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
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 Email Nationality
Krenar Loshi Local Consultant krenar.loshi@gmail.com 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.

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

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.

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.

4. 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. 

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.

 


Recommendations
1

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

2

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.

3

The project should maintain and potentially increase its efforts to monitor and to push for the adoption of developed anti-corruption legislation and policies.

4

The project should continue and potentially expand approaches to increase judiciary independence, develop e-tools, to increase budget transparency and to improve social accountability.

5

Increase sustainability with the development of an exit strategy and develop a step-by-step approach ensuring a transition from UNDP to a national driven approach

1. Recommendation:

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: 2019/04/12]

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]
Project team 2019/12 Initiated
2. Recommendation:

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.

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

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]
Project team 2020/01 Initiated
3. Recommendation:

The project should maintain and potentially increase its efforts to monitor and to push for the adoption of developed anti-corruption legislation and policies.

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

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]
Project team 2020/03 Initiated
Activities to increase KACA capacities with the new mandate of monitoring the implementation of integrity plans have been initiated.
[Added: 2019/04/03]
Project team 2020/03 Initiated
4. Recommendation:

The project should continue and potentially expand approaches to increase judiciary independence, develop e-tools, to increase budget transparency and to improve social accountability.

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

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]
Project team 2020/12 Not Initiated
5. Recommendation:

Increase sustainability with the development of an exit strategy and develop a step-by-step approach ensuring a transition from UNDP to a national driven approach

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

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]
Project team 2020/12 Initiated

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