Success message
error message
warn message
Midterm Evaluation - Support to Anti-Corruption Efforts in Kosovo II
Commissioning Unit: Kosovo
Evaluation Plan: 2016-2020
Evaluation Type: Project
Completion Date: 03/2019
Unit Responsible for providing Management Response: Kosovo
Documents Related to overall Management Response:
 
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

Latest Evaluations

Contact us

1 UN Plaza
DC1-20th Floor
New York, NY 10017
Tel. +1 646 781 4200
Fax. +1 646 781 4213
erc.support@undp.org