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

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Evaluation Plan:
2016-2020, Kosovo
Evaluation Type:
Final Project
Planned End Date:
07/2020
Completion Date:
08/2020
Status:
Completed
Management Response:
Yes
Evaluation Budget(US $):
6,000

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Title Final Evaluation - Support to Anti-Corruption Efforts in Kosovo II
Atlas Project Number: 00086608
Evaluation Plan: 2016-2020, Kosovo
Evaluation Type: Final Project
Status: Completed
Completion Date: 08/2020
Planned End Date: 07/2020
Management Response: Yes
UNDP Signature Solution:
  • 1. Governance
Corporate Outcome and Output (UNDP Strategic Plan 2018-2021)
  • 1. Output 1.2.3 Institutions and systems enabled to address awareness, prevention and enforcement of anti-corruption measures to maximize availability of resources for poverty eradication
SDG Target
  • 16.5 Substantially reduce corruption and bribery in all their forms
  • 16.6 Develop effective, accountable and transparent institutions at all levels
Evaluation Budget(US $): 6,000
Source of Funding: SDC - 10282 and DANIDA - 00095
Evaluation Expenditure(US $): 24,800
Joint Programme: No
Joint Evaluation: No
Evaluation Team members:
Name Title Email Nationality
Krenar Loshi Local Evaluation Consultant krenar.loshi@gmail.com KOSOVO
GEF Evaluation: No
Key Stakeholders: Kosovo Institutions, Donor and UNDP
Countries: KOSOVO
Lessons
1.

Addressing requests for external donor support to different donors:

The Kosovo beneficiaries quite often address requests for same type of support to various international organisations and development partners. If there is no regular donor coordination and cooperation among them, then there exist a huge risk for duplication of efforts and overlaps. Nevertheless, it’s evident that the project is aware of this and has taken measures to avoid such situations in the future, as for e.g. having made a written agreement with the CoE PECK project on exchanging information, forging joint policies and implementing joint activities in SAEK III.


2.

Over-reliance on external donor support:

In general, the Kosovo beneficiaries over-relay on external donor support even in cases when they would be capable to develop and provide certain results without external donor support. As such, the beneficiaries’ possibility to obtain easily external donor support makes beneficiaries rather passive, less pro-active and over-reliant on donor support. Although it’s a general risk, the project needs to strongly consider and build in this risk in future phases. 


3.

UNDP neutrality:

The UNDP neutrality provides strong project impartiality and ensures that no hidden geo-political interest are behind the offered assistance. Various development partners, international organisations and individual donor states have various geo-political interest and agendas. These interests sometime can put beneficiaries in temptation and confusion in selecting appropriate aid cooperation partners due to political divergences. As such, as a neutral entity, UNDP has a significant advantage built over the years through provided assistance, and strengthening trust by government institutions. Based on this, a conducive environment has been established for further assistance by UNDP in various areas, not exclusively in the field of anti-corruption.


4.

Success of the project depended on political will:

In general, the staff-turn over within the Kosovo public institutions seems not to be problematic except within the Kosovo Police. Nevertheless, the effectiveness of the project is heavily dependent on political and institutional willingness which remains problematic even though anti-corruption remains one of the main societal problems


5.

UNDP/SAEK as a guardian of Kosovo anti-corruption institutions:

The Kosovo public institutions, particularly KACA, are often under strong political influence and unjustified political attacks, even by ruling elites that many times oppose or reject developed legal solutions. UNDP/SAEK turned out to be a guardian of recognised international standards and best practices and providing impartial and neutral technical back-up to agencies as well as adequately supporting agencies’ efforts to introduce anti-corruption standards in line with international treaties (e.g. UNCAC). For this reason, SAEK remains highly important for Kosovo anti-corruption governance.


6.

Flexibility in project implementation:

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.


7.

Demonstrating competence and gaining trust:

The solid competencies of the project team, reconfirmed also during the final project evaluation, provided the project with access to get involved in sensitive issues and gain full trust of key stakeholders. This approach, and possibly the same staffing, to the possible extent should be maintained also during the next phase.  


Findings
1.

Relevance: SAEK II builds on the firm foundation of SAEK I, which allows for greater continuity and accurate interventions. As such, the project was highly relevant to the situational context and addressed in nature the challenges and demands of the targeted beneficiaries. The project had a coherent Logical framework and a clear Theory of Change. One aspect highlighted by the key stakeholders was the participatory character of the design process. The selection of the targeted beneficiaries was also particularly adequate and encompasses all the key anti-corruption institutions. The project was also well aligned with the relevant Sustainable Development Goals and national policies.


2.

Effectiveness: The evaluation of the effectiveness showed that the project has achieved most of the expected results as envisaged in the project action document. SAEK successfully supported prevention and suppression of corruption within the Kosovo public institutions by providing effective support to various national beneficiaries and stakeholders. The project was not only successful in providing capacity building support, but also in providing necessary technical support, resulting in more efficient detection and prosecution of corruption (e.g. providing access to Egmont Group, relevant databases, etc.). With the shift in the project concept, the project has also become directly engaged in criminal justice matters.  With a number of activities that SAEK provided to the criminal justice institutions, the project went into the heart of anti-corruption.


3.

Efficiency: SAEK applied an adequate and comprehensive approach, supporting the macro policy level,  prosecution, judiciary, legislative, executive and citizen engagement through the existing civil society mechanisms on reporting corruption and promotion of investigative journalism. SAEK had sufficient and adequate internal capacities and capabilities to comprehensively support beneficiaries’ anti-corruption efforts. The challenges that emerged during the project life-span were adequately addressed by the project as adequate mitigation measures have been developed and implemented to tackle the challenges/problems, which impacted on the project implementation. The available resources were well transformed into the project activities which has led to achievement of intended results in qualitive, quantitative and timely manner. The project’s management and expertise capacities were sufficient to ensure adequate implementation of the planned activities as the project engaged skilled and experienced project staff, embedded advisors and external experts who significantly contributed to the achievement of the project objectives. SAEK also had an important role in pushing policies and laws through the Kosovo Assembly which most likely would have not passed without SAEK’s push and support. Furthermore, the SAEK’s yearlong Certified Fraud Examination course, implemented through a Train-the-Trainer approach, enabled the Society of Certified Accountants and Auditors of Kosovo (SCAKK) instructors who attended the course to use the course material for regular Certified Fraud Examination courses, delivered exclusively through SCAAK. This is an excellent example of successful ToT, handed over to national authorities who now run it completely on their own without UNDP’s support. Yet, the evaluation found that there is room for improvement regarding the project visibility and better institutionalisation of knowledge provided through capacity building activities (e.g. strengthened cooperation with relevant educational institutions, retain train of trainers approach similar to SCAAK, etc).


4.

Impact: Across the board, it was clear that the project beneficiaries had experienced capacity and organisational changes as a result of project interventions, which were able to influence the regulations and mandate of the partner agencies. The project had an explicit focus on strengthening partner agency leadership and strategy, particularly evident in relation to Kosovo Anti Corruption Agency The project contributed to greater confidence in pursuing fight against corruption largely due to learning new knowledge and techniques at individual and organizational level. All partner agencies were able to demonstrate changed processes and systems as a result of interventions by the project through capacity development measures and systems development. The transformation at the community level is best demonstrated by the number of reports on corruption through CSO platform kallxo.com, which increased fivefold to 2852 reports received in 2019, compared to 402 reports received in 2015.


5.

Sustainability: Overall, it is clear that the project was able to contribute to sustainable results in terms of improved capacity of government agencies to fight corruption, particularly in relation to systems and processes. However, sustainability of achieved results remains vulnerable due to the persistent lack of political will, which is a concern since the systemic changes achieved are more fragile if structural and legal changes required for the full functioning of the systems and processes designed are stalled or not taking place. In absence of a clear EU integration path, the public pressure poses as the main influencing factor in fight against corruption, and should be supported and strengthened further.


Recommendations
1

1: Continuation of donor support

2

2: Retainment of  mixed aid approach consisted of capacity building and hard component

3

3.  Continuation of capacity building activities and specialised training courses

4

4: Further support in facilitation inter-agency and international cooperation in fight against corruption

5

Improve the project visibility

6

6: To follow up on corruption risk assessments and increase cooperation with the Kosovo Bar Association, Notary and Bailiff services

7

7: To enhance gender and other cross-cutting issues

8

8:  Strengthen evidence gathering, monitoring and data analysis

1. Recommendation:

1: Continuation of donor support

Management Response: [Added: 2020/08/03] [Last Updated: 2020/08/10]

The overall anti-corruption efforts have been successful during SAEK I and SAEK II with the focus to support and assist relevant public institutions on putting different anti-corruption mechanisms, regulations and policies in place, while raising awareness and engaging citizens in the fight against corruption. Building upon achieved results during SAEK II still requires sustained donor support..This was foreseen in during the implementation of SAEK II, which was also prerequisite in order to continue combatting corruption in new ways, such as assets confiscation and recovery

Key Actions:

Key Action Responsible DueDate Status Comments Documents
1.1 Mid-way of the final implementation year of SAEK II programme management initiated discussion with the donor SDC and engaged in discussion with the new possible donor SIDA for funding of SAEK III. The continuation of donor support has been ensured and agreement signed with SDC and SIDA until 2024
[Added: 2020/08/10]
Project Team and Senior Management 2020/06 Completed
2. Recommendation:

2: Retainment of  mixed aid approach consisted of capacity building and hard component

Management Response: [Added: 2020/08/03] [Last Updated: 2020/08/10]

The project has planned for SAEK III a mixed aid approach in order to retain high buy-in, keep the momentum and enhance sustainability of the results. Further, during SAEK III we will also minimise beneficiaries over-reliance on SAEK support and stimulate for anti-corruption efforts despite the external donor support.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
The interventions in the project document for SAEK III have been developed in the manner of mixed aid approach.
[Added: 2020/08/10] [Last Updated: 2020/10/13]
Project and Programme Team 2020/09 Completed SAEK III has addressed this recommendation, by reflecting it in the interventions and activities of SAEK III project document, and also the annual work plan. History
Establishment of an Assets Recovery Resource Centre
[Added: 2020/08/10]
Project and Programme Team 2024/03 Not Initiated History
Establishment of a Unit for Tracing and Identification of Stolen Assets
[Added: 2020/08/10]
Project and Programme Team 2023/03 Not Initiated The Unit will be established by the Office of the Chief Prosecutor and UNDP together with the Basel Institute will set up the SoPs and train staff. History
3. Recommendation:

3.  Continuation of capacity building activities and specialised training courses

Management Response: [Added: 2020/08/03] [Last Updated: 2020/08/10]

The project will continue with the provision of further support in capacity building and specialised training courses and to greater extent provide knowledge through the ToT approach or by adapting relevant training curricula in order to ensure better top down institutional dissemination of knowledge.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Development of accredited assets recovery training curricula
[Added: 2020/08/10]
Project team 2022/06 Not Initiated The accredited assets recovery curricula will be mandatory for newly appointed staff to the Assets Recovery Unit and a continuous education programme will be developed to ensure knowledge retention.
Training of trainers for specific modules covered by the project
[Added: 2020/08/10]
Project team 2021/01 Not Initiated Basel Institute will conduct ToTs for the accredited courses so as to pass them over to the Judicial Academy who will conduct the courses after the end of the project.
4. Recommendation:

4: Further support in facilitation inter-agency and international cooperation in fight against corruption

Management Response: [Added: 2020/08/03] [Last Updated: 2020/08/10]

It is important to increase fight against grand corruption and achieve more tangible results, therefore the project, during SAEK III, will further facilitate international cooperation with relevant law enforcement and anti-corruption agencies in other countries and relevant international organisations. The project will engage in a partnership with Basel Institute of Governance.

Key Actions:

Key Action Responsible DueDate Status Comments Documents
The project will continue to organize and host the now-traditional Partnership Briefing forum whereby all international actors in the anti-corruption field will discuss matters pertinent to its activities
[Added: 2020/08/10]
Project Team/Programme Team 2020/12 Initiated Partnership briefings will be held twice a year so as to ensure complimentarily among international actors.
Support to the investigations of criminal corruption cases through Basel Institute on Governance expertise on assets recovery
[Added: 2020/08/10]
Project Team/Programme Team 2020/12 Not Initiated The Basel Institute will provide expert advice on cases, international cooperation and assets tracing with an aim towards building the capacities of the investigators to handle cases completely on their own by the completion of the project.
5. Recommendation:

Improve the project visibility

Management Response: [Added: 2020/08/03] [Last Updated: 2020/08/10]

The project developed numerous visibility materials especially in the last year of SAEK 2.During SAEK III UNDP will increase visibility of project results to a greater extent

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Use social media and UNDP website for visibility of project results Develop a communication/visibility plan
[Added: 2020/08/10]
Project and programme team 2020/12 Initiated The plan will ensure visibility for the results of the project which aim to strengthen the public support of local institutions tasked with combating corruption.
Review and update if necessary, the comms/visibility plan on quarterly bases
[Added: 2020/08/10]
Project and programme team 2020/12 Not Initiated Regular reviews will ensure maximalization of impact.
6. Recommendation:

6: To follow up on corruption risk assessments and increase cooperation with the Kosovo Bar Association, Notary and Bailiff services

Management Response: [Added: 2020/08/03] [Last Updated: 2020/08/10]

While the project deems it important to follow up on the CRA’s, this output is not at the core of the implementation of SAEK III

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Organize public hearings through the Assembly of Kosovo Legislative Committee to discuss the CRAs and responses to recommendations
[Added: 2020/08/10]
Project and programme team 2020/12 Not Initiated The public hearings will ensure a wider public debate and the initiation of new policies and reforms by local authorities thereby maximizing the results of the project and ensuring local ownership.
Organize round tables with the MoJ and the respective chambers to discuss findings and possible solutions.
[Added: 2020/08/10]
Project and programme team 2020/12 Not Initiated The roundtables on the CRAs will ensure follow up measures that can be taken by the local authorities.
7. Recommendation:

7: To enhance gender and other cross-cutting issues

Management Response: [Added: 2020/08/03] [Last Updated: 2020/08/10]

The project has taken in greater account gender and other cross-cutting issues during the design of SAEK III project.

 

Key Actions:

Key Action Responsible DueDate Status Comments Documents
The project will conduct a Gender Equality Related Corruption Risks and Vulnerabilities survey in public and private sectors
[Added: 2020/08/10] [Last Updated: 2020/10/13]
Project and programme team 2020/09 Completed SAEK III has addressed this recommendation, by implementing the activity of Gender Survey on Corruption Related Vulnerabilities in the Public and Private sector. As per rules and procedures, the RfP for companies/organizations/institutions is already announced, and steps will be followed to complete the process, resulting in the company/organization/institution selected to conduct the survey and deliver the report, by the end of 2020, beginning of 2021. History
8. Recommendation:

8:  Strengthen evidence gathering, monitoring and data analysis

Management Response: [Added: 2020/08/03] [Last Updated: 2020/08/10]

The project will enhance monitoring and data analysis through its activities as foreseen in the AWP

Key Actions:

Key Action Responsible DueDate Status Comments Documents
Ensure strong and well informed indicators and targets in the new AC strategy
[Added: 2020/08/10]
Project and programme team 2020/12 Initiated
Monitoring of implementation of Anti-corruption Strategy
[Added: 2020/08/10]
Project and programme team 2024/06 Not Initiated Monitoring by KACA allows transparency oversight and the accountability of local institutions.

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