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ANTI-CORRUPTION COMMISSION OF SIERRA LEONE

An independent institution established for the prevention, investigation, prosecution and punishment of corruption, corrupt practices and to provide for other related matters. 

Contact us on: +23278832131 or info@anticorruption.gov.sl
Address:  Integrity House, Tower Hill, Freetown Sierra Leone, West Africa.

Annual-Review-February-2017

Pay No Bribe / Resources Publications

The programme has made good progress since the last Annual Review (AR) in February 2016 and overall progress is rated an A for this year: ‘outputs meet expectations’.

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9. Compleme ntary outreach work to educate citizens about their rights and the Pay No Bribe campaign is being undertaken through the President’s Delivery Team and through partner MDAs. A number of MDAs noted that they are stepping up efforts to educate citizens about their service charter and legitimate fees as a result of the PNB responses. The police also took action to address the corruption itself by visiting Kenema, and dismantling a number of illegal checkpoints. Warnings have been issued to staff to improve be haviour and supervisors are being challenged to monitor their teams closely. In EDSA, the team undertook an investigation to establish the issues behind the high report volume, and have issued a warning to staff of disciplinary action should bribery be ide ntified against a specific staff member. EDSA also spent time in communities they serve asking about the quality of service they received. The review team discussed this with MDAs at the technical committee, and proposed that some guidelines be given to MD As on this type of follow up, to ensure anonymity is not compromised and that messages around the programme are clear. A press release is being prepared that will summarise the responses and actions taken by the 6 MDAs, and a press conference is expected to be held to encourage feedback and scrutiny of the quality of responses. The MCCU and ACC will be leading on this. Recommendations - Strong er engagement is needed from the ACC Public Outreach team, making effective use of t he available resources . The communication strategy should be reviewed, and where necessary updated , and disseminated , and the use of social media considered . - ACC, CSO, MDA collaboration is needed on communications and outreach . A core script to ensure the consistency of messaging across partners may be helpful . More routine, strategic engagement should be supported through steering and technical committees. - Work with the Freetown CSO to improve delivery.

7. The a reas for improvement include: exte nding the operating hours to the evenings, so that citizens working during the day can call in; Setting up a clear out of hours message , so that citizens know when the line is open. Call centre staff speak English and Krio, but do not speak other local lan guages (Mende, Temne etc), although the app has functionality in local languages , with a voice over guide to allow access for the less literate . Additional call centre staff, with additional local languages, could be considered for the future, as long as this can be sustained by the ACC. The call centre is redirecting callers who wish to provide names and additional details to the core ACC anti - corruption hotline. How ever, this call centre is not always functional and cases were reported where the PNB call centre received complaints about the core hotline. In what is a positive move by the ACC, the core hotline is now being reviewed in light of this feedback. There is an important opportunity here to achieve full integration of the two systems on one site, and there was agreement from the ACC that this could be done. Doing so would create a more coherent, efficient and sustainable system, which will be easier to use for citizens. R eporting data and some analysis are available on the website , but rapid improvements in the quality of analysis on the website are needed (e.g. adding breakdowns by district, value of bribe paid) . Coffey is in the process of developing versio n 2.0 of the website, which should address this . As originally envisaged, the final version of the website should allow users to see a range of metrics about corruption trend s, reported issues and how the Government has responded. Recommendations - Website version 2.0 and the PNB call centre should be integrated with the ACC website and call centre to streamline and simplify reporting of bribery. The programme should also review the utility of the call centre , before the end of the pilot phase , with a view to making changes which broaden access.

4. needs to shift public perceptions and provide assurance of a GOSL response if t his score is to move further. I mportantly, Sierra Leone also passed the MCC’s Control of Corruption indicator in 2016, which is in fact one of the end targets for the programme. Overall output score and description The overall output score is rated A. The programme has made con siderable progress since the last review and delivered against the output indicators. The component on the institutional strengthening of the ACC was less of a focus this year as the programme pushed forward with PNB establishment, but some progress was made that can be built upon. Under output one, t he PNB reporting platform was launched in late September 2016, following intensive work to establ ish a call centre, free hotlines, and a mobile application and to recruit and train staff to manage the system. B y early January more than 7,6 00 reports have been made through the platform (call centre, app, and website ) to report honest officials and/or t he payment of a bribe. The website is hosted at www.pnb.gov.sl , and the front page is captured below. Launch of the platform has been complemented by a series of media announcements and CSO activities (vox pops and radio shows) aimed at raising the profile of PNB under output 2 . However, there are gaps in the communications and outreach, with Western Area being weaker than expected. The responsible CSO will need to raise their efforts in this area, and the ACC will need to ensure financial resources and materials a re properly utilised. T here was less activity in this period on outputs 3 and 4. The planned work was delivered, with investigative journalism training being conducted, media engagements on the P NB platform, and support to strengthen key skills in the ACC. The approaches in these components need to be reviewed and realist ic targets set, to deliver more as the programme evolves. At the point of writing, all 6 target MDAs have submitted responses on time to the ACC for publication on the website. The strength of response from the target MDAs is encouraging, and shows that the system is already having an impact.

15. Asset monitoring and control In line with DFID guidance, Coffey and the ACC are maintaining asset register s . Partners provide reports on the status of these assets and regular checks are unde rtaken by the programme management team in DFID. During the annual review process, we verified the use of tablets and mobiles provided to the project in the areas/ CSOs visited. The tablets are locked as agreed so that only the PNB platform is accessible o n them, which is an important safeguard to avoid misuse. G: CONDITIONALITY (½ page) Update on partnership principles (if relevant) This programme provides assistance in enabling GoSL to uphold the partnership principles, as improving the mechanisms for addressing corruption remains a priority. The September 2016 assessment confirmed credible commitment on the part of GoSL across ea ch principle. GoSL failure to execute this programme well would call into question the commitment of the government. This will need to be monitored carefully, particularly during the challenging election period. H: MONITORING & EVALUATION ( ½ page) Evidence and evaluation Following earlier concerns about weak monitoring and evaluation, the supplier brought in dedicated resource to monitor programme outputs. This resulted in the delivery of a robust baseline survey, conducted in partnership with a credible local partner and with the agreemen t of the ACC. This survey offers a valuable resource to the programme and should be repeated towards programme closure. Additionally, systems are now in place to undertake regular field visits to assess the progress of CSOs, and the frequency of these visi ts should increase as implementation rolls out. The ACC institutional strengthening will be tracked through strengthened data collection within the ACC as well as feedback on activities delivered, and monitoring of the quality of these inputs. This will be done through both Coffey TA, DFID staff and self - reporting . Finally, there is an agreed timeline for smaller surveys to assess the impact of public awareness activities, media engagement, and to get feedback on the platform itself. Monitoring progress throughout the review period DFID Sierra Leone has maintained a close overview of the programme, including through an intensive PIP process which was completed in October 2016. During this period the DFID SRO regularly visited the ACC, the call centre, th e MCCU and State House to assess programme performance and meet with stakeholders. This annual review was carried out by a Governance adviser and two programme managers in DFID Sierra Leone. The review was based on documentation of activities as well a s eries of meetings with the supplier’s in country team . The review team met a range of GoSL counterparts : notably the ACC, EDSA, Ministry of Heath, Police, The Sierra Leone Water Company (SALWACO), MCCU, President’s Delivery Team, to get feedback on their e xperience in the programme, and CSOs both in Freetown and in Bombali.

14. Overview of programme risk The risk and mitigation activity outlined in the original business case remain valid. Additional risks identified in the last annual review – supplier underperformance and GoSL leadership – also remain, although steps have been taken to address this. Mitig ation measures have included leveraging the PDT process, strengthening the Coffey TA team, regular engagement with the ACC and ACC taking increasing ownership of the programme. Th is has been reflected in the good progress made in the 12 months since the la st annual review, guided by intensive support from DFID Sierra Leone’s Governance team through the PIP process. However, the operating environment remains challenging and the pressure on delivery will intensify as the programme moves beyond the pilot phase and expands the number of potential reportees and MDAs covered by PNB. The upcoming elections, slated for February 2018 pose an additional risk to sustained, focused delivery, as GoSL as a whole is likely to be increasingly occupied by political processes . Sustaining MDA responses and engagement in this period will be difficult, and the programme should develop explicitly mitigation strategies e.g. strong links to technical officers in target ministries, to help mitigate this. The ACC will need to leverage its independence to focus on impartial delivery of its mandate and embedding the PNB approach into systems. Outstanding actions from risk assessment Review and update the risk matrix to ensure elections, delivery and reputational risks are updated and mitigation measures are in place. F: COMMERCIAL CONSIDERATIONS (½ page) Delivery against planned timeframe Following intensive engagement to redesign the delivery plan, logframe and timelines during the PIP, t he delivery of planned activitie s in the technical assistance component is going according to plan. An amended workplan/milestone has been agreed which has laid out the implementation schedule . The TA team will need to reflect the recommendations of this annual review and the agreed roll out strategy for the PNB platform in an updated implementation plan for the period April 2018 - December 2018. Disbursements to support the implementat ion of activities under this component have been made in the agreed timeframe. The delivery of planned ac tivities under the financial aid component is going at a slower pace as the workplans for this component are in the stage of being agreed . This is behind schedule and DFID and ACC have agreed that there is a risk of underutilisation of these funds in the a nnual review meetings. The DFID team will be engaging with the ACC to discuss whether the total amount allocated should remain, and whether it can achieve the intended impact in the remaining time. This will inform a decision on whether the financial aid c omponent should be changed or reprogrammed for the remainder of the programme. Performance of partnership (s) Partnerships have improved over the course of the last year, with stronger leadership from the supplier as management moved to the London based team and a new Programme Director . There is also increasing buy in, leadership and ownership of the process and programme from the ACC and wider GoSL. The GoSL is delivering against the commitment to coordinate and provide responses to PNB feedback, which is itself a commendable undertaking. DFID has agreed steering committee meetings, technical committee meetings and programme team meetings with the various stakeholders. These meetings have been taking place on a regular basis wh ere DFID, MCCU, GoSL and Coffey and MDA stakeholders participate to drive implementation and MDA responses. This arrangement has facilita ted good working relati ons amongst the various stakeholders .

12. D: VALUE FOR MONEY & FINANCIAL PERFORMANCE (1 page) Key cost drivers and performance The project cost drivers are the costs of consultants providing technical assistance and project management, related operating costs, running the call centre and financial support to the ACC. VfM performance compared to the original VfM proposition in t he business case DFID is constantly monitoring the delivery of value for money on the programme to ensure that the funds provided to the implementing partners Coffey and the Anti - Corruption Commission are used for intended purposes and as per approved wo rk p lans and budgets. An annual internal VfM assessment has been undertaken through the collection of evidence against the ‘ three E’s ’ - economy, efficiency and effectiveness. Economy . What does the programme do to ensure that input costs are in line or under the prevailing market costs, minimise expense costs whilst maintaining the quality of project support, and identify and leverage economies of scale? - Tablet procurement: As part of PNB outreach activities, Coffey procured a number of tablets to equip CSO animators to facilitate citizen reporting. To save on fees, a portion of these tablets were procured in the UK and shipped to Freetown. This saved £840. - The DFID team facilitated the transfer of second - hand tablets and smart phone handsets used on Ebola response programmes, to save on programme procurement. 106 smartphones were transferred saving the programme £11,520 on the phones. 26 Tablets were also given to the programme, saving £3,900. In sum, this saved £15,420. - Vehicle Hire: as the level of in - country support surges from month to month, Coffey has negotiated a flexible car - hire arrangement in Freetown which allows the team to take on cars as and when required for up - country and Freetown travel with a reduced daily rate of 20% (inclus ive of driver). As a result Coffey has saved £2,426 since June 2016. Efficiency . What does the programme do to ensure that the inputs it delivers produce the maximum possible output, identify and use synergies across project work streams, and ensure deplo yment of the most cost - effective personnel? - National Consultants: Coffey has taken on board feedback about using local and regional consultants where possible to complete programme inputs, saving on international fees and accommodation. This has resulted in the sourcing of quality local consultants to facilitate i nvestigative j our nalism training in December , and the programme will continue to use t his approach where possible . Effectiveness . What does the programme do to leverage additional effect from outside the project by identifying leverage opportunities with external stakeholders and ‘multiplier effects’, and ensure best practice is shared from and with other comparable interventions? - Coordination with the Presidential Delivery Team: The programme reports in to the Presidential Delivery Team and has strengthened relationships with the team in order to maximize outputs. This delivered additional leverage and value added when coordinating the launch of the PNB platform. - Coordination with the MCCU: The MCCU has been a long term partner in the programme and adds significant value by linking in to the Office of the Chief of Staff, and facilitating coordination with MDAs. This ne eds to be further strengthened in order to increase effectiveness.

3. A. Introduction and Context (1 page) DevTracker Link to Business Case: https://devtracker.dfid.gov.uk/projects/GB - 1 - 203881 DevTracker Link to Log frame: https://devtracker.dfid.gov.uk/projects/GB - 1 - 203881 Outline of the programme The programme is providing £4.7m over five year s to reduce corruption in Sierra Leone’s service sectors (health, education, water and sanitation, power) by enabling citizens to report requests or payment of bribes , and supporting a GoSL response to reports of corruption . Corruption remains a serious c hallenge in Sierra Leone, with 2016 Transparency International data showing Sierra Leone scoring only 30/100 (with 100 being very clean), a one point improvement on the year before. The custom of using corruption to foster patronage, power and personal gai n remains endemic. Petty corruption is rife amongst junior officials, and commonly consists of imposing ‘charges’ for free services, as well as additional charges to avoid long wait times. Although relatively small sums of money, these charges bear most he avily on the poorest. The programme is delivered through two components: 1. Supporting citizen and media engagement: The programme should e stablish a platform through which citizens can report the payment of bribes. Reporting is anonymous and makes innovati ve use of technology to broaden access. Simultaneously the programme is to work with the media to increase the quality and quantity of coverage of corruption in Sierra Leone’s service sectors, using the published results to stimulate debate. 2. Support to the Anti - Corruption Commission (ACC) to increase capacity to address both petty and grand corruption and improve the enforcement of public standards. The financial aid and the supplier, Coffey, offer two mechanisms to support delivery of these compon ent areas . Coffey provid es technical assistance and systems support, and financial aid is targeted to bolster ACC capacity to respond to petty and grand corruption issues. Th e programme has support from the highest level of government and is one of the R ecovery Priorities . The Millennium Challenge Corporation Unit (MCCU) , under State House, is a partner to the programme due to shared goals of reducing corruption in Sierra Leone. The Chief of Staff has chaired regular Steering Committees over this period t o drive progress. In November 20 16, President Koroma noted the role of PNB for improved governance within the public sector: “We have therefore ensured that the Anti - Corruption C ommission’s new ‘Pay No Bribe approach to tackle corruption harnesses technology to collect the first - hand experiences of members of the public. Over time, it will spotlight the best and the worst in the delivery of our public services. This will enable us to address challenges where they exist.” B: PERFORMANCE AND CONCLUSI ONS (1 - 2 pages) Annual outcome assessment The programme is making progress towards the outcome of government and citizens being more aware and capable of addressing bribery and corruption . Specific data on outcome indicators will be gathered after the pilot completes in March and will be reviewed to inform next steps . This was delayed due to the launch happening later than expected. In the interim, the review team found evidence of progress towards this objective, in line with the theory of change. The establishment of an anonymous reporting system, increasingly functional Integrity Management Committees in MDAs, and increased engagement of citizens in addressing corruption are all required in order to achieve the outcome. At the impact level, Sierra L eone has gained one point in the Transparency International index (30/100) since last year, but this remains fairly consistent with scorings over a 5 year period . The programme

13. Asse ssment of whether the programme continues to represent value for money Yes. Following the Performance Improvement Plan and successful establishment of the PNB platform, value for money is being achieved . Coffey is now providing a quality management and technical function , and the ACC and MDAs are now strongly engaged in driving delivery . The AR team expects the VfM case for this programme to improve over the course of delivery, as the number of PNB reports increase and stakeholders build their understand ing of corruption across the sectors targeted. The feedback loop and outreach should contribute to a slow and steady reduction in the acceptability of bribery, which offers long term impact for Sierra Leone and high impact in VfM should the quantity of res ources lost to bribes progressively reduce. The financial aid component is being used for activities which contribute to the programme objectives , and in line with the set of activities agreed with DFID. A due diligence assessment was conducted by the prog ramme team in 2016 to ensure the right systems are in place to manage financial aid to deliver value, which found the ACC’s procurement and FM systems to be robust. However, utilisation rates are slower than expected, and this raises concerns about the abs orptive capacity of the ACC. The review team recommends that the quantity , the use and added value of the financial aid is reviewed in more detail, to ensure it can be used in a timely, effective way to deliver best impact for the project. Quality of fin ancial management The finances of the programme are monitored in close collaboration with the managing agencies of the different components. DFID monitors foreca sts and reporting on a regular basis, split into monthly and quarterly for both the technical assistance and financial aid com ponents. Reviewing of invoices has played an important role in ensuring that a robust financia l tracking is active both within DFID SL and the implementing partner. The rigorous checks in cases where payment i s against miles tones ensure that the payment is in line with agreed deliverables and timelines. Project Component Name Budget £ Forecast £ Spend to date £ 203881 - 101 DFID support to tackling corruption in Sierra Leone 915,992 915,992 585,852 203881 - 102 Financial Aid to the Anti - Corruption Commission 450,000 450,000 225,000 Total 1,365,992 1,270,739 610,851 The spend against the forecast for component 101 will be at a 100% by the end of the financial year as invoices relating to the final quarter would have been in and paid. Component 102 will be a 50% spend by the end of the financial year due to slow rate of utilisation of the financial aid by the ACC during this period . As flagged above, based on the due diligence conducted the systems are in place for proper management of spending within the ACC, but interdepartmental coordination and planning issues seem to be the cause of slow spending. This will be monitored closely over the coming 2 months as the ACC are presently finalising work plans that should increase spend in the next financial year. DFID will consider whether this can address the issue, or whether reductions in the financial aid/ reprogramming are needed. Date of last narrative financial report: Technical Assistance 02/12/2016 Date of last narrative financial report: Financial Aid 18/01/2017 Date of last financial statement Technical Assistance TBC Date of last audited annual statement Financial Aid Not yet due E: RISK (½ page) Overall risk rating: Major

6. C: DETAILED OUTPUT SCORING (1 page per output) Output Title 1 Reporting mechanism and information on i nstances of bribery and corruption are available and accessible to the public and MDAs in Sierra Leone. Output number per LF 1 Output Score A Risk: Moderate Impact weighting (%): 25 Risk revised since last AR? Y Impact weighting % revised since last AR? Y Key Points The PNB platform was launched in September 2016 and members of the public were now able to report payment of bribes, or engagement with an honest official through a call centre, website or PNB app. By early January 2017, more than 7,000 citizens had used t he platform , and data is published in real time on a public website . T he PNB app proving overwhelmingly to be the most used mechanism for reporting. This is likely to be driven by the use of the app by CSO animators who facilitate reports from citizens in the four target districts. A lack of clarity amongst citizens on whether calling in is indeed anonymous and/or free may also be a factor in smaller numbers of reports to the call centre, as well as the high number of call centre calls which are dropped. T h is needs to be addressed through improved communications and improvements to call centre systems . This indicator captures a range of more granular activities undertaken by the ACC and the supplier, tracked through the PIP , which enabled the call centre to be established. This included : f inalisation of the call centre location, hiring of staff, training, and establishment of a new phone line, toll free on major operators (515). It has received a wide range of callers from school children to the elderly. M any initial calls were for more information about the system, but as the programme has become more familiar to citizens there has been an uptick in the number of reports. Overall the pilot reporting systems are working well, with reports being analysed by the ACC and translated into reports for MDAs to act on. Reports are logged in the website in real time and made public. Reports with more detailed information were also processed by the ACC’s call centre data analyst (a post supported through the financi al aid component) and delivered monthly to target MDAs by the ACC . Technical meetings have been convened with each MDA to support them and their Integrity Management Committees (IMCs) to take action on the reports. Indicator(s) Milestones Progress a. % time PNB has an accessible reporting system (call centre, website and app) receiving information and generating live, accurate public analysis and reports on bribe trends; b. Monthly PNB reports prepared by ACC and shared with target MDAs, disaggregated by district and sector a. 75% b. 15 monthly analysis reports (3 per sector) + 1 other report a. The current accessibility rate is at 91% b. 15 Monthly MDA repor ts and one quarterly report for each MDA have been completed , disaggregated by district and sector . Number additional pieces of quality information, analysis and research reviewed and made available to the public by the ACC about corruption trends. This should be shared on either the ACC or PNB sites. Baseline survey in place and one additional report generated 2016 Baseline Survey report has been published on the PNB website 2016 Behavioural Analysis report has been published on the PNB website % of citizens in PNB target areas who state that it is easy or fairly easy to report a bribe via the website, call centre or app. Information available at the end of pilot phase Results not available until the end of Pilot, March 2017.

5. Key lessons - The programme has shown some significant impacts early into the pilot period. Some of these are unexpected, such as police taking action to dismantle illegal checkpoints around areas with a high volume of reports; MDAs pushing out information on citizens’ rights to address ‘erroneous reporting’; and citizens reporting that P NB materials (stickers and wristbands) are deterring service providers (in some cases) from asking for bribes. - The programme creates an incentive towards providing citizens with clear information on their rights rather than withholding it. Greater, proactive effort is needed to sustain the engagement of MDAs . This includes engaging State House effectively and supporting MDAs to develop their response to PNB reports. - Outreach and communications are critical to the success of the system: peo ple need to understand their rights, the different reporting mechanisms, and what they can expect as a response. They also need to hear about the responses delivered by MDAs. Stronger engagement between partners is needed to ensure there are consistent messages about PNB, how it works, and its innovative focus on anonymity and systemic change . - A strong in - country support team is crucial for sustaining the relationships and political engagement that this programme needs. This point has been acknowledged by Coffey and they’ve already put in place plans to strengthen the Freetown team. Key actions Action Lead Responsible By When Identify next steps on the development of a Strategic Plan and institutional strengthening. ACC and Coffey 2 8 /2/17 Manage the timelines to deliver a public MDA response on the website and press release. MCCU 28 /2/17 All partners to review the communications strategy and disseminate broadly, and step up the distribution of materials and engagement with CSOs and the media. A CC Communications Dept. 2 8 /2/17 Revise contract to reflect the final end date - Dec 2018. DFID/ Coffey 1/3 /17 R ecruitment plan and risk management strategy between now and Dec 2018 developed and agreed. Coffey 10 / 3 /17 Implement measures to improve CSO delivery in Freetown Coffey 28/2/17 P rovide a timeline for the new website to be in place with additional analytics and geographical roll out. Coffey and ACC 5/3/17 Review call centre functions and make improvements Coffey and ACC 30/3/17 Review financial aid DFID 15/3/17 Coffey and partners to review PNB and recommend sectors for scale up based on : a) number of people affected (geographical spread) b) level of engagement expected through the MDA responsible c) practicality of using the PNB syst em for this issue. Coffey 30/3/17 Review logframe to consider amending Output 3 to cover all GOSL. DFID 10/4/17 Has the logframe been updated since the last review? Yes. The logframe was updated during Performance Improvement Plan (PIP) , with a n update in August followed by a final version agreed with the ACC in October when the PIP closed and to incorporate the results of the baseline survey .

11. Output Title 4 The media is better prepared to engage with citizens, CSOs, ACC and MDAs at national and district levels to pursue news stories on corruption. Output number per LF 4 Output Score A Risk: Major Impact weighting (%): 25 Risk revised since last AR? N Impact weighting % revised since last AR? Y Key Points The baseline study has been developed which will enable tracking of the media engagement and public awareness it generates. T he ACC and Coffey have worked together to develop an outreach and communications strategy which should serve as a guide for this ou tput . However, the review found that this strategy has not been widely shared within the ACC or with other partners. T his strategy needs to be translated in to an action plan and both TA and financial aid leveraged to deliver against it. As part of the media engagement component the ACC has held press briefings to raise awareness of PNB among journalists . In partnership with the TA and MCCU, press releases have been issued, and investigative journalism training was sourced by Coffey and de livered in December 2016. This was targeted at increasing the quality and quantity of media articles investigating corruption. R adio shows , v ox pops and videos have been developed and circulated. 110 articles on anti - corruption were recorded , substantial ly exceeding the target . T he review team has not been able to evaluate the quality of all these products, but there was community feedback indicated that people have heard the radio shows, and the vox pops and posters that the team has seen have been of a good quality. Over the next 12 months, progress against this indicator will be critical as the programme expands beyond the 5 pilot districts and MDAs. The media needs to be much more engaged in critically analysing the data generated through the PNB system, reporting on anti - corruption in Sierra Leone and engaging in a public debate on accountability more broadly. The media in Sierra Leone is diverse an d active, but quality remains weak and support towards more independent and professional reporting will be of benefit to the programme and Sierra Leone more broadly. Recommendations - The communication strategy should be reviewed , updated, and disseminate d widely . - Coffey should review the ir approach to engagement with the media and strengthen this , with appropriate planning for risk management as elections approach . Indicator(s) Milestones Progress Number of citizens: a. claiming to have listened to/read information on anti - corruption in the previous 3 months; b. claiming to have had a discussion about corruption with family/friends in the last 3 months. Baseline developed, outreach strategy in place The baseline surv ey report is published via the PNB website. Outreach and Communication s strategy is in place but not well used or widely disseminated. Number of: a. diverse radio formats covering corruption/bribery; b. community radio/FM station journalists producing content in rural areas (by district) c. number of responsible media articles/programmes highlighting grand and petty corruption and/or bribe paying. a. 3 b. 5 local radio journalists per district (20 total) c. 50 (at end of pilot in 4 districts)" a) 8 v ox pops capturing community voices and 8 r adio d iscussion shows b) 32 journalists in Community Radio Stations (8 per district ) c) 1 10 responsible media articles

10. Output Title 3 Anti - Corruption Commission capacity to tackle grand and petty corruption increased. Output number per LF 3 Output Score B Risk: Major Impact weighting (%): 25 Risk revised since last AR? N Impact weighting % revised since last AR? Y Key Points Th is output met its indicators, but there have been issues with the quality of process and deliverable. O nly some limited activities were undertaken this year as the programme as a whole prioritised the establishment of the PNB system due to its urgency , and due to difficulties in agreeing on an approa ch to this work . The annual review confirm s the need for a significant change in approach to achieve impact by programme close. Activities undertaken in this area include a learning exchange on prosecution techniques, training to staff on rolling out the PNB in districts, and collection of baseline data to support performance management and case tracking within the ACC. Coffey supported development of an outline for a strategic plan which must be developed and finalised with ACC leadership . The ACC also pr ovided regular support to MDA integrity management committees (IMCs) to support their engagement with the PNB process, and preparation of MDA responses were supported through the MCCU, Coffey and the ACC jointly. The overall financial and technical capac ity of the ACC is already sound, h owever, t he ACC has recognised the need to improve internal coordination and delivery, including how it supports the PNB platform and how it utilises financial aid. Some work is already underway, with the ACC making improvements to the running of the core ACC reports centre, and a commitment to increase the functionality of the outreach department. Institutional strengthening needs to be tailored and ACC led if it is to succeed. T he ACC has not been happy with the approach to capacity building taken by t he supplier , and the supplier has also recognised the need to change the approach to delivering this. Going forward, the approach needs to be reviewed and the strategic plan process provides a basis for this discussion. The key deliverables fo r the next year will be strong systems within the ACC for sustainable PNB delivery , and the completion of a strategic plan that can support the ACC to deliver more effectiv ely, with the right resourcing from GoSL, over the longer term. Agreement is needed with the ACC on target areas for capacity development, and how to deliver this . If agreement cannot be reached, the overall allocation to this component may need to be revi ewed and potentially reduced. Coffey will shift to a model of longer t erm TA to better enables both PNB and ACC development . Additionally, this component c ould refocus to include MDA responses , to maintain public faith through a demonstrated and thoughtful response . This should be considered over the next month and the logframe updated accordingly. Recommendations - GoSL and Coffe y to develop plan to a) deliver PNB consolidation and sustainability and b) progress strategic plans and deliver r ealistic, agreed plan for wider capacity support. - Coffey team should increase in - country support to work in partnership with the ACC . - Consider revision of this indicator to capture work that aims to increase the MDAs capacity to respond to PNB reports , ‘s trengthening GOSL response to corruption’. Indicator(s) Milestones Progress Number of HQ and regional ACC staff: a. trained in metho d s for pursuing and managing higher value corruption cases; b. identifying >3 ways in which they feel that their performance has improved after 12 months. a. 10 b. 0 a. 15 people trained. Number of grand corruption cases being investi gated by ACC : a. baseline data collected b. 4 new cases over baseline a. baseline data collected b. 13 new cases within 2016.

2. ministries, departments and agencies (MDAs) is encouraging. R eports are prompting MDAs follow up on complaints proactively, and to release service charters in order to avoid reports for legitimate fees. Summary of rec ommendations for the next year For the programme to strengthen the impact and sustainability of the reporting platform and deliver on the objective of a stronger GoSL response to corruption , three elements will be critical: 1. Ongoing leadership, commitment and engagement of the ACC , MDAs and State House. 2. The presence of a strong in - country TA team 3. Increased outreach and communications through CSOs, ACC and the media. Strategic Direction: A s the programme moves into full implementation, it needs to consolidate the current system, strengthening key aspects of delivery, ensure sustainability and safeguard against risks in the elections period. The priority will be ensuring the sustainability of the reporting system, with a collaborative, flexible and realistic approach to institutional strengthening in the ACC . - Strong leadership from the ACC and a politically aware approach to engaging partners will be critical. The ACC will be advancing the fight against corruption in a politically intense conte xt, and will need to underline its independence from these processes. T he programme needs to continue actively leverag ing senior political support for delivery: particularly through the Millennium Challenge Corporate Unit (MCCU) and the steering committee. - The programme will consolidate its nationwide coverage by increasing CSO activities. One additional sector may also be included when the website is updated . The review found that the judiciary/ courts, have emerged as a consistent demand from users. Next steps will be based on availability of resource to deliver this and the feasibility of delivery in this period. - T he component on ACC strengthening will be taken forward in three ways: 1) Discussions between the supplier and ACC to agree actions to e nsure the sustainability of the PNB system. 2) The strategic plan ning process will help to draw out specific areas of capacity development. 3) The strategic plan itself should help the ACC plan for longer term support from GOSL and internal next steps to p rogressively strengthen delivery . - There is agree ment that there should be a dedicated TA assigned to support MDA responses to the PNB reports, working with MCCU and ACC. A strong MDA response is critical to sustain public faith and engagement in the sys tem. Resourcing: - We will closely monitor and engage with t he supplier to ensure that the right team is brought in in a timely manner, and with the expected impact. - The programme will s upport the ACC to establish the right team to manage and monitor PNB , with clear lines of decision making. The amount and the use of financial aid will be reviewed to ensure it is a useful mechanism for the ACC to deliver against the programme outputs. - ACC take s over responsibility for financing the call centre posts later this year, and will need to ensure the required budget is allocated for this. Operations: - ACC will assign a focal point to drive delivery of the communications strategy , working with CSOs a nd MDAs . The strategy should be reviewed, updated and disseminated widely , considering use of social media and a ‘core script’ . - Website version 2.0 and the PNB call centre should be integrated with the ACC website and call centre to streamline and simpli fy reporting of corruption , and improve sustainability . - The Coffey team will deliver a strategy for consolidation and risk management over the next period , bearing in mind the potential impacts of elections on delivery.

8. Output Title 2 Citizens are more knowledgeable about legitimate service charges and their rights not to pay bribes. Output number per LF 2 Output Score A Risk: Moderate Impact weighting (%): 25 Risk revised since last AR? Y Impact weighting % revised since last AR? Y Key Points PNB sensitisation was undertaken both prior to and after the launch of the PNB platform. A communications and outreach strategy was finalised in October 2016. The quality of posters and other materials (T - shirts, videos, radio shows, wrist bands) is generally high. The posters, commissioned by the ACC, appropriately deliver messaging on legitimate fees as well as promoting cultural change towards the non - accepta bility of bribery. Four CSOs are undertaking sensitis ation work across the five pilot Districts (Western Urban and Rural , Kenema, Bombali, and Bo ) with oversight from the supplier . In Bombali, the AR team saw first - hand the highly - engaging and innovative methods some were employing to raise the profile of PNB, and stimulate dialogue on anti - corruption. T his ha s translated into steady growth in the number of reports. However, this early success ha s not been replicated across all districts . For example, rep orts from Western Urban were much lower than one would expect from the most densely populated di strict. This was identified as being due to slow start up and roll out by the Freetown lead CSO, and the Coffey team has initiated remedial actions to address t his issue. Some regional ACC office s are collaborating well with the CSO partner in their district, but in one area this is not yet effective. Additionally, t ransport costs were cited as a barrier to CSOs (animators) and the ACC staff reaching citizens across larger chiefdoms. A number of CSOs reported that they required more promotional materials. At the same time, discussions with the ACC revealed that that not all available materials had been distributed, and procurements of other co mmunications equipment were behind schedule . The ACC team agreed that the ACC will need better interdepartmental coordination t o improve outreach and the financial aid should be used to ensure local staff have access to transport and materials . Indicator(s) Milestones Progress Number of: a. ACC outreach officers . b. CSO partners that are trained in awareness raising for PNB and monitoring of activities. a. 12 ACC outreach officers (3 per district) b. 100 (25 per CSO ) a. 12 ACC outreach officers (3 per district) have been trained during pre - launch sensitization workshops, as well as post launch. b. 100: 25 CSO staff in each of the 4 CSOs Number of m/f citizens in pilot programme areas: a) reached by information on correct payments for services b) trained to access and use PNB. a. 5,000 (at end of pilot in 4 districts) b. 4,750 a.& b. 4,991 people have been both sensitized on correct payment services and trained on how to access PNB. (Male: 2,841. Female: 2,150). . Percentage of (m/f) citizens in programme areas (disaggregated by sex and age) who can describe one or more ways of reporting bribery and corruption issues. N/A - survey to be conducted in 2018. This data will not be captured until 2018. Number of reports/complaints received from citizens highlighting petty corruption through: a. free call centre b. website c. mobile app a. 2,000 b. 350 c. 1650 a. Call Centre: 1,007 b. Website : 482 c. Mobile app: 6050 Total: 7695

1. Annual Review - Summary Sheet Title: Support to Anti - Corruption in Sierra Leone Programme Value: £4.7 million Review Date: January 2017 Programme Code: 203881 Start Date: 21 /11/2013 End Date: 31/12/2018 Summary of Programme Performance Year 201 4 201 5 201 6 Programme Score A C A Risk Rating Moderate Major Major Summary of progress and lessons learnt since last review The programme has made good progress since the last Annual Review (AR) in February 2016 and overall progress is rated an A for this year : ‘outputs meet expectations’ . Following the last review in which the programme was scored a C, a performance improvement plan (PIP) was put in place which ran from April to October 2016. This annual review therefore covers a period of restructuring, intensive prioritisation and delivery on the programme . The main focus has been to establish t he Pay No Bribe (PNB) platform . This was la unched in September 2016 to enable citizens to report requests or payment of bribes in the services they receive , and to support Government ’s response to these reports . C itizens are now able to report the request or payment of bribes (or a meeting with an honest official) via the PNB website, call centre or mobile app lication , and data on reports is made public . To deliver this, additional staff joined the supplier team, the website and app were designed and established ; a call centre was set up; political economy and baseline analysis was completed which enabled the programme to update the logframe; and a communications strategy has been developed. In addition, f our CSOs have begun sensitisation work across five pilot d istricts , complemented by a growing outreach campaign of radio shows and posters . CSOs use mobile phones and tablets loaded with the app to help citizens log reports. The five sectors targeted have now drafted responses to three months of PNB data , which shows potential for significant impact . These are police, education, health, water and energy. Responses include references to positive actions, including internal investigations, staff training, site visits and stronger monitoring to tackle the issues ra ised . During the review period the ACC saw a change in leadership, with a new Commissioner taking office in March 2016. The ACC assigned a director from its leadership team to act as the PNB programme manager, and it actively supported the delivery of th e programme outputs. This period of programming also coincided with the launch Presidential Recovery Priorities (PRP), where PNB was included under the Governance pillar. This AR falls towards the end of the PNB platform ’s 6 month pilot phase, running October 2016 - March 2017 , and ahead of ,elections . The programme is now moving into the core of its implementation phase , where it will consolidate the current system and ensure capacity for nationwide resporting. One additiona l sector could be considered based on feedback from the pilot period. This will be assessed for technical and political feasibility and an implementation plan developed. DFID and ACC will assess the use of financial aid, which has been used much slower tha n expected , and make recommendations . During th e PIP and AR process, an agreement was made to bring forward the end date by 6 months to December 2018. This change would allow the concentration of resources into a shorter time frame, accelerating delivery and results, while supporting G o SL to sustain and embed the PNB system . Summary of l essons: Pay No Bribe SL is unique : Other ‘I paid a bribe’ reporting systems (E.g. Uganda, India) are not government owned, nor has there been a commitment respond. The engagement and response from the

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