Midterm Evaluation - Support to Anti-Corruption Efforts in Kosovo II

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Evaluation Plan:
2016-2020, Kosovo
Evaluation Type:
Mid Term Project
Planned End Date:
01/2019
Completion Date:
03/2019
Status:
Completed
Management Response:
Yes
Evaluation Budget(US $):
6,000

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Title Midterm Evaluation - Support to Anti-Corruption Efforts in Kosovo II
Atlas Project Number: 00093846,00097537
Evaluation Plan: 2016-2020, Kosovo
Evaluation Type: Mid Term Project
Status: Completed
Completion Date: 03/2019
Planned End Date: 01/2019
Management Response: Yes
Focus Area:
  • 1. Others
Corporate Outcome and Output (UNDP Strategic Plan 2018-2021)
  • 1. Output 2.2.2 Constitution-making, electoral and parliamentary processes and institutions strengthened to promote inclusion, transparency and accountability
Evaluation Budget(US $): 6,000
Source of Funding: SDC - 10282 and DANIDA - 00095
Evaluation Expenditure(US $): 20,323
Joint Programme: No
Joint Evaluation: No
Evaluation Team members:
Name Title Nationality
Julia Mager International Consultant
Krenar Loshi Local Consultant KOSOVO
GEF Evaluation: No
Key Stakeholders: Kosovo Institutions, Donor and UNDP
Countries: KOSOVO
Lessons
1.

Embedded advisors: Physical presence of embedded advisors in the key institutions has proven to be a great value added proposition of the project, securing not only effective on the-job capacity development, direct communication and follow-up with beneficiaries, but also an added quality assurance. Nevertheless, the project must be mindful of capacity substitution trap and ensure that there’s a clear exit strategy to such involvement.

Flexibility in approach: The project’s flexible approach in addressing emerging needs of the key stakeholders has turned the project into a trusted partner, enabling stakeholders to swiftly address any emerging issues, thus clearing obstacles to a successful accomplishment of the set objectives. In advancing further, the project must capture well and document these key turning moments into project reports.

E-tools and platforms: The project’s efforts in digitalizing the corruption reporting, tracking and investigation is enabling key anti-corruption institutions, as well as citizens to interact with one another much more effectively and at the same time adding to institutional transparency and accountability towards the citizens. During the next phase, the project must ensure higher degree of sustainability of use of such tools and platforms once the project has ended.

Shifting focus on integrity plans: The shift of focus from corruption prevention to corruption suppression entailed a change in approach on integrity plans moving from a UNDP-supported system to a national system on integrity plans. While the latter has potential to ensure sustainability of integrity plans in the long-run, an incremental approach moving from the UNDP-driven system to a national system on integrity plans is required.

Establishing and maintaining a comprehensive approach to combatting corruption: While the project established a comprehensive approach on addressing gaps in the anti-corruption system and developing the corresponding policy and legislative framework, there is the need to develop a more coherent approach on ensuring sustainability of the newly established anti-corruption system. This is particular due to the significant policy and legislation gap and the  lack of capacities to effectively monitor and report on the implementation of relevant policies and legislation.

Increasing impact: While establishing an enabling environment for corruption prevention and suppression, intervention areas providing for more impact such as increasing judicial independence, establishing e-tools, increasing budget transparency and strengthening social accountability through kallxo.com and GAP should be prioritised in this complex context of Kosovo.

Demonstrating competence and gaining trust: The solid competencies of the project team provided the project with access to get involved in sensitive issues and gain trust of key stakeholders. This approach should be maintained in the remainder of the project implementation.

Keeping low profile: Although, at a cost to project’s visibility, the project managed to influence policy direction in several relevant areas, while keeping a low profile to not attract the reaction of “interest groups” that could potentially become obstacle to reforms. This approach proved to be successful and should be maintained in ‘sensitive’ areas of intervention.

Long-term commitment: The project collaborates with a large number of stakeholders on highly complex issues and thus requires longer-term commitment in order to ensure impact of the suppression approach.


Findings
1.

V FINDINGS

5.1 Relevance

1. Relevance: shift of focus from corruption prevention to corruption suppression highly relevant to the situational context, tackling key problems at the central and local level. The relevance criterion focuses on the extent the project has been developed and implemented in line with UNDP and national policies, extent of the needs of the targeted group reflected, and extent of alignment with the chosen goal. For this purpose the following key questions have been analyzed (see Annex 2 for details): - To what extent does the project fit into the relevant strategic frameworks? - To what extent does the project reflect the needs of the target group? - To what extent does the design of the project is adequately adapted to the chosen goal? 

The project is highly relevant to the situational context, tackling key problems at the central and local level through the three components. The project is well aligned with central and local strategies as well as UNDP priorities. The research conducted by the Evaluation Team (ET) shows that there is a high demand to strengthen institutional capacities to deter, detect and sanction corruption involving institutions and public officials, which is fully in line with the objective of the project. The project design has allowed for substantial degree of flexibility required to address different and emerging needs of key stakeholders and beneficiaries. Upon demands of the SDC, the project has been able to make a significant shift from corruption prevention to corruption suppression without disturbing the balance of activities overall. Some of the shortcomings on prevention aspect regarding implementation of the Integrity Plans are expected to be dealt in the oncoming period through the new legal framework. This amended legislative and policy framework is expected to be adopted in the first half of 2019, whereby the new Anti-corruption Strategy 2018 – 2022 and new Law on KACA will make Integrity Plans obligatory for all institutions and will equip KACA with the mandate to monitor their implementation. 


Tag: Capacity Building Theory of Change Relevance Anti-corruption Civic Engagement e-Governance Rule of law Knowledge management Policies & Procedures Programme/Project Design Results-Based Management

2.

5.2 Effectiveness

The evaluation of the effectiveness criterion showed that the project is well on track to achieve its expected results (outcomes, outputs). The project implementation resulted in a track record of achievements such as the development of comprehensive anti-corruption institutional and legal framework and e-tools aiming at covering main gaps in the system and working with all anti-corruption institutions.The evaluation of the effectiveness criterion focused on the extent the project has achieved its goal and expected results. For this purpose the following questions have been analyzed. • Is the project on track to achieve its expected results (outputs, outcomes)? What has been achieved?; • What challenges have been faced? What has been done to address the potential challenges/problems?; • Have the capacity development measures served the needs and demands of the stakeholders?; • In what ways could the project improve its efforts in the second half of project’s implementation toward achieving the expected results (outcomes, outputs)? The effectiveness criterion has been assessed against the evaluation matrix analyzing data gathered from semi-structured interviews and document review. In order to evaluate whether the project is on track to achieve its expected results (outputs, outcomes) progress achieved has been evaluated against the RFF. The project’s overall objective is to develop institutions that are able to deter, detect and sanction corruption involving institutions and public officials. In line with the theory of change, this approach is manifested through enhancing the policy, regulatory and monitoring framework on prevention and suppression of corruption (outcome 1), in supporting anti-corruption institutions in detecting and processing anti-corruption cases effectively (outcome 2), and in strengthening civic engagement mechanisms to hold institutions accountable (outcome 3). The evaluation at the outcome level led to the following findings:


Tag: Effectiveness Anti-corruption Justice system Local Governance Parliament Rule of law Policies & Procedures Results-Based Management Country Government Technology Capacity Building

3.

5.2 Effectiveness(continuation) 

Output 1.2 Anti-corruption monitoring framework established and functioning The project aims at establishing a comprehensive anti-corruption monitoring framework. Assessing the results achieved on anti-corruption monitoring framework established and functional (output 1.2), the evaluation found the following: Establishing a monitoring mechanism to oversee the effective implementation of the AntiCorruption Strategy and its Action Plan (2018-2022), will depend on their adoption. Yet, monitoring of the implementation of anti-corruption policy was previously conducted through the Prime Minister’s High Level Dialogue monthly meetings in 2018. This process has been completed with the support of an embedded UNDP adviser in the PM’s office. Considering that it is expected that the new Anti-Corruption Strategy will be adopted in the upcoming period, it can be assumed that the target on monitoring the implementation of the Anti-Corruption Strategy and its Action Plan will be met. Work on the e-integrity tool will commence in 2019. It will provide the KACA with the possibility to monitor the implementation of integrity plans of central level institutions and municipalities. The implementation of this e-tool is envisaged for 2019/2020 and it is likely that the target stating that at least five public sector institutions will use this tool is going to be met. This is due to the fact that institutions and municipalities, which already developed integrity plans are interested in continuing to work on the implementation. Moreover, according to the new Law on KACA the development of integrity plans will be mandatory and KACA will monitor the implementation.


Tag: Data and Statistics Anti-corruption Rule of law Communication Knowledge management Monitoring and Evaluation Policies & Procedures Country Government Technology Capacity Building

4.

5.2 Effectiveness(continuation) 

Outcome 3 Civic engagement mechanisms to hold institutions accountable strengthened - Output 3.1 Civic engagement platforms for corruption reporting, referral and monitoring supported This output aims at supporting the civic engagement platform kallxo.com for corruption reporting, referral and monitoring. The project supported kallxo.com to improve its reporting platform by developing and launching a corruption-reporting app available for both Android and iOS platforms. This app is a new corruption-reporting tool, which is directly linked to the main kallxo.com database where corrupt cases are stored. The project also facilitated meetings between kallxo.com and other anti-corruption institutions to discuss anti-corruption cases and improve the referral and monitoring processes. Since the beginning of the implementation of SAEK II, 3.455 reports have been received by kallxo.com; whereas the team of researchers managed to verify 986 cases leading to 591 followups with institutions, which resulted in 98 impacts. In order to foster the impact of the work of kallxo.com the project aims at increasing the verification rate of potential corruption cases reported on kallxo.com. The baseline for this output indicator has been 10% of cases that have been reported and processed are verified, while the current verification rate is at 25 % and it is expected that all cases will be verified to meet the target of this indicator. Consequently, there is still need to increase the verification rate in order to achieve this output. 

Output 3.2 Awareness on how corruption is tackled is increased This output aims at increasing awareness on how corruption is tackled. The implementation builds on a series of innovative anti-corruption awareness raising activities, which have been transformed into activities aiming at increasing awareness on how corruption is being tackled. To this end, the project supports developing and airing the TV show the prosecutor, an award on investigative journalism in the field of corruption, and developing the GOPAC chapter. The following progress has been achieved: The implementation of this output initially focused on increasing citizens’ awareness on corruption and following activities have been implemented: • Grants on awareness raising have been provided to civil society organisation in 2017 and 2018; • In line with the recommendations of the Corruption Risk Assessment in Education with the Ministry of Education, the project supported developing and disseminating education materials for youth especially women and vulnerable /marginalized groups, on active citizenship; • Innovative awareness raising activities such as data cuisine, game over, and an innovation challenge on corruption have been held, the Anibar Transparency Animation Workshop has been conducted, a Corruption Museum has been established and an OpenData/Transparency workshop have been held; • A communications campaign for the Kosovo Association of Patients' Rights (PRAK) has been conducted. 


Tag: Effectiveness Impact Anti-corruption Civic Engagement e-Governance Communication Monitoring and Evaluation Technology Advocacy Data and Statistics

5.

5.2 Effectiveness(continuation) 

Key achievements

While there has been constant progress in the implementation, the following key achievements have been established based on an analysis of semi-structured interviews and project documents: • Key stakeholders see the project team as a trusted partner who provides hands-on participatory advice, in particular, in drafting legislation and policy. This also allowed the project to focus on sensitive issues such as a review of 20 past corruption cases and establishing of inter-institutional cooperation.; • Development of comprehensive anti-corruption institutional and legal framework and etools aiming at covering main gaps in the system and working with all anti-corruption institutions. This approach is crowned with establishing e-platforms expected to lead to significant efficiency gains.; • Kallxo.com is a key mechanism increasing demand in anti-corruption measures and holding anti-corruption institutions accountable. Kallxo.com established itself as one of the most trusted anti-corruption platforms, which is very popular among the population. According to a survey conducted by UBO Consulting for measuring citizens’ perceptions on whom they trust in fighting corruption, kallxo.com is the second most trusted institution in Kosovo, following the Kosovo Police. It developed a very effective approach on receiving, investigating and monitoring corruption cases. Innovative shows such as “The Prosecutor” contribute to increasing transparency and accountability of key anti-corruption stakeholders such as the Chief Prosecutor.; • Well-targeted capacity building measures such as the accredited fraud and forensic accounting course developed and implemented in cooperation with SKAAK.; • Contribution to knowledge management within UNDP. The project has shared its experience and approach upon request of the UNDP Istanbul Regional Hub, UNDP country offices in Georgia, Korea, and Ukraine. 


Tag: Effectiveness Relevance Anti-corruption Civic Engagement e-Governance Rule of law Communication Donor relations Knowledge management Policies & Procedures Strategic Positioning Bilateral partners Country Government Capacity Building Coordination

6.

5.2 Effectiveness(continuation) 

In sum, most of the identified challenges are adequately addressed by the project as measures have been developed to tackle the challenges/problems, which hindered the effective implementation. Key challenges such as lack of political will to effectively combat corruption is very difficult to effectively address. Therefore, tangible results in combatting corruption will depend on political will. The capacity building measures served the needs and demands of the stakeholdres. This is due to a very demand-driven and participatory approach: All of the capacity development exercises were developed through a series of discussions/meetings with the heads of all relevant institutions. The usual process has been that the SAEK project has received requests from relevant heads of institutions for areas of training. Based on these requests, the project team developed the proposed curricula and presented it to the relevant heads of institutions for comments and acceptance. Tailor-made trainings to prosecutors and investigative authorities to specialize on handling corruption cases and other anti-corruption bodies have been developed in participatory manner with key stakeholders and based on international standards. For example, the Tax Evasion and Financial Investigation courses were developed jointly with US FBI special agents, US IRS special agents, and an ex-UK Metropolitan Police (Scotland Yard) agent. The project discussed with the heads of the police, prosecution, tax administration what their needs were, developed case studies and a training course and presented it to the heads of relevant institutions for their review and acceptance. The feeback has been very positive. Regarding the accredited course on fraud examination/forensic accounting, the SAEK project team held meetings with all of the heads of institutions to explain to them this field and how it is the cutting edge of financial investigation and is used by EU member states and the US. The course was split into two modules. Module 1 was based on Kosovo law and was developed by SCAAK as a modified version of their regular courses on accounting and auditing. Module 2 was developed by a licensed fraud examiner who designed the course to follow the international standard Accredited Certified Fraud Examiner’s (ACFE) course. The aim here was to ensure that our course was in compliance with the international standard and to prepare our participants for taking the international course in the future. There was large interest in this course and a waiting list of investigators who wanted to attend. Therefore, the project had to turn away 20 investigators due to a lack of space. This highly participatory approach of developing training and capacity development measures shows that the needs and demands of stakeholders have been fully respected, while considering the objectives and available resources of the project. 

Aiming to ensure overall aid coordination, UNDP has organized and jointly chaired with SDC partnership briefings on anti-corruption with relevant international donors and organizations on a quarterly basis. These partnership briefings have served as a forum to discuss upcoming initiatives, to develop synergies, and to discuss strategic policy priorities, current events, and proposed legislation. In addition, a specific timely topic is identified for each meeting and one of the partners is invited to provide a short briefing on their work. Partnership briefings are comprised of all key development partners that deal with anti-corruption.


Tag: Effectiveness Aid Coordination Anti-corruption e-Governance Rule of law Knowledge management Partnership Results-Based Management Bilateral partners Capacity Building

7.

5.3 Efficiency

The project’s use of its own resources in terms technical advice is a very efficient approach to ensure high quality and timeliness of intended results. Also, the use of embedded advisors, development of annual accredited training courses are approaches and regional activities resulting in achieving intended deliverables in terms of quality, quantity and timeliness.The evaluation of the efficiency criterion focused on the extent the project’s use of resources is appropriate with regard to the outputs and outcomes achieved. To this end, the following four questions have been evaluated in line with the terms of reference: • Are the management and administrative arrangements sufficient to ensure the effective implementation of the project? • Have the roles and responsibilities been clearly defined and described? • How well have the various activities transformed the available resources into the intended results in terms of quantity, quality and timeliness? (in comparison with the plan)

The efficiency criterion has been assessed against the evaluation matrix analyzing data gathered from semi-structured interviews and document review. The approach chosen to evaluate the efficiency criteria is the expert judgment which is based on a focused analysis of the project document and the implementation of annual work plans. On that the management and administrative arrangements the evaluation found the that the project is managed through the following structures:

• The UNDP SAEK Project Team under a Direct Implementation Modality (DIM) has carried out the management of the project. Accordingly, UNDP is responsible for the overall management and administration of the project, primarily with regard to the responsibility for the achievement of the outputs and the stated outcome. UNDP has delegated managerial duties for the day-to-day running of the project to the Project Manager, selected by UNDP through a competitive and transparent selection process. ; • There are two oversight structures: - A management meeting composed of UNDP senior management, SAEK, SDC and DANIDA that meets immediately prior to every board meeting to discuss implementation of the project, risks to be encountered, and to make policy level decisions. - The board (or steering committee) composed of beneficiaries, donors, SAEK and UNDP senior management. This decision making body discusses and decides upon strategic issues pertaining to annual work plans, impacts on outcomes, revisions to the annual work plans and budgets to ensure activities and interventions remain pertinent to needs and achieve optimum results. ; • Partnership briefings serve as donor coordination platforms. These meetings serve as a forum to discuss upcoming initiatives, develop synergies, and discuss strategic policy priorities, current events, proposed legislation. In addition, a specific timely topic is identified for each meeting and one of the partners is invited to provide a short briefing on their work. 


Tag: Efficiency Aid Coordination Implementation Modality Operational Efficiency Oversight Partnership Project and Programme management Quality Assurance

8.

5.3 Efficiency (continuation)

Quality Assurance and oversight responsibilities lie with the Assistant Deputy Resident Representative due to the comprehensive nature and the complexities of the project. Comparing the current staffing structure with the originally envisaged one, it appears that the original staffing structure would have provided the project more staff and a clearer division of technical and project management functions. This is due to the fact that the original staffing structure envisaged two instead of currently one staff member on technical advice and three instead of currently one staff member focusing on project management. Assessing the administrative and management further, the evaluation found that providing the project manager with technical advisory responsibilities has led to challenges in fulfilling all responsibilities with equal dedication, in particular, at times requiring significant technical support. Consequently, some project management responsibilities such as knowledge management, monitoring and evaluation, ensuring visibility of the project have not been fully realized. It is expected that the recruitment of a fulltime project manager will address this issue and provide for a more efficient organisational structure of the project.

The remaining roles and responsibilities have been divided in line with the needs arising from the implementation of the project. Accountability for project results could be increased by clearly providing staff involved in technical advisory work and capacity building with distinctive portfolios in line with the reconstructed theory of change. This would imply providing staff members with the responsibility to implement selected outputs and outcomes. Due to the nature of the project requiring significant administrative, logistical and organisational support, the division of roles and responsibilities could be increased leading to an improved workflow and efficiency gains. In sum, the findings on management and administrative arrangements and definition of roles and responsibilities demonstrated that there is a need to strengthen the project management role as already foreseen with the current vacancy for the position of project manager. 

Evaluating how well have the various activities transformed the available resources into the intended results in terms of quantity, quality and timeliness (in comparison with the plan) the evaluation resulted in the following findings: - An analysis of the implementation of annual project work plans found that the implementation of activities transformed available resources using efficient approaches leading to intended results. Particularly, the technical advice provided by project staff in the drafting of essential policy and legislation such as the new anti-corruption strategy and the law on political party financing led to efficiency gains. This is due to the fact that resources for external consultants have been saved, while the project team deepening relations with key stakeholders, efficiently used their expertise in providing technical advice. This approach is particularly efficient as it resulted in high quality deliverables and the expected quantity due to participatory approaches and high-level technical input. Compared to the originally planned approach of using external consultants this approach demonstrates to be of value added as direct technical advice provided by the project team has certain advantages such as: External consultants first need to fully understand the complexities of combatting corruption in Kosovo, and establish a relationship with relevant key stakeholders, while the project team already has both a deep understanding of Kosovo specific issues and trust of key stakeholders. Additionally, the project’s approach of using seven embedded advisors in key institutions to provide technical expertise and mentoring demonstrated to be an efficient use of resources to achieve expected results. This is due to the fact that the embedded advisers provided everyday support and were incorporated as full staff members within relevant institutions. The embedded advisers were sued to support one-to-one trainings and transfers of knowledge. Additionally, the embedded advisors provided the project team with day-to-day information about the needs and functioning of the institutions. This approach allowed the project team to address the needs of the institution in a tailor-made and time manner. Hence contributing to the quality of the implementation. 


Tag: Efficiency Anti-corruption Justice system Local Governance Rule of law Communication Human and Financial resources Knowledge management Operational Efficiency Oversight Policies & Procedures Project and Programme management Quality Assurance Country Government Advocacy Capacity Building Technical Support

9.

5.4 Potential for impact

The project has been successful in establishing an enabling environment for corruption prevention and suppression. While contributing to decreasing corruption in a challenging environment, the project devised some approaches, which have particular potential for impact:  approaches focusing on increasing judicial independence, establishing e-tools, increasing budget transparency and strengthening social accountability through kallxo.com and GAP have solid potential to have impact. The potential for impact criterion focuses on the extent the project might have long lasting changes and benefits. For this purpose the following key questions have been analyzed: - Has the project appropriately reached its target groups? Is the project serving the needs of vulnerable groups, i.e. women, youth, minorities? - To what extent did the project contribute to behavioral changes and motivation of key stakeholders regarding corruption prevention and corruption suppression? The project actions undertaken under the three outcomes carry significant potential for impact in decreasing the level of corruption in targeted public institutions, which is the desired impact of the project. To this end, the project has been successful in establishing an enabling environment for corruption prevention and suppression by engaging with key anti-corruption institutions in defining the necessary legal environment and mechanisms/tools for deterring, detecting and sanctioning corruption involving institutions and public officials, which is the key objective of the project.


Tag: Country Government Data and Statistics Impact Gender Mainstreaming Anti-corruption Civic Engagement e-Governance Election Local Governance Rule of law Monitoring and Evaluation Policies & Procedures

10.

5.5 Sustainability

The project’s systematic approach to anti-corruption on the supply and demand side provides a solid basis to ensure sustainability of the anti-corruption system in Kosovo.The evaluation of the sustainability criterion focused on the extent the benefits of the project are likely to continue after the project has ended. To this end, the following four questions have been evaluated in line with the terms of reference: • How will the project ensure sustainability of its results when the project will have ended (i.e. continuity of developed capacities, use of knowledge, improved practices, implementation of policies, strategies, laws, plans developed within the framework of the project etc.)? • What has been achieved in institutionalizing the acquired knowledge and skills? • To what extent has the project led to a change of behaviours and motivations in terms of paying attention to marginalised and vulnerable population groups. • Does the project have a concrete and realistic exit strategy to ensure sustainability? The sustainability criterion has been assessed against the evaluation matrix analyzing data gathered from semi-structured interviews and document review. 

The evaluation found the following: On the question how the project will ensure sustainability of its results when it will have ended, the evaluation found that UNDP SEAK project team developed a holistic approach to tackling corruption. Accordingly, a strong emphasis has been put on developing an anti-corruption system that is there to remain. In line with the theory of change, this approach to anti-corruption is manifested through enhancing the policy, regulatory and monitoring framework on prevention and suppression of corruption (outcome 1), in supporting anti-corruption institutions in detecting and processing anti-corruption cases effectively (outcome 2), and in strengthening civic engagement mechanisms to hold institutions accountable (outcome 3). These three main intervention logics have the following different implications regarding how the project will ensure sustainability of its results when the project will have ended. On enhancing the policy, regulatory and monitoring framework on prevention and suppression of corruption (outcome 1), in particular, on anti-corruption legislation and policies developed and capacities for implementation fostered (output 1.1) the project has achieved the following progress: It supported the development of the Anti-corruption Strategy including the corresponding Action Plan (2018 - 2022) and the amendments to the Law on Financing Political Entities/Law on General Elections. Both require to be adopted by central institutions and the Assembly in the upcoming period. Furthermore, the project has supported drafting the amendments to the Law on the Anti-corruption Agency, the Law on High Officials Assets and Income Declarations and the UNCAC GAP Assessment. The process of drafting the aforementioned laws is on-going and should be completed by April 2019, while the UNCAC GAP Assessment is envisaged to be completed by December 2019. Moreover, the project completed the development of 21 integrity plans for central level institutions and municipalities. (revised ToC)


Tag: Sustainability Anti-corruption Civic Engagement Justice system Parliament Rule of law Policies & Procedures Country Government Capacity Building

11.

5.5 Sustainability (continuation)

On the integrity plans the evaluation found that most of the 21 central and municipal level institutions that developed integrity plans would require additional support to ensure their sustainability. This pertains mainly to smaller institutions, however, even bigger institutions such as Pristina municipality expects support from UNDP in the implementation of the integrity plan. In this connection, it is crucial to point out that shifting focus moving from corruption prevention to corruption suppression resulted in ceasing direct support to developing and implementing integrity plans. While the project – as part of the strengthened focus on corruption suppression - foresees to move to a nationalized system on integrity plans led by KACA, there is a need to ensure a stepby-step transition from the UNDP-driven to the nationalized system. This transitional approach is particularly required as most developed integrity plans and corresponding action plans have not been linked to the budget of the institution. Not reflecting the integrity action plan in the budget of the institution bears significant sustainability risks as integrity action plans will not be implemented in a comprehensive manner. Moreover, it seems that not all institutions involved in the development of integrity plans are fully aware of the project’s new approach. The nationalized system to integrity plans envisages that integrity plans are mandatory according to the amended Law on KACA and that KACA is going to monitor the implementation of the integrity plans. In order to ensure the development of the integrity plans it is foreseen to develop a train-the-trainer system on integrity plans led by KACA. However, it will take some time to make this approach fully functional, in particular, as the law has not been adopted yet and the monitoring and ToT system first need to be established. Therefore, an approach bridging the fully UNDP-led system to the national system is needed to ensure sustainability of the projects results. 

Assessing the results achieved on anti-corruption monitoring framework established and functional (output 1.2), the evaluation found the following: The implementation of this output has only commenced on developing an e-integrity tool, corruption proofing and sentencing guidelines (indictors 1.2.2, 1.2.3, 1.2.4). At this stage of the implementation, the project did not establish an approach on ensuring the sustainability of achieved results beyond ensuring local ownership and participatory approach. On corruption proofing of legislation there is high-interest of key stakeholders, in particular, the KACA, the Office of the Prime Minister and the Ministry of Justice, in taking the lead and being involved. In order to ensure sustainability of corruption proofing it is required to determine the institutions in charge of this tool. 

Sentencing guidelines have been developed, adopted and are in used on a voluntary basis. In order to sustain the efforts on using the sentencing guidelines transparency and accountability on using the guidelines should be strengthened. According to the Supreme Court, the sentencing guidelines will need to be adjusted in line with the new Criminal Code to be adopted in 2019. Due to a lack of capacities, these amendments will need to be supported by UNDP. In order to ensure sustainability of the sentencing guidelines required institutional capacities will need to be built to regularly update the sentencing guidelines. 


Tag: Sustainability Anti-corruption Civic Engagement e-Governance Justice system Rule of law Communication Human and Financial resources Monitoring and Evaluation Results-Based Management Risk Management Capacity Building

12.

5.5 Sustainability (continuation)

Evaluating how the project will ensure sustainability of effective institutional communication on corruption cases established, the evaluation team identified the following findings: With the support of an embedded advisor a communication strategy has been developed and two PR events with media and CSOs have been held. Based on this KACA will develop their own capacities in line with their new internal policy. This demonstrates that the efforts made by the project achieved a certain level of sustainability enabling KACA to continue building communication capacities by themselves. The Chief Prosecutor’s Office developed a communication strategy with the support of the project in 2018. The implementation of the communication strategy is envisaged until 2020. Considering the fact that an embedded advisor is supporting this work on PR and taking into account the benefits the Chief Prosecutor sees in effective communication, it is likely that the communication strategy will be implemented. The Communication Advisor has helped to implement the new Public Communication Strategy and spokespersons in charge of public communication have been recruited at all prosecution offices. At this stage, the Chief Prosecutor would need increased coordination to ensure the effective functioning of the communications system and gradual withdrawal of the Communication Advisor from PR duties. This would also contribute to the sustainability of the communications system of the OCP. 

The findings on strengthening civic engagement mechanisms to hold institutions accountable (outcome 3), in particular, civic engagement platforms for corruption reporting, referral and monitoring supported (Output 3.1) are as follows: This output refers to the work conducted by Kallxo.com, which is one of the most trusted institutions in Kosovo in fight against corruption. Kallxo.com is still completely dependent on donor funding and the sustainability of results achieved through is platform would be significantly impacted after the project ends. There is currently a lack of a strategy to ensure sustainability of the results achieved through Kallxo.com. However, assessing and implementing a business model not fully dependent on donor funds, would increase the sustainability of Kallxo.com. Regarding public awareness and communication products developed and published (output 3.2) the evaluation found: The TV-show “The Prosecutor” is part of the Kallxo.com and faces the same sustainability issues as outlined above. The anti-corruption journalism award celebrating the anti-corruption day is also fully depends on the project’s funding and it should be considered to hand the celebration of the anti-corruption day over to relevant institutions or a leading CSO or a state institution. 


Tag: Sustainability Anti-corruption Civic Engagement e-Governance Rule of law Communication Knowledge management Policies & Procedures Country Government Donor Capacity Building

13.

5.5 Sustainability (continuation)

Analytical and investigative capacities have been increased through a year-long certified fraud examination and forensic accounting course for 45 police, prosecutors, tax, customs and financial intelligence agents and investigative journalists. The aim of this training has been to build financial investigation capacities to identify corruption schemes and confiscate illicit proceeds. This accredited course developed and run in partnership with the Kosovo Association of Accountants and Auditors (SCAAK). SCAAK is the official professional association in this field and its courses are accredited by the Kosovo Accreditation Agency. While institutionalizing this certified fraud examination and forensic accounting course and ensuring that it is run by SCAAK is a solid foundation for ensuring sustainability, it still needs to be determined how the certified fraud examination and forensic accounting experts will be used. The project is currently following-up on this with the Chief Prosecutor and the President of the Supreme Court to ensure that those accredited are used for joint investigation teams and as court appointed experts (see also above). 

The project resulted in an increased knowledge and awareness on Politically Exposed Persons which is institutionalized through the use of the PEP e-tool. Furthermore, with the support of the SAEK project the knowledge and skills of the Office of the Disciplinary Prosecutor to effectively and efficiently investigates misconduct by judges and prosecutors have been increased. However, due to a change in mandate of the aforementioned institution, the knowledge and skills will not be used in the Office of the Disciplinary Prosecutor, but through the new institutional setup. While the SAEK project tries to ensure the sustainability of these results by transferring established capacities and skills to the new institution it is not clear whether this approach is going to succeed. Moreover, the project put efforts on developing knowledge and skills on communication and PR. Particularly, the embedded Communication Advisors placed in KACA and the Office of the Chief Prosecutor played an important role in strengthening skills and knowledge in communication and PR. Establishing a communications and PR system in the Chief Prosecutors Office and appointing 10 spokespersons in prosecution services, ensures that the acquired knowledge and skills are institutionalized. Building on the skills gained in the project, KACA envisages further strengthening their communications work building on the skills acquired through the project. This also shows that the gained knowledge has been institutionalised. Kallxo.com can be seen as institutionalized mechanisms for reporting, referral and monitoring of corruption cases. This platform provides a very solid foundation for ensuring sustainability of knowledge and skills gained on reporting, referral and monitoring of corruption cases. Yet, as pointed out above Kallxo.com is fully depend on donor funds. In sum, the findings show that while skills and knowledge such as in kallxo.com and the communications functions of KACA and the Office of the Chief Prosecutor have been institutionalized, the next phase of the project implementation will need to pay particular attention to institutionalizing knowledge and skills in order to ensure the sustainability of the achieved results. 

 


Tag: Gender-Based Violence Anti-corruption e-Governance Local Governance Rule of law Communication Donor relations Knowledge management Ownership Risk Management Vulnerable Sustainability Gender Equality Gender Mainstreaming

14.

Relevance (Continuation from Finding 1)

In the new ToC the first outcome focuses on development of policies, legislation, plans and strategies in line with international standards on anti-corruption in order to enable anti-corruption institutions to oversee integrity and transparency of central and local institutions and of political parties. The outcome 1 theory of change is that if selected institutions are supported to develop policies, legislation, plans and strategies in line with international standards on anti-corruption and aided in their implementation and monitoring, then anti-corruption institutions will demonstrate increased compliance with principles of integrity, transparency and improved capacities to suppress corruption. This is because of the policy and legislative framework once implemented will close existing loopholes for corruption and ensure increased integrity and transparency through integrity plans, and various e-tools e.g. asset declarations etc. 

The second outcome focuses on strengthening the anti-corruption institutions and providing them with the capacity and tools to effectively detect and combat corruption. The outcome 2 theory of change is that if relevant anti-corruption institutions operate in line with an improved policy and legislative framework and have improved capacities and tools to detect and reveal corruption then these institutions will have the capacities to seize illicit assets and to ensure their repatriation to the public budget. 


Tag: Relevance Anti-corruption Civic Engagement e-Governance Human rights Rule of law Theory of Change Institutional Strengthening

15.

5.2 Effectiveness - Output 2.1 E-mechanisms for corruption detection and processing established( Continuation from Finding 3)

The e-tool for monitoring PEPs is functioning by providing access to a global database used by FIUs and law enforcement agencies. This monitoring mechanism has been only established in December 2018. However, considering the high interest of FIU in using database it can be expected that this tool will be used to monitor at least 10 cases per year. This is mainly due to the fact that it provides FIU with new opportunities and increased efficiency to monitor PEPs. Establishing an e-tool with the KACA for case management system of preliminary investigations should increase the efficiency of KACA in this field. Depending on the functionality and usefriendliness of this tool, it is expected that the paper-based system is going to be replaced by 2020. Establishing an e-tool for the Office of the Chief Prosecutor to access criminal and financial records is another mechanism supported by the project. Providing e-access to financial and criminal records within the Police, Tax Administration, Customs Administration, Cadaster aims at improving the capacities of the Chief Prosecutor in investigating corruption cases. During 2018 the legal framework (an interagency MoU) was drafted by SAEK in December 2018 and presented to all of the Agencies. The MoU is expected to be signed early 2019. There is no formal adoption process needed, only signatures by all heads of institutions.It is expected that the IT system will be completed in 2019. While the Chief Prosecutor is highly interested in using this tool, its effective use will depend on the capacities of staff investigating corruption cases. If needed capacities are built, it is expected that the target of 20 individuals investigated using the e-tool is going to be achieved. Overall the findings on progress achieved on output 2.1 show that the project will most likely achieve its targets if e-tools are user-friendly leading to efficiency gains of all stakeholders involved and capacities of staff using e-tools is built.


Tag: Effectiveness Anti-corruption Civic Engagement e-Governance Public administration reform Communication Knowledge management Technology Institutional Strengthening

16.

5.3 Efficiency (Continuation from Finding 8)

While these activities and approaches transformed the available resources into the intended results in terms of quantity, quality and timeliness (in comparison with the plan) in an efficient manner, the approach taken regarding integrity planning shows some room for improvement. According to the work plan the project envisaged to support local and central institutions in developing integrity plans. During the first year of the implementation of SEAK II 17 integrity plans have been developed for municipalities and central level institutions. To this end, a consultancy company was hired which supported relevant institutions in developing integrity plans. The decentralized bottom-up approach on developing integrity plans has been changed an institutionalized top down approach due to the following reasons: It was reassessed that the project should first develop the policy and legislative framework making integrity planning mandatory and providing KACA with the mandate to monitor the implementation of integrity plans. The project assumes that this approach would allow them to measure results of the implementation and thus go beyond the mere adoption of integrity plans. Furthermore, the shift of focus from corruption prevention to corruption suppression required the project team to focus more resources on corruption suppression at the expense of integrity planning. Institutionalizing the development of integrity plans is certainly a precondition to ensure that integrity plans including their implementation become a regular practice. Yet, ceasing all activities on integrity planning without any support to institutions with integrity plans bears the risk that integrity plans will not be implemented and the resources invested at the beginning of the project implementation have not been used efficiently. In this connection, it is also important to point out that some activities previously envisaged such as involving NGOs as watch-dogs to monitor the implementation of integrity plans could have been an efficient transition approach to foster the implementation of integrity plans.


Tag: Efficiency Anti-corruption Civic Engagement e-Governance Human rights Justice system Public administration reform Awareness raising Institutional Strengthening

17.

5.3 Effectiveness (Continuation from Finding 9)

Outcome 3: Internews/Kallxo.com: The project is strengthening the Research Unit of the online platform Kallxo.com to manage the information flow on www.kallxo.com and coordinate follow-up activities with responsible anti-corruption bodies. The project will also roll-out and presence of Kallxo.com platform in 38 municipalities in Kosovo through established cooperation agreements with small CSOs and local media operating across Kosovo. Through project monitoring and coordination mechanisms, support is being provided to Kallxo.com team and the anti-corruption institutions on sharing of information on corruption cases and follow-up. Assembly of Kosovo Legislative Committee/GOPAC: The project is providing training and legal review support to the Legislative Committee on reviewing legislation and conducting hearings on anti-corruption issues and oversight hearings over the KACA. The project is also supporting the establishment of a GOPAC chapter and support in organizing public hearings with cross-party support on such issues as passing anti-corruption legislation, the functioning of anti-corruption measures. 


Tag: Effectiveness Efficiency Anti-corruption Civic Engagement e-Governance Local Governance National Institutions Vulnerable Women and gilrs Youth

Recommendations
1

Recommendations The evaluation suggests that the project on oncoming future phases needs to undertake the following measures: 

Increasing relevance through elaboration of the assumptions and risks in line with the revised reconstructed theory of change.

2

Strengthening effectiveness While the overall approach of the project demonstrated to be effective in achieving the expected results (outcomes, outputs), the following could be improved in remaining implementation period: 

• Develop a coherent approach fostering the adoption of the Anti-corruption Strategy, and the amended laws, in particular, the Law on Financing Political Entities/Law on General 64 Elections. In order to increase the needed political clout, closer cooperation with international key players such as the European Union or the United States of America is recommended. If successful this approach of fostering the adoption of laws should also be applied to other policies and laws to be adopted within the framework of this project. 

• Considering that the project focused the first half of the implementation on developing and amending key laws and regulations, the focus on the second half needs to be on ensuring that key stakeholders possess the necessary capacities and mechanisms to effectively implement the improved policy and regulatory framework.

• Develop a coherent approach on ensuring the effective implementation of the Law on Financing of Political Entities/Law on General Elections and increase the capacities of newly established monitoring body in the CEC.

• Institutionalize the approach to corruption proofing based on stakeholder interests, capacities and potential to effectively apply the corruption proofing guidelines in the longrun. Clear institutional accountability lines should be established in order to avoid “blameshifting” in case the guidelines are not implemented coherently. It is recommended to further develop the approach on corruption based on good practices in the region.

• Ensure that key stakeholders such as the Kosovo Anti-corruption Agency are supported in increasing their capacity to implement its expanded mandated in line with the Law on Anti-corruption Agency and the Law on High Officials Assets and Income Declarations. This will require training of staff and eventually establishing a ToT approach to increase the sustainability of the KACA.

• Ensure that institutions using e-tools to detect and process corruption cases will have the needed capacities to use these tools on a regular basis. E-tools need to be developed as user-friendly platforms, which will lead to efficiency gains.

• To support the Supreme Court in amending the sentencing guidelines in line with the revised Criminal Code and to build capacities enabling the Supreme Court to amend the sentencing guidelines regularly.

• Improve cooperation with EU and US in order to increase the political leverage and clout needed to move ahead with the implementation of the project.

• Further develop an approach to foster political will and decrease resistance to change.

• Support Kallxo.com in improving their security architecture to be better protected against threats in the course of anti-corruption investigations. The project could offer a training on security measures for investigative journalists working on corruption. 

3

Improving efficiency

• The UNDP Programme Associate responsible for SAEK should ensure that all relevant data is captured and inserted in Atlas on regular basis and as comprehensively as possible, covering all RRF indicators.

• Based on the evaluation the proposed set up of the SAEK project team would be: 

- Project Manager – oversight, monitoring and management o CTA – overall technical advise o Dedicated Project Officers: one for implementation of outcome1 with legal background and another Project Officer with governance/CSO background for implementation of outcome 2 and 3 - JPO – responsible for knowledge management, communication and visibility 

• Alternative approaches to support institutions with integrity plans should be considered such as regular mentoring through the project team. 

• The project should maintain and potentially increase its efforts to monitor and to push for the adoption of developed anti-corruption legislation and policies. Coordinating and building coalitions with other key stakeholders including international actors with political clout such as the European Union or the United States should be considered. This can be further explored through partnerships meetings where key stakeholders participate that SAEK organizes regularly for the last 2 and a half years. 

4

Increasing potential for impact:

• Decreasing corruption is a very complex endeavour, in particular, in Kosovo. In order to increase the potential for impact it is recommended to consider latest research findings on anti-corruptiontools and approaches.

• Accordingly, The project should continue and potentially expand approaches to increase judiciary independence, develop e-tools, to increase budget transparency and to improve social accountability  through kallxo.com and GAP. These approaches demonstrated high potential for impact.

• Develop a comprehensive monitoring and reporting system on RRF indicators at the project level.

• Enhance the kallxo.com platform by introducing additional features that enable reporters of corruption besides location to also indicate the age group, gender and ethnicity. The features could be optional, although there is no strong reason for it as they don’t reveal identity.

5

Increasing sustainability

• Given that the project experience a major shift in its approach, the upcoming implementation period should be focused on sustainability. The project team is encouraged to develop an exit strategy in participatory manner with key stakeholders involved in the project as well as close coordination with the donors to the project. This is also necessary in case a follow-up project is envisaged. The following recommendations should be considered in the upcoming period and could also be included in the exit strategy.

• Develop a comprehensive approach on how to ensure sustainability of the developed policy and legislative framework. Ensure that key stakeholders such as the Kosovo Anticorruption Agency are supported in increasing their capacity to implement its expanded mandate in line with the Law on Anti-corruption Agency and the Law on High Officials Assets and Income Declarations. This will require training of staff and eventually establishing a ToT approach to increase the sustainability of the KACA.

• Considering the comprehensive changes resulting from the newly developed policy and legislative framework, any follow-up project should focus on increasing its sustainability and building on achievements to date.

• Develop a coherent approach on ensuring the effective monitoring of implementation of the Law on Financing of Political Entities/Law on General Elections and increase the capacities of newly established monitoring body.

• Develop a step-by-step approach ensuring a smooth transition from UNDP-driven to nationally driven approach to integrity plans. This approach should focus on increasing the sustainability of existing integrity plans, in particular, linking them with the budgets of the relevant institutions and communicating the new approach to institutions.

• Consider establishing a monitoring mechanism on the implementation of recommendations of the corruption risk assessments carried within the framework of this project. It is assumed that this would result in an increased implementation rate and improved sustainability of the results.

• Institutionalize the approach to corruption proofing based on stakeholder interests, capacities and potential to effectively apply the corruption proofing guidelines in the longrun. Clear institutional accountability lines should be established in order to avoid “blameshifting” in case the guidelines are not implemented coherently. It is recommended to further develop the approach on corruption based on good practices in the region.

• In order to ensure the sustainability of the sentencing guidelines and strengthen accountability on their use, it is recommended to establish an electronic platform providing an overview of the sentencing on corruption cases.

• Support the Supreme Court in amending the sentencing guidelines in line with the revised Criminal Code and build capacities enabling the Supreme Court to amend the sentencing guidelines regularly.

• Ensure that institutions using e-tools to detect and process corruption cases will have the needed capacities to use these tools on a regular basis. E-tools need to be developed as user-friendly platforms, which will lead to efficiency gains.

• Review the use of the PEPs typology in order to strengthen the sustainability of the tool.

• In order to address obstacles to sustainability of the Office of the Disciplinary Prosecutor, it is advisable to recommend relevant institutions a transfer of civil servants who have been involved in the capacity building measures.

• In order to strengthen the sustainability of communication and PR functions of the Office of the Chief Prosecutor, it is recommended to increase communication capacities of this office avoiding any capacity gaps once the embedded advisor will leave in 2020. To thisend, it is recommended to review the communication system and see how capacity gaps and coordination could be increased.

• It is recommended to engage an Expert on Business Model development in order to assess opportunities for Kallxo.com to develop a business model, which does not solely depend on donor funds. In case technical and regulatory obstacles could be overcome crowdfunding through a specific application would be an option to consider.

• In order to ensure the sustainability of the anti-corruption award it is recommended to hand-it over to domestic institutions – either any of the well-known anti-corruption NGOs and/or KACA.

• It is recommended to expand the approach to gender mainstreaming and minority inclusion to move beyond equal participation to empowerment tackling, in particular, areas in which vulnerable and marginalized groups are potentially exposed to corruption. Measures can include support Kallxo.com to add additional features to its platform besides geographical location, whereby users/reporters are also asked to declare their gender, age group and ethnicity. These features can also be optional, but are important in order to assess the impact of corruption awareness and nature of their concerns amongst vulnerable groups i.e. women, youth and minorities.

1. Recommendation:

Recommendations The evaluation suggests that the project on oncoming future phases needs to undertake the following measures: 

Increasing relevance through elaboration of the assumptions and risks in line with the revised reconstructed theory of change.

Management Response: [Added: 2019/04/03] [Last Updated: 2020/12/11]

The Project will continue to be highly relevant to the situational context, tackling key problems at the central and local level through the three components. It will strengthen institutional capacities further to deter, detect and sanction corruption involving institutions and public officials and to strengthen civic engagement mechanisms to hold institutions accountable. The revised theory of change will serve as a platform to assess risks and assumptions continuously to be able to embed strongly the suppression approach of the project.  

Key Actions:

Key Action Responsible DueDate Status Comments Documents
In addition, trainings have been planned for respective institutions to increase capacities based on their amended mandates as per the legislative changes. Also, periodical meetings will be held with institutional representatives to monitor the capacities vis-à-vis the change of the mandates as per the new legislation, the implementation of corruption proofing of legislation, and other regulatory changes.
[Added: 2019/04/03] [Last Updated: 2020/04/16]
Project team 2020/02 Completed All the planned activities for 2019 in this regard were competed successfully. A number of activities regarding meetings, workshops and travel due to COVID-19, has resulted in action for re-programming of activities and funds. As such, the project is focused actually on the development and publication of policy documents, and development of E-tools for KACA and SCPO, in order to support authorities in the anti-corruption efforts. History
2. Recommendation:

Strengthening effectiveness While the overall approach of the project demonstrated to be effective in achieving the expected results (outcomes, outputs), the following could be improved in remaining implementation period: 

• Develop a coherent approach fostering the adoption of the Anti-corruption Strategy, and the amended laws, in particular, the Law on Financing Political Entities/Law on General 64 Elections. In order to increase the needed political clout, closer cooperation with international key players such as the European Union or the United States of America is recommended. If successful this approach of fostering the adoption of laws should also be applied to other policies and laws to be adopted within the framework of this project. 

• Considering that the project focused the first half of the implementation on developing and amending key laws and regulations, the focus on the second half needs to be on ensuring that key stakeholders possess the necessary capacities and mechanisms to effectively implement the improved policy and regulatory framework.

• Develop a coherent approach on ensuring the effective implementation of the Law on Financing of Political Entities/Law on General Elections and increase the capacities of newly established monitoring body in the CEC.

• Institutionalize the approach to corruption proofing based on stakeholder interests, capacities and potential to effectively apply the corruption proofing guidelines in the longrun. Clear institutional accountability lines should be established in order to avoid “blameshifting” in case the guidelines are not implemented coherently. It is recommended to further develop the approach on corruption based on good practices in the region.

• Ensure that key stakeholders such as the Kosovo Anti-corruption Agency are supported in increasing their capacity to implement its expanded mandated in line with the Law on Anti-corruption Agency and the Law on High Officials Assets and Income Declarations. This will require training of staff and eventually establishing a ToT approach to increase the sustainability of the KACA.

• Ensure that institutions using e-tools to detect and process corruption cases will have the needed capacities to use these tools on a regular basis. E-tools need to be developed as user-friendly platforms, which will lead to efficiency gains.

• To support the Supreme Court in amending the sentencing guidelines in line with the revised Criminal Code and to build capacities enabling the Supreme Court to amend the sentencing guidelines regularly.

• Improve cooperation with EU and US in order to increase the political leverage and clout needed to move ahead with the implementation of the project.

• Further develop an approach to foster political will and decrease resistance to change.

• Support Kallxo.com in improving their security architecture to be better protected against threats in the course of anti-corruption investigations. The project could offer a training on security measures for investigative journalists working on corruption. 

Management Response: [Added: 2019/04/03] [Last Updated: 2020/12/11]

While the evaluation found that the overall approach of the project is effective in achieving the expected results (outcomes, outputs), UNDP will develop a more coherent approach fostering the adoption of the Anti-corruption Strategy, and the amended laws; ensure key stakeholders possess the necessary capacities and mechanisms to effectively implement the improved policy and regulatory framework; communicate  regularly to key stakeholder at decision making level for effective implementation of the Law on Financing of Political Entities/Law on General Elections and increase the capacities of newly established monitoring body in the CEC;  institutionalize the approach to corruption proofing based on stakeholder interests, capacities and potential to effectively apply the corruption proofing guidelines in the long-run; ensure that key stakeholders such as the Kosovo Anti-corruption Agency are supported in increasing their capacity to implement its expanded mandated in line with the Law on Anti-corruption Agency and the Law on High Officials Assets and Income Declarations;  ensure that institutions using e-tools to detect and process corruption cases will have the needed capacities to use these tools on a regular basis;  support the Supreme Court in amending the sentencing guidelines in line with the revised Criminal Code and to build capacities enabling the Supreme Court to amend the sentencing guidelines regularly;  improve cooperation with EU and US in order to increase the political leverage and clout needed to move ahead with the implementation of the project; support Kallxo.com in improving their security architecture to be better protected against threats in the course of anti-corruption investigations. Based on these recommendations, the Project team has already reflected in the annual work-plan interventions to address the above-mentioned recommendations as follows: tailored trainings for the relevant institutions such as the prosecution and the Kosovo Anti-Corruption Agency to develop a better understanding of the new laws and amendments; trainings for CEC in regard to the implementation of the new Law on Political Party Financing;  extending cooperation with regional institutions to develop an approach based on good anti-corruption practices in the region; training designed and implemented for KACA staff and establishing a ToT approach to increase the sustainability of KACA to further increase capacities as a need after the implementation of the Law on Electronic Declaration of Assets and Incomes; e-tools developed such as the software for the electronic declaration of assets and incomes; provide training on security measures for investigative journalists working on corruption.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
The project has already designed interventions to implement the recommendations and reflected them duly in the annual work-plan for 2019.
[Added: 2019/04/03] [Last Updated: 2020/02/03]
Project team 2020/01 Completed As an effort to build capacities the representatives of Supreme Court were sent on a study visit to UK Sentencing Council in order for them to learn best practices and increased capacities to develop and implement Sentencing guidelines for the Kosovo context. Similarly a group of representatives form State Chief Prosecutors Office were sent to a study visit in Zagreb, Croatia to learn from the USKOK who uses an e-tool on investigation and prosecution. History
3. Recommendation:

Improving efficiency

• The UNDP Programme Associate responsible for SAEK should ensure that all relevant data is captured and inserted in Atlas on regular basis and as comprehensively as possible, covering all RRF indicators.

• Based on the evaluation the proposed set up of the SAEK project team would be: 

- Project Manager – oversight, monitoring and management o CTA – overall technical advise o Dedicated Project Officers: one for implementation of outcome1 with legal background and another Project Officer with governance/CSO background for implementation of outcome 2 and 3 - JPO – responsible for knowledge management, communication and visibility 

• Alternative approaches to support institutions with integrity plans should be considered such as regular mentoring through the project team. 

• The project should maintain and potentially increase its efforts to monitor and to push for the adoption of developed anti-corruption legislation and policies. Coordinating and building coalitions with other key stakeholders including international actors with political clout such as the European Union or the United States should be considered. This can be further explored through partnerships meetings where key stakeholders participate that SAEK organizes regularly for the last 2 and a half years. 

Management Response: [Added: 2019/04/03] [Last Updated: 2020/12/11]

UNDP has ensured that the project management function, due to resignation of the previous manager for personal reasons, is substituted by the other project staff member as a temporary solution. In the meantime, UNDP has initiated the recruitment process for the new project manager that will be hired before the end of March. Important to note that the first round of recruitment was cancelled due to unavailability of the suitable candidates.  The second round is well in progress and the PM will be recruited before March 2019.

In addition, as it was recommended that further action is to be taken to achieve better results, in particular monitoring of integrity plans. The Project is working with KACA to support existing capacities in monitoring the implementation of integrity plans for public institutions, as per the requirement of the new law on the Kosovo Anti-Corruption Agency.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Complete the written test and interview process and finalise the recruitment latest by 30 March.
[Added: 2019/04/03] [Last Updated: 2020/04/16]
Project team 2020/03 Completed it is completed, new Project Manager started in April 2019. History
Activities to increase KACA capacities with the new mandate of monitoring the implementation of integrity plans have been initiated.
[Added: 2019/04/03] [Last Updated: 2020/04/16]
Project team 2020/03 Completed There were developed the specifications on functional technicalities of the database for monitoring integrity plans. A company was contracted to develop the database, it is foreseen to be ready in June 2020. History
4. Recommendation:

Increasing potential for impact:

• Decreasing corruption is a very complex endeavour, in particular, in Kosovo. In order to increase the potential for impact it is recommended to consider latest research findings on anti-corruptiontools and approaches.

• Accordingly, The project should continue and potentially expand approaches to increase judiciary independence, develop e-tools, to increase budget transparency and to improve social accountability  through kallxo.com and GAP. These approaches demonstrated high potential for impact.

• Develop a comprehensive monitoring and reporting system on RRF indicators at the project level.

• Enhance the kallxo.com platform by introducing additional features that enable reporters of corruption besides location to also indicate the age group, gender and ethnicity. The features could be optional, although there is no strong reason for it as they don’t reveal identity.

Management Response: [Added: 2019/04/03] [Last Updated: 2020/12/11]

While the context remains highly complex and challenging, the project will expand on strengthening the enabling environment for corruption prevention and suppression, work further to increase judicial independence, establishment of e-tools, promote budget transparency and strengthening social accountability through kallxo.com and GAP. In it will strengthen mechanisms for a comprehensive monitoring and reporting system on RRF indicators at the project level. The project will enhance kallxo.com by introducing additional features that enable reporters of corruption besides location to also to indicate the age group, gender and ethnicity.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
The project will undertake actions to address the recommendation to support kallxo.com with the gender disaggregated data. In addition, the Project staff will investigate the most feasible options to allow for a better functioning of a monitoring and reporting system on RRF indicators, especially pursuant to the new theory of change
[Added: 2019/04/03] [Last Updated: 2021/01/06]
Project team 2020/12 Completed SAEK II’s multi-stakeholder approach resulted in creating an inhouse cadre of financial investigation experts who are now using their knowledge to investigate complex financial crime cases. Moreover, the completion of e-tools has enabled anti-corruption authorities to monitor and track cases which has resulted in increased efficiency. History
5. Recommendation:

Increasing sustainability

• Given that the project experience a major shift in its approach, the upcoming implementation period should be focused on sustainability. The project team is encouraged to develop an exit strategy in participatory manner with key stakeholders involved in the project as well as close coordination with the donors to the project. This is also necessary in case a follow-up project is envisaged. The following recommendations should be considered in the upcoming period and could also be included in the exit strategy.

• Develop a comprehensive approach on how to ensure sustainability of the developed policy and legislative framework. Ensure that key stakeholders such as the Kosovo Anticorruption Agency are supported in increasing their capacity to implement its expanded mandate in line with the Law on Anti-corruption Agency and the Law on High Officials Assets and Income Declarations. This will require training of staff and eventually establishing a ToT approach to increase the sustainability of the KACA.

• Considering the comprehensive changes resulting from the newly developed policy and legislative framework, any follow-up project should focus on increasing its sustainability and building on achievements to date.

• Develop a coherent approach on ensuring the effective monitoring of implementation of the Law on Financing of Political Entities/Law on General Elections and increase the capacities of newly established monitoring body.

• Develop a step-by-step approach ensuring a smooth transition from UNDP-driven to nationally driven approach to integrity plans. This approach should focus on increasing the sustainability of existing integrity plans, in particular, linking them with the budgets of the relevant institutions and communicating the new approach to institutions.

• Consider establishing a monitoring mechanism on the implementation of recommendations of the corruption risk assessments carried within the framework of this project. It is assumed that this would result in an increased implementation rate and improved sustainability of the results.

• Institutionalize the approach to corruption proofing based on stakeholder interests, capacities and potential to effectively apply the corruption proofing guidelines in the longrun. Clear institutional accountability lines should be established in order to avoid “blameshifting” in case the guidelines are not implemented coherently. It is recommended to further develop the approach on corruption based on good practices in the region.

• In order to ensure the sustainability of the sentencing guidelines and strengthen accountability on their use, it is recommended to establish an electronic platform providing an overview of the sentencing on corruption cases.

• Support the Supreme Court in amending the sentencing guidelines in line with the revised Criminal Code and build capacities enabling the Supreme Court to amend the sentencing guidelines regularly.

• Ensure that institutions using e-tools to detect and process corruption cases will have the needed capacities to use these tools on a regular basis. E-tools need to be developed as user-friendly platforms, which will lead to efficiency gains.

• Review the use of the PEPs typology in order to strengthen the sustainability of the tool.

• In order to address obstacles to sustainability of the Office of the Disciplinary Prosecutor, it is advisable to recommend relevant institutions a transfer of civil servants who have been involved in the capacity building measures.

• In order to strengthen the sustainability of communication and PR functions of the Office of the Chief Prosecutor, it is recommended to increase communication capacities of this office avoiding any capacity gaps once the embedded advisor will leave in 2020. To thisend, it is recommended to review the communication system and see how capacity gaps and coordination could be increased.

• It is recommended to engage an Expert on Business Model development in order to assess opportunities for Kallxo.com to develop a business model, which does not solely depend on donor funds. In case technical and regulatory obstacles could be overcome crowdfunding through a specific application would be an option to consider.

• In order to ensure the sustainability of the anti-corruption award it is recommended to hand-it over to domestic institutions – either any of the well-known anti-corruption NGOs and/or KACA.

• It is recommended to expand the approach to gender mainstreaming and minority inclusion to move beyond equal participation to empowerment tackling, in particular, areas in which vulnerable and marginalized groups are potentially exposed to corruption. Measures can include support Kallxo.com to add additional features to its platform besides geographical location, whereby users/reporters are also asked to declare their gender, age group and ethnicity. These features can also be optional, but are important in order to assess the impact of corruption awareness and nature of their concerns amongst vulnerable groups i.e. women, youth and minorities.

Management Response: [Added: 2019/04/03] [Last Updated: 2020/12/11]

The project tackles a very complex issue with potential political implications. Nonetheless, it will make continuous efforts to demonstrate tangible results on regular bases. It will further develop policy frameworks in the remaining life time of the project, that will become the strong platform for suppression. The team will continue to maintain a “careful” approach to not attract the reaction of “interest groups” that would become obstacle to reform when pushing for legal frameworks that will contribute to sustainable project results.  The project will continue to collaborate with a large number of stakeholders who have strong political cloud in order to promote the suppression approach and action by relevant institutions beyond the project end date

Key Actions:

Key Action Responsible DueDate Status Comments Documents
The Project will consider external expertise where feasible to develop and exit strategy as per the recommendation of the evaluation team. The exit strategy will be developed as part of an inclusive process, with key stakeholders, beneficiaries and project partners. The project will develop a step-by-step approach ensuring a smooth transition from UNDP-driven to nationally driven approach, especially to integrity plans, capacities of KACA and other relevant institutions, establishing an electronic platform providing an overview of the sentencing on corruption cases with all relevant institutions involved. UNDP will engage an expert on Business Model development in order to assess opportunities for Kallxo.com to develop a business model, which does not solely depend on donor funds. And last but not least, to expand the approach to gender mainstreaming and minority inclusion to move beyond equal participation to empowerment, tackling in particular areas in which vulnerable and marginalized groups are potentially exposed to corruption
[Added: 2019/04/03] [Last Updated: 2021/01/06]
Project team 2020/12 Completed SAEK II has handed over to beneficiaries a number of e-tools including an e-declaration of assets system, case management system and e-monitoring tools for the anti-corruption strategy and integrity plans to the Anti-corruption Agency that has allowed the Agency to fulfill its mandate independently. An e-tool for tracking discrepancies in declared income against expenditures has opened up new cases for the Tax Administration, and the FIU has two databases for tracking PEPs assets. The prosecution now has appointed spokespersons who regularly inform the public of their work. Through training and expert advice a corruption proofing of legislation inter-agency working group became fully functional and completed independently a pivot review of legislation for potential gaps and risks. History

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