2018
Anti-Corruption Commission, Sierra Leone, we believe in communication, accountability and transparency.

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NACS NATIONAL ANTI-CORRUPTION STRATEGY 2014-2018

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40. 40

21. 21 8. KENEMA The NACS Team, Regional Manager Kenema & Implementation Committee Members Participants in Kenema

32. 32 NACS Manager Patrick M George Making a Power Point Presentation A Cross - Section of IMCs of various MDAs in Freetown

9. 9 process namely: The Procurement Officers, Internal Auditors and the Focal Persons. Focal Persons of MDAs without IMCs were required to make a representation on behalf of their MDAs. The NACS Secretariat was mindful of the fact that a member of the Implementation Committee in the person of the Prof. Abu Sesay had been relieved of his duties and may need a replacement at the end of the Implementation Year. This means in effect that we only now have five (5) members of the Implementation Committee.

13. 13 Implementation Committee meets with ACC staff in the Southern Regional Office  Established an IMC at ACC Regional Office, Bo comprising 5 members and have appointed a focal person . Cross Section of Staff of the Bo Regional Office during the meeting

36. 36 The engagement ended on a positive note with IMCs encouraged to approach the NACs Secretariat for clarifications and/or information. The Secretariat was advised by the Chairman of the occasion to forward addition information like the Terms of References for IMCs and Focal Persons, NACS 2014 - 2018 documents, Template of the Work Plan and copies of the Power Point presentation to all IMCs. Efforts are now being made by the Secretariat to visit those IMCs that did not attend the two assessment meetings . The Fire Force Boss Making a Contribution A Representative from Airport Authority Making a Comment

31. 31 Hon. Claude M D Kamanda Making a Statement Mohamed Abu Sesay Making a Statement The NACS Manager, in his Power Point presentation gave the background to the Strategy, the Terms of Reference of both the Implementation Committee, the Integrity Management Committees and Focal Persons. He drew attention to the fact that some work plans submitted by certain MDAs were not in line with the matrix. He therefore gave an example of a work plan in the form of a template which was to be replicated by all MDAs for the sake of uniformity. He emphasized the fact that if the IMCs got it wrong on the matrix then they were bound to fail on the implementation itself. MDAs were bound to implement what was spelt out in the matrix. Emerging corruption issues could be added only when what was spelt out in the matrix was captured otherwise the efforts would go in vain. He encouraged all to contact the Secretariat for clarification or issues of concern to the smooth implementation of the matrix.

1. REPORT OF THE ASSESSMENT ON THE IMPLEMENTATION OF THE NATIONAL ANTI - CORRUPTION STRATEGY 2014 - 2018 BY THE INTEGRITY MANAGEMENT COMMITTEES PREPARED BY THE NACS IMPLEMENTATION COMMITTEE JULY 2015

28. 28 The team also requested that the ACC office in the district provide all the relevant documentation to the MDAs. They also requested that two copies of each document be sent addressed to the head of the entity and the Focal Persons respectively to ensure that the information is available to them specifically. They also advised them to ensure that they open at least two files (one for the head of the entity and another for the focal person) to ensure that NACS activities in the MDA is well recorded and kept. They also advised that it is preferable for each MDA in the district to have their own IMC or have a focal person in the case that they do not have the requisite number of personnel. Above all they should try to form their IMCs immediately and develop their work plans which should be submitted to the ACC Office. These work plans will be reviewed to ensure that the activities correspond to the issues to be addressed by the MDA in the NACS Implementation Plan as activities that do not correspond though implemented will not be considered. The team reminded them that there will be another Assessment Exercise in six months time by which time substantial progress should have been made by each MDA.

33. 33 Sixty (60) MDAs in all were invited but only forty - four(44) were in attendance. Sixteen (16) MDAs in all did not attendance. Efforts are now being made by the Secretariat to visit the sixteen MDAs in their various offices. Thereafter, follow up actions on the MDAs that did attend would follow. These efforts are all geared to ensuring that no excuses are made for non compliance by MDAs. A Representative of the Sierra Leone Police Force Making a Statement The meeting ended with questions and comments on the way forward. One question that pricked the attention of the Secretariat and that is worth reporting on was the one asked by a representative of the National Commission for Privatization. (NCP). Dr. Susan Robert of NaCSA Making a Comment

20. 20 Contributions/Comments/Questions asked by participants The team also requested that the ACC office in the region provide all the relevant documentation to the MDAs. They also requested that two copies of each document be sent addressed to the head of the entity and the Focal Persons respectively to ensure that the information is available to them specifically. They also advised them to ensure that they open at least two files (one for the head of the entity and another for the focal person) to ensure that NACS activities in the MDA is well recorded and kept. They also advised that it is preferable for each MDA in the district to have their own IMC or have a focal person in the case that they do not have the requisite number of personnel. Above all they should try to form their IMCs immediately and develop their work plans which should be submitted to the ACC Office. These work plans will be reviewed to ensure that the activities correspond to the issues to be addressed by the MDA in the NACS Implementation Plan as activities that do not correspond though implemented will not be considered. The team reminded them that there will be another Assessment Exercise in six months time by which time substantial progress should have been made by each MDA.

15. 15 4. KENEMA The Regional Manager Kenema - Mr. Peter Baio Kamara making a statement 4.1 Progress made Issues raised Manager Mr. Peter B. Kamara informed the team of the following in terms of progress made:  A follow - up engagement was done in February 2015 wherein they engaged the MDAs on their expected tasks/roles. In May 2015, the NACS Manager and NACS Coordinating Officer from the Secretariat also paid a visit.

11. 11 Statement by Hon. Claude M.D. Kamanda (Chairman Transparency and Accountability Committee - House of Parliament) Mrs. Lavina Banduah making a statement (Executive Director TI - SL)  The Anti - Corruption National Strategy is a plan to prevent corrupt practices in MDAs. This is also in line with Sec 7(1)(a) and 7(2)(g) & (h) of the ACC Act 2008. Further on the fight and for ease of implementing the NACS at MDA level, the IMCs are to be established. The word 'Integrity' clearly depicts who is in such Committee. It speaks that you are outstanding and to be responsible. The IMCs are aides to the fight against corruption in the MDAs,

18. 18 6. KONO 6.1 Not much had been done in the Kono office therefore the NACS Manager made the following Recommendations  ACC regional office should be encouraged to form an IMC there is need for staff and the Manager to be aufait with the NACS 7. MEETING WITH IMC/FOCALPERSONS OF MDA 7.1 Bo The Southern Province meeting for MDAs in the Southern Province was held in Bo city, at the Bo District Council Hall. Participants comprised representatives of MDAs from Bo, Moyamba, Bonthe and Pujehun Districts.

27. 27 Due to the location of Kono District in the Eastern Province, a separate meeting was conducted exclusively for the MDA ’ s in the district on Wednesday 22 nd July 2015. It was held at the Fachima hall in Koidu town, Kono district. Due to the fact that all MDA representatives present claimed that they have not received any of the related documents, they have not been able to undertake the requisite action. In view of this the team informed them of some of the progress and challenges faced by other MDAs in the other regions visited. They informed them of the legal provisions mandating their compliance and the actions that could be taken for non - compliance. They encouraged them to work harder to fulfill their expected tasks as no further excuse will be accepted for non compliance by the end of 90 days as prescribed by the ACC Act for compliance. At the end of the exercise a report will be compiled by the Team and an Annual Report will be presented to H.E. the President who is the head of the Implementation Committee. Cross - section of the Participants at the Fachima Hall in Kono

35. 35 A Representative of an IMC Making a Comment Emerging corruption issues could only be addressed by an MDA if and only if steps are being taken by that MDA to implement what is already spelt out in the matrix. The actions spelt out in the matrix are therefore not voluntary but mandatory in contrast with issues as spelt out in the Anti - Corruption Toolkit. MDAs will not be assessed or monitored with reference to issues in the Toolkit. It is however important to note that some corruption issues as stated in the Toolkit are already action points for some MDAs as provided for under the matrixes specific to their institution; e.g issues surrounding Asset Declaration and adherence to NPPA Laws and regulations are relevant to almost all MDAs. It must be noted therefore that if the law stipulates that certain actions must be done by MDAs then it must be followed irrespective of whether that particular act is only "voluntary" to the overall strategic objectives of the ACC in achieving its policy outlines as provided for in the NACS. Therefore the use of the word "Voluntary " in defining the ACC Toolkit does not necessarily mean non observance of the provisions of the law as they relate to Procurement or Asset declaration. It basically means that with reference to the Strategy the mandatory provisions are those spelt out in the matrix and that outside the matrix other issues are voluntary. This does not however imply that if the law demands compliance, this must not be done by virtue of the fact that the NACS 2014 - 2018 says so.

26. 26 the entity and another for the focal person) to ensure that NACS activities in the MDA is well recorded and kept. They also advised that it is preferable for each MDA in the district to have their own IMC or have a focal person in the case that they do not have the requisite number of personnel. Above all they should try to form their IMC ’ s immediately and develop their work plans which should be submitted to the ACC Office. These work plans will be reviewed to ensure that the activities correspond to the issues to be addressed by the MDA in the NACS Implementation Plan as activities that do not correspond though implemented will not be considered. The team reminded them that there will be another Assessment Exercise in six months time by which time substantial progress should have been made by each MDA. 10. KONO Sub - Regional Office Assessment Team, LUC,ONS, RSLAF and Sub Regional Manager Kono on the High Table Due to the location of Kono District in the Eastern Province, a separate meeting was conducted exclusively for the MDA ’ s in the district on Wednesday 22 nd July 2015. It was held at the Fachima hall in Koidu town, Kono district.

25. 25  Some MDAs claimed they have formed their IMC and have embarked on public education and awareness raising activities. However their activities have been hampered by the lack of funds for related activities as provision for such was not part of their MDA ’ s budget. 9.3 Response by the Team The Team commended the MDAs in general for the frank discussions and for the efforts made by some to comply with the mandate. They informed them of the need to ensure full compliance with the mandate specific to their MDAs in the NACS implementation plan and again reiterated the legal provisions in the ACC Act mandating their compliance and the actions that could be taken for non - compliance. They encouraged them to work harder to fulfill their expected tasks as no further excuse will be accepted for non compliance by the end of 90 days as prescribed by the ACC Act for compliance. At the end of the exercise a report will be compiled by the Team and an Annual Report will be presented to H.E. the President who is the head of the Implementation Committee. The team also requested that the ACC office in the region provide all the relevant documentation to the MDAs. They also requested that two copies of each document be sent addressed to the head of the entity and the Focal Persons respectively to ensure that the information is available to them specifically. They also advised them to ensure that they open at least two files (one for the head of

6. 6 to put this as a thing of the past especially as we envisage help from our development partner DFID through its project "Pay - No - Bribe" campaign. Most importantly, MDAs have also been encouraged to implement the provisions in the Anti - Corruption Toolkit as provided for in the NACS 2015 - 2018.. In May this year, an Integrity Pledge was signed with five pilot MDAs. They were required in turn to sign Integrity Pacts in all procurement contracts thereby negating all instances or likelihood of offering, soliciting or accepting bribes through the procurement process. These efforts are all geared to redefine ourselves as Sierra Leoneans in the fight against corruption. The IMCs have got the primary responsibility to ensure that measures specific to their MDAs are implemented. It is meant to be a seven man committee with two compulsory members namely the Procurement Officer and the Internal Auditor. I do wish to talk on the numerous problems and challenges that they face but suffice to say that they are surmountable. Some of the actions do not need any budgetary implications but only require carrying out the day to day chores of the various MDAs. Arising from the above, we want to encourage those MDAs that have done well to do more and those who are still faced with challenges to put more effort. Together we can confront and control the "cancer of corruption". Nabillahi - Musa Kamara - Director of NACS

34. 34 A cross - section of the IMCs of Various MDAs His question was why was it that the NACS Manager described actions worth implementation by MDAs under the Anti - Corruption Toolkit as Voluntary. The question was very important, he claimed, by virtue of the fact that if donor partners were to know, for example, that issues relating to MDAs adherence to National Public Procurement Authority (NPPA) Laws and Regulations were voluntary, they might not be satisfied. The Manager's response to his question is crucial and worthy of note. This is so because a member of the Implementation Committee also thought he was wrong in saying so and that the provisions must not be described as voluntary. As technical experts on the NACS 2014 - 2018 the claim is laid that the provisions under the Anti - Corruption Toolkit are voluntary. They are not mandatory. This is in contrast with the mandatory provisions spelt out under the matrix i.e The National Ant - Corruption Strategy Implementation Action Plan 2014 - 2018 which all MDAs specified in the strategy must implement. Those MDAs that were not specifically mentioned could, through the Secretariat initiate their own system weaknesses and proposed measures which they could implement. However if an MDA is specifically mentioned, issues identified in the matrix must be implemented. Failure to comply would have negative implications for the entity which may not be limited to activating the sanctions pursuant to Section 8 of the ACA 2008. If an MDA carries out actions contrary to what is spelt out in the matrix, then these cannot be of help to the institution for the purpose of the Assessment by the Implementation Committee members or monitoring purposes by the Civil Society organization (CSO).

23. 23 8.4 Response by the Team The team commended the MDAs in general for the frank discussions and for the efforts made by some to comply with the mandate. They informed them of the need to ensure full compliance with the mandate specific to their MDAs in the NACS implementation plan and again reiterated the legal provisions in the ACC Act mandating their compliance and the actions that could be taken for non - compliance. They encouraged them to work harder to fulfill their expected tasks as no further excuse will be accepted for non compliance by the end of 90 days as prescribed by the ACC Act for compliance. At the end of the exercise a report will be compiled by the Team and an Annual Report will be presented to H.E. the President who is the head of the Implementation Committee. The team also requested that the ACC office in the region provide all the relevant documentation to the MDAs. They also requested that two copies of each document be sent addressed to the head of the entity and the Focal Persons respectively to ensure that the information is available to them specifically. They also advised them to ensure that they open at least two files (one for the head of the entity and another for the focal person) to ensure that NACS activities in the MDA is well recorded and kept. They also advised that it is preferable for each MDA in the district to have their own IMC or have a focal person in the case that they do not have the requisite number of personnel. Above all they should try to form their IMC ’ s immediately and develop their work plans which should be submitted to the ACC Office. These work plans will be reviewed to ensure that the activities correspond to the issues to be addressed by the MDA in the NACS Implementation Plan as activities that do not correspond though implemented will not be considered. The team reminded them that there will be another Assessment Exercise in six months time by which time substantial progress.

24. 24 8. MAKENI The Northern Province meeting for MDAs in the Northern Province was held in Makeni city, at the Sierra Leone Teachers Union (SLTU) Hall. Participants comprised representatives of MDAs from Bombali, Tonkolili, Kambia, Koinadugu and Port Loko. 9.1 Progress Made  Some MDAs have formed their IMCs, developed their Work plan which has been either submitted to the ACC office or is presently with their Focal Person 9.2 Challenges Faced  The frequent transfer of personnel  The inadequate number of personnel in some MDAs to form the 7 man IMC. As such some have formed their IMC at regional level.  Lack of funding allocation for NACS related activities.  Some MDAs claimed they have not received the related documents and as such have not taken the required action. They requested that the documents be made available to them.

2. 2 Table of Contents List of Abbreviations Foreword .......................................................................................... 1. Introduction...................................................................................................4 2. Issues Identified .............................................................................. 3. Meetings with the ACC Regional Staff........................................................16 3.1 Bo..............................................................................................................17 3.2 Kenema.....................................................................................................2 3.3 Makeni.......................................................................................................24 3.4 Kono..........................................................................................................26 4. Meeting with IMCs/Focal Persons...............................................................27 4.1 Bo..............................................................................................................27 4,2 Kenema.....................................................................................................32 4.3 Makeni.......................................................................................................36 4.5 Kono..........................................................................................................39 5. Meetings with IMCs/Focal Persons in Freetown..........................................43 6. General Observations and recommendations ...................................... Appendixes...................................................................................................44

12. 12 3. MEETINGS WITH ACC REGIONAL STAFF 3.1 Bo Regional Manager South Samuel M Marah Making a Statement 3.2 Progress Made  Held Strategic Meetings targeting key management personnel of MDAs but that due to the ban on public meetings as a result of the ebola outbreak they were able to hold meetings in large groups.  Developed a Work plan for the NACS implementation action plan.  Conducted some public education and awareness raising activities including radio discussions on SLBC and Kiss FM in Bo Town on Tuesdays and Thursdays.  Facilitated the establishment of IMCs in the region. 60 Letters were sent to MDAs in the region including the specific NACS Action Plan for each MDA. 38 MDAs have formed their IMCs so far of which 22 are in Bo district, 10 in Pujehun District, 3 in Moyamba district and 3 in Bonthe district.  Requested Work plans and Minutes of Meeting of IMCS to which only 7 MDAs have responded.

5. 5 proposed measures to cure those weaknesses that have been identified in the Strategy. MDAs are required under the Strategy to take steps to remedy those weaknesses that leave those MDAs vulnerable to corruption and susceptible to corrupt practices. This actions are to be done or rather implemented within specific time limes ranging from short term, quick wins and long term. The MDAs would be assessed with respect to how they have effectively implemented the actions within the time frames. All MDAs were therefore required to submit to the NACS Secretariat their work plans, minutes of meetings and evidence of the implementation process so that they would be guided through the process. Suffice to also state that some MDAs have neither submitted to the NACS Secretariat their work plans nor set up their IMC. Some have also not expressed keen interest in the exercise. Most of them have barely gone beyond the setting up of an IMC and nothing else. Some could not even attend meetings even when invited by the Secretariat to do so. Some could not avail themselves to the Secretariat even when visited in their various offices with a notice. At this juncture, however, I wish to single out a few MDAs that have done extremely well in the entire process ; namely NaCSA, EPA, MTI, Immigration Department, NEC, SLRSA and the ACC. I am also mindful of the fact some MDAs have not been captured in the NACS Action Plan (Matrix) e.g Sierra Leone Roads Authority (SLRA), Statistics Sierra Leone (SSL), Sierra Leone Library Board (SLLB), Sierra Leone Commercial Bank (SLCB), Rokel Commercial Bank (RCB), Sierra Leone telecommunication (SIERRATEL), Human Rights Commission (HRC), National Commission for Democracy (NCD),Ministry of Labour , Sierra Leone National Shipping Company (SLNSC) and the Sierra Leone Postal Services. (SLPS). This would however be discussed in the midterm review of the NACS 2014 - 2018. Some of these have however begun to take steps to identify systems weaknesses in their MDAs and proposed measures to cure the weaknesses, on their own, of cause with support from the Secretariat to close the gap. This year's Monitoring will be done by the CARITAS Sierra Leone. The Service Delivery contract has already been signed with them by the Commission. If all goes as planned, the monitoring exercise would commence in October 2015. It is my hope that MDAs would do as much to be satisfactorily graded. Some of my compatriots have always asked me about the importance of these exercises and why take the pains to do all this work. Well a quick response would be that the fight against corruption is one of the pillars in the Government's agenda for prosperity. Secondly the fight against corruption is a good governance issue which any well meaning nation or society must take seriously if it is to ensure economic development and investor confidence. Sierra Leone has over the years consistently lost out on the Millennium Challenge Cooperation Compact. One of the bench marks used in assessing countries is the control of corruption. Suffice to also state that as a nation we are now ready

30. 30 must only be used for Government work/activity otherwise we must use our own personal resources if the work has got nothing to do with Government. In his address, Mr. Mohamed Abu Sesay - One of the Implementation Committee members noted that MDAs must feed from the Strategy so that they could build their own Anti - Corruption strategies. The NACS 2014 - 2018 is a national strategy and MDAs are to deal with these measures especially in terms of our international ratings. He further asked MDAs to state what were their issues and challenges so that they can map a way forward. Among the challenges faced by them in the implementation of the strategy was the issue of Communication. This fact was alluded to by the representative from the Office of the Ombudsman and the Permanent Secretary of the Ministry of Lands Country Planning and the Environment (MoLCPE). The Chairman advised all present to start all over again and that they were to set up an IMC and a work plan that must be submitted to the Secretariat within a week. The Chairman of the Western Area Rural District Council (WARDC) assured the meeting that they will form their IMC and hold meetings to address the corruption issues as provided for in the matrix. Alhassan Cole of the WARDC asked the NACS Implementation Committee to give them a month in order to look at the document again. With reference to the second set of MDAs, these were referred to as Complaint MDAs. They had submitted to the Secretariat their work plan and had formed their IMCs. The Assessment meeting was held on Thursday 3rd September 2015. Sixty (60) MDAs were invited. See Appendix () for the list of Invitees. However, only forty - four (44)attended the meeting. See appendix 1 &2 for the list of MDAs that actually attended the meeting. Sixteen (16) MDAs did not attend. The meeting was again chaired by Hon. Claude M D Kamanda and co - chaired by Mr. Mohamed Abu Sesay. The chairman spoke at length on the need for compliance to the instructions of the Commission, highlighting sanctions for non compliant officials . He highlighted some conducts by officials in MDAs which were not in line with best practice ranging from late coming, back dating of age, poor recordskeeping and so on. He advised all to adhere to the ACC. His presentation was essentially that of his previous speech delivered during the provincial engagements with MDAs on the NACS implementation.

4. 4 FOREWORD I want to take this opportunity on behalf of the Commissioner to express my sincere thanks and appreciation to all of us who in diverse ways have made efforts to make the Assessment of IMCs in MDAs a success this year. The Strategy as it were, puts in place three mechanisms for the implementation of the NACS 2014 - 2018. Firstly, we have got the Implementation Committee. This is a Committee of Seven eminent members of the society headed by the His Excellency the President Dr. Ernest Bai Koroma, drawn from the civil society, academia, media, NGOs, the Private and Public sectors. They were selected by His Excellency the President. They have the responsibility to lead the process in the implementation of the Strateagy. The overarching idea is that although the ACC leads the fight, other stake holders must be seen holding strategic positions at the fore front in the fight against graft. This underscores the fact that members of this Committee are drawn from the citizenry of Sierra Leone and not from the ACC who want to ensure that they rapport with their compatriot to see reason and put an end to graft. Their job basically was to ensure that they meet with IMCs of the various MDAs in the county on a one to one basis, share experiences, understand their strengths, constraints, challenges in the implementation process and proffer together a way forward. Their activity was more or less in preparation for the monitoring activity that would be done by a civil society group. The Assessment of IMCs in MDAs is a Bi - Annual activity as NACS. The Secretariat intends to have it twice in the coming year as provided for in the NACS 2014 - 2018. It must be noted also that although provision was made under the previous strategies for the setting up of an Implementation Committee, it was never carried out.(The NACS Steering Committee) This is the very first time that we have an Implementation Committee up and running. On behalf of the Commissioner, Advisory Board, Management and staff of the ACC, we wish to extend our sincere thanks and appreciation to the Implementation Committee for the exemplary and ground breaking efforts you showed in the just concluded Assessment of the Implementation of the NACS 2014 - 2018. Essentially therefore, the progress of a nation is determined, in part, not by the numbers but by the quality of the people it produces. Yours is a call to duty worthy of emulation. The Commission remains grateful and shall always call upon you to continue your invaluable contribution to the fight against corruption in Sierra Leone. Secondly, we have the Civil Society Organizations who are tasked with the responsibility to assess performance on the Implementation of the Strategy itself. Suffice to state that each MDA has got specific system weaknesses and

39. 39  Implementation Committee carry out district assessment, to foster commitment as have been seen or sensed in the regions.  Budget line for the region and district be made available to aid the work . GENERAL CHALLENGES  Bribery and extortion still remain a major problem nationwide. Many individuals and companies report that they face demands for bribes in the course of doing business and that these demands sometimes constitute extortion. Globally extortion remains a major challenge in the fight against corruption.  Problems in Public Procurement: Given that public procurement is one of the primary areas where there is monetary transaction between public and private sector entities, it is particularly exposed to risks of corruption, fraud anti - competitive behavior, bribery and kickbacks. Corruption in public procurement transaction is often a double edged sword – If a supplier engages in corrupt practices, to receive a public tender, they put themselves at risk of extortion additional costs of doing business due to bribe payments and the legal penalties of corrupt practices. On the other hand, if a company resists corrupt activities and does not submit to the demand of bribes, they are likely to lose the public tender bid. Companies that resist in these instances suffer an unfair disadvantage against their competitors who give in to the demands of corruption. Corruption in public procurement transactions creates an uneven - playing field in the market and erodes fair competition.  There is a distinct lack of training and capacity building in the anti - corruption arena. Employees are unaware of the best way to tackle corruption scenarios in some cases due to the lack of requisite training. The Anti - Corruption Commission lacks sufficient resources to train its staff in much needed anti - corruption courses. Lack of knowledge about challenges and opportunities regarding the fight against corruption can impact the fight against corruption in a negative way.  Attitude of the public towards the fight against corruption. The tendency for the public to hail corrupt individuals whilst vilifying persons of integrity leaves much to be desired in the fight against corruption in Sierra Leone.

16. 16 The Regional Manager Mr. Ibrahim Kargbo and the Implementation Committee Members  In the related engagement with MDAs, the focus had been on the NACS Implementation Plan to help them develop their action plans.  Technical Support also been to some MDAs. 4.2 Challenges faced  All MDAs in the two districts had failed to submit their work plan despite all efforts made.  Some MDAs are yet to form their IMCs whilst some have changed their focal persons.  Break in communication and coordination due to the frequent transfer of officials from one MDA to the other.  MDAs do not ensure that their work is cascaded throughout their offices in the districts.  The Training conducted for the IMCs was not adequate due to time constraints.  Some MDAs do not have the requisite number of staff in order to form the 7 man IMC.  Some recommendations in the matrix are only applicable to the main office of the MDA ’ s should have been made by each MDA. 5. Makeni

8. 8 Committee had gone out to carry out its mandate. This effort is therefore laudable. It was an opportunity for the Implementation Committee members to have firsthand knowledge on how the NACS was implemented by MDAs, through their various IMCs and Focal persons and acknowledge what their problems were, and the challenges and opportunities faced. As an outcome of these engagements, it is hoped that the Implementation Committee will be able to liaise with the appropriate parliamentary unit to address issues in system reviews that have conflict with government policies. It is also hoped that the Implementation Committee will collaborate with agencies responsible for the monitoring of policy recommendations in the strategy (Integrity Committees Focal Persons, NACS Monitors). The engagement with IMCs started off with a second quarterly meeting that was held on the 3 rd July 2014 as provided for in the NACS. During this meeting, the Implementation Committee members were able to review their work plan and discuss the matrix that was to be used in assessing the MDAs. Other relevant issues were also discussed. In keeping with this, two members of the implementation Committee, Hon. Claude M.D. Kamanda and Mrs. Lavina Banduah including the NACS Manager Patrick M George and the NACS Coordinating Assistant Ms. Roseline Johnson visited the Eastern, Southern and Northern provinces. The Assessment Visit was characterized by the following activities in each region visited:  Meeting with ACC Regional Staff.  Meeting with IMC ’ s/Focal Persons of MDA ’ S in the cities of Bo, Kenema, Makeni, and Kono.  Press Conference Radio Discussion Program The Implementation Committee did not go to all District head quarter towns due to budgetary constraints and owing to the fact that members of the Implementation Committee had busy schedules in their various engagements For the aforementioned reasons, the NACS Secretariat therefore decided to have IMCs in the various district head quarter towns converge at the Provincial head quarter towns for a day ’ s engagement with members of the Implementation Committee. Reasons of budgetary constraints also required the NACS Secretariat to choose just three (3) members of every IMC to be involved in the

22. 22 The Eastern Province meeting for MDAs was held in Kenema city at the IFAD Hall Blama Road Kenema. Participants comprised representatives of MDAs from Kenema and Kailahun Districts. 8.1 Progress Made Some MDAs have formed their IMCs and have compiled their work plan. 8.2 Challenges Faced  Inadequate number of personnel to form the requisite 7 man IMC.  Some MDAs do not have a Procurement officer and an Internal Auditor who are supposed to be among the main personnel to form the IMC. Can an IMC be formed without them?  Some MDAs have devolved their functions to local councils. In such instances can they form an IMC co - opting the specified Procurement Officer and Internal Auditor of the Council within their MDA ’ s IMC?  Meeting the financial implications for implementing the NACS as they had no budgetary provision for related activities.  Can the IMC meet without the focal person? 8.3 Requests Made  Copies of the NACS Implementation Plan and the NACS 2014 - 2018 to be made available to them including the Terms of Reference for establishment of IMCs  Technical Support to develop the Action Plan (Kenema District Council)  The need for an assistant focal person to be appointed in case of sickness or unforeseen circumstances.

29. 29 11. REPORT ON THE ASSESSMENT OF IMCs BY THE IMPLEMENTATION COMMITTEE ON 1ST AND 3RD SEPTEMBER 2015 An Assessment of all Integrity Management Committees (IMCs) for all Ministries, Departments and Agencies(MDAs ) in Freetown was conducted by the Implementation Committee on the 1st and 3rd September 2015. The meetings were chaired by Hon Claude Kamanda - Chairman Transparency and Accountability Committee (TAC) of the House of Parliament (HoP). The IMCs were divided into two groups. The first group comprised a list of all non - compliant MDAs - this is the group of MDAs that have neither submitted to the National Anti - Corruption Strategy (NACS) Secretariat their work plan for the implementation of the Action Plan under the strategy nor formed their IMCs. They were thirteen (13) in number. See appendix ( ) for the full list of non compliant MDAs. The meeting for the Assessment of Non Compliant MDAs was held on the 1st September 2015. Only five (5) MDAs were in attendance out of a total of thirteen (13) non - Compliant MDAs. This meant in effect that a total of eight (8) MDAs were not in attendance. See Appendix ( ) for the list of MDAs that were in attendance. Letters were again written to those MDAs that were not in attendance, re - inviting them to the second leg of the Assessment meeting that was held on the 3rd September 2015. Only five(5) additional MDAs attended the aforementioned meeting. Two (2) MDAs and one (1) Non - Governmental Organization namely The Bank of Sierra Leone (BSL), The National Telecommunications Commission (NATCOM) and The Sierra Leone Association of Journalists (SLAJ) respectively, never showed up for the Assessment meetings. During the meeting of non - Compliant MDAs, the Chairman Hon Claude M D Kamanda gave a rundown of the activities of the Implementation Committee in the Provinces highlighting their Terms of Reference and also emphasizing the fact that Non Compliance to the instructions of the Anti - Corruption Commission (ACC) would incur sanctions pursuant to Sections 8 of the Anti - Corruption Act (ACA) 2008. The Commissioner of the ACC Mr. Joseph F Kamara gave the keynote address emphasizing the fact that the fight against corruption must not be left to the ACC alone but that MADs were encouraged under the Strategy to implement certain actions specific to their institution in order to curb corruption. He gave the story of an Islamic Scholar who people visited for advice. As they were all seated in a dark room he would allow the light to burn out if the question asked had to with the Government, otherwise, he would switch the light off if the question was a private one. He then drew the distinction between the use of Government Property/funds and that of private property/fund. Government property

17. 17 NACS Manager – Mr. Patrick M George making a statement 5.1 Progress Made  Made some progress in terms of implementing the 2014 - 2018 NACS as follows:  Held customized meetings with some MDAs (Health, MSWGCA, NACSA, Lands, Education, SLRTC and the Media).  Responses received from 11 MDAs. 22 MDAs are yet to form their IMCs. 5.2 Challenges Faced  Funding constraints to implement NACS related activities especially in the other districts in the north.  Lack of cooperation from some MDAs 5.3 Way forward  The need for the ACC regional office Makeni to form its IMC and to start implementation of the Action Plan This work to be done alongside their responsibility to coordinate the other MDAs  The need for staff to be aufait with the NACS

38. 38  Ownership challenges and resource constraints is a perennial obstacle to mainstreaming the NACS.  The information gap between offices at the centre and those in the regions is critical to the implementation of the NACS.  Institutional complementarily in terms of building sustainable strategic and constructive partnerships with other anti - corruption bodies like Audit Service Sierra Leone and the National Public Procurement Authority is to be deepened.  The unpredictability of the jurisprudence in anti - corruption matters in the Court of Appeal detracts from the fight against corruption.  Logistical challenges in the form of vehicles, the death of staff with expert knowledge in investigation and auditing, insufficient office space impinge on the efficiency of the Commission.  The creeping, latent and widening of the scope of parliamentary oversight functions serves as an emerging challenge that needs to be cleared and clarified to allow for a proper understanding of roles and functions between Parliament especially the PAC and the ACC.  The NACS Implementation has not been given the seriousness it deserves especially by the MDAs.  ACC Staff in the provinces need to prioritize the implementation of the NACS and should be aufait with it. It is recommended that a staff be assigned for NACS activities in each regional office.  MDAs need to be informed of the legal mandate and provisions for compliance and sanctions for non compliance. They need to be well informed of the responsibilities of their district offices to implement the NACS.  The Monitoring by Civil Society to be undertaken against the 90 days from the end of this first assessment visit.  Regional and district offices ensure that NACS matrixes are sent to MDAs.  Regional and district offices ensures IMCs are established.  Capacity building for IMCs, as well as, for regional and district ACC staff.  Regional and district offices ensures that work plans are done.

7. 7 1. INTRODUCTION Pursuant to Section 5 (1) (c) of the Anti - Corruption Act (ACA) 2008, the Commissioner of the Anti - Corruption Commission Sierra Leone (ACCSL) coordinates the implementation of the National Anti - Corruption Strategy (NACS). This function is however delegated to the National Anti - Corruption Commission Strategy Secretariat. The Commissioner however supervises it activities. The NACS 2014 - 2018 which was launched by Prof. Monty Jones on behalf of His Excellency the President of the Republic of Sierra Leone Dr. Ernest Bai Koroma on the 17th June 2014, makes provision for other bodies to help in the work of making the strategy a national commitment. These bodies are the Integrity Management Committees (IMCs) established in most Government's Ministries Departments and Agencies (MDAs) and the NACS Implementation Committee appointed by the President. The President serves as titular head of the Implementation Committee with six (6) other persons as members. They include: Ms. Valnora Edwin (Chairperson) - Campaign for Good Governance (CGG); Mrs. Lavina Banduah Transparency International (TI) Sierra Leone Chapter; Mr. Mohamed Abu Sesay - Public Private Partnership (PPP); Hon. Claude M. D. Kamanda - Chairman Transparency and Accountability Committee in the House of Parliament (HoP); Mrs. Gladys Strasser - King - Chairperson Sierra Leone Chamber of Commerce (SLCC), Prof. Abu Sesay - Former Principal Njala University College and Kelvin Lewis (Sierra Leone Association of Journalists SLAJ). These persons were drawn from the private sector, public sector, academia, civil society, the media and NGO as provided in the strategy. Their inaugural meeting was held on 5th March 2015 at the NACS Secretariat in Freetown. As part of their mandate, "they shall lead and oversee the implementation of the National Anti - Corruption Strategy". However more specifically, and even more importantly, as part of their specific responsibilities, the Committee "shall make oversight visits possibly every six months to interact with monitors, with a view to identifying and resolving any emerging problem" 1 . It is against this back drop that the Implementation Committee with support from the NACS Secretariat accomplished this objective by visiting all the Provincial head quarter towns. They met with the IMCs and Focal persons of MDAs and interacted with them. It must be noted that since the enactment of the first NACS in 2005, there had never been a moment when the Implementation Committee had gone out to carry out its mandate. This is the first time the Implementation 1 See Terms of Reference (TOR) for Implementation Committee

19. 19 7.2 Progress made  Some MDAs have established their IMCs and have also developed their Work plans (NASSIT, MSWGCA, Moyamba District Council, Ministry of Education Science and Technology (MEST), Environmental Protection Agency (EPA). 7.3 Challenges faced  Some MDAs claimed that their activities are centralized and need directive from the head office in Freetown to take any necessary action (Sierra Leone Road Safety Authority) (SLRSA).  Some claimed that they have not received any related information or documentation from their heads e.g Political Parties Registration Commission (PPRC), Ministry of Works and Housing).  Some MDAs do not have the requisite personnel to form the 7 man IMC (Ministry of Tourism and Cultural Affairs).  Frequent transfers of personnel hampering the work of the IMCs  Some MDAs do not have Procurement Officers and Internal Auditors who should form part of their IMC.  Majority of the attendees are really not IMC members, but just sent to witness the session 7.4 Way forward  Related documents e.g Matrixes, a template of the work plan and Power point presentation on the NACS to be made available to IMC Focal persons  The need to address the issue of frequent transfer of personnel  Funds to be made available to the MDAs for NACS activities. As such provision will be made in the forthcoming budget for such activities as it will not be possible now. 7.5 Response by the Team

10. 10 2 . MEETING WITH IMC ’ s/FOCAL PERSONS OF MDA ’ S OF BO, KENEMA, MAKENI AND KONO. 2.1 Key Issues  Corruption hinders national growth  IMCs are and partners  Corruption in Sierra Leone continues to be a very serious issue especially in Sierra Leone ’ s development efforts. As such the need to fight Corruption is not an option or a matter of choice. It is now a MUST.  Transparency and Accountability Committee (TAC)in Parliament. This Committee, unlike all other Committees in Parliament, is constitutionally mandated to investigate all MDAs and to probe into any issue of public interest. Section 93 of the Constitution of Sierra Leone Act no. 6 of 1991, especially subsection 3 and 6 empowers the Committee to enforce witnesses in attendance and compel the production of documents. The TAC committee works on compliance. The Committee seeks to pursue adherence of MDAs on their binding legal mandates and responsibilities.  Accountability is ensuring that officials in public, private and voluntary sectors or organizations are answerable for their actions and that there is redress when duties and commitments are not met. Failure to act transparently and accountably is mostly as a result of corrupt practices that is not limited to embezzlement, bribery, fraud, extortion and/or favoritism that Parliament in its fight on Corruption not only constituted the Transparency and Accountability Committee, but also enacted the Anti Corruption Act 2000. It further amended the 2000 Act in 2008 to empower the ACC to prosecute alleged corrupt individuals. The TAC in Parliament works very closely with the ACC.  Parliament has also enacted other laws to fight Corruption in their own way, though all at the end boils down to the Commission's final work:  Financial Management Act 2007  The Audit Service Act 2014  PublicProcurementAct2004 Local Govt.Act2004  Govt.BudgetingandAccountabilityAct200  All these Acts geared towards the fight against corruption and the need to promote...

14. 14 3.3 Challenges faced  Lack of adequate funds and logistics for NACS related activities especially transportation to other districts in the regions.  No budget line at Regional and District ACC office to facilitate NACS implementation  Lack of cooperation from some MDA ’ s especially the Bo District Council and Bo Town Council. In Pujehun the Sierra Leone Police and RSLAF are yet to form their IMCs  Lack of proper coordination within MDAs (in terms of communication and information flow, handling of related documents).  MDAs do not keep records on ACC/NACS Implementation.  Lack of ACC's presence in Bonthe District 3.4 Way forward  Visits to be made to each district as this might also create an impact  Capacity building activities for MDAs on the NACS  Pro - active monitoring of the NACS implementation  Penalties to be levied for non - compliance . Mr. Wilfred Bangura (SPEO - ACC Bo) making a statement

37. 37 12. GENERAL ODSERVATIONS AND RECOMMENDATIONS  The NACS Implementation has not been given the seriousness it deserves especially by the MDAs.  ACC Staff in the provinces need to prioritize the implementation of the NACS and should be aufait with it.  MDAs need to be informed of the legal mandate and provisions for compliance and sanctions for non compliance. They need to be well informed of the responsibilities of their district offices to implement the NACS.  The Monitoring by Civil Society to be undertaken against the 90 days from the end of this first assessment visit.  The need for increased nationwide public education and awareness raising on the NACS and its Implementation Plan, the legal provisions for compliance and sanctions for non - compliance.  Regional and district offices ensure that NACS matrixes are sent to MDAs.  Regional and district offices ensures IMCs are established.  Capacity building for IMCs, as well as, for regional and district ACC staff. Regional and district offices ensures that work plans are done. Implementation Committee carry out district assessment, to foster commitment as have been seen or sensed in the regions. Budget line for the region and district be made available to aid the work .  Lack of willingness on the part of MDAs to implement activities highlighted in the Implementation Action Plan of the Strategy.  The need for increased nationwide public education and awareness raising on the NACS and its Implementation Plan, the legal provisions for compliance and sanctions for non - compliance to be implemented.  Problems with Integrity Management Committees - considered the implementing partners of the NACS - IMCs, not constituted on time in MDAs.  Lack of support from Management of institutions, among others has affected the implementation process as a whole.  Making IMCs proactive in addressing non - related anti - corruption measures poses a serious challenge.

3. 3 List of Abbreviations ACA - Anti Corruption Act ACCSL - Anti - Corruption Commission Sierra Leone CGG - Campaign for Good Governance EPA - Environmental Protection Agency IMC - Integrity Management Committee MEST - Ministry of Education Science and Technology MSWGCA - Ministry of Social Welfare Gender and Children's Affairs MDA - Ministries Department and Agencies MoU - Memorandum of Understanding NACS - National Anti - Corruption Strategy NASSIT - National Social Security and Insurance Trust NaCSA - National Commission on Social Action NGO - Non Governmental Organization PPP - Private Public Partnership PPRC - Political Parties Registration Commission SLCC - Sierra Leone Chamber of Commerce SLAJ - Sierra Leone Association of Journalists SLBC - Sierra Leone Broadcasting Corporation SLTU - Sierra Leone Teachers Union SLRTC - Sierra Leone Road Transport Corporation SLRSA - Sierra Leone Road Safety Authority TAC - Transparency and Accountability Committee TI - Transparency International UK - United Kingdom

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