,
of how to identify corruption and of the rationale behind anti-corruption
measures.
Participatory decision-making in humanitarian
relief and reconstruction
6. The involvement of affected communities
and vulnerable social groups in decisions relating to relief and
reconstruction lies at the heart of effective and transparent
aid strategies. The active participation of affected communities
in relief and reconstruction decisions should be encouraged and
facilitated to minimise the risk of corruption. In particular:
— Affected communities should be involved
from the earliest stages of relief, through to the design, implementation
and evaluation of long-term reconstruction activities. Such participation
ensures a greater sense of ownership over reconstruction plans
and increases the likelihood of their success. In situ owner-driven
reconstruction of private housing has proved to be particularly
effective where properly supervised.
— The principle of subsidiarity should
be followed wherever possible ie decisions relating to relief
and reconstruction and its implementation should be taken at the
most local level possible to facilitate greater accountability
to affected communities.
— Cross-sector representation on the
boards of key institutions (eg disaster relief trust funds) should
be ensured to facilitate real coordination between government,
donors, local and international NGOs and socially vulnerable groups.
— Government and other implementing
agencies in affected countries, including NGOs, should ensure
that affected communities are provided with accessible and understandable
information about relief and reconstruction efforts as well as
about the relief and compensation benefits they are entitled to.
Appropriate formats and local languages should be used to ensure
ease of access by such communities.
— Governments, public and private donors,
international organisations and local civil society organisations
should implement comprehensive and harmonised information strategies
that uphold internationally recognised access to information standards.
Publishing lists of aid figures on websites is not enough, especially
as access to computers and the internet is likely to be particularly
difficult in disaster-affected areas.
— All stakeholders should seek to support
the role of the media in providing information and acting as a
watchdog in relation to relief and reconstruction efforts.
— Where feasible, existing community
support programmes should be used in relation to land and property
allocation decisions, the rebuilding of community infrastructure
and the restoration of livelihoods.
Transparency and monitoring of aid flows
7. Ensuring full transparency in humanitarian
aid flows and in the allocation and distribution process is vital.
Public disclosure of all aid flows should be ensured and robust
systems of accounting and oversight established. In particular:
— National tracking systems should
contain all information from all stakeholders in order to contribute
to coordinating, monitoring and managing the overall relief and
reconstruction effort.
— Such systems should show the funding
mechanism, preferably on budget, and the contribution of multi-donor
funds set up for the disaster.
— They should contain information comprehensive
enough to respond to government and donor exigencies yet simple
enough to be accessible by affected communities.
— International organisations and donors
should support the development and maintenance of such tracking
systems.
— In order to ensure the relevance
and accessibility of information tracked, affected communities
should be consulted about the type of information they require
and the form in which they would like to receive it.
— Access to information on financial
flows is, by itself, not enough to improve the transparency and
effectiveness of aid flows. The actual outputs of funds used must
also be monitored.
Transparency, monitoring and evaluation of procurement
and service delivery
8. Non-transparent or closed procurement
systems can lead to the diversion of resources away from intended
beneficiaries through corruption or uncompetitive processes. Effective
independent monitoring and evaluation is key to ensuring the transparent
implementation of humanitarian relief and reconstruction programs,
including both procurement and service delivery. The development
and application of mechanisms that facilitate such monitoring
without impeding swift and effective humanitarian response is
of vital importance. In particular:
— Auditing mechanisms play an important
role in enhancing the transparency of project implementation.
Pre-audits conducted during reconstruction can lead to rapid reductions
in project expenditures. Such audits should be accompanied by
appropriate whistleblower protection as well as fraud-awareness
training.
— Effective internal control and external
auditing (including real time and field audits) should be complemented
by community-led approaches, such as people's audits, that reinforce
accountability towards affected peoples.
— All stakeholders should commit themselves
to maintain adequate accounts and provide timely, transparent,
comprehensive and accessible information on programming, aid flows
and expenditure. Accountability to beneficiaries is vital as are
both horizontal and upwards accountability.
— The role of centralised agencies
should be reinforced by institutional, parliamentary and citizen
oversight, for example, via third party quality audits and monitoring
by both aid providers and NGOs.
— National and international NGOs involved
in the implementation of relief and reconstruction efforts should
adhere to common, verifiable standards for auditing and monitoring
their use of aid monies.
— The implementation of contracts is
highly vulnerable to corruption and appropriate mechanisms should
be established to deal with, for example, change or variation
orders to the original contract.
— Government institutions and other
implementing agencies in affected countries should use appropriate
means (ie photography) to record damaged infrastructure. These
records should then be periodically reviewed by a third party
to ensure their accuracy.
— Government institutions and other
implementing agencies in affected countries should strive to be
accountable to the intended beneficiaries of reconstruction assistance
by, for example, undertaking regular community satisfaction surveys.
— In some cases, greater transparency
can be fostered by promoting the economic capacity and expertise
of affected communities, as well as local technology and materials,
in delivering relief and reconstruction.
Effective enforcement and complaint-handling
9. Ensuring appropriate mechanisms and capacity
to capture complaints of abuse, investigate potential corruption
cases and enforce anti-corruption measures is also of vital importance.
Accessible grievance procedures, including channels for reporting
corruption with protection for whistleblowers and witnesses, should
be provided in the context of humanitarian relief and reconstruction
efforts. In particular:
— Grievance procedures should cover
private and public sector employees, the media, and the general
public. Ombudsmen at the district and local community levels should
be in place to enable effective redress of public grievances.
— A toll-free telephone number should
be established to allow public complaints to be registered and
handled effectively. Citizen complaints boxes should be put in
place to make reporting of abuse easier.
— Sufficient resources and capacity
need to be made available to the institutions responsible for
dealing with and following-up on complaints.
— Aid beneficiaries should also be
provided access to complaints mechanisms in humanitarian organisations.
SECTION TWO: RESPONSES
TO SPECIFIC
IDC INQUIRY QUESTIONS
What should be the role of the military and civil
defence actors in humanitarian response?
10. Domestic military actors in countries
affected by natural disasters can and do play an important role
in delivering and coordinating the relief phase of humanitarian
responses. Apart from their provision of human resources and hardware,
they often bring extensive logistical, technical and geographic
expertise of disaster zones to bear in responding to humanitarian
emergencies. A key concern, however, is that military involvement
in humanitarian relief and reconstruction efforts could potentially
compromise the transparency and accountability necessary to address
the risk of corruption in humanitarian response. This concern
is particularly relevant in countries where institutional integrity
systems are already weak and where independent civilian oversight
of military activity is limited.
11. Following the South Asia Earthquake
of October 2005, Pakistan's military has played a leading role
in the provision and coordination of humanitarian relief and reconstruction
efforts. The Federal Relief Commission (FRC) established to coordinate
immediate relief needs included a military and civilian wing under
the overall leadership of Major General Farooq Khan, who was appointed
Federal Relief Commissioner. This body, which oversaw the relief
operation in its early stages, has been praised for its largely
positive role in the initial response to the disaster. As attention
turns to the longer-term task of reconstruction, to be coordinated
by the Earthquake Reconstruction and Rehabilitation Authority
(ERRA), there is, however, a need for increased civilian public
oversight of reconstruction activities to supplement the military's
own accountability arrangements. Reconstruction conducted under
the auspices of the military should be subject to pre-audits to
minimise the risk of waste and corruption.
What local consultation and accountability processes
does DFID engage in when providing humanitarian aid?
12. Part of DFID's response to the South
Asia Earthquake of October 2005 has been an attempt to improve
the coordination of monitoring and evaluation (M&E) activities
by introducing a joint M&E framework for use by the Government
of Pakistan and other major donors. This framework, which will
cost an estimated US$2 million a year, includes provision for
an annual independent evaluation of relief and reconstruction
programmes, the capturing of experiences from the affected population
via a "key informant network" and the collection of
data on past and planned activities via household surveys. While
such steps to strengthen coordination of, and increase beneficiary
input into, M&E activities are an important and necessary
contribution to curbing the risk of corruption in Pakistan's relief
and reconstruction efforts, they must be supplemented by other
actions that seek to reinforce the active participation of beneficiaries
in designing and implementing aid projects. Experience from the
2001 Gujarat Earthquake indicates that such participation is an
important means for reducing opportunities for corruption, particularly
in relation to housing reconstruction.
Attachments[66]:
1. Asian Development Bank, OECD, Transparency
International, Curbing Corruption in Tsunami Relief Operations,
April 2005.
2. Transparency International and Transparency
International Pakistan, Workshop Conclusions and Recommendations
for Action, International Workshop on Transparent Utilization
of Earthquake Reconstruction Funds, Islamabad, Pakistan, 7-8 February
2006.
3. Transparency International, Corruption
in Humanitarian Aid, TI Issue Brief No 3 2006.
May 2006
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