Concept Note Anti-Corruption Programme ( )

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1 Concept Note Anti-Corruption Programme ( ) Context and justification There is renewed emphasis on corruption issues within the international community including a new focus on the linkages between corruption and sustainable growth. The discussion is among others taking place among and between governments, business, CSOs and international organizations within forums such as the G20, B20 and C20 and at international anti-corruption summits such as the International Anti-Corruption Conference (IACC) hosted by Denmark in the autumn of Promoting the international anti-corruption agenda is a high-priority issue for Denmark as also reflected in the Danish strategy for development cooperation and humanitarian action, The World Concerns about corruption have mounted over the years, in tandem with growing evidence of its detrimental impact on development. Corruption affects macroeconomic stability and there are negative implications of corruption on the efforts at increasing investments and production as well as improving governments ability to nurture sustainable growth and create job opportunities. It is being widely recognized that economic activity is harmed by corruption and that the negative impact of corruption as well as illicit financial flows on the global GDP is more than 3% annually. 1 Developing countries, struggling to become middle-income countries, are generally hardest hit by these negative effects of corruption, and especially fragile countries are often caught in a vicious cycle of conflict, poverty and poor politics fuelled by corruption. Corruption also lowers the quality of social services such as education and health. It reduces the effectiveness of development assistance and increases income inequality and poverty. 2 Corruption makes it more difficult for the poor and disadvantaged groups such as rural women to obtain public services. All of this has serious repercussions on reaching the SDGs especially in developing countries. Combating corruption is thus an issue that cuts across all of the Danish development engagements in all countries, sectors and thematic areas. There is increasingly a recognition of the trans-national aspects of corruption and a realisation that corruption is a common agenda for developing, emerging as well as high-income economies. International cooperation is an essential prerequisite for the fight against corruption to be successful due to the many ways the corruption challenge transcends borders. The proceeds of corruption for example find their way to safety abroad in the form of illicit financial flows and through money laundering mechanisms, shell companies and tax havens into legitimate-looking economic activities and consumption by the perpetrators and their associates. There needs to be measures against these activities in the North while also holding 1 Global Corporate Governance Forum Corruption, Economic development and Governance Issues two, See among others OECD Issue Paper on Corruption and Economic Growth, 2013, World Bank World Development Report 2017 and IMF staff discussion note Corruption: Costs and Mitigating Strategies, See among others: Transparency International Global Corruption report: Education 2013 and OECD Consequences of Corruption at the Sector Level and Implications for Economic Growth and Development: Chapter 5 Health

2 governments in the South accountable for their promises of combating corruption through building strong institutions and showing ethical leadership. In The World 2030, it is highlighted that Denmark will help build effective, accountable and inclusive institutions in partner countries. Part of Denmark s brand is also being one of the world s least corrupt countries. This is something to treasure and use actively- also in Denmark s development cooperation. Denmark has supported anti-corruption and broader governance reforms through its bilateral engagement, through multilateral partners, through government-to-government engagement such as the collaboration between the Danish Ombudsman and partners around the world, through support to international NGOs such as Transparency International, and finally through the support to anti-corruption and governance channelled by Danish NGOs to their partners. Denmark has thus over the years become an important player in the anti-corruption arena in the global South. This programme will continue and complement these existing Danish efforts and will partly comprise future support to existing partners and partly add new partners to the anti-corruption portfolio. The consolidation of these engagements in one programme will serve to increase the visibility of the Danish anti-corruption engagement in the wake of the IACC in October 2018 and to maintain the momentum among Danish stakeholders created by the conference. Theory of Change and Strategic Objective The strategic objective of this programme is To enhance the effectiveness of anticorruption through strengthened cooperation, advocacy, monitoring and research in key organisations and networks at national and international level. The indicators of effective anti-corruption efforts are that governments and businesses actually implement the commitments they have signed up to under UNCAC and SDG 16 as well as other international forums such as Global Compact, G20 and B20. The overall approach is to help reducing the opportunities for corruption and increase the risk of getting caught. The assumption behind this programme is that anti-corruption efforts will only be effective when the right incentives - negative and positive - are in place. An end to impunity through effective and predictable enforcement of the legal framework is an effective negative incentive - a powerful mechanism for discouraging corrupt behaviour. An end to impunity is among others facilitated by civil society and investigative journalists exposing corruption and advocating for preventive anti-corruption reforms. Positive incentives are however equally important. The SDG agenda constitutes such a framework of positive incentives. 3 Most governments as well as a growing number of companies have already made the SDGs, including Goal 16 on anti-corruption, a priority on their strategic agenda. Compliance and ethical behaviour in the field of anti-corruption is gradually becoming an important parameter of competitiveness. Further, since governments, the private sector and civil society all have important, but distinct roles to play in combating corruption, building alliances and collective action between these stakeholders is likely to make the anti-corruption efforts more effective. There is thus a momentum for launching a Danish anti-corruption programme focused on ending impunity while also taking advantage of the positive incentives that the SDG agenda provides for all stakeholders. 3 See the Business and Sustainable Development Commission Better Business Better World

3 The Theory of Change (ToC) is thus that all stakeholders have a role to play and if the right incentives are in place, then both the private and the public sector will be more willing to show ethical leadership and contribute to combating corruption. The Programme and its Development Engagements In line with the Theory of Change the programme has three clusters to strengthen the role of governments, civil society and the private sector respectively and to use both positive and negative incentives to motivate key stakeholders 1) Support to governments in the South to domesticate UNCAC and the SDG Goal 16. Key partners are UNODC and OECD 2) Support to four global civil society organisations to enable them to strengthen their watchdog role (Transparency International, Publish What You Pay and the Global Anti-Corruption Consortium) and to improve the coordination of the work of civil society in relation to UNCAC (UNCAC Coalition) and finally 3) Support to two global private sector-based initiatives; Alliance for Integrity and Maritime Anti-Corruption Network (MACN). As mentioned above, some of these partners are already receiving Danish support, and their capacity to manage Danish funds and achieve results is therefore well known. Others are new, and the preparation of these engagements will comprise varying degrees of further capacity assessments and determination of the precise modalities of the support. Cluster one - Governments and Multilateral Collaboration The prime responsibility for creating a corruption free environment that facilitates long-term inclusive and sustainable development rests with national governments. This includes a host of issues such as the responsibility for agreements and collaboration with other governments and adherence to international conventions and agreements such as UNCAC and the SDGs. SDG 16 on peace, justice and strong institutions is a strong weapon in the fight against corruption. Most countries have signed up to goal 16 and hereby committed themselves to combating corruption and building strong institutions. Most countries have also all signed up to various international anti-corruption conventions- most notably the United Nations Anti-Corruption Convention (UNCAC). Governments and state institutions in low income countries do however not always have the capacity to domesticate international conventions and commitments. OECD is therefore setting up an SDG Hub with the aim of supporting governments to integrate the SDGs in their national planning and administration, and UNODC sees a need to provide increased technical assistance for UNCAC implementation in low-income countries that do not have access to bilateral support for this purpose. Engagement 1: UNODC - Technical assistance for UNCAC implementation The UN Office on Drugs and Crime (UNODC) is the organisational anchor of the UN Convention against Corruption (UNCAC), the only existing universal and legally binding anti-corruption instrument. Since the adoption of the Convention by the General Assembly in 2003, 183 parties have ratified or acceded to the Convention (status as of April 2018), representing a near universal commitment to combating corruption. The most important mechanism to ensure progress in the implementation of the Convention is the UNCAC Implementation Peer Reviews. UNODC has piloted a regional platform approach to fast-track UNCAC implementation in South 3

4 East Asia and Eastern Africa. Based on thematic areas identified during the review process, regional-level meetings comprising technical experts and policy makers drawn from relevant government departments, civil society, the private sector, and development partners are convened. These meetings identify regional synergies, innovative approaches and opportunities for South to South cooperation and serve as a platform for development partners for providing direct support to countries. The Danish support will target the implementation process in two ways: 1) by supporting the participation of low-income developing countries in the second cycle of the Implementation Review Mechanism and 2) by funding delivery of follow-up technical assistance relating to needs identified in the Implementation Reviews. The Danish funds will serve to finance technical assistance to countries that are not able to mobilise bilateral support for this purpose, and it may further allow for the expansion of the regional platform approach to Central and Southern Africa. The Danish funds will supplement the funding for these purposes coming from the UN core budget. Engagement 2: OECD - Anti-corruption to achieve the SDGs In agreement with UNDP the owner of the SDGs in a development context OECD intends to set up an SDG Hub with the aim of supporting governments to integrate the SDGs in their national planning and to enable the public sector to work in an integrated manner, across entities and institutions, to deliver on the SDGs in short, to tackle the significant governance issues linked to the attainment of the SDGs. The Hub is meant to bring together expertise and mobilise support for the implementation of the SDGs. The OECD will partner with institutions such as the African Peer Review Mechanism, the UNDP, and the Sustainable Development Network to extend the global reach of existing efforts to build governance capacity for the SDGs. While the SDG Hub will cover all of the SDGs, the Danish funding will be earmarked to support activities focused on SDG 16.5 and other corruption-related SDG targets. The exact organisational and budget set-up that will allow funding to target specific SDGs are yet to be developed, and a funding agreement will not only await a concrete project proposal from the OECD, but also certainty that other sources of funding are available, allowing the project to take off at a reasonable scale and scope. Cluster two - Civil society Civil society has a crucial role in monitoring that government, the private sector and community organisations are transparent and respect the rule of national and international law. Civil society can likewise engage actively in global and national multi-stakeholder coalitions to advocate for changes to law and practice where these are failing or inadequate to deal with corruption and monitor policy implementation. Civil society also has an important role to play in terms of exposing the corrupt and highlighting individual corruption cases. Finally, civil society plays a role in prevention and education by helping to build an enlightened citizenry. Engagement 3: UNCAC Coalition - Organising civil society for improved UNCAC implementation 4

5 This network has 350 CSOs as well as a number of individual expert members dedicated to promoting the implementation and monitoring of UNCAC. The Implementation Review Mechanism (IRM) provides several opportunities for civil society: CSOs may inform the review process by sharing their assessments and recommendations with reviewers and through the UNCAC Coalition they can support UNCAC implementation with technical expertise, benchmarking capabilities and inputs from across the globe. The Coalition was up to now hosted by TI in Berlin, Starting from July 2018, the UNCAC Coalition is setting up its Coalition Hub in Vienna. A permanent presence in Vienna, where UNODC hosts the UNCAC Secretariat, will allow the Coalition to better support the research and advocacy needs of its civil society member organizations and to ensure that the voices, concerns and demands of civil society are heard in UNCAC-related fora and other UN bodies. The vision for the Hub is to stay small and agile with a team of 2.5 to three people, who will lead and support international advocacy efforts while providing support to Coalition members to help them use the UNCAC to advance their mission on the national and regional levels. Norway, who has previously supported the Coalition, is presently preparing new support at least from 2018 to The most appropriate funding approach will therefore most probably be a basket fund the Coalition s preferred funding modality with Danish and Norwegian funds, by which the Coalition can fund any of its activities benefitting ODA-eligible countries, including direct headquarter costs linked to such activities. This would also allow Denmark to draw maximum benefit from Norway s prior knowledge of the Coalition. Engagement 4: Transparency International (TI)- Keeping anti-corruption high on the agenda Danida has supported TI - the global anti-corruption movement - since This longstanding partnership with TI is an integral part of the Danish support to the global fight against corruption. TI is a central actor and has over 100 national chapters all over the world. The current TI strategy Together against Corruption provides the strategic framework for Transparency International s collective ambition and actions for the years The strategy aims at contributing to citizens around the world taking increased action to confront corruption while also involving a growing number of key partners and leaders to drive anticorruption progress. The purpose is that public and private institutions actually implement the highest transparency, accountability and integrity standards to prevent and confront corruption. In recent years TI has also increasingly focused on ending impunity by ensuring that the corrupt are held to account and punished. TI also has a focus on ensuring that countries are held accountable for the commitments they make in international forums such as the IACC in Copenhagen. Finally, TI is also strongly focused on being a focal point for knowledge generation and sharing of expertise. Danida has strengthened its strategic collaboration with TI the last few years among others by jointly preparing the IACC that Denmark and TI co-host in the autumn of Denmark will continue to extend core funding to TI in the coming years, and it is agreed that from 2019, these funds will partly serve to finance the monitoring mechanism that TI will set up to follow up on the anti-corruption commitments of the countries and organisations participating in the high-level segment of the IACC The financial support will be managed by TI s secretariat in Berlin. 5

6 Engagement 5: Global Anti-Corruption Consortium (GACC) - Combining investigative journalism and advocacy to expose and fight corruption The GACC was launched in 2016 by five governments and seven partners that bring distinct media, advocacy, tech, and legal expertise. GACC is a partnership that brings together investigative journalism spearheaded by the Organized Crime and Corruption Reporting Project (OCCRP) and advocacy driven by Transparency International (TI). This collaboration allows OCCRP s global network of local journalists and Transparency International s 100+ chapters to share data and knowledge, informing advocacy with actionable data generated through crossborder investigations. In its first year, the GACC has made significant contributions to spotlighting and pushing for policy reforms in response to money-for-influence scandals and exposés of global money laundering. The GACC is currently supported by the Governments of Argentina, Australia, Denmark, Norway, and the United States. With initial 2018 contributions of $10,000 each from Argentina, Australia, Denmark, and Norway, the U.S. State Department funds the vast majority of the effort for a total of $4.8 million through January The continued and increased Danida core funding will go towards accelerating consortium reporting and nationaland local-level advocacy in developing countries. This work will build on new capacity in Africa, Asia, and Latin America in particular and allow GACC to fully pursue identified priority themes, complementing the first-year emphasis on what can be characterized as global investigations and campaigns. Engagement 6: Publish What You Pay (PWYP) - Improving transparency in extractives PWYP works to address the resource curse, a phenomenon by which countries rich in natural resources (such as oil, gas and minerals) tend to have less economic growth, worse development outcomes, higher inequality and weaker institutions than countries with fewer natural resources. PWYP is a global coalition of more than 700 member organisations advocating for transparency, accountability and good governance in the extractive sector. PWYP s advocacy targets both governments and companies; PWYP further supports civil society to demand accountability along the entire extractive value chain, including the allocation of revenues to national and sub-national budgets. This includes supporting the participation of civil society in initiatives such as the Extractive Industries Transparency Initiative (EITI); promoting information disclosure by oil, gas and mining companies; advocating for legislation that promotes the extractive sector s good governance; and building the capacity of citizens to hold governments and companies to account. PWYP has broad outreach in addressing governance weaknesses in the extractive sector. Danida is already partnering with PWYP and will continue core funding to the organisation. Cluster three - the private sector 6

7 Companies on their side are responsible for implementing effective compliance programs in their organizations to prevent, detect and address corruption and for complying with anticorruption legislation. Furthermore, they have, and gradually accept, a broader responsibility for improving the environment for doing business in the countries in which they operate by engaging in collective action and multi-stakeholder forums in line with the SDG agenda. In recent years there is also focus on more strategic dialogues between the public and private sector. Engagement 7: Alliance for Integrity: Improving compliance in the private sector Alliance for Integrity (AfIn) is a German collective-action initiative that was launched in 2015 jointly by BMZ and BDI (the German sister organisation of Dansk Industri, the Association of Danish Industry) with the aim of supporting German companies and companies in some of their major markets to share knowledge and experience in improving compliance. The initiative is implemented by GiZ using a multi-stakeholder approach that also involves relevant publicsector actors. Today, AfIn has approx. 120 companies (German, Latin American, Asian, and African) in its active network and has had more than 1000 companies involved in its compliance training events, in which companies compliance officers are training others. AfIn presently has regional outreach in Latin America and country-level activities in Indonesia, India, and Ghana. At central level, there is a small secretariat in Berlin. The Danish co-financing of AfIn aims at bringing Danish companies into the AfIn network in collaboration with DI and the Danish branch of the UN Global Compact in order for them to benefit from the experience, training materials, and networking opportunities provided by AfIn. Also, the Danish contribution will serve to increase the AfIn outreach in Africa, probably by establishing a regional hub in Nairobi for East Africa. The Danish presence in the AfIn set-up is presently being discussed, with a part-time position hosted by DI as one possible element. Also, there will be Danish representation in the steering committee of AfIn, and it could be envisaged to establish a Danish advisory committee to increase the involvement of Danish stakeholders. The Danish contribution of DKK 24 million over 4 years will supplement BMZ support of Euro 5 million over three years starting mid-2018, expected to be extended into the following years, as well as substantial in-kind contributions by the participating companies (training staff, coaching, ). A model gradually ensuring financial independence of the network is presently being sought. Denmark s involvement is likely to attract interest from additional countries, in line with the ambition to extend the initiative across European countries and their private sectors. The Danish support is likely to be in the form of a delegated partnership with BMZ. Engagement 8: The Maritime Anti-Corruption Network (MACN)- Fighting facilitation payments in the shipping industry This network is an example of an innovative business initiative that has successfully addressed corruption in the maritime sector through private sector collective action as well as in partnership with industry players, governments and civil society. MACN was established in 2011 as an industry-led initiative, working collaboratively towards the vision of a maritime industry free of corruption that enables fair trade to the benefit of society at large. The Danida funding will go towards implementing collective action projects in Nigeria and Senegal, and to conduct regional best practice sharing workshops with stakeholders from neighbouring 7

8 countries over 3 years, starting in This support would allow MACN to deepen its current engagement in Nigeria, use the learnings gained in Nigeria, bring this knowledge to neighbouring countries as well as expanding MACN s work and presence in West and Central Africa. The project will be led and managed by a project manager based at MACN s secretariat in Denmark, which is managed by the non-profit business network BSR (Business for Social Responsibility). BSR s backstopping and support functions will be made available to support on financial management, reporting and technical backstopping. In-kind resources will also be made available via the MACN secretariat and the MACN Steering Committee. The project manager will be working closely with and overseeing the implementing partner in West Africa - the Convention on Business Integrity (CBi). MACN has been working with CBI since 2012 and established a close and successful partnership with the organization. CBi will provide project management resources in Nigeria and across other targeted African countries. MACN will engage with the Embassy of Denmark in Abuja, the Trade Council, the Danish General Consulate in Lagos, and the General Consulate in Dakar during implementation. Engagement 9: Others (U4) - Knowledge generation and sharing on corruption In supporting U4 with continued membership, Danida is supporting generation and dissemination of knowledge of corruption and illicit financial flows. Since 2003 the U4 Anti- Corruption Resource Centre has studied how corruption threatens development outcomes. Together with global research networks and practitioners, it pursues emerging topics and advance the anti-corruption field. It is a unique multi-donor partnership under the Christian Michelsen Institute in Bergen, Norway and is hailed as one of the leading resource centres with regard to the topic of fighting corruption, and provides assistance and services to both members, developing countries and donors. U4 supplements Danish governance programmes in partner countries among others by providing anti-corruption trainings. As a member of U4, Danida has also benefitted from privileged access to the U4 knowledge and resources among others through their helpdesk. Along with the other current U4 partner countries, Australia, Finland, Germany, Norway, Sweden, Switzerland and the UK, Denmark is supporting the continued research on the topic of corruption. The membership allows Danida to draw on the expertise of U4 staff and resources. The membership fee of Euro per year is equivalent to core funding and the work plan and budget are based on the overall organisation strategy of U4. A yearly budget and work plan are presented by management for the approval of the Steering Committee, where Denmark is an active member represented by the Technical Quality Support department (KFU). Management and Communication Each individual engagement will be managed and implemented by the engagement partner. The reporting and accounting requirements will differ according to the support modality (core funding in the cases of TI, GACC, Publish What You Pay; project funding in the cases of UNODC, OECD, MACN; (probably) basket funding in the case of the UNCAC Coalition; delegated partnership in the case of the Alliance for Integrity, and finally membership fee in the case of U4). 8

9 There is no intention to establish any advisory or other regular forum bringing together the partners. However, the budget provides a possibility to organise events, e.g. involving programme partners together with Danish anti-corruption stakeholders and media to facilitate mutual learning, promote the anti-corruption agenda, and maintain the momentum among Danish anti-corruption stakeholders created by the IACC in October KFU participation in reviews as well as annual or bi-annual meetings with partners may be relevant in some cases (UNODC, AfIn, OECD in particular), where possible in coordination with other donors. Otherwise, the engagements will largely be monitored through the progress and financial reports of the partners. Application of human rights-based approach The human-rights based approach is key to effective anti-corruption efforts. Transparency and accountability in the operations of governments and businesses as well as participation of citizens in decision-making at all levels is a goal in itself but it is also an effective anticorruption measure. All of the partners involved in this programme promote and advocate for respecting and upholding these key governance principles as a central part of their work. There is also a strong focus on anti-corruption as a way of upholding human rights including the rights of marginalised group to social services free of corruption and for anti-corruption activists to exercise their political and civil rights to speak out against corruption without risking serious repercussions including jail and murder. Supplementing the programme, the Swedish Raoul Wallenberg Institute for Human Rights is presently finalising a study commissioned by Danida on the relationship between corruption and human rights, which will be presented at the IACC. Sustainability and exit Most of the activities funded through the programme will only continue as long as external funding Danish or other is available. Only the Alliance for Integrity intends to become stakeholder-funded in the longer run. For the rest, the sustainability is in the longer-term impact of the activities funded (the effect of UNODC and OECD technical assistance; the local and global impact of the exposure of corruption cases by the GACC journalists ref. their exposure of the Azerbaijani laundromat; the impact of the MACN anti-bribery projects; etc.). All of the partners will undoubtedly survive the end of Danish funding, with varying impact on their level of activity. In some cases, e.g. OECD, the UNCAC Coalition and the Alliance for Integrity, the Danish presence is expected to attract other donors and will actively be used for that, with Danish assistance. Preliminary budget 9

10 Engagement Period Amount (million DKK) 1. UNODC Remarks 2. OECD Support will only start once cofinanciers have been brought on board by OECD 3. UNCAC Coalition Basket-funding with Norway to be agreed 4. Transparency International Global Anti- Corruption Consortium 6. Publish What You Pay 7. Alliance for Integrity Capacity assessment needed Possibility of delegation to BMZ to be confirmed 8. MACN Capacity assessment 9. U Membership fee already paid up to Communication, reviews, studies Ialt

11 Annex 1: Preliminary results framework Programme Anti-Corruption Programme Programme To enhance the effectiveness of anti-corruption through strengthened Objective cooperation, advocacy, monitoring and research in key organisations and networks at national and international level Impact Indicator Governments and businesses live up to their commitments in relation to UNCAC, SDG 16 and other relevant anti-corruption pledges (IACC, Global Compact, G20, B20) Baseline Year Target Year Engagement Title Outcome Outcome indicator Baseline Year Target Year Engagement Title Outcome Outcome indicator Baseline Year Target Year Engagement Title Outcome Outcome indicator Baseline Year Target Year Engagement Title Outcome Outcome indicator 1. UNODC: Technical assistance for UNCAC implementation UNCAC implementation enhanced in low-income countries that do not have access to bilateral support for this purpose -Increase in the number of developing countries that actively and effectively use the Review Mechanism of UNCAC for assessing their existing anti-corruption frameworks and for planning and prioritizing future steps, including reviewing progress in implementation. -Increase in the number of follow-up activities carried out in response to country review recommendations 2. OECD: Anti-corruption to achieve the SDGs The global hub is an effective clearing house and help-desk for countries and institutions in support of SDG 16.5 implementation -In-country assistance provided through practical advice, institutional matching, peer-to-peer learning, and institutional partnerships that are tailored to needs on the ground. -The Hub facilitates knowledge exchange on technical topics related to anti-corruption and its multidimensional risks and challenges. 3. UNCAC Coalition: Organising civil society for improved UNCAC implementation Enhanced civil-society influence on the implementation of UNCAC Effective global and national-level advocacy using the UNCAC review process as a platform for achieving improved implementation and increased civil society engagement 4. Transparency International: Keeping anti-corruption high on the agenda Continued global agenda-setting capability of TI -TI increasingly engage citizens to confront corruption -TI engage with a growing number of key CSO partners and government and private sector leaders to drive anti-corruption progress -TI exposes the corrupt in order for them to be held accountable and punished -TI monitors whether anti-corruption commitments are actual implemented in practice 11

12 Baseline Target Year Year -TI contributes to an increased body of knowledge on corruption and anticorruption focusing on what has worked and enabling the sharing of expertise Engagement Title Outcome Outcome indicator Baseline Year Target Year Engagement Title Outcome Outcome indicator Baseline Year Target Year Engagement Title Outcome Outcome indicator Baseline Year Target Year Engagement Title Outcome Outcome indicator 5. Global Anti-Corruption Consortium: Combining investigative journalism and advocacy to expose and fight corruption Improved data and knowledge sharing, informing advocacy with actionable data generated through cross-border investigations -Increased exposure of money laundering in the global web of Western financial systems, including continued and expanded advocacy to address the use of tax havens and anonymous shell companies by illicit cross-border networks and the criminal services industry; -Increased exposure of corrupt state capture resulting in legalized corruption and plutocratic exploitation, including coverage of the undermining of democratic institutions in developed and developing countries; -Increased exposure of natural resource exploitation by the grand corrupt for personal benefit and ramifications for developing countries and local communities, with an emphasis on advocacy to address national- and local-level institution strengthening and policy change. 6. Publish What You Pay: Improving transparency in extractives Effective advocacy for information disclosure (by oil, gas and mining companies) -Improved capacity of Civil Society Organisations (CSO) to effectively promote the Extractives Industries Transparency Initiative (EITI). -More strategic engagement with supreme audit institutions to curb corruption in the extractive sector at national level. 7. Alliance for Integrity: Improving integrity in the private sector Improvement of internal corporate compliance and corruption prevention capability in AfIn partner countries and regions and engage SME to contribute to SDGs Strengthened anti-corruption capacity in selected SME including Danish SME -The special concerns of SMEs in relation to corruption is increasingly addressed in international policy discussion (e.g. B20) 8. The Maritime Anti-Corruption Network: Fighting facilitation payments in the shipping industry Improved integrity in Nigeria, Senegal and neighboring countries - Increased integrity awareness and accountability of key stakeholders in the maritime sector in selected countries - Improved cross learnings between the public and private sector, and inter-industry on tackling bribes, facilitation payments and other forms of corruption in ports globally 12

13 Baseline Target Year Year Engagement Title Outcome Outcome indicator Baseline Year Target Year 9. U4: Making anti-corruption knowledge and tools available to donors Knowledge generation and sharing on corruption and illicit financial flows -The partner countries (currently Australia, Finland, Germany, Norway, Sweden, Switzerland, the UK and Denmark) increasingly have a shared approach and more coherent programming of anti-corruption activities. 13

14 Annex 2: Risk Management Matrix Contextual risks Risk Factor Likelihood Impact Risk response Civil society space and freedom of expression continue to shrink in many countries and investigative journalists are jailed and killed while exposing corruption at the highest levels Likely Major Denmark will strongly advocate with like-minded development partners for space for civil society and journalists in all relevant international forums and at national level with governments in partner countries Residual risk Major but discussions with Transparency International and others on how to protect individual activists under threat will be on-going Background to assessment The space for civil society to expose corruption and human rights abuses more generally is rapidly shrinking and repercussions from governments towards civil society and media are becoming more severe. Programmatic risks Risk Factor Likelihood Impact Risk response Engagement 1 and 3: Questions are raised on the UN and UNCAC s ability to credibly and legitimately tackle corruption Engagement 2: The SDG Hub initiative Likely Minor Denmark is actively engaged in on-going discussions on how to reform the UN system and make it more effective Unlikely Major Denmark will support OECD to approach other Residual risk Major. In the short run as UN reforms take time. But an increased implementation of UNCAC commitments by national governments as advocated for under this programme may gradually increase trust in the system Minor. The risk is significantly reduced if just a few partners help Background to assessment The UNCAC Peer review Mechanism continuously show that even when countries domesticate the convention they fail to implement and enforce the legislation and policies in practice. Civil society and citizens increasingly question the gap between commitments and implementation on the ground. There are a number of competing initiatives to 14

15 does not attract sufficient funding to take off Engagement 4: TI does not attract enough core funding to be able to respond in a flexible and need-based manner Engagement 5: GACC will experience a backlash from governments and organised crime as it successfully exposes the corrupt and their networks potential development partners Likely Medium Denmark will approach other potential development partners to advocate for core funding to TI Likely Medium Denmark will strongly advocate with like-minded development partners for space for civil society and journalists in all relevant international forums and at national level with governments in partner countries Denmark will support GACC in coming up with measures for improving the security of activists and data protection launch the initiative and it is able to prove its value to a broader group of funders. Major. The risk is significantly reduced if the new TI strategy (beyond 2020) is based on in-depth consultation with all stakeholders and as such is a document with broad ownership Major. But anticorruption activists and investigative journalists make a difference in exposing the corrupt and changing norms and legislation (as witnessed with the panama papers). Dedicated journalists and activists are still playing a vital role in even the most hostile environments and it would therefore be counterproductive not to extend support. monitor the SDGs and provide technical assistance for implementation. Skal lige slå op hvor meget af deres nuværende midler some er kernebidrag Freedom of Expression and Press freedom are facing new threats in major democracies as well as in repressive states, where authorities are focusing their efforts on social media and other online platforms after subduing the independence of major print and broadcast outlets. In the short run the more successful activists and journalists are in exposing the corrupt and mobilizing citizens against corruption, the more severe the backlash will become. Engagement 6: A lack of expertise and capacity Likely Medium Denmark will encourage the PWYP secretariat to offer trainings Minor. The risk is significantly reduced if the use of new technology The data revolution, which refers to both quantities of data now 15

16 among PWYP members to effectively access, analyse and use the data that has become available through new technology of PWYP members in data usage and data literacy is prioritized by PWYP available and technological innovation, has the potential to tackle corruption more effectively. However many CSOs do not currently have the skills to take full advantage of the data revolution. Engagement 7 It proves impossible to find a model ensuring financial sustainability for the Alliance for Integrity. Unlikely Major Denmark will approach other potential development partners to ensure support for the initiative Minor. The risk is significantly reduced if more European partners are brought on board. The initiative is currently perceived as a very German initiative (anchored by BMZ and beneficiaries are German companies). The initiative will need to be rebranded to extend the initiative across European countries and their private sectors. Engagement 8 Danish companies prove less interested in the Alliance for Integrity than foreseen. Unlikely Major The Danish presence in the AfIn setup is presently being discussed, with a parttime position hosted by DI as one possible element. Also, there will be Danish representation in the steering committee of AfIn (probably one company and DI), and Minor. The risk is significantly reduced if DI is involved. The initiative is currently perceived as a very German initiative (anchored by BMZ and beneficiaries are German companies). 16

17 Engagement 8: (MACN) Loss of stakeholder buy-in due to change in leadership in key stakeholders in selected countries it could be envisaged to establish a Danish advisory committee to increase the involvement of Danish stakeholders Likely Medium MACN recognizes that not only top-level support from stakeholders is needed. It is important to target multiple levels such as port officials and immigration officers. Medium. The risk is somewhat reduced if MACN, based on previous experience, will conduct a stakeholder mapping to find motivating factors and map power relations at multiple levels Leadership changes can happen quickly in government authorities. This has been a material risk in previous projects implemented by MACN. Elections in Nigeria are planned in 2019 Institutional risks Risk Factor Likelihood Impact Risk response High level investigations by civil society/investigative journalist may expose corruption cases that involve Danish authorities or companies High level investigations by civil society/investigative journalist may expose corruption in Danish partner countries in the Global South Minor Minor Potential cases will be referred to the appropriate authorities and MFA will not comment on concrete cases unless there is a final verdict Likely Minor MFA will respond with zero tolerance to all cases involving Danish development assistance and will discuss Residual risk Minor. The reputational risk for the MFA is significantly reduced Major. The reputational risk is significantly reduced if MFA takes swift action, acts transparently and follows the Background to assessment In recent years there have been a number of cases involving Danish companiesmost notably the money laundering case involving Danske Bank. In many of the partners countries, corruption is endemic and often involve high ranking government officials or politicians that Denmark may 17

18 major corruption cases in policy dialogue forums with the government established channels. have formed a long-term partnership with. 18

19 Annex 3: Process Action Plan 10 October 2018 Concept Note discussed in Programme Committee November 2018 December 2018 February 2019 March 2019 Drafting of programme document and engagement documents Appraisal Submission to UPR Signing of engagement documents with partners and first disbursement 19

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