IMPLEMENTATION OF OF ANTI- ANTI- CORRUPTION PLANS PLANS IN IN FEDERATION OF OF BOSNIA BOSNIA AND AND HERZEGOVINA. Evaluation Report. Sarajevo, 2014.

Transcription

1 IMPLEMENTATION OF OF ANTI- ANTI- CORRUPTION PLANS PLANS IN IN FEDERATION OF OF BOSNIA BOSNIA AND AND HERZEGOVINA Evaluation Report Sarajevo, 2014.

2 This report has been made within the project Support to the Federation of Bosnia and Herzegovina (FBiH) government in anti-corruption efforts through creation and implementation of operative anti-corruption plans and education programs The project has been financed by the Government of the United Kingdom. The project has been implemented by the Criminal Policy Research Centre (CPRC) from Sarajevo. The project implementing partner have included Monitoring and Coordination Board for Implementing the Federation BiH Government General anti-corruption plan and Federation BiH Civil Service Agency. The project has been supported by the Federation BiH Government Prime Minister s Office, as well as by the Federation BiH Government. Making of this report has been supported by the Government of the United Kingdom. The content of the report has been a sole responsibility of CPRC and authors views do not necessarily reflect the views of the Government of the United Kingdom. CRIMINAL POLICY RESEARCH CENTRE Čekaluša Sarajevo, Bosnia-Herzegovina www. cprc.ba

3 Contents Executive Summary...5 Introduction...9 Description of Evaluated Programs...12 Evaluation Framework...16 Evaluation Approach and Methods Evaluation Results Relevance Effectiveness Sustainability Efficiency Concluding Remarks Recommendations Lessons Learned Bibliography... 45

4

5 Executive Summary Bosnia-Herzegovina has been a country with large economical, political, security and other issues. To a certain extent, corruption has been a common denominator of all issues, as it has been widespread in all areas and segments of society. The country has not succeeded to make a significant progress in overcoming corruption, this fact has been acknowledged in many publications and research. Although, a new state level Anti-Corruption Strategy and accompanying Action Plan was adopted in 2009, its implementation stage has not been satisfactory, whereby many public institutions were not aware of these policy documents. This unsatisfactory situation triggered the Federation BiH entity Government to move things ahead at the end of Following several month efforts, the (Federation BiH) General Anti- Corruption Plan was made, a document which was supposed to articulate clearly goals and activities to curb corruption. The Plan considered Federation BiH obligations which stem from the state level Anti-Corruption strategy and action plan, but it intended to identify issues specific to this level of government and offer potential remedies. Plan s template followed the format of other similar documents developed in the region and world, and served as a basis to specify anti-corruption activities through the anti-corruption operational plans further. Each public sector institution at the Federation BiH level has been required to develop its operational plan. The purpose of this evaluation is to assess a level of accomplishment of anti-corruption tasks by the six Federation BiH institutions (namely the Federal Ministry of Interior, Federal Police Administration, Federal Inspection Agency, Federal Ministry of Finance, Federal Ministry of Justice, Federal Ministry for Issues of Veterans and Disabled Veterans of the Defensive-Liberation War) in the course of the first year of plan s implementation. The applied criteria included relevance, efficiency, sustainability, and effectiveness of the anti- corruption plans. Furthermore, an interim assessment and a program evaluation used here included drafting recommendations during a process of evaluating activities followed by their dissemination to responsible officers entrusted with anti-corruption activities ( activity owners ); the evaluation could be regarded also as a lerning tool. Therefore evaluation has intended to facilitate anti-corruption capacities and advance anti-corruption policy, but also to point out to factors which affected positively outcomes and issues faced in the course of implementation. These information should serve as a basis for developing following anti-corruption programs and campaigns. The evaluation report has also been intended to the attention of interested donors, in order to avoid overlapping activities in principle and financial and other support. In addition, the information concerning hardships encountered in enforcing anti-corruption activities and factors facilitating their completion seem to be very valuable. Therefore, the report can be of use to all public institutions in BiH, and particularly to decision makers when considering the new anticorruption initiatives as well as of use to bodies entrusted with monitoring and coordinating the anticorruption operations. In general terms, the evaluation results are satisfactory and optimistic. Systematic and realistic approach, as guiding principles in developing and implementing anti-corruption plans within aforesaid institutions, seemed to be critical for such findings. These plans were adopted in the template of action and operational plans for combating corruption, and focused on corrupt systems, 5

6 not on individuals. Large number of stakeholders were involved in drafting procedure, mainly future activity owners who had an opportunity to comment draft plans. The final anti-corruption plan have been developed as balanced document, compromising between wishes and realistic capacities, obvious and less obvious needs for reform. The assessment of anti-corruption tasks completion, as a crucial part of evaluation, demonstrates that approximately three quarters of a total of 135 planned activities were fully or in principle realized. This number represents a total sum of all activities fully implemented along with activities implemented partially with major crucial tasks undertaken (this refers to tasks which constitute core part of intervention described by activity). It is noteworthy that activities implemented fully or by major part focused on actual capacity building efforts of public sector in prevention of corruption (e.g. capacity building to fight against corruption, establishing communication channels with beneficiaries of services, raising awareness on forms and causes corruption), rather than on activities focused on legislation drafting (e.g. updating and amending the book of rules on internal controls and audits). In this process, there were both types of factors present including those that favoured implementation of activities and those which aggravated its implementation. The first group of factors which facilitated implementation of anti-corruption activities refer to a level of entity Federation BiH institutions, where relevant activities were undertaken. Importantly, the realistic objectives and activities were set, as this process consulted anti-corruption activities owners by providing an opportunity for activity proposals. For the first time in Federation BiH anti-corruption internal focal points in form of coordinators of anti-corruption activities has been established, which contributed positively to the process. A due attention has been paid to dispersion of responsibilities and tasks, resulting with properly distributed workload, not on individuals, but to an organisation. The second group of aforesaid factors pertained to a level of Federation BiH entity, where a pretty determined political initiative and due attention was made by adopting a range of anti-corruption regulations, and establishing the Monitoring and Coordination Board for Implementing the Federation BiH Government General anti-corruption plan. This board made an additional positive pressure by directing, coordinating, and overseeing the implementation of anti-corruption efforts. International community support and pressure also played an important role in prioritising fight against corruption over some other processes. With respect to unimplemented pending activities, possible reasons could be long lasting and large scale processes which cannot be finalised in the course of medium term anti-corruption plans, alternatively their completion is conditioned by cooperation with other bodies (frequently structured under other levels of government, characterised by many bureaucracy procedures) which hinders process completion. A lack of interest in diminishing opportunities for corruption, then integrity strengthening, busy schedule of public sector employees, and belief that combating corruption is pointless represent other optional reasons for unimplemented activities. In summary, involvement of anti-corruption tasks implementers in the early phase of tasks development, and responsibility dispersion to several stakeholders with clearly defined focal points as activities coordinators, represent main advantages of evaluated anti-corruption plans and general approach promoted by them. In the early phase of suppressing corruption, positioning an appropriate focus to implementable activities is an important factor leading to successful outcome, as oppose to important activities perceived as such by theory and general public, whose implementation, however, requires a lot of time, resources, good will and often leading to frustrations and counter effects. It is noteworthy to state again, systematic and realistic approach have been fundamental principles, 6

7 resulting with successful implementation of evaluated anti-corruption plans. The main shortcomings are related to deficient efforts in attaining support of public, as generally public campaign and other promotional activities would contribute to a more transparent reporting on existing anti-corruption activities and their implementation progress. Furthermore, implementation of anti-corruption plans frequently implies cooperation with other institutions, which necessarily don t have to share enthusiasm required or their awareness of this issue has not been developed enough. Based on completed evaluation, the following recommendations can be made: Assert a larger importance to anti-corruption coordinators work and role. In order to maximise accomplishments of focal points, namely anti-corruption coordinators, it would be advisable to strengthen and promote their roles additionally in further activities; Continue implementing moderately advanced objectives, and consider including slightly complex tasks into the anti-corruption measures catalogue. As whole Bosnia-Herzegovina presently is in the early stage of fighting corruption, it is reasonable to continue with activities that send positive examples in such struggle, but also consider proceeding with more complex measures such as integrity test implementation, drafting citizen charter, rotation of public officers from posts prone to corruption; Raise further awareness on forms, causes and measures to combat corruption. Despite of significant current efforts made in promoting public awareness on meaning of acts of corruption through meetings, promotional materials, code of ethics obligations, further efforts in this regard are required; Create incentives for anti-corruption activities. Anti-corruption operations should be made attractive to all anti-corruption activities owners, and all other public sector employees, who should be motivated to earn immaterial incentives (e.g. individual recognition of professional references). The same would apply at organisational level: providing recognition to organisations which perform the tasks falling under competency extremely professionally, while penalising those organisations involved in corruptive behaviour; Undertake activities in order to obtain public support. Public campaign represents the most evident method of attaining public support. It may be developed as planned and systematic activity of promoting anti-corruption standards and values, but if this approach seems to be too demanding, this may involve sporadic informational activities on standards applied by institutions (e.g. deadlines established by law and by-laws for decision making by institutions; civil servants rights and obligations in conducting citizens proceedings etc.), available mechanism for reporting on acts of corruption. This information could be distributed through press releases, in public appearances, web pages releases, etc.; Increase level of transparency in anti-corruption activities. As set out in the previous recommendation, the same tools can be used to increase visibility of anti-corruption activities; they would significantly strengthen institution credibility and attain public support; Devote larger attention to certain segments of anti-corruption fight, whereas higher expectations are raised due nature of corruption. Larger attention should be devoted to this particular segment as well as others of public service performance, demonstrating authentic efforts for reform course and leveraging public support. The opportunity, involving more agile actions in certain promising activities which could attain public support, such as objectivising criteria for employment and promotion in civil service was not utilised. 7

8

9 Introduction Although corruption has been a phenomenon widespread throughout the world, it seems to be a problem that particularly impeded BiH social reality over the last decades. After stormy and dreadful events occurring in the early nineties of the 20 th century, corruption gradually but surely became one of crucial issues in BiH war torn society in the course of its recovery. Recently, there have been many researches, which differ concerning objectives and methodology, but are agreeable that BiH attains modest progress in curbing corrupt practices. For example one of such prominent research papers, namely the World Bank Governance Indicators, consider a large number of data from documents produced by various subjects, aggregate them into six dimension of governance, of which one dimension pertain to control of corruption. The research states that BiH has been stagnating with respect to this dimension. It has been ranked bellow the 50 th percentile, which is bellow than European average and average of neighbouring Republic of Croatia, and significantly bellow in comparison with Western Europe developed countries and the US. Another research carried out by the United Nations Office on Drugs and Crime has identified corruption as a large that and great impediment to development of private sector and overall investment into private sector (United Nations Office on Drugs and Crime, 2011; United Nations Office on Drugs and Crime, 2013). For the last several years, in particular period, EC progress report on BiH (attachments enclosed to Communication of Commission to the EU Parliament and Council), stated that corruption has been clearly identified as a large problem in moving towards EU integrations, and that BiH has been in early phase of its fight. Given the present state, the FBiH Government decided to enact its strategic framework for the fight against corruption in a form of the anti-corruption plan, which created basis for systemic and comprehensives actions to be taken in this entity. Pursuant to the decision no. 725/12 of May 8, 2012 of Federation BiH Government, General anti-corruption plan was enacted as one of appropriate anti-corruption measures. It is noteworthy to say that the Plan addressed a subject matter by use of two fold approach, by considering obligations stemming from the state level Anti-Corruption Plan ( ), and by addressing specific issues relevant to the working environment of Federation BiH institutions. The plan was created by using a concept promoted by United Nations; it referred to a period and was consisted of five components: legal framework improvement, capacity building of public sector to prevent corruption, promotion of civil society role, efficient law enforcement, and monitoring mechanisms ensuring plan s efficient enforcement. The UK Embassy in BiH through the Foreign and Commonwealth Office supported the project entitled Support to the Federation of Bosnia and Herzegovina (FBiH) government in anti-corruption efforts through creation and implementation of operative anti-corruption plans and education programs, which intended to provide assistance in developing and implementing plans addressing counter corruption efforts at the level of six individual public institutions. The Criminal Policy Research Centre (CPRC), a non-governmental organisation, has been entrusted with the project implementation. The previously referred plans can be considered a part of overall anti-corruption program (campaign/ intervention) launched by General Anti- Corruption Plan of the Federation BiH Government. 9

10 A detail from promotion of General anti-corruption plan of the Federal government (Sarajevo, ): Federation BiH Prime Minister, Mr. Nermin Nikšić and UK Ambassador in BiH (at the time), H. E. Nigel Casey The public institutions assisted through the project included: the Federal Ministry of Interior, Federal Police Administration, Federal Inspection Agency, Federal Ministry of Finance, Federal Ministry of Justice, Federal Ministry for Issues of Veterans and Disabled Veterans of the Defensive-Liberation War. 1 Due to a fact that project implied cooperation with public institutions, it required provision of formal concurrence from the highest level of executive branch. Although the project start was planned for April 2012, its launch was delayed by the end of 2012, as this formal concurrence was obtained in late October. The evaluation of project results, accomplished in the course of implementation of anticorruption measures described in anti-corruption plans, was one of project activities. The purpose of this evaluation was to assess a level of completion of anti-corruption tasks by the six Federation BiH institutions in the first implementation year of anti-corruption plans, by addressing issues of relevance, efficiency, sustainability and effectiveness. In fact, the evaluation has been undertaken throughout whole project duration, aiming to suggest policy changes that would result with more successful anti-corruption efforts. 2 As one year passed since launching the anti-corruption plans (and at the same time, as of starting date of this evaluation), that was assessed as sufficient period for conceiving and firming up awareness to comply with the plans and to register institutional work performance changes. Therefore, evaluation was scheduled to begin at the end of the 1 st quarter of The interim assessment and a program evaluation applied here implied development of recommendations in the course of evaluated activities and their distribution to anti-corruption activities owners, and also could be regarded as a learning tool. Therefore, the evaluation has aimed to facilitate advancement of anti-corruption policy and strengthen anti-corruption capacities. Also, the evaluation aimed to point out factors that 1 It is noteworthy to state that complex and demanding project scope required an engagment of team, and that an eventual expansion of activities to other institutions would furhter complicate the matter and likely affect a focus dispersion and level of assistance. Therefore it was decided to target the aforesaid institutions by the project, selected for several reasons: crucial segments of public policies are within their respective jurisdictions, large number of employees and large number of beneficiaries/users of their services. Considering a nature of phenomenon addressed by the project, it was assessed that assistance and cooperation to these institutions can serve as a good example what can be accomplished in implementing planned activities on prevention and repression of corruption. 2 It was so called interim assessment and program evaluation. See the following report chapter. 10

11 impacted outcomes of implementation, as well as to point out on problems arising in the course of implementation process. This feedback could assist in developing future anti-corruption programs and campaigns. Since donors are very much interested in supporting anti-corruption efforts, the purpose of report is to inform interested parties on outcomes of this particular program, and thus to avoid overlapping with other similar activities and support offered by donors and others. In addition, the program encountered various obstacles in its implementation. Familiarising with such obstacles encountered while providing assistance in counter corruption efforts would facilitate other similar future activities or even suggest remedies for avoidance. In addition to drawing attention to issues, the report also mentions factors which facilitated the implementation of anti-corruption activities successfully. The report section on lessons learned particularly serves that purpose. For the same reasons, the report can be of use to all public bodies (authorities) in BiH. In particular, the report can be of assistance to decision makers in their considerations of new anti-corruption initiatives, more exactly to bodies in charge of monitoring and coordinating anti-corruption activities. The report aims to present the most relevant moments registered while evaluating operations of the six institutions, which were initiated by the General anti-corruption plan of the Federal government. The report has been structured in several chapters standardised for similiar activities and is largely based on recommendations for report development promoted by the United Nations Development Programme (UNDP 2009), and by considering good practices for evaluating the anticorruption programs and anti-corruption activities in general. 3 At first, an overview containing basic information on anti-corruption programs formalised under anti-corruption plans within six aforesaid institutions as well as context of their implementation will be presented. Afterwards, goals and methods of evaluation along with the main results perceived through the four dimensions: relevance, efficiency, sustainability and effectiveness will be laid out. The concluding section of report will present main findings, recommendations for further activities, and lessons learned. 3 More details in Johnsøn, J., Hechler, H., De Sousa, L.& Mathisen, H. (2011). 11

12 Description of Evaluated Programs The report deals with review and assessment of anti-corruption tasks completion laid out in anticorruption plans for the six aforesaid institutions. Program evaluation and activity monitoring have been applied in this process. 4 This means that collected data demonstrating implementation status of anticorruption activities were also used as a basis for creating recommendations. They were structured in a way to be relevant and feasible, following the best practice from relevant fields. In this way, monitoring and evaluation process were intended to be used as instruments for knowledge transfer, and not only as tools for collecting data and assessing a status of completion of anti-corruption tasks. The evaluated institutions have approached a fight against corruption in systematic way, by articulating their objectives and activities in the strategic documents, such as anti-corruption plans. Experts of United Nations Office for Crime and Drug stipulate that important advantages of this planned and programmed approach in curbing corruption assist in planning future activities and evaluating current or past experience. This approach also includes defining activities, subject of implementation, time period of implementation and responsible implementer. Further, it provides that by establishing clear goals and deadlines expectations of those involved in objectives realisation are met, that by developing and discussing plans their quality gets raised, in particularly by providing a realistic estimate on content, etc. The ultimate beneficiaries of these actions are citizens, users of public services, who would benefit by better public sector with more integrity if level of corruption gets reduced. The Anti-Corruption plans were consisted of several components: improvement of legal framework, strengthening public sector capacity to prevent corruption, promotion of civil society role and efficient law enforcement. Each of these components was consisted of several activities, and activities were further broken down to tasks. Due to a fact that indicators were developed at the level of outputs, 5 and that each output had one or several indicators, it was fairly easy to enforce the evaluation. By collecting data showing accomplishment of each task, it was possible to conclude whether activity, and tasks within its framework, was completely accomplished, partially accomplished or were not accomplished at all. As components were measured at the level of outcomes, whereas such level implied slightly different methodology, this evaluation has primarily targeted the outputs. The map of results has been enclosed bellow. Since the General Anti-Corruption Plan of Government of Federation BiH, which served as basis for developing and acting upon on anti-corruption(operational) plans, contained more activities than those presented at map, it should be note that only results set out under at least one evaluated operational plan were showed there. 4 Monitoring and evaluation (assessment) of planned activities are closely related, as integral part of strategic planning. The plans offer clear projection of anticipated progress (based on SMART methodology) representing a framework fo implementing monitoring and evaluation. The monitoring itself has been substantial for tracking progress, but insufficient for review of ultimate success, and for this reason evaluation mechanisam has been applied. Furthermore, data are frequently offered in the course of evaluation process that were unavailable in course of monitoring. 5 Results can take place at three levels: outputs, outcomes and impacts. See more in Johnsøn et al.,

13 Results map for the implementation of the anti-corruption plans Improved legal framework Analysis of the act on free access to information conducted and training delivered Criteria and guidelines for planning of budget created Improved legislative framework for confiscation of proceeds of corruption Oversight of operational funds expenditures regulated Anti-corruption procedures adopted/harmonised Operational funds expenditures regulations analysed and amended Book of rules on internal systematization of posts analyses and amended Procedures in law enfocement agencies to prevent abuses analysed and amended Mechanisms for integrity assessment, professionalism nad ethics established Regulations governing employment, performance and promotion in public sector analysed and amended Higher compliance to proceed to reports which do not have imperitive characted (audit office, etc) Amendments to regulations ensuring more effective prosecution of corruption offences initiated Reduced loopholes in legislation that causes or may cause detriment to public interest DECREASED LEVEL OF ACTUAL AND PERCEIVED CORRUPTION Strenghtened public sector capacities in corruption prevention Larger civil society role in corruption prevention Intensified actitivies in prosecution of corruption offences Capacities for anti-corruption plans implementation developed Internal audit and control resources functional Public relations improved Analysis conducted and recommendations for more succesful prosecution of corruption made Central harmonisation unit functional Modernisation of public sector continued Continuos public campaign on causes, forms and consequences of corruption organised Proper funding and equipment to judicial and police authorities ensured Inspections` operations strenghtened Anti-corruption training designed and implemented Special training on investigation of corruption and confiscation of proceeds of corruption System for tackling corruption risks introduced Improved practice on allocation of funds per projects Cooperation of relevant authorities for more effective detection and prosecution of corruption improved Oversight under operational expenditures per projects intensified Special communication mechanisms to provide anonymous assessment of the quality of service established Anti-corruption related educational/promotional materials developed Recommendations concerning public procurement issued by competent authorities consulted and implemented More consistent adherance to regulations and increased work discpline ensured Employees trained on implemenation of laws and by-laws, standards of performance, etc. Situations leading to conflict of interest reduced 13

14 As envisaged by project design, the anti-corruption program implementation, as rather complex one, implied cooperation with the public sector institutions. These counterparts were: Monitoring and Coordination Board for Implementing the Federation BiH Government General anti-corruption plan, in charge of overseeing plan s enforcement and coordinating the overall counter corruption efforts, Federation BiH Government and other relevant institutions, where appropriate. Close cooperation was accomplished in particular with Monitoring and Coordination Board for Implementing the Federation BiH Government General anti-corruption plan, as the most relevant authority to initiate and coordinate anti-corruption efforts. Also, there was a project cooperation accomplished with the Criminal Policy Research Centre (CPRC), by providing its technical and consultant s assistance in designing anti-corruption plans through aforesaid project. This has demonstrated a good example of cooperation between governmental and non-governmental sector in pursuing anti-corruption efforts, as stipulated by art. 13 of the UN Convention against Corruption inter alia. However, time period in the course of which anti-corruption activities occurred, was not unfortunately favourable to their implementers. Existing political stability, public order, absence of (macro)economic crisis, linkages between political gains and accomplishments related to anticorruption activities, strong civil society and foundations of rule of law represent assumptions for achieving sustainable results in curbing corruption (Meagher; 2005; UN Office on Drugs and Crime, 2003). Although foundations for each listed assumption were in place, they were not stable. For example, Federation BiH and overall country are faced with a decreased scope of foreign investments, negative balance of trade, huge recession, a large unemployment rate of working population (close to 30%). Furthermore, a term of current Government was characterised by an intensive and deep political turmoil, which resulted by voting no confidence to the government by the Parliament in early of February In a situation when the Government was voted no confidence, as an executive power body which spurred anti-corruption initiatives by its decisions, it would be hard to expect a full support in implementing the General Anti-Corruption Plan measures. Enumerated facts have to be considered in a process of assessing accomplishment of anti-corruption tasks in their implementation. Scarce human resources have been significant impediment in conducting anti-corruption tasks set out in the anti-corruption operational plan, subject to this evaluation and monitoring. In general, a large number of public servants and employees ought to be involved in plan implementation, as a successful counter corruption fight require a comprehensive and systemic efforts, in line with developed anti-corruption plans. Nevertheless, no employee was assigned a task of implementing anti-corruption tasks solely, rather they implemented those tasks as one of their regular official duties. This has been at the same time an advantage and disadvantage of approach applied, as many activities stemming from anti-corruption plans were implemented within their regular official duties, but not to full extent and as certain enthusiasm and attachment to anti-corruption values was required. The absence of specifically tailored anti-corruption public campaign was the following impediment. The experience has demonstrated that common factor of all anti-corruption efforts seem to be a public support (Pope, 2011). Although Government officials attempted to draw attention to more determined fight against corruption in their official addressing, whereas implementation of measures set out in its General Plan was not isolated (initiative for amending legal framework were launched and range of other associated activities), this could not substitute visible and properly tailored PR campaign. 14

15 It would be particularly focused on goals and measures set out in the General Plan and would inform public on undertaken activities to a larger extent. This resulted with inappropriate level of awareness on existing General Anti-Corruption Plan of Federation BiH government and intended objectives. The absence of this positive pressure in a form of comprehensive, specific and continuous anti-corruption campaign resulted with a lower commitment to anti-corruption tasks to a certain degree. Lastly, modern public sector has been characterised by existence of organisational values and personal individual values at the organisation. Absence or shortage of public sector organisational values imply to formalism and procedures, avoidance and transfer of responsibility, responsibility expansion, authority augmentation and negative selection (Brčić& Vuković, 2008). All these have been moments largely present in public sector of Federation BiH, which leads to unrecognisable and unclear organisational values, whereas each initiative for reform or other method of work is considered as an attack to standardised order. Anti-corruption tasks, initiated by the anti-corruption plans certainly insist on resourcefulness, quality, increased commitment and code of ethics, and are further based on organisational values. In this regard, it is very likely that aforesaid reasons lead to a lack of support in promoting anti-corruption initiative by activity owners and by those decision makers who could impact its implementation. 15

16 Evaluation Framework A whole idea of project implementation was demonstrated earlier through description of evaluated projects in systematic, precise and detailed manner; and their results correspond with early beginning of organised anti-corruption activities at the Federation BiH level. Standardised evaluation framework should respond to several crucial issues, including understanding of program itself and its context (UNDP, 2009). It is evident that purpose of evaluated program was to establish fundamental anti-corruption frameworks within six selected administrative authorities (institutions) at the Federation BiH level. While the frameworks imply initial and systematic activities of administrative bodies in this area, their context has been certainly wider and encompass compliance with political, strategic and operational efforts of BiH state to control the problem of corruption. The evaluation framework usually implies consideration of timeframe targeted by evaluation, space targeted by evaluation, target groups, evaluation objectives, evaluation questions and criteria. Considering timeframe of evaluation conduct and its relation to schedule of implemented program, the evaluation could be regarded as both ad hoc and post festum evaluation addressing implementation of anti-corruption plans at the level of individual institutions which were included under the program. The entity of Federation BiH was in geographical terms covered by evaluation, while public officers tasked with implementation of anti-corruption activities from aforesaid institutions were a target group of evaluation. A scope and nature of anti-corruption activities coordinators role in a process of diagnosing corruption, as a problem, has already been mentioned, and in this regard adopted General Anti- Corruption Plan has been an appropriate response. From a wider perspective, these subjects are equally important with respect to evaluating program evaluation as a whole or its portion soundly, as applicable here. It is vital to ensure and promote participation of crucial stakeholders in the evaluation process, not just for sake of evaluation, but for upgrading evaluation quality by ensuring validation, data verification and evaluation findings (Johnsøn et al., 2011). In accordance with generally accepted methodological approach, their involvement in all evaluation phases including: evaluation guidance, development of questions, verification of valid evidence sources, revision of findings and assistance in their interpretation, increase reliability, potential benefit and sustainability of evaluation results/outcomes (UNDP, 2009). Among the three groups of identified stakeholders of respective programs(those involved in project implementation, those served/or referred by program, and those who are primary evaluation beneficiaries), it is noteworthy that a focus has been on the subjects who participated in program implementation (points of contact within 6 Federal Ministries and other administrative authorities). Further, the role of primary beneficiaries, in particular program donors has been more passive and informative and was associated with monitoring a project schedule. It is relevant to note that points of contact participated in few phases including an implementation phase (since they have been actively involved in program implementation from the very beginning), and took part in the later phase of periodical evaluations (including this particular evaluation). In this way, one of relevant methodological recommendations in conducting evaluations was carried out: it suggested that crucial stakeholders should be involved in the early phase of this process in order to be able to participate in developing evaluation framework, for example by identifying areas to be addressed by evaluation questions and their responses (OECD, 2010). 16

17 The objectives of evaluation are stipulated in one or several sentences describing the activities which should be subjected to evaluation to accomplish the purpose. These goals are founded on diligent consideration of types of decisions to be made by evaluators; questions to be considered by evaluators in decision making; and what accomplishments would be made by evaluations, as benefits to those decisions. Most importantly, goals of evaluation directly arise from purpose of evaluation and they intend to streamline the evaluation towards decisions to be made (UNDP, 2009). The goal of subject evaluation is to assess implementation status of anti-corruption plans in six Federation BiH institutions and plans appropriateness in fulfilling their purpose. In this regard, due attention will be paid to factors that impacted achieved outcomes, and assessment of their sustainability and efficiency. Evaluation criteria and evaluation questions are core, central part of methodological rules for successful evaluation conduct. It is frequently said that they represent main basis of any evaluation (Johnsøn et al., 2011). Their role is to provide assistance in guiding evaluation goals, by setting standards to be used in assessing the program or project. The most sources refer to them as criteria of relevance, effectiveness, sustainability and efficiency, which were elaborated in detail by he UN principles (UNDP, 2009), as in the text bellow: 1. Criteria: Relevance Scope of activity positioned within priorities and policies, target group, assistance recipients and funder. Furthermore, relevance refers to examining a degree of compliance between perception of what is required from perspective of plan and reality of what seems to be required from the perspective of assistance beneficiary. Within this criteria, a sub criteria of appropriateness, which refers to cultural acceptance, and feasibility of activities or method of delivery of a development iniative. The questions relevant to this criteria include: 1) Was it possible to accomplish a purpose of assessed programs by use of applied form and content? 2) How much are program goals relevant today? 2. Criteria: Effectiveness It represents a measure of scope of activity s contribution to the program goals. The questions relevant to the criteria include: 1) How much were results (aims) accomplished or are expected to be accomplished? 2) What have been crucial factors that lead towards results accomplishment or failure? 3. Criteria: Sustainability Sustainability includes measuring the activity benefits after funder s withdrawal. In a wider context, sustainability implies assessing the scope of relevant social, economical, political, institutional and other circumstances. Based on this assessment, projections/prognosis of national capacities to sustain and administer developed results in future are made. The questions related to this criteria include: 1) Will program benefit continue to exist and to which extent after the program completion? 2) What were crucial factors that affected project/programme sustainability s existence or failure? 17

18 4. Criteria: Efficiency Effectiveness measures accomplished results- quantitative and qualitative ones- with respect to resources. It is a pure economic term which implies that the intervention used the most effective resources to accomplish anticipated results. In general, effectiveness requires comparison between alternative approaches in attaining identical results, in order to establish whether the most effective approach was applied. Questions related to the criteria include: 1) Were the activities efficient? 2) Were the results accomplished in time, more exactly how much time was spent for their accomplishment? 3) Was the program or project implemented more efficiently with respect to other alternative methods? 18

19 Evaluation Approach and Methods Speaking of approach used in evaluating this specific program, it should be noted that standards procedures assuring that evaluation results are objective, accurate, reliable and usable were applied in methodological sense. The methodological framework of subject evaluation, address several crucial issues, including method of data collection (including data sources) as well as procedures and instruments for data collection. Purpose and goals of evaluation, accompanied by nature of programme or project and availability of data and information sources all together determine the selection and use of specific evaluation method. The general rules imply that evaluation methods should be selected in such a fashion to fulfil strict and empirically based requests, and thus to respond to an evaluation criteria and evaluation questions (UNDP, 2009). Defining these questions, in a process of identifying appropriate methods to be used in specific evaluation procedure from a range of available evaluation methods, represents very relevant segment. Secondly, identifying appropriate evaluation focus or its streamlining whereas some of well-known recognised methods are used is relevant as well. In their research of studies addressing evaluation, McGee and Gaventa (2010, cited by Johnsøn et al., 2011) identified four types of analytical methods, most frequently used in evaluation procedures: Surveys/primary research: they are used for various purposes, and stakeholders frequently prefer raw data received from primary research. This type of methodological procedures can be either quantitative (whereas complex statistical analysis are used, such as multi-variety multiple regression and other) or qualitative ones; Experimental approach: it encompass randomly selected experiments, which contain fundamental scientific principles of cognisance acquisition. This approach has been frequently used in medicine and lately in economy. However, experiment taking has not been a practice in humanities due to ethical reasons, but it is considered that cognisance acquired by an experiment or quasi experimental paradigm have a larger weight than other cognisance; Qualitative case studies: case study analysis can be used frequently in corruption research. In fact, evaluations which don t apply special methodology are usually referred as case studies. The case studies are combined well with other methods as a method of contextualising findings and they offer possible explanations based on causal linkages; Interviews. This is well known and widely represented qualitative method, which is frequently combined with other methods (including both quantitative and qualitative ones) in systemic efforts to obtain combined research methodology. Interviews can be structured, semi-structured or free ones. There are focus group interviews as well (if more persons were interviewed on some specific subject). This particular evaluation has been largely based on this method, since program concept has included continuous field evaluation with implementers involvement in this process. 19

20 There is a general rule to attempt applying a principle of triangulation, as recommended research approach, regardless of nature, advantages and deficiencies of certain methods and their possible use in evaluation procedures. Specifically, relying to only one source of data or analytical technique in complex area such as reducing corruption decreases trust in evaluation results (Johnsøn et al., 2011). The subject evaluation with respect to selected methodological approach and nature of data and information collection has been largely based on use of semi structured individual and group interviews with the anti-corruption activity coordinators within the six institutions, subjected to evaluation. Document analysis, involving analysis of periodic field evaluation reports, previously performed by researches in these institutions was the additional method. The assumption of such approach involves that researchers perform a field work continuously in respective institutions. In this process, official and publicly available documents on performance of evaluated institutions and status reports concerning implementation of anti-corruption plans, previously submitted to the Monitoring and Coordination Board for Implementing the Federation BiH Government General anticorruption plan were used as the additional source of data. In principle, field reports were prepared on the basis of regular visits paid to institutions where program was implemented. In this process, all, clarifications and verification of information and data, collected by field evaluators, were re-affirmed e by conducting interviews and own perception. Relatively simple matrix has been used for field data and information collection for developing a final evaluation report. Evaluators periodic summary reports were used for determining evaluation indicators, which were mainly further based on indicators set out in operational plans of the six Federation BiH institutions, participating in program implementation. In this process, understanding of relevant content of tasks and activities implemented was crucial in order to establish whether and to which extent they corresponded to goals, set in the operational plans. In this process, discrepancies with respect to anticipated activities were identified, so that they could be later rectified in the course of implementation process. A list of findings and conclusions was made at the end of periodic evaluations, followed by recommendations related to six individual operational plans, more exactly to institutions where anti-corruption operations occurred. It should be noteworthy that realistic approach was applied in the process of creating the anticorruption operational plans and progress indicators in selected Federation BiH institutions: they will certainly facilitate the evaluators task in validating success of activity stemming from operational plans. 20

21 Evaluation Results Relevance Relevance could be regarded from several perspectives. Some of perspectives are related to evaluating adequacy of a program for accomplishing a planned purpose, while other pertain to relevance and actual importance for beneficiaries. The following text will at first present the adequacy of evaluated anti-corruption plans aimed at reducing level of corruption by assessing their forms and content. Also, plans relevance and actual benefit to intended beneficiaries will be elaborated as well. The form of anti-corruption programs developed in six evaluated Federation BiH institutions seem to be promising. As stated by Klitgaard (1988), anti-corruption program should be focused on corrupt systems, not to individuals. In other words, instead of understanding corruption as an act of unethical individual who infringes legislation and misuses public confidence, an accent should be on systems which are prone to severe or less severe various illegal activities. The strategy or plan has been a usual form used for shaping such (anti-corruption) programs. As there were several individual institutions, it seemed reasonably to enact such operational/anti-corruption action plans, authorized by institutions managers, and made in accordance with the similar document, namely, the Federation BiH General Anti-Corruption Plan. Instead of creating unclear, partial, and unfocused activities which seem to offer change, the plans articulated in line with above principles have an additional leverage. As mentioned earlier in the report, anti-corruption plans had an outside support, namely from the Criminal Policy Research Centre, an organisation conducting the program evaluation of anti-corruption activities. Cooperation with the Centre was of facilitating and consultative nature. This is in line with general statement that cooperation with non-governmental sector has been recommended in various phases of anti-corruption campaign whereas deficient expertise in developing anti-corruption plans can be compensated by relevant consultant assistance. In absence of such support, dynamic and schedule of anti-corruption plans adoption would go in another direction. Development of anti-corruption plans at the level of respective institutions aimed to further elaborate obligations set out in the General Plan and to identify their work related weaknesses, as well as to consider potential and feasible solutions aimed at diminishing or abolishing such weaknesses. In this process of developing operational plans, a work approach involving consultations with many public officers and review of extensive number of publicly available documents was used. At several occasions, draft plans were commented and amended, and in closing phase, the plans were largely adjusted to needs and capacities of institutions involved. So called, participatory diagnosis approach was promoted which implied discussions on anti-corruption systems analytically and without fear of reprisal with anti-corruption activities stakeholders, and like therapy elsewhere self- prescription can be made here as well on the basis of self-diagnosis (Klitgaard, MacLean-Abaroa, & Parris, 2007). The process involving plan development and adoption, as well as tools for its conceptualising, were in hands of evaluated 21

22 institutions. The approach which considered previously undertaken anti-corruption actions, accompanied by analysis on specific issues and a work performance at institutions, in principle promised a large support to these efforts than previously. In terms of content, evaluated anti-corruption plans have addressed intended goals well. As they were based on the General Anti-Corruption Plan, these plans contained the same components like the General plan and in fact further elaborated them. This has been universal concept, which proved to be successful in similar interventions worldwide. Furthermore, all listed anti-corruption plans were drafted by utilising so called integrated approach, meaning it needs to be evidence-based, transparent, non-partisan, inclusive and comprehensive, integrated and impact oriented (United Nations Office on Drugs and Crime, 2003). This means that plans should be founded on analysis related to institutions operational weaknesses; dissemination of responsibility for accomplishing anti- corruption tasks to several stakeholders (as the anticorruption campaign would not represent a sole rider activity). Also, promoting the anticorruption plan visibility to public and activity owners; insisting on political neutrality and plans understanding as acts of general welfare, promoting higher professional standards within public sector; and setting realistic attainable goals should be part of this process. It seems that evaluated program documents reached these features, at least on their conceptualised level. Furthermore, plans seem to be coherent, they utilise resources well and dispose activities in logical framework. One could conclude that the plans were harmonised well internally. This could be also said for their external harmonisation, meaning harmonisation with other efforts beyond the institutions. In this regard, General Anti-Corruption Plan of Federation BiH and individual institutional anti-corruption plans were based on the state level Anti-Corruption Strategy and its Action Plan ( ), and in line with goals of public administration reform. Federation BiH Government s legislative initiatives exercised at some other areas (for example, amendments to the misdemeanour legislation; confiscation of assets gained from criminal activities, establishment of specialised Federation BiH judicial institutions, etc) were occurring at the same time as plans implementation and were based on the similar goals. If diminishing real and/or perceived level of corruption was a purpose of plans development by respective institutions, it is very likely that purpose could have been achieved by evaluated anti-corruption plans. Several items should be raised in regard with evaluated anti-corruption programs content adequacy aimed at diminishing a level of corruption. Analysed anti-corruption plans may seem to be too generic (generalised) and they may rely upon significantly to other processes which have been initiated or conducted in parallel with developing and implementing anti-corruption plans. To this end, a distinction should be made between the activities developed as tools for overcoming corruption in line with decisions of higher authorities (e.g state Anti-Corruption Action Plan and Federation BiH General Anti-Corruption Plan) from those activities based on some regular or extraordinary processes within the institutions. The implementation of the first group of activities was obligatory, while there have been rare examples of anti-corruption plan activities initiated or implemented as an outcome of other processes. Most likely, due to absence of particular activity or their slow realisation, they were included under appropriate plans, with an intention to spur their realisation by appropriate synergy with other previously launched or current anti-corruption efforts (Klitgaard, MacLean-Abaroa & Parris, 2007). It has been hard to differentiate whether anti- 22

23 corruption activities accomplishments were the result of suggestions set out in respective anticorruption plans or the outcome of some other (administrative) procedures. Therefore, anti-corruption program and activities should at first focus on easily attainable goals and cooperation with bureaucracy, rather to struggle against it. In this light, public sector mobilisation can be primarily accomplished within own working environment. Also, if extensive changes are initiated in countries with systemic corruption, it is obvious that their implementers will not receive stable support, so the overall undertaking will end with a failure and wish list, followed by a larger dissatisfaction and service beneficiaries frustrations. Therefore an obvious or less obvious need for reform represents an appropriate approach in finding balance between wishes and realistic capacities. It seems that analysed plans have accomplished that purpose. Learning from failures encountered in similar campaigns, promoting positive examples and encouraging a step by step approach seem to be a promising strategy for reform. Corruption has been recognised as a pressing problem throughout Bosnia-Herzegovina, and fight against corruption has been highly positioned on the agenda of authorities at all levels. It has been stressed numerously that fight against corruption, through developed and implemented strategy documents with clearly indicated deadlines and subjects who enforce anti-corruption policy, requires clear determination of the Federation BiH government. Four institutions leaders are part of the Government structure anyhow, but there is no doubt that similar determination is shared by the leaders of remaining two institutions. It has been noted that the anti-corruption plans were designed systematically. From a content perspective they applied universal and tested mechanisms in order to reach objectives. Other processes also proclaim diminishing the corruption impact and overall professionalism in public sector s operations. In this light, anti-corruption plans can serve as the effective tools in reaching goals set by those other processes and also to acknowledge a general purpose of public sector. Accordingly, the public administration sector reform strives to improve organisation of governance, its cost effectiveness and professionalism as well as to be a better service provider to citizens. Civil servants and public sector operations in general are lead by principles of legality, transparency, public overseeing, accountability, efficiency, effectiveness, professional objectivity and political independence. In addition, numerous research in the area of social confidence 6 show a low level of political confidence in BiH, whereby its absence leads to non functional modern society and government apparatus. These are relevant reasons to regard anti-corruption plans, founded on aforesaid principles, as useful tools in reaching organisational goals and work purpose, by all Federation BiH institutions, including the evaluated ones. Interestingly, only few institutions have determined their vision, mission and goals, which would facilitate understanding if their focus have included all or certain dimensions of anticorruption work. In closing, anti-corruption plans subject of this evaluation are considered to be actually relevant and valid. 6 See, Šalaj, B. (2009) Social trust in Bosnia-Herzegovina. Sarajevo: Friederich-Ebert- Stiftung 23

24 Effectiveness The activities whose level of implementation are subjected to evaluation, are usually complex ones and imply several tasks (steps) which need to be taken in order to have the activity completed. Since there were hundreds of tasks, their detailed evaluation would make the text cumbersome, so anti-corruption efforts accomplishment will be assessed at the output level. The bellow table demonstrates a status of specific activities undertaken by institution. Table gaps indicate that specific activity has not been planned for the respective institution, whose title is listed under column heading. 24

25 TABLE 1: REVIEW OF IMPLEMENTED ACTIVITY STATUS WITH RESPECT TO OPERATIONAL ANTI-CORRUPTION Level of implementation Measure Activity FMI FPA FIA FMF FMJ FMVW Analyze enforcement of the Law on Free Access to Information, and based on analysis (particularly weak points), develop guidelines for Law s enforcement and deliver appropriate personnel training. Establish clear criteria and guidelines for developing Federation BiH budget. Establish normative framework and build institutional capacities for efficient confiscation of proceeds of corruption Analyze status of oversight under operating funds expenditures per projects within current transfers; if necessary develop appropriate legislation in this area. Enact procedures in the anti-corruption areas (in particular the book of rules on internal control and audit) in line with legislation regulating subject area, and harmonise existing legislation with higher-ranked regulations Analyse internal documents regulating current expenditures (eg. travel costs, representational and phone costs) in order to ensure their consistency with a higher level regulations. IMPROVEMENT OF LEGILSATIVE FRAMEWORK FOR THE FIGHT AGAINST CORRUPTION 25

26 Measure Level of implementation Activity FMI FPA FIA FMF FMJ FMVW Analyse and amend, if required Book of Rules on internal systematization of posts to reflect actual needs of Federation BiH institutions Analyse and amend, if required provisions regulating work procedures of enforcement agencies in order to prevent abuses by agency personnel. Establish mechanisms for employees integrity assessment, professionalism and code of ethics, by considering in particular audit findings in performance evaluation of elected officials, civil servants and employees. Analyse and amend if required regulations on FBiH civil servants, including employment, grading and promotion, aimed to reduce discretionary decision making, and increase transparency and ensuring citizens equality in procedures employed by civil service. Ensure larger degree of compliance with reports and recommendations (e.g. non-binding audit reports, etc) Propose/support amendments regulating use of investigative actions in criminal proceedings, which are related to successful criminal prosecutions. IMPROVEMENT OF LEGILSATIVE FRAMEWORK FOR THE FIGHT AGAINST CORRUPTION 26

27 Measure Level of implementation Activity FMI FPA FIA FMF FMJ FMVW Identify and reduce legal gaps which cause or may cause detriment to public interest Develop capacities to implement anti-corruption plans Provide adequate resources for internal control and audit, and deliver appropriate training Ensure functionality of the Central Harmonisation Unit (in terms of human and material resources) Continue with modernisation of public sector through e-government and regulations on e-management, ensure appropriate budget funds and coordinate the activity with the Revised Public Admin. Reform Plan in BiH Analyse needs of inspection teams and if required, improve respective regulations and strengthen them by material and human resources ESTABLISHMENT/IMPROVEMENT OF ACTVITITIES RELATED TO PREVENTION OF CORRUPTION IN PUBLIC SECTOR 27

28 Measure Level of implementation Activity FMI FPA FIA FMF FMJ FMVW Develop anti-corruption training programs; at least two sessions per annum delivered to managerial civil servants and chiefs of organisational units Introduce a system for monitoring and risk management of corruption prone areas and posts Establish precise and clear criteria for funds allocations to projects within current transfers, and increase transparency in reporting on their completion Intensify oversight of expenditures per projects within current transfers, particularly by reviewing appropriate documentation and expenditures at the field. Establish special communication mechanisms for citizens to provide anonymous assessment of quality of services. This entails, inter alia, open comm. channels which encourage clients or officers to report on acts of corruption. Develop educational promotional materials on corruption causes, forms and consequences, and mechanisms to report corruptive behaviour of public officers ESTABLISHMENT/IMPROVEMENT OF ACTVITITIES RELATED TO PREVENTION OF CORRUPTION IN PUBLIC SECTOR 28

29 Measure Level of implementation Activity FMI FPA FIA FMF FMJ FMVW Consult and implement where appropriately recommendations related to public procurement, set out in the Public Procurement Agency and FBiH Supreme Audit Institution reports Ensure that legislation adherence and compliance are respected; increase a work discipline Create conditions that employees are familiarised with relevant laws, by-laws, operating standards in the Ministry, Code of Conduct, internal control and deterring actions related to work of future employees Undertake activities with respect to reducing situations of conflict of interest and following up regulations in this areas Improve public relations concerning providing timely and sound information pertaining to the operations of public institutions During plan s implementation, organise continuos public campaign on corruption causes, forms, and consequences in public institutions STRENGTHENING CIVIL SOCIETY SECTOR PARTICIPATION IN CORRRUPTION ESTABLISHMENT/IMPROVEMENT OF ACTVITITIES RELATED TO PREVENTION OF CORRUPTION IN PUBLIC SECTOR 29

30 Level of implementation Measure Activity FMI FPA FIA FMF FMJ FMVW Analyse use of pre-investigative and (special) investigative actions, and based on review develop and implement recommendations for their efficient enforcement Build capacities of Federation BiH judicial and law enforcement bodies to fight corruption through adequate funding and equipping. Initiate/introduce specialised training for judicial and police officers involved with investigation of corruption and confiscation of proceeds of corruption Improve cooperation of authorities in charge of overseeing and auditing Federation BiH institutions with judicial and law enforcement authorities aimed at increasing efficiency in detecting and prosecution of corruption IMPROVEMENT OF JUDICIARY AND LAW ENFORCEMENTS ACTIONS RELATED TO ENFORCING ANTI-CORRUPTION LEGISLATION Legend: Institution: FMI- Federal Ministry of Interior; FPA- Federal Police Administration; FIA- Federal Inspection Agency; FMF- Federal Ministry of Finance; FMJ- Federal Ministry of Justice; FMVW- Federal Ministry for Issues of Veterans and Disabled Veterans of the Defensive-Liberation War. Level of implementation: - activity completed; - activity partially completed, - activity was not completed. 30

31 Looking through a prism of evaluated activities, it seems that the largest prospect to full implementation had those activities, specific to one or two activities. Some of fully implemented activities were part of legislative procedures; for example the Law on Budget of Federation BiH clearly stipulated a procedure of budget adoption for entity institutions, thus increasing managers fiscal liability, improving control of lawful, timely and purpose-led spending of budget resources, which seem to be one of fully implemented activities envisaged by anti-corruption plans. Other activities were the outcome of previously launched processes; for example it is establishment of the Central Harmonisation Unit within entity Ministry of Finance or improving capacities of Federation Police Administration to fight against corruption and other forms of crime. Further additional activities were caused by a genuine concern for safeguarding the public interest (e.g. effort to identify and reduce legal loopholes that may or can cause detrimental effects to public interest). Regulating the issue of current expenditures, through legal document, has been one activity, fully implemented and common to all institutions. In fact, this activity responded to previously created general administrative legal document (namely, the Guidelines for Establishing and Strengthening Internal Control of Budget Users), often prioritized by the Federation Supreme Audit Office. One can state that synergy was accomplished by range of factors, including a response to operational anti-corruption plans, which all lead towards better management of public finance. With regard to the status of anti-corruption plans implementation and a total number of planned activities (versus a total number of implementing institutions) involved in this process, fully implemented activities constituted a slight majority per author s impression. With respect to ratio, a number of activities focused on public sector capacity building aimed to preventing corruption was double then the number of legal drafting operations. It has been encouraging fact that capacity building anti-corruption operations were already taken, communication channels established for beneficiaries of public services, public relations improved, and awareness raised on need to prevent corruption, its causes and forms. Aforesaid accomplishment were noted by many institutions. Within a context of true fight against corruption, legislative efforts to improve regulations on free access to information and update by-laws on internal controls and audits seem to credible efforts. Quantitative review describing a degree of anti-corruption activities accomplishment has been provided bellow. 31