20. - 20 -

19. - 19 - Detailed Illustration of Compliance Status of MDAs .

48. - 48 - DIALOGUE ON THE NACS

1. - 1 - a Sierra Leone

18. - 18 - performance score of 62 % recording 416 out of 677 action points fully implemented. Detailed Compliance Sta tus of Local Councils

15. - 15 - It will as well help increase the resource mobilization and service delivery processes in the institutions thereby, creating a room for reduction of corrupt practices in both the councils and the MDAs. This situation is critical because the fo cus of the 2019 - 2023 NACS is to see that transparency and accountability in the MDAs and Local Councils become central in the implementation of tasks in institutions. Regional Analysis of Implementation of Action Plan & Compliance Status The graphical illustration above, indicates that no region achieved 100% compliance status taken into consideration the ACC Compliance Barometer 2021. Data analysis shows that all Regions achieved an average moderate compliance status.

14. - 14 - Based on the monitoring result, a comparative analysis of MDAs and Local Councils was carried out to showcase the p erformance/progress made at National Level. The results indicate that there is a tremendous progress made by responsive Institutions. However, in trying to measure the performances of MDAs and Local Councils, there is an indication that, 63% of the agreed action points of the 2019 - 2023 NACS have been fully implemented by MDAs and 59% at Local Councils. The graph further, emphasizes 30% and 23 % of the agreed action points for both MDAs and Local councils were never implemented. Notwithstanding the high com pliance status of MDAs and Local Councils, there is a serious concern for non - compliance. Meanwhile, the implication for such performance is that the Implementation of the NACS by MDAs and Councils is in progress in order to achieve the focus of the NACS 2019 - 2023.

2. - 2 -

4. - 4 - component in the NACS, which, marks progress and addresses weakness in MD As and Councils that have the opportunity to create corrupt practices, and hinder service delivery. The First Monitoring exercise conducted in August 2020 focused on functionality of Integrity Management Committees ie the establishment of Integrity Managem ents Committees and submission of work plans. This report focuses on the second Monitoring conducted between April - August 2021 and is compliance focused. It seeks to provide a fair view of progress made by MDAs whilst highlighting challenges and areas of improvement.

16. - 16 - Some possible explanations for thi s overall performance could be internal and external factors; internal factors could be associated with poor coordination of the NACS activities in the Councils and the MDAs and lack of management commitment and wiliness to support the implementation of th e agreed actions of the NACS. It was noted during the monitoring exercise that the NACS Implementation in Council and MDAs was viewed as an Anti - Corruption task rather than as a complementary arm that aid the work of the councils in a bid to enhance best p ractice. Coordinating the work of the NACS among focal persons could also be an associated challenge that led to the poor performance of the institutions. There is poor understanding of the methodology of tracking and documenting the implemented NACS Actio n Plan. External factors could be the ACC Regional Offices being overwhelmed with workload, much time and attention is not given in the coordination and implementation of the NACS work plan especially in the councils. Thus, it is expected of the regional offices to coordinate, coach and mentor focal persons in the implementation of the NACS. District Level Analysis Compliance status of MDAs and Councils

28. - 28 - la cked supporting documents to indicate the implementation of this activity. Human Resource : In respect of Human Resource there is a Low performance. Eight (8) out of a total of ten (10) activities were implemented in all of the councils scoring a complia nce rate of 80%. Only two (2) were partially implemented with a compliance rate of 20%. Action point relating to senior public officers filed and signed score card and Development of Internal Anti - Corruption Policy were not implemented and eventually not complied to. Procurement Units : There was an impressive performance in respect of procurement action points ten (10) out of ten (10) Action Point in Procurement were fully implemented with a compliance rate of 100%, indicating full Compliance.

30. - 30 - strengthening of functional Audit Committees, strengthen Audit Committee at devolved sectors , and Vote Controller held meetings with Head of Internal Audit to promote the work of Integrity Management Committee (IMC), were all not fully implemented. Functionality of the Integrity Management Committee (IMC): T en (10) out of eighteen (18) activit ies were fully implemented with 56% compliance rate and two (2) out of the total Action Points with significant action taken with a compliance rate of 11%, indicating ‘ ’No Compliance’’ ; while six (6) of the Action Points were never implemented with a compl iance rate of 33%. Activities relating to the development of updated customers service charters, having organized and functional Integrity Management Committee (IMC) and Councils to have accountability forum on funds allocated to them were not effectively and efficiently administered. As there was lack of supporting documents in some Councils to show the implementation of this activity. Human Resource : Poor performance in human resource units Seven (7) out of a total of twelve (12) activities were never implemented in all of the councils scoring 58% compliance rate. Action points relating to senior public officers to fill and sign

39. - 39 - execution of any activities by the ACC through the Council administration.  Councils and MDAs should hold at least two meetings per quarter on the NACS 2019 - 2023.  Counci ls and MDAs to main stream Anti - Corruption Policies and recommendations in their Strategic Plan.  Non - compliant MDAs, should fast track the full implementation of all Action Points within their respective institutions or the Commission will be left with no option but to Invoke Compliance Sanction in accordance with section 8(4) of the ACC Act 2008 as amended in 2019. CONCLUSION

49. - 49 -

23. - 23 - forum on funds allocated to them, lack of filling system, poor coordination of the IMC activities by the focal persons could form part of the challenge. Human Resource Department : In respect of Human Resource there is limited progres s made; five (5) out of a total of eight (8) activities were implemented fully with 62% compliance rate. Significant actions were taken in one (1) out of eight (8) and two (2) with no action taken representing 25% donating No Compliance. Activities relatin g to senior public officers filed and signed Score Card and Development of Internal Anti - Corruption Policy were not implemented. Procurement Departments : Much improvement was made in this area as seven (7) out of eight (8) Action Points in procurement we re fully implemented with a compliance rate of 88%, indicating Significant Compliance and one (1) out of the total never implemented measuring 17% compliance status. Activities related to procurement include; Procurement Officers to sit in senior managemen t meetings

22. - 22 - of 40% and eleven (11) out of the total actions were never implemented with compliance score of 55% denoting 0% Compliance. This is a crucial and critical point that requires attention. The establishment of internal audit i n the Local councils is to enhance internal control and address weaknesses in resource mobilization, transparency, accountability and service delivery. The overall poor performance in the audit actions by the four local councils will create a recipe for c orrupt practices. Activities relating to the establishment and strengthening of functional audit committees, at devolved sectors were all not fully implemented. Functionality of Integrity Management Committees (IMC ): With respect to the functionality of the IMC, six (6) out of a total of twelve (12) Action Points were fully implemented in all of the four Local councils with a cumulative compliance rate of 50%, indicating ‘ Moderate Compliance’ , some actions were taken on two (2) Action Points and no actio n taken in three (3) out of the total with a compliance rate of 25% denoting ‘’ 0% compliance’’ . Activities relating to: the development of updated customers service charters, having organized and functional Integrity Management Committee (IMC), Councils t o have accountability

32. - 32 - Western Rural District Council has total of twelve (12) Action Point in all thema tic areas of focus as indicated in the table above. Data analyzed shows that ten (10) out of twelve (12) total Action Points were fully implemented with a compliance rate of 83% on a scale of 0 - 100%. And two (2) out of the total Action Points were partial ly implemented with a compliance rate of 17%. Internal Audit : From the table above, result shows that the Internal Audit Unit fully implemented four (4) out of five (5) Action Points with a compliance score of 80% and activities relating to the strengthen functional audit committee, strengthen audit committee at devolved sectors and vote controller held meetings with head of Internal Audit with emphasis on audit questions and promote the work of the Integrity Management Committee (IMC), were all not fully implemented. Functionality of the Integrity Management Committee (IMC): Result shows that three (3) out of three (3) activities were fully implemented with 100% compliance rate. Action relating to the updated customers service charter, organize and funct ional Integrity Management Committee (IMC) accountability forum on funds allocated to councils were effectively and efficiently administered.

37. - 37 - concern that Chief Administrators in some councils, tend to conceal important information that worth sharing to the staff members (Pujehun District Council). This has affected some of the poor performance of some Councils visited.  Setting up of Audit Report Recommendation Committees is stil l a major challenge. In response to the issue yearly bad Audit Reports across MDAs, one of the key activities for implementation by all MDAs and Councils was the setting up of Committees that have the sole responsibility of following up on Audit Report rec ommendations. The monitoring team noted that most MDAs have not set up these committees. RECOMMENDATIONS  Local Council Coordinating Institutions to hold regular meetings to address issues of Transfer and other factors affecting the administration of Cou ncils. The NACS Secretariat convened a meeting of these institutions on 23 June 2021 at the ACC Conference Room to share findings on the NACS monitoring and to discuss promoting effective coordination of the activities of District and Local Councils. Reco mmendations were proffered for action

25. - 25 - sc ore of 47.4%. It is important to note that the North - Eastern Region only implemented nine (9) out of nineteen (19) Action Points with regards to Internal Audit and recorded a compliance score of 47%. Activities relating to the establishment and strengtheni ng of functional Audit Committees, strengthening of Audit Committees at devolved sectors, remain a challenge. Functionality of the Integrity Management Committee (IMC): Result of the monitoring exercise shows that nine (9) out of the total of twelve (12) activities were fully implemented with a compliance rate of 69% indicating ‘ ’Moderate Compliance ‘ with significant actions taken in two (2) and no action taken in two (2) activity showing compliance status of 15%. Activities relating to: the development of updated customers service charters, having organized and functional Integrity Management Committee (IMC) and Councils to establish accountability forums on funds allocated to them were not effectively and efficiently implemented. There was lack of suppo rting documents in some Councils to indicate the implementation of this activity. Human Resource ; T here was a low performance in Human Resource Units. Five (5) out of a total of ten (10) activities never implemented in all of the Councils resulting to 50 % compliance rate. Two (2) out of ten (10) activities fully

27. - 27 - The Eastern Region host (5) District Local Councils with a total of sixty (60) Action Points in a ll thematic areas of focus; Audit, functionality of the IMC, Human Resource and Procurement as indicated in the table above. Data analyzed shows that the Region made a performance progress of Thirty - Six (36) out of sixty (60) fully implemented Action Point s with a compliance rate of 60% on a scale of 0 - 100%. Internal Audit : Result from the Internal Audit Unit shows an Impressive Performance as the unit scored 55% of compliance rate. However, it is important to note that 30% of the actions of Internal Audi t in the region were never implemented. Much effort is required to achieve 100% compliance status. Functionality of the Integrity Management Committee (IMC) : Result show that fourteen (14) out of a total of twenty (20) activities were fully implemented wi th a 70% compliance rate and three (3) out of a total Action Points of twenty (20) were never implemented with a compliance rate of 15%, indicating ‘ ’No Compliance’’ , with some limited actions taken on three (3) with a compliance rate of 15%. Activities re lating to the development of updated customers service charter, having functional Integrity Management Committee (IMC) and Councils to have accountability forum on funds allocated to them were not effectively and efficiently administered. Some Councils

35. - 35 - the area of transfe rs. The HR Policy stipulates that the staff members should be transferred after every two years or a two term tour. The Team however noted that some staff were moved from their last post after six months with no reference to the district or city HR offic er/Policy. Such a challenge can result in poor performance of Councils in the implementation of the NACS (2019 - 2023). It was challenging for the Monitoring Team to have an engagement with the respective focal person(s) of some Councils, due to transfer of such persons by Local Government Service Commission (LGSC); especially when no handing over from the outgoing focal persons to the current was done for instance in Kambia, Kailahun and WARD - C etc. Thus, making it difficult for the current focal person to have any proper idea about the operation of the IMC in the council. The Ministry of Foreign Affairs is greatly affected by this challenge.  MDAs and Councils are still to set up Audit Report Committees. One of activities recommended for implementation by a ll MDAs and Councils is the establishment Audit Report Committees. This was in direct response to the perennial problem of bad Audit Reports across Government Institutions. Proper Audit Committees would be charged with the responsibility of

6. - 6 - In the period under review the Secretariat targeted to monitor a total of seventy Nine (79) institutions; comprising twen ty - two (22) Local Councils and fifty Seven (57) Ministries, Department and Agencies in all regions (North, North - West, South, East and Western Area). DATA COLLECTION AND ANALYSIS Data collection A questionnaire and progress assessment tool seeking cl arification on efforts made by MDAs and Councils were administered. Examination and physical verification of related documents was conducted, personal interviews were conducted, processes were observed in the respective MDAs and Councils, analytical review s were carried out and recalculations carried out. All was done to ascertain the validity and reliability of the responses submitted by the targeted MDAs and Councils. Data Analysis A Compliance Barometer tool was used to determine the level of complia nce on the implementation of each activity; measuring the level of compliance using a scale of 0% - 100%.

34. - 34 - The table above shows that, there is an impressive overall performance of the councils in the implementation of the National Anti - Corruption Strategy action plans. From the table above, procurement units stand out to perform so well, with 86% im plementation of the total action points, followed by Functionality of the IMC with 64% compliance status. Forty - Nine (49) out of eighty - seven (87) activities of the Internal Audit were fully implemented recorded a compliance rate of 56%. Human Resources s coring 31% being the least performing Indicator measured. However, there is much room for improvement especially in all area of focus, to ascertain 100% of compliance status, thereby helping to address issues bordering around corruption and corrupt practi ces and eventually enhances transparency, accountability and service delivery. LIMITATION/ CHALLENGES  Lack of Coordination/communication among key Institutions responsible for coordinating activities of District and City Council ; namely the Local Governm ent Council Finance Department, the Local Government Service Commission, the Decentralization Secretariat and Ministry of Local Government and Rural Development. This has affected the effective functioning of the Councils especially in

38. - 38 -  The Setting up of Audit Report Recommendation Committees to be included in the Performance Contract of MDAs/Councils. The NACs Steering Committee to escalate this issue to the office of the President/Vice President.  For an increase in performance of MDAs, management of the IMC and the councils should be obliged to provide supporting documents in line with activity plan as a measure of compliance to each line of activity.  Staff should be given coaching in tracking, doc umenting and filing of NACS activities for ease of reference and monitoring or auditing purpose.  The coordination of the NACS activities is key, and it should be given a priority by staff of the ACC Regional offices and in turn by the management of the co uncils if performances are to be measured.  Proper handing over mechanism should be put in place by the IMC members and management of the councils in order to ensure a smooth operation of the IMC activities in the council.  Timely information sharing is ke y in the operation of the IMC activities, focal persons should be informed before the

36. - 36 - following up o n the implementation of Internal/external Audit recommendation to ensure that Audit issues are addressed. This was evident in Kenema City Council which has no Internal Audit Unit let alone an Audit Report Committee.  Lack of Supporting Documents : The team encountered difficulty in ascertaining compliance in most cases when MDAs failed to produce supporting documents as proof of implementation. Some only provided partial documentation.  Poor Filing System: The team identified poor Filing System nearly in a ll of the MDAs/Councils. Focal persons could not maintain a proper filing system and could not therefore keep track of progress in the implementation process.  Weak Coordination: The Monitoring Team also identified that, there is a serious challenge in th e coordination of IMC activities in MDAs. And that there is a lack of willingness and commitment by some management to support IMC activities and the implementation of NACS Action Points; thus, affect the performance of the Councils/MDAs.  Lack of Coord ination and Information Sharing: It was identified that, there is a lack of information sharing between and among the management of the Institutions with regards transfer and posting of staff. Also, the Team noted with

3. - 3 - INTRODUCTION/BACKGROUND In line with Section (5)(1)(c) of the Anti - Corruption Act, of 2008 as amended in 2019 the National Anti - Corruption Strategy Coordinating Secretariat (NACS), of the Anti - Corruption Commi ssion (ACC) is tasked with the responsibility to coordinate the Implementation of the National Anti - Corruption Strategy. Since 2005 the NACS Secretariat has rolled out Four (4) National Anti - Corruption Strategies. The current 2019 - 2023 NACS which is the fourth NACS implemented by Sierra Leone and coordinated by the ACC through the Secretariat is primarily geared towards assessing the level of compliance in the implementation of Action Plans by Ministries, Department and Agencies (MDAS) and Local Council s. Thus the 2019 - 2023 NACS is designed to point out two critical success factors: bench marking institutional specific action plans and corruption control measures within MDAs and Councils for implementation. Two years into the implementation of the NACS 2019 - 2023, the Secretariat has been able to undertake two monitoring exercises to ascertain progress by MDAs and Councils in the Implementation of the NACS. Monitoring is a critical

5. - 5 - OBJECTIVES The overall focus of this monitoring exercise was to assess and measure the level of compliance of MDAs and councils to the implementation of Action Plan of the NACS. To achieve this focus, the key objectives includ e; to 1. Measure compliance levels of each MDA and council to approved activities as listed in the Implementation Action 2. Measure compliance; National and Regional Compliance status of MDAs and Local Councils. 3. Gauge and compare the implementation of activity plan at regional level. 4. Identify challenges and issues derailing the implementation of the NACS and recommendations for possible corrective intervention. 5. Provide guidance on the effective implementation of activity plans and functionality of the Integrity Management Committee. 6. Produce and present a report on the find ings (compliance Level) of MDAs and Councils. SCOPE AND METHODOLOGY

50. - 50 - Published by the Anti - Corruption Commission Headquarters: 3, Gloucester Street, Freetown, Sierra Leone, West Africa Website: http//www@anticorruption.gov .sl Bo Office Address: 10 Bo Pujehun Drive, Kebbie Town Email: info@anticorruption.gov.sl Makeni Office Address: Mena Hill Reservation, Makeni Kenema Office Address: Reservation Road, Off Maxwell Khobe Street Kono Office: 37 Masingbi Road, Koidu City, Kono Port Loko : 27 Conteh Street, Port Loko Hotline Nos: 077 - 985985 , 077 986 986 , 515 (All Networks)

13. - 13 - 4 Ministry of Planning and Economic Development 5 Office of The Chief Minister 6 Ministry of Technical and Higher Education 7 Ministry of Basic and Secondary Education 8 Ministry of Labour and Social Security 9 Ministry of Water Resources 10 Ministry of Fisheries and Marine Resources 11 Ministry of Transport and Aviation 12 Ministry of Gender and Children’s Affairs 13 Ministry of Sport 14 Ministry of Youth Affairs 15 National Youth Commission 16 Petrole um Directorate 17 Sierra Leone Roads Safety Authority 18 Ministry of Agriculture These MDAs were targeted but did not respond to the April – August 2021 quarterly monitoring of the NACS thus, non - non - responsive and non - compliant to issues regarding fu nctionality of IMCs and implementation of Action Points. Comparative Analysis of National Compliance Status of MDAs and Local Councils

8. - 8 - The table above indicates the total number of MDAs and Councils monitored in respect of the number of Action Points implemented in the monitoring exercise. Out of six hundred and seventy - seven (677) Action Points, only Four hundred sixteen (416) were fully implemented. A total of Two hundred and sixty - one (261) outs tanding activities were not implemented during the period under review. This table further indicates that MDAs and Council need to improve on the implementation of agreed action so as to reduce incidences of corruption. Table 3 – MDAs with full Complian ce Score The table above indicates that overall three (3) out of sixty - one (61) Institutions monitored scored full compliance rate which is only 5% of the total number of Institution targeted. These Institutions implemented almost all of thei r agreed Action Points except three (3) outstanding Action Points of the NACS 2019 - 2023. See table above for names of institutions. FULL COMPLIANCE SCORE No MDA Total Action Points Implemented Action Points Outstanding Action Points Compliance Status % 1 Anti - Corruption Commission 15 14 1 93% 2 National Telecommunication 14 13 1 93% 3 Pujehun District Council 11 10 1 91% TOTAL 40 37 3 93%

7. - 7 - The tool was graduated into the following Table 1 – Compliance Barometer The data was analyzed using this tool in order to determine the threshold that will lead to the enforcement of a compliance sanction for non implementation of the Commission’s instructions through the National Anti - Corruption Strategy (NACS). SUMMARY OF COMPLIANCE STATUS OF COUNCILS & MDAS IN THE IMPLEMENTATION OF ACTION PLANS . Summary of Cumulative Compliance Status of Action Points Table 2 – MDAs / Council s and the implementation of Action Description of Progress No Compliance Moderate Compliance Significant Co mpliance Full Compliance Score Range (0 - 49%) (50% - 79%) (80% - 89%) (90 - 100% ) Color Code # of MDAs & Councils Total # of Action Points Activities implemented Outstanding Activities Total Activities 61 677 416 261 Average Compliance (%) 61%

47. - 47 - Policy public officers PROCUREMENT Recommendations Indicator Activity (Input & output) Impor tance Baseline situation/ Challenges Target Means of Verification (MOVs) Current Progress Measure Comments /suggestio ns 10 Head of procurement should t ake part in senior management meetings and they should enforce the operations of the IM C No. of senior management meetings participated by the head of procurement High Head of procurement to take part in senior management meetings and they should enforce the operations of the IM C. One Meeting per month  Verify minutes of meeting and Attendance register 11 Procurement officer should follow the stages in the procurement process ad - hoc procurement of goods and services should not be allowed City/Councils t o follow the stages of procurement process. High Procurement Officer should follow the stages in the procurement process ad - hoc procurement of goods and services should not be allowed 100% compliance  Verify procurement plan,  Updated procurement committee,  Minute of procurement committee,  Updated suppliers list, payment procedure,  Work completion certificate & integrity packed.

33. - 33 - Human Resource : there was a significant implementation of Human Resource action points as one (1) out of a total of two (2) activities implemented with a score of 50% compliance rate. Procurement Department : There was an excellent performance in respect of procurement two (2) out of two (2) action points were fully implemented with a compliance rate of 100%, full C ompliance. WESTERN AREA DISTRICT COUNCIL (FCC) The Freetown City Council recorded a moderate compliances score indicated in table 5. Table 13 - Analysis of Area Of Focus & Their Compli ance Rate Indicators # of Activities Fully Implemented Higher progress Limited Progress No Progress % of Fully Implemented % of No Progress Internal Audit 87 49 0 5 33 56% 38% Functionality of the IMC 66 42 6 4 14 64 % 21 % Human Resource 42 13 1 6 22 31 % 52 % Procurement 42 36 2 0 6 86 % 14 % Totals 237 140 9 15 75 59 % 32 %

9. - 9 - The overall percentage score of the three (3) Institutions is 93% in a scale of 0 - 100 in the compliance barometer indicating Full Compliance Table 4 – MDAs with Significant Compliance SIGNIFICANT COMPLIANCE SCORE No MDA Total Action Points Implemented Action Points Outstanding Action Points Compliance Status 1 Environment Protection Agency 13 11 2 85% 2 National Commissio n for Privatization 6 5 1 83% 3 National Public Procurement Authority 11 9 2 82% 4 Ministry of Trade and Industry 15 13 2 87% 5 Western Area Rural District Council 12 10 2 83% 6 Kenema District Council 11 9 2 82% TOTAL 68 57 11 84% The table abov e indicates that six (6) out of sixty - one (61) Institutions monitored scored an average high - performance record of 84% indicating an impressive performance in the

21. - 21 - NORTH WEST Table 8 - Detailed Analysis of Compliance Level of Thematic Area of Focus Area of Focus # of Action Point Full compli ance Significant Compliance Moderat e Compliance No Compli ance Compliance % None Compliance % Audit 20 8 0 1 11 40% 55% IMC Functionality 12 6 2 1 3 50% 25% Human Resource 8 5 1 0 2 62% 25% Procurement 8 7 2 0 1 88% 17% Grand Total 48 26 5 2 15 54% 31% Percentages 54% 10% 4% 31% Th e above data shows that North Western Region’s cumulative compliance performance is 54% on a scale of 0 - 100%. It is important to note that, out of a total of forty - eight (48) actions in all of the Councils in the region, twenty - six (26) were fully implemen ted with 54% Compliance score, five (5) with significant actions, 10% compliance rate and fifteen (15) with no action taken representing 31% compliance score. Internal Audit : In respect of Internal Audit 8 out of a total of 20 Action Points were fully imp lemented with a Compliance Score

26. - 26 - implemented with a compliance rate of 20%. Activities relating to Human Resource which included: Senior public officers to fill and sign score cards and Development of Internal Anti - Corruption Po licy were not implemented. Procurement Units : There is an impressive performance in respect of Procurement. Nine (9) out of ten (10) Action Points in procurement were fully implemented with a compliance rate of 90%, indicating significant Compliance. Act ivities related to procurement included; Procurement officers to conduct procurement in the prescribed processes and procedures and avoid adhoc methods, Procurement Officer to sit in senior management meetings, these activities were effectively and efficie ntly implemented. EASTERN REGION Table 10 – Areas of Focus Eastern Region Area of Focus # of Action Point Full compli ance Significant Compli ance Moderate Compli ance No Compliance Compli ance % None Compli ance % Audit 20 11 0 3 6 55% 30% IMC Functiona lity 20 14 0 3 3 70% 15% Human Resource 10 1 0 1 8 10% 80% Procurement 10 10 0 0 0 100% 0% Grand Total 60 36 0 7 17 60% 28% Percentages 60% 0% 12% 28%

31. - 31 - score cards and Development of Internal Anti - Corruption Policy were not implemented and eventually not complied to. Procurem ent Department : There was an impressive performance in respect of procurement eight (8) out of twelve (12) Action Points were fully implemented with a compliance rate of 67%, indicating Moderate Compliance, taking into consideration the compliance baromet er launched by the ACC in 2021. Activities related to Procurement Officers conducting procurement in the prescribe processes and procedures and avoiding adhoc procurement and Procurement Officer to sit in senior management meetings were all implemented. Western Rural District Council WARD - C : Table 12 - Areas of Focus on Western Rural District Council WARD - C Ar ea of Focus # of Action Point Full comp liance Significant Compliance Moderate Compliance No Compli ance Compliance % None Compli ance % Audit 5 4 0 1 0 80% 20% IMC Functionality 3 3 0 0 0 25% 0% Human Resource 2 1 0 1 0 50% 0% Procurement 2 2 0 0 0 100% 0% Grand Total 12 10 0 2 0 83% 17% Percentages 83% 0% 17% 0%

45. - 45 - 3 Vote controller must have regular meetings with A to en sures that internal Audit questions are responded to # of meetings vote controller held with Internal Auditor on response of Audit questions High Vote controller must have regular meetings with A to ensure that internal Audit questions are responded to. On e meetings per month  Verify minutes of meetings with vote controller 4 There should be a coordinated system to ensure councils track funds coming to MDAs. All development patterns should update councils on funds disbursement of funds to sectors Develop ed an updated funds tracking systems High There should be a coordinated system to ensure councils track funds coming to MDAs. All development patterns should update councils on funds disbursement of funds to sectors Updated tracking systems  Verify Updated List of development partners.  Development partner Implemented activity plan tracking systems/tools to track funds. ADMINISTRATION & FUNCTIONALITY OF IMC Recommendations Indicator Activity (Input & output) Impor tance Baseline situation/ Challenges T arget Means of verification (MOVs) Current Progress Measure Comments / suggestio ns 5 All councils to have an organized Integrity Management Committee. Established functional and effective Integrity Management Committee (IMC) High Create an organize Integri ty Management Committee 100% Effective IMC  Verify IMC minutes of meetings.  Attendance Register

44. - 44 - IMPLEMENTATION MONITORING GUIDING TOOL MATRIX Description of Progress No Compliance Moderate Compliance Significant Compliance Full Compliance Score Range (0 - 49%) (50% - 79%) (80 % - 89%) (90 - 100% ) Color Code Anti - Corruption Objectives Improved accountability and Transparency Area of Focus INTERNAL AUDIT Recommendations Indicator Activity (Input & output) Impor tance Baseline situation/ Challenges Target Means of Verific ation (MOVs) Current Progress Measure (%) Challenge s/Commen ts/suggesti ons 1 Councils to establish a functional Audit report Committee. Established an Approved Audit Report Committee High Established and strengthen an Audit Report Implementation Committee Approved Audit Report Committee  Verify Minutes Audit Committee.  Updated List of Audit Committee Members. 2 Internal Audit MUST participate into senior management committee No. of senior management meetings participated by the Internal Auditor High Head of Internal Auditor should take part in senior management meetings and they should enforce the operations of the IM C. One meeting per month  Verify minutes of senior meeting  Attendance register Please indicate current progress in percentage on each recommendation

29. - 29 - SOUT HERN REGION Table 11 - Areas of Focus Southern Region The Southern Region, consist of six (6) District Local Council with a total of sixty - two (62) Action Points in al l thematic areas of focus; Audit, functionality of the IMC, Human Resource and Procurement as indicated in the table above. Monitoring result shows that thirty - eight (38) out of sixty - three (63) total Action Points were fully implemented with a compliance rate of 60%. Twenty - two (22) out of the total Action Points were not implemented with a compliance rate of 35%. Internal Audit : Result from the Internal Audit Unit shows that sixteen (16) out of twenty - three (23) Action Points were fully implemented with a compliance score of 70% and Seven (7) out of the total which record 30% of the Action Points were never implemented. Activities relating to the establishment and Area of Focus # of Action Point Full compli ance Significant Compliance Moderate Compliance No Compli ance Compliance % None Compliance % Audit 23 16 0 0 7 70 % 30 % IMC Functionality 18 10 2 0 6 56 % 33 % Human Resource 12 4 0 1 7 33 % 58 % Procurement 12 8 0 0 4 67 % 33 % Grand Total 63 38 2 1 22 60 % 35 % Percentages 61% 3% 2% 35%

24. - 24 - NORTH - EAST Table 9 – Areas of Focus North - Eastern Region The North - Eastern Region hosts five District councils with a cumulative total of fifty - two (52) Actio n Points in all thematic focus areas; Audit, functionality of the IMC, Human Resource and Procurement as indicated in the table above. Data analyzed shows that North - East Region made effort in implementing one hundred and thirty (l30) out of the total Acti on Point with a compliance performance of 58% on a scale of 0 - 100%. Internal Audit : Data analyzed from the Internal Audit Unit indicate that ten (10) out of nineteen (19) of the Action Points were fully implemented and recorded a progress Performance Area of Focus # of Action Point Full compliance Significant Compliance Moderate Compli - ance No Compli ance Compli ance % None Compli ance % Audit 19 10 0 0 9 53% 47.4 % IMC Functional ity 13 9 2 0 2 69% 15% Human Resource 10 2 0 3 5 20% 50% Procurement 10 9 0 0 1 90% 10% Grand Total 52 30 2 3 17 58% 33% Percentages 58% 4% 6% 33%

17. - 17 - District # of Institutions Monitored Total # of Action Points No progress Rate Limited Progress Rate H igh Progress Rate Target Achieved or Exceeded Compliance Score (%) North West 4 48 15 2 5 26 54 % North East 5 52 17 3 2 30 58 % East 5 60 17 7 0 36 60% South 6 63 22 1 2 38 60 % Western Rural 1 12 0 2 0 10 83 % Western Urban 40 441 98 49 14 276 63 % Average Compliance 61 676 169 64 23 416 62 % The above table, indicates that the average performance score of each district council or institution is 50 %. Furher analysis of the data also shows that on average 62 % of the agreed action points for ea ch Council and MDA was fully implemented. For instance, the North west Region, has four (4), Local Council Administrations, with 48 agreed action points in total; this means that each District council administration has a total of 12 agreed action points t o be implemented. With an average compliance score of 54%, this shows an indication that, 6 out of every 12 action points by every district council were fully implemented, with a compliance score of 50 %. By further, looking at the other variables in the t able, one could establish relationship between the total number of action points and those that have been fully implemented; with a total average

46. - 46 - 6 City/District council and MDAs/Sectors to have an accountability forum on the use of money allocated to them. # of City and District councils that have acc ountability forum on the use of money allocated to sectors. High City/District Council and MDAs/Sectors have a weak accountability forum on the use of money allocated to them. All City/District council have accountability forum.  Verify Accountability forum meeting minutes,  Attendance List etc 7 Developed and execute Customers services charter Developed an approved and execute Customers services charter. High Developed and execute Customers Services Charter 100% compliance Physical Verification of Customers Services Charter HUMAN RESOURCE MANAGEMENT. Recommendations Indicator Activity (Input & output) Impor tance Baseline situation/ Challenges Target Means of Verification (MOVs) Current Progress Measure Comments /suggestio ns 8 Developed a score card for all senior public officers. # of score card filled and signed by senior public officers in the council High To have a score card for all senior public officers. All senior public officers  Verify filled score card by senior public officers.  List of senior public officers signed score card 9 Developed an Anti - Corruption Policy Developed an approved an Anti - Corruption High To have an internal Anti - Corruption policy signed by all the staff  Verify approved An anti - corruption policy sig ned List of

12. - 12 - 43 Koinadugu District Council 10 7 3 70 44 Koidu New Sembenhun City Council 16 8 8 50 45 Kenema City Council 11 7 4 64 46 Kailahun District Council 11 6 5 55 47 Kono District 11 6 5 55 48 Mattru District Council 10 5 5 50 59 Bonthe Municipal Counci l 10 5 5 50 50 Moyamba District Council 10 5 5 50 51 Bo District Council 11 6 5 55 52 Bo City Council 11 6 5 55 Average Compliance 557 312 246 56 % Secretariat The table above indicates that fifty - two (52) MDAs and Councils fall within Moderate Com pliance Score out of sixty - one (61) MDAs/Councils targeted. The fifty - two (52) Institutions have an overall total Action Points of five hundred and fifty - seven (557). The monitoring result indicates that there is an average performance of 56 % indicating m oderating compliance, donating more work need to be done on their Action Points and that there is room for improvement . Table 6 – MDAs with Non - Responsive Status NON - RESPONSIVE MDAs No MDAs 1 Public Sector Reform Unit 2 Immigration 3 Ministry of Fore ign Affairs and International Cooperation

10. - 1 0 - overall Monitoring Exercise. It further indicates that out of sixty - eight (68) agree Action Points, fifty - seven (57) were fully implemented whilst an outstanding eleven (11) Action Points were not fully implemented. The table above shows that two (2) Local Councils made an impressive performance of implementing their Action Points. See table abov e for details and specific names of Institutions . The overall percentage score of the six (6) Institutions is 84% in a scale of 0 - 100 in the compliance barometer indicating Significant Compliance Table 5 – Moderate Compliance Score # MDA/Institutions Total Action Points Implemented Action Points Outstanding Action points Compliance Status % 1 Office of the Vice President 6 4 2 67 2 Ministry of Energy 3 2 1 67 3 National Commission for Social Action 12 6 6 50 4 Ministry of Socilal Welfare 11 6 5 55 5 Off ice of The OMBUDSMAN 14 10 4 71 6 Ministry of Lands 8 4 4 50 7 Ministry of Works 9 6 3 67 8 Ministry of Health and Sanitation 7 5 2 71 9 National Civil Registration Authority 10 5 5 50 10 Sierra Leone Roads Authority 10 7 3 70 11 Sierra Leone Maritim e Administration 10 5 5 50

41. - 41 - 12 Kenema City Council 11 7 64 0 0 2 18 2 18 13 Kai lahun District Council 11 6 55 0 0 0 0 5 45 14 Kono District 11 6 55 0 0 2 18 3 27 15 Pujehun District Council 11 10 91 0 0 0 0 1 9 16 Mattru District Council 10 5 50 1 10 0 0 4 40 17 Bonthe Municipal Council 10 5 50 0 0 0 0 5 50 18 Moyamba District C ouncil 10 6 60 0 0 0 0 4 40 19 Bo District Council 11 6 55 1 9 0 0 4 36 20 Bo City Council 11 6 55 0 0 1 9 4 36 21 WARD - C 12 10 83 2 17 0 0 0 0 22 FCC 10 5 50 2 20 0 0 3 30 Average Score 245 145 59 % 13 5 % 13 5 % 74 30 %

40. - 40 - DETAILED ANALYSIS OF LOCAL COUNCILS . # Institutional Action Points Full Compliance Significant Compliance Moderate Compliance No Compliance Local Councils Action Points Implemented Action Point % Implemented Action Point Compliance Score Implemented Action Point % Non - Implemented Action % 1 Port Loko District Council. 12 6 50 1 8 1 8 4 33 2 Port Loko City Council 12 6 50 2 17 1 8 3 25 3 Karena District Council 12 7 58 1 8 0 0 4 33 4 Kambia District Council 12 7 58 1 8 0 0 4 33 5 Bombali District Council 10 6 60 0 0 1 10 3 30 6 Tonkolili District Council 11 6 55 0 0 1 9 4 36 7 Makeni City Council 10 5 50 1 10 0 0 4 40 8 F alaba District Council 11 6 55 1 9 0 0 4 36 9 Koinadugu District Council 10 7 70 0 0 1 10 2 20 10 Koidu New Sembenhun City Council 16 8 50 0 0 2 13 6 38 11 Kenema District Council 11 9 82 0 0 1 9 1 9

11. - 11 - 12 Ministry of Finance 10 7 3 70 13 Ministry of Information 16 9 7 56 14 Sierra Leone Correctional Services 10 6 4 60 15 Parliament 7 4 3 57 16 Ministry of Justice 15 9 7 60 17 National Fire Force 9 5 4 56 18 Office of Nat ional Security 12 6 6 50 19 Office of the president 5 3 2 60 20 Political Parties Registration Commission 5 3 2 60 21 Ministry of Tourism 13 7 6 54 22 Sierra Leone Road Transport Corporation 10 6 4 60 23 Human Resource Management Office 14 7 7 50 24 Independent Media Commission 14 7 7 50 25 Ministry of Internal Affairs 14 7 7 50 26 Ministry of Local Govt 14 7 7 50 27 Sierra Leone Ports Authority 14 7 7 50 28 Ministry of Defense 10 5 5 50 29 National Revenue Authority 9 6 3 67 30 Pharmacy Board SL 11 8 3 73 31 Ministry of Mines and Mineral Resources 10 6 4 60 32 National Social Security and Insurance Trust 10 5 5 50 33 Sierra Leone Ports Authority 14 7 7 50 34 Freetown City Council 10 5 5 50 35 Port Loko District Council. 12 6 6 50 36 Port Loko City Council 12 6 6 50 37 Karena District Council 12 7 5 58 38 Kambia District Council 12 7 5 58 39 Bombali District Council 10 6 4 60 40 Tonkolili District Council 11 6 5 55 41 Makeni City Council 10 5 5 50 42 Falaba District Council 11 6 5 55

43. - 43 - 22 SLRTC 10 6 60 0 0 0 0 4 40 23 HRMO 14 7 50 0 0 0 0 7 50 24 IMC 14 7 50 0 0 0 0 7 50 25 Min istry of Internal Affairs 14 7 50 0 0 5 36 2 14 26 Ministry of Local Govt 14 7 50 0 0 1 7 6 43 27 SLPA 14 7 50 0 0 0 0 7 50 28 MOD 10 5 50 0 0 0 0 5 50 29 NRA 9 6 67 3 33 0 0 0 0 30 Pharmacy Board 11 8 73 1 9 0 0 2 18 31 Ministry of Mines 10 6 60 0 0 2 20 2 20 32 NASSIT 10 5 50 0 0 2 20 3 30 33 SLP 14 7 50 0 0 4 29 3 21 34 EPA 13 11 85 2 15 0 0 0 0 35 ACC 15 14 93 0 0 1 7 0 0 36 NATCOM 14 13 93 1 7 0 0 0 0 37 NPPA 11 9 82 2 18 0 0 0 0 38 NCP 6 5 83 0 0 1 17 0 0 39 Ministry of Trade 15 13 87 0 0 2 13 0 0 Average Compliance 431 271 63 % 14 3 % 49 11 % 98 23 %

42. - 42 - DETAILED ANALYSIS OF MDAS COMPLIANCE STATUS # MDA Total Action Points Full Compliance Compliance Score Significant Compliance % Moderate Compliance % No Compliance % 1 VPO 6 4 67 0 0 1 17 1 17 2 Ministry of Energy 3 2 67 0 0 0 0 1 33 3 NACSA 12 6 50 1 8 1 8 5 42 4 SOCIA L WELFARE 11 6 55 0 0 1 9 4 36 5 OMBUDSMAN 14 10 71 0 0 1 7 3 21 6 Ministry of Lands 8 4 50 0 0 1 13 3 38 7 Ministry of Works 9 6 67 0 0 2 22 1 11 8 MOHS 7 5 71 0 0 2 29 0 0 9 NCRA 10 5 50 0 0 2 20 3 30 10 SLRA 10 7 70 0 0 1 10 2 20 11 SLMA 10 5 50 0 0 5 50 0 0 12 Ministry of Finance 10 7 70 0 0 3 30 0 0 13 Ministry of Information 16 9 56 0 0 5 31 2 13 14 SLCS 10 6 60 0 0 4 40 0 0 15 Parliament 7 4 57 0 0 0 0 3 43 16 Ministry of justics 15 9 60 0 0 0 0 6 40 17 National Fire Force 9 5 56 0 0 1 1 1 3 33 18 ONS 12 6 50 2 17 1 8 3 25 19 Office of the president 5 3 60 0 0 0 0 2 40 20 PPRC 5 3 60 0 0 0 0 2 40 21 Ministry of Tourism 13 7 54 0 0 0 0 6 46