An independent institution established for the prevention, investigation, prosecution and punishment of corruption, corrupt practices and to provide for other related matters. 

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Address:  Integrity House, Tower Hill, Freetown Sierra Leone, West Africa.

PNB 2018 Annual Review

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7. Smart Guide (version March 2016) 7 PNB r eports are disaggregated and submitted to partner MDAs each month . As a result of the programme, Integrity Management Committees (IMCs) in MDAs have been reinvigorated and are taking a lead on raising PNB issues with senior management and reporting back to the ACC , which is done monthly . This is supported by the ACC and a Coffey Adviser , who have helped introduce Standard Operating Procedures for these processes and who facilitate regular technical working groups. However, capacity and resourcing remain a challenge. The ACC holds a quarterly press conference to share the platform reporting figures and inform the public of the actions taken in response and the consolidated reports are published on the PNB website. The press conferences are important events to highlight the problem of petty corruption in public, as well as the ways to report it through PNB. The press conferences are also an important public signa l, that there is institutional backing to fighting petty corruption. Communication from the centre to the MDA regional and district off ices is weak , with feedback on the reports and actions taken not being systematically communicated down. In response, the ACC is directly liaising at subnational levels through its regional ACC offices. Regional Technical Working Group meetings have been established in each District to this end , which enables effective communicat ion of reports and responses down wards, as well as to harvest stories at the local level . This is capturing government anti - corruption responses that otherwise would not filter upwards to the central level, 7 Furthermore, by the ACC maintaining this link between the central and sub - national level i nteraction between citizens, civil society and local government at the District level is supported, and District Councils are strengthened in line with decentralisation policy . . While the ACC through its regional offices is enabling effective communications and information gathering, this role should be performed by MDAs. I n this regard, government response has been variable. While the Ministry of Education had been slow to engage, at the time of the revi ew they had recently started to respond. The IMC in the Ministry of Health was already active, making implementation faster. It has prioritised the display of service charters in health facilities so citizens have information on their entitlements and the right fees. The Sierra Leone Police (SLP) service has responded to reports by removing check points and transferring officers in areas where a large numbers of reports have been made. Government responsiveness is a pre - condition for the sustainability of the PNB platform; if citizens do not feel that the government is responding to complaints, they will stop reporting. Ensuring that actions taken are effectively communicated is also critical. Sustainability should be the focus of the programme in the co ming year, drawing on all levers available, both programmatic and non - programmatic. Summary of responses to issues raised in previous annual reviews Website version 2.0 and the PNB call centre should be integrated with the ACC website and call centre to streamline and simplify reporting of bribery. The programme should also review the utility of the call centre, before the end of the pilot phase, with a view to making changes which broaden access. The PNB , ACC and Social Safety Net (SSN) call centre s h ave been integrated in a single location, with equipment for the co - location installed and configurations undertaken. A single hotline is expected to be finalised by the end of February 2018 . This is an important contribution to sustainability of the PNB platform . Nevertheless, there continue to be substantial challenges regarding the smooth operating of the call centre’s IT model, in addition to concerns regarding adequate levels of staffing. Around 1/3 of attempted calls to the hotline are unsuccessful, especially from rural areas where mobile phone reception tends to be poor . IT upgrades form part of the strategy to mitigate these issues: The establishment of the planned PNB website version 2.0, including an update of the PNB questionnaire and new mob ile applications (apps), will now be undertaken as part of the Freetown Enterprise Resource Platform ( ERP ) software development - an improved IT system for the ACC’s information management and connectivity. This is expected to be completed by December 2018 . 7 For example, in Bo, additional Saturday lessons have been eliminated in schools and nurses were removed by the District Medical Officer.

9. Smart Guide (version March 2016) 9 To date there have been 46,669 reports of citizens paying a bribe 8 , 7,557 reports of not paying a bribe and 5,396 reports of meeting an honest official. The PNB app continues to be the most popular way of reporting, driven by civil society (CSO) animators who facilitate reports from citizens in the target districts, which increased from four to five in this reporting year to include Kono. Plans to extend the platform to the judiciary in addition to education, health, water, electricity and the police have advanced and are expected to be realised in early 2018. This level of reporting is significant, reflecting an increase in trust in both the genuine anonymity of th e PNB platform and the ACC by citizens . The four CSO partners engaged in the programme have played a big part in building citizen confidence. T here has been an investment in sensitisation and public education on citizen’s rights, GoSL service delivery char ters and corruption . This has resulted in early indications of a genuine change in social norms and behaviours; citizen’s appear to recognise bribery / illegal user fees as a form of corruption and unacceptable . T he risk of service users reporting bribery through the PNB Platform is also reported to be having a deterrent effect on some service providers. This is an impressive result in such a short period, but needs to be further embedded over the remaining programme . Issues of contracting delays wi th CSOs have largely been addressed. CSOs report that more funds would enable them to do more outreach . This should be discussed, balancing the sustainability prospects of this work stream against the potential impacts. Th e ACC should also consider reallo cating a portion of their available budget (core and financial aid) to ensure delivery of their new public engagement and communications operational plan, submitted in November 2017. The learning workshop in Kenema with coordinators and animators , held in August 2017, was consistently highlighted as a turning point in the programme. Coffey also appointed a new CSO Coordinator in September 2017 , who has introduced measures to improve monitoring, coordination and communication. Mobile telephones with the Kobo collect tool were introduced in October 2017 to enable animators to report m ore easily, and to also enable Coffey to monitor performance. ACC/CSO Accountability Forum s , consisting of ACC offices, MDAs, CSOs, a radio journalist and citizens, have bee n established in each District. This provides a platform for citizens and CSOs to engage with government at the local level, with wider governance benefits. The programme has also built good working relationships between the CSOs and the ACC, with outreach activities being undertaken as a team. CSOs reported that th is has been a valued outcome of the programme, and that ongoing collaboration beyond DFID support represented as much of an incentive as funding. The PNB programme has also begun coordinating with the DFID supported SABI programme for local accountability. SABI staff operating in communities now regularly share information on how to report through PNB and the important of doing so. This will also help improve the sustainability of messaging to communities after the programme ends. This give s some confidence that PNB has the potential to be sustained beyond DFID support. Over the next year, the linkages between PNB, SABI and other basic services projects and programmes will be strengthened . This will include identifying the most promising and effective elem ents of PNB , SABI and other programmes, and developing an integrated new programme to strengthen accountability and decentralized state structures. Summary of responses to issues raised in previous annual reviews Stronger engagement needed from the ACC Public Outreach team, making effective use of the available resources. The communication strategy should be reviewed, and where necessary updated and disseminated, and the use of social media considered. A communications consultant worked closely with ACC Public Education team in November to update and develop a Communications Operations Plan based on the 2016 Communications Strategy 8 Data disaggregated by sector ( Ed ucation 12,791; Electricity 2,765; Health 16,580; Police 24,402; Water 886; and others 2,198 ); by district (Bo 8,974; Kenema 14.075; Bombali 10,910; Western Area Rural 3,508; Western Area Urban 14,026; and Kono 7,537) ; and by source (call centre 4,876; PNB mobile app 53,618, website 972; web and call centre 156) .

17. Smart Guide (version March 2016) 17 mobiles provid ed to the project in the areas CSOs visited . With the programme in its final year, it will be important to develop a strategy for what happens to assets post - 2018. G: CONDITIONALITY (½ page) Update on partnership principles (if relevant) DFID - SL assesses GoSL performance against the partnership principles (PP) every 6 months. The four principles are: PP1 Poverty reduction and the MDGs; PP2 Respecting human rights and other internation al obligations; PP3 Strengthening financial management (PFM) and accountability, and reducing the risk of funds being misused through weak administration or corruption; PP4 Strengthening domestic accountability.PPs 2, 3 and 4 are particularly relevant to t his programme and are monitored in discussion with GOSL. There continues to be evidence of commitment to each of the four partnership principles, but it varies across GoSL – it is uneven across and within ministries, departments and agencies. Across all fo ur principles we assess commitment as medium level. H: MONITORING & EVALUATION ( ½ page) DFID Sierra Leone has maintained a close overview of the programme, including regular visits to the ACC, the call centre, the MCCU and State House to assess programme performance and meet with stakeholders. A total of four up - country field visits to Makeni , Bo, Tombo and Kenema have been conducted throughout the review period. The log frame was jointly revised during 2017 and approved in October . Monitoring of ACC institutional strengthening has been improved through data collection by ACC as well as feedb ack on activities delivered. CSOs have made further progress in improving and standardising the way they monitor their animators , using innovati ve models, including technology, to bring more transparency into DFID’s delivery chains. This A nn ual R eview w as carried out by an external Governance A dviser and a Programme M anager , from DFID Ghana and London respectively. It consisted of document reviews, consultations with a wide range of stakeholders in Freetown over a one - week period, analysis of findings, a nd the drafting of this report. The review team met a range of different stakeholders, notably DFID Sierra Leone, Coffey, the ACC, IMCs (ESDA , Ministry of Heath, Police, and t he Sierra Leone Water Company (SALWACO)), the MCCU, and President’s Delivery Team , to get feedback on their experience in the programme, in addition to CSOs both in Freetown and in Tombo.

14. Smart Guide (version March 2016) 14 Financial aid to the ACC After a 50% underspend last FY, component 102 is expected to be at 65% spending by the end of the FY, due to slow rate of utilisation of the FY by the ACC during this period The ACC is working within the paramet er s of the government procurement system which has c onsequently delayed spending . After the last Annual Review, it was agreed to reduce the ACC’s budget for FY 17 /18 by 50% to £225,000. Actual spend was again below par at only 50%, prompting our decision to suspend fina ncial aid. F inancial aid is now on hol d until further notice. Quality of financial management The financials of the programme are monitored on a monthly and quarterly basis in close collaboration with the managing agencies of the different components. R eviewing of invoices and ensuring that the payment is in line with agreed deliverables and timelines has supported robust financial tracking . Financial management in Coffey has improved significantly over the course of the last year and a new dedicated programme manager has led to impro vements in the quality of financial infor mation received . DFID has worked closely with Coffey and the ACC to ensure the FY17/18 forecast has been in line with expectations. Spot - checks were conducted on the ACC and Coffey . The F inancial A id (FA) component has been used for activities which contribute to the programme objectives and in line with t he set of activities agreed between the ACC and DFID. A due diligence assessment was conducted in 2016 to ensure right systems are in place to deliver va lue for money . FA utilisation rate was slower than expected . One reason for this is the absorptive capacity of the ACC which failed to plan , authorise and execute FA expenditure. Only 50% of the 2016/17 budget was spent, prompting a 50% reduction of the FA budget for 2017/18. Despite the reduction the spend rate was again low at only 57%. The consistent inability of the ACC to effectively execute budgets was one of the key reason s for the above mentioned budget reduction and freezing of FA . VfM performance Assessment of whether the programme continues to represent value for money The VFM assessment focuses on issues of economy, efficiency and equity. It is also important to note that the VfM case for this programme is expected to improve ove r the course of delivery and potentially beyond the end of the programme, with more districts and sectors integrated into the programme, the number of PNB reports increasing and stakeholders building a stronger understanding of corruption across targeted s ectors. Economy Office Rent  Coffey Sierra Leone moved to a new office which culminated in a 60% saving. Procurement for Call Centre Integration  As part of the call center integration, PNB procured three laptops f or the new operators in the UK, and shipped them to Freetown , which led to savings . Those were reinvested in the procurement of headsets for each call center operator in the call center . National Consultants  PNB has worked to source local and regional consultants where possible, saving on international fees and accommodation. This has included the sourcing of a National Deputy Team Leader, as well as for facilitation of the Kenema Lesson Learning workshop in Augus t. Efficiency Last year’s effectiveness has suffered from a lack of progress in the first part of the year, mostly as a result of disruptive interpersonal dynamics within the implementing partner team . Some of the recruitment processes were lengthy with the post of the CSO C oordinator and Deputy Team Leader only filled in September and October 2017 respectively and with a decision on the permanent Team Leader being delayed. Programme team turnover has impacted upon project implementation and resulted in

11. Smart Guide (version March 2016) 11 Key Points The ACC identified 15 no - fee training courses and utilised financial aid funds to cover the travel and accommodation costs. The training courses and the legal texts purchased with financial aid were clearly appreciated by the Investigations and Intelligenc e Department and Prosecutions Department, who are under - resourced to handle the increase in cases since the PNB programme started. A capacity assessment and training plan for investigators and prosecutors was delivered by the Pro Bono Network through the DFID Rule of Law Expertise (ROLE - UK) programme. The last AR recommended that the programme take a flexible approach to institutional strengthening in the ACC that responds to needs and opportunities. This reflected a m ove away from the programme design’s focus on the ACC’s capacity to conduct investigations and prosecutions. A strategic plan, including a needs assessment, was intended to inform the capacity development plan for the ACC and inform the use of the financia l aid. However, a consultant was only contracted by Coffey in October 2017 and the process to develop a strategic plan commenced in early November. Although led by the ACC and despite efforts by the consultant to make the process inclusive, some of those i nterviewed felt that they had not been sufficiently involved. At the time of the review, the draft strategic plan was under consideration by ACC management. The delay has impacted on delivery of the output overall. The objective of a sustainable PNB syste m should inform the identification of capacity development investments in this final year. In the review team’s opinion, this should include support on monitoring and evaluation (M&E), communications, IT and the IMCs in partner MDAs. Strengthening the ACC’ s own capability to respond to corruption reports was relevant to the programme’s initial theory of change, but this should be de - prioritised given the long - term nature of this kind of capacity development and the greater priority to sustain the investment s to date. DFID Sierra Leone should consider whether this longer - term capacity building support could be provided in future programming. Moving forward, t he Coffey team should focus on mentoring and skills transfer approaches, ensuring that the team is ap propriately staffed to respond to ACC needs, and be located in the ACC as much as possible. This approach is being brought in, but needs to be strengthened. Roles and responsibilities should be clarified in respect to this output and the ACC supported to p rioritise its needs . Summary of responses to issues raised in previous annual reviews (where relevant) GoSL and Coffey to develop a plan to a) deliver PNB consolidation and sustainability and b) progress strategic plans and deliver realistic, agreed plan for wider capacity support. Steps taken to consolidate the PNB platform are covered under Output 1. While sustainability issues have been discussed and actions to strengthen it taken, a draft Sustainability Plan was finalized by Coffey and the ACC in May 2018. T he review team is concerned that t his comes very late in the programme. As noted above the Strategic Plan also has been delayed , and as such a capacity development plan has not been developed. Indicator(s) Milestones Progress Number of HQ and regional ACC staff trained in methodologies for pursuing and managing higher value corruption cases 20 Not a chieved : 15 Number of HQ and regional ACC staff identifying >3 ways in which they feel that their performance has improved after training 50% of those trained Exceeded : 60% ACC organisational development supported and strengthened 30% of strategic plan organisational and capacity development actions under implementation or complete Not achieved : Draft strategic plan developed by consultant under discussion

16. Smart Guide (version March 2016) 16 E: RISK (½ page) Overall risk rating: Major Overview of programme risk The risk and mitigation activities outlined in the original business case remain valid. Additional risks identified in the last two annual reviews – supplier underperformance and GoSL leadership – also remain, although steps have been taken to address this. Mitigation measures have included leveraging the PDT process, strengthening the Coffey TA team, regular engagement with the ACC and ACC taking increasing ownership of the programme. As a result of upcoming elections in Sierra Leone in March 2018, there is a risk of government counterpar ts showing reduced buy - in to reform initiatives. The ACC will need to leverage its independence to focus on impartial delivery of its mandate and embedding the PNB approach into its systems. Sustaining MDA responses and engagement in this period may be dif ficult , although the establishment of strong links to technical officers in target ministries will help to mitigate this. The key sustainability risks involve the maintenance of the PNB reporting platform, call centre and ACC IT infrastructure; PNB outreach and communication after support for CSOs is likely to end; strengthening ACC capacity and integrating M&E into all aspec ts of ACC work. Coffey has recently submitted a draft Sustainability Plan which captured mitigating actions underway and planned. A new sustainability plan has been submitted by Coffey in May 2018. U nderperformance risks have been escalated. Mitigation measures include a consolidation of efforts to complete the software component of the ERP by the end of the project life - cycle and a renewed focus on sustainability by Coffey and the ACC. This includes a project proposal for the infrastructure phase of the PNB/ERP project that will be developed by Coffey in concert with the ACC. This proposal will form the basis of a continuation of the efforts beyond December 2018. F: COMMERCIAL CONSIDERATIONS (½ page ) Delivery against planned timeframe The programme’s delivery timescales have altered significantly since the programme was conceived with an overall reduction of the overall delivery period from initially 60 to 44 months . As outlined above, most Coffey programme activities were suspended for a 4 - month period between April and July 2017. Performance of partnerships Coffey’s relationships with both DFID and the ACC have significantly improved in the second half of 2017. In order to further st rengthen this relationship, it will be important to deepen the ongoing dialogue and to fully inform and where relevant involve the ACC in key decision making processes. T here seems to be increasing buy - in, leadership and ownership of the process and prog ramme from the ACC and wider GoSL. Engaging MDAs continues to be a challenge but the programme has seen good improvements in response from some of the MDAs over the last year. There continue to be regular steering committee meetings, technical committee meetings and programme team meetings, wh ere DFID, MCCU, GoSL and Coffey and MDA stakeholders participate to drive implementation and MDA responses. This arrangement has facilitated good working relati ons amongst the various stakeholders . Asset monitoring and control In line with DFID guidance, Coffey and the ACC are maintaining asset register s . Partners provide reports on the status of these assets and asset checks have be en undertaken by the DFID programme management team . During the period covered in th e r eview, DFID also verified the use of tablets and

13. Smart Guide (version March 2016) 13 Although attribution is a challenge, it is likely that PNB activities have resulted in the increase of reported exposure to and discussions about corruption. This is corroborated by the communication activities undertaken, but also the CSO/ACC outreach activities, the ACC communication materials and the reporting levels. A radio journalist is now attached with each CSO partner to accompany outreach event, with content from the events aired on local radio and discussed in their daily shows. In February 2017, a Communications Adviser supported the Public Education Department to develop a strategy and core script. In November 2017, Coffey supported the ACC Public Education Department to refine the communications strategy by identifying appropriate channels for different audiences. A consultant worked with the ACC team over two weeks to develop different types of radio formatting, including shortening the 1 hour panel discussion programme to a 30 minute format including endorsements and jingles. The team has since produced and commissioned further material in a variety of formats for airing, including agreeing a character line in the Talking Drum S tudio soap Atunda Ayenda and a mini drama s eries. These efforts have extended the programme’ s coverage nationwide. Summary of responses to issues raised in previous annual reviews (where relevant) The communication strategy should be reviewed, updated, and disseminated widely. As noted above and in response to the similar recommendation under Output 2 , a consultant worked with the ACC Public Education Department to revise the Communications Strategy. Coffey should review their approach to engagement with the media and strengthen this, with a ppropriate planning for risk management as elections approach. The introduction in October of a radio journalist to accompany outreach activities and cover the Accountability Working Group meetings at District level has improved media coverage . A variety of content has been utilised, including vox pop, MDA actions, and public endorsements of PNB as well as discussion programmes. The approach has also built relationships between the media, CSOs and the ACC that are likely to be sustained beyond t he programme. Wider engagement with the media has b een limited. Coffey plans to initiate longer term mentoring support in the year ahead to increase the standard of journalism on corruption issues, including an investigative journalism workshop. An ele ction risk mitigation strategy was drafted in December 2017 and e lection - related risks are included in the programme’s risk register. It will be important to ensure that the actions contained in the strategy are implemented in accordance with the strategy. Recommendations - By June 2018 , DFID and Coffey should revise the log frame to 1a) only reflect the percentage number for indicator 1 and b) better measure the quality and genuine number of media articles. - By June 2018 , Coffey should articulate plans to engage with the media in a work plan that reflects the sustainability plan D: VALUE FOR MONEY & FINANCIAL PERFORMANCE (1 page) Key cost drivers and performance The key cost driver s are the costs of consultants providing technical assistance and project management, related operating costs, running the call centre and financial assistance to the ACC. Coffey contract Spend against component 101 is expected to be at 100% against forec ast by the end of the FY , with all but one milestone paid for. After the last Annual Review, a decision has been made to cut this component’s budget by 33% for FY 2017 and 2018. A contract amendment is currently underway .

15. Smart Guide (version March 2016) 15 implementation delay s, and a loss of institutional memory. The milestone payment system insulated DFID from the financial impact of these delays. Yet, the impressive acceleration in activities over the last six months demonstrates that the programme does not lack the foundations required for success. With the new Team L eader in place since July 2017, and recruitment of a CSO Coordinator and Deputy Team L eader completed in September and October 2017, Coffey has provided quality management and technical function over the 2nd half of this period, with many of the issues outlined above being addressed. The relationship between Coffey and the ACC has improved significantly, with regular meetings bet ween the ACC and Coffey Team L eader. Clear ex amples of increased efficiency over the last months include: Database coordination  PNB has linked up the PNB website, call center and a pp database, joining different suppliers together, to pool information into one consolidated database at no extra cost to the programme. This has increased the efficiency of data extraction, improved systems and enabled knowledge sharing. Office Location  The new premises are ideally situated for closer engagement between Coffey a nd ACC plus other stakeholders within the Judiciary and SLP , and for quick access to the call center . CSO and ACC Public Education Outreach  PNB has been working to maximize synergies and coordination between the ACC Public Education Teams and CSOs to multiply the effect of PNB outreach e.g.in Kenema and Bo .  There are also clear signs of increased efficiency within the ACC, for instance by leveraging the effect of DFID - funded training, with trained ACC staff conducting wider training within their organ isation. It is also notable that while DFID initially funded PNB call centre agents, the ACC has now taken over responsibility for financing those posts. Equity Equity has focused on reaching the poorest and people in rural as well as urban areas, inclu ding non - literate people. Specific actions have also been taken to ensure women are targeted (particularly groups vulnerable to bribery in key services such as maternal health, and girls in education). However, more can be done to collect data on and targe t those with disabilities, and other under - represented groups. Diversity of IEC Materials  PNB has procured IEC materials which will be produced in Krio, Mende and Temne. They will be made available in formats that can also be understood by non - literate audiences. The app carried Temne , Mende and Krio audio files to allow less literate people to self - report and ensure their reports are properly registered. Narrowing the Gender Gap in PNB Sensitization  Through a diverse outreach strategy, PNB has narrowed the gender gap in PNB sensitization. This has been achieved through tailoring the PNB message to expectant mothers and female students. 66,300 females were taught on how to report, compared to 60,868 males. Outreach Strategy  Throughout the inception pha se, PNB outreach had been heavily focused in larger towns. In August, PNB held discussions with partner CSOs to widen the scope of work in each targeted district and it was agreed that CSOs would evenly distribute their animators thro ughout the targe ted di stricts to ensure the PNB message reaches all citizens, regardless of location. Recommendations from the VfM and financial performance sections  VfM of the FA component : In light of the upcoming PCR in early - 2019, it will be important to start thinking about the value for money of the FA component of the programme, which has not been included in previous Annual Review s .  VfM Equity assessment : In light of the upcoming PCR in early - 2019, it will be crucial to consider the 4th “E” (equity) more broadly, wi th a focus on the most vulnerable groups . Date of last narrative financial report December 2017 Date of last audited annual statement

1. Smart Guide (version March 2016) 1 Annual Review - Summary Sheet This Summary Sheet captures the headlines on programme performance, agreed actions and learning over the course of the review period. It should be attached to all subsequent reviews to build a complete picture of actions and learning throughout the life of the programme. Title: Support to Anti - Corruption in Sierra Leone Programme Value: £4.7 million Review Date: 01/02/18 Programme Code: 203881 Start Date: 21 /11/ 13 End Date: 31/12/ 18 Summary of Programme Performance Year 2014 2015 2016 2017 Programme Score A C A A Risk Rating Moderate Major Major Major Summary of progress and lessons learnt since last review Overall, the programme has made good progress since the last review and has performed well against the log frame . Milestones at the outcome level have been met and all of the output level milestones have mostly been met, demonstrating good progress toward s end of programme targets. The log frame has been updated to reflect the current activities, but the overall level of ambition was maintained. The year under review has been a year of two distinct halves. The first few months of the year saw very little implementation, with the service provider, Coffey International , dealing with severe internal staffing issues . Following an independent review 1 focused on programme resourcing and management, commissioned by Coffey Internationa l, in June 2017 , new personnel were brought in, including a new Team Leader and Programme Director . This review does not seek to duplicate or rep eat the findings of that review, but focuses on the latter half of the year where there has been solid progress . Highlights of key results achieved this year include:  The PNB platform has been operational 93% of the time , with over 5 5,000 reports made over the year 2017, of payment of bribes or engagement with an honest official through the call centre, website or PNB a pp lication (app) . Of these incidents, 35 , 146 were reports of cash bribe s being demanded. Capturing this data and shining a light into corruption in service del ivery is a success in its own right . There is also some evidence that e xposure of this crime by generating publicly available data might have ha d a direct impact on the behaviour of officials: Over the year, there has been a n increase in reports of citizen s meeting honest officials, risin g by over 300% from 213 in Q1 2017 to 690 in Q4 2017. This increase is greater than the increase in incidents reported ( 150% ) , indicating that there a relatively more honest officials being reported through PNB .  Efforts by CSOs to promote self - reporting through the free 515 phone line are ongoing through public education (including media and direct contact) . Also, t he operating hours of the call centre have been extended to 8pm in the evenings and on Saturdays (ha lf day) and two new staff who speak the predominant local languages (Mende and Temne) have been recruited.  The programme was extended to Kono , in October 2017. The ACC and CSO now extend into additional districts from the 5 hub districts . Data from the following districts is now feeding into the PNB: Kenema District , Bo District , Western Area Urban, Western Area Rural, Kono District, Bombali District, Bonthe District, Koinadugu District, Kambia District, Tonkolili District, Kailahun Distr ict, Port Loko District, Moyamba District, and Pujehun District . This means that the ACC is effectively starting to extend CSO coverage nationwide. The swift uptake of the platform in Kono suggests that citizens were already sensitised to the programme bef ore its roll out, and that (media) outreach activities raise awareness beyond the initial target districts .

10. Smart Guide (version March 2016) 10 recommendations. The Plan focuses on a range of radio and other media formats. These programmes have been produced and a ired nationwide in order to maximise PNB coverage. Overall there is greater ACC use of social media and WhatsApp. The Communications Strategy was revised in November 2017 to increase the focus on practical implementation. So far, the approach has been to focus on means of communication with wide reach, including vulnerable groups such as the poor, women and youth - particularly through increased use of radio. M ore should be done to look at other vulnerable groups, particularly those with disabilities. AC C, CSO, MDA collaboration is needed on communications and outreach. A core script to ensure the consistency of messaging across partners may be helpful. More routine, strategic engagement should be supported through steering and technical committees. CSO A nimators and ACC Public Education Officers were retrained during October and November 2017 . There is evidence of a much greater level of collaboration , which is appreciated by all stakeholders . The outreach programme now includes accountability foru ms with MDAs/ACC , CSOs and the public, establishing an effective platform between government and civil society. The outreach programme utilises core scripts, targeted messaging and “ message of the month ”, resulting in consistent and high impact messaging. The CSO Coordinator has established WhatsApp groups for these key stakeholders which have encouraged the sharing of stories, pro viding evidence of GoSL responsiveness not necessarily captured in the MDA reports, as well as lessons. Work with the Freetown CSO to improve delivery. Coffey reviewed CSO performance in August 2017 and poorly performing coordinators and animators were removed from the programme. The kobo software enables Coffey to monitor animator performance and triangulate reports with PNB platform d ata. Recommendations - By April 2018 , Coffey should review remuneration , in particular the stipends, for CSO partners, to inform the new contracts from April . - By July 2018 , DFID and Coffey should disaggregate output indicator 2.3 by gender and other characteristics in order to better understand preferences and capacities of women, girls, men and boys and marginalised groups to use the different reporting mechanism. While the l og frame disaggregates a selected number of indicators by gender ( whereby the milestones do not give an update on this, see comment above ), it is recommended to also disaggregate by age and location, information which is being collected via the platform already. - By July 2018 , Coffey should conduct social inclusion analysis of t he programme to inform its strategy after DFID support is coming to an end. This will not only be crucial as the programme is trying to reach scale, but also as it is moving away from a model of CSO outreach which previously had the ability to target cert ain groups directly. - At the next Steering Committee meeting a recommendation to include a minimum of one civil society representative, to be self - identified from amongst the CSO partners engaged in the programme, should be considered. Output Title Anti - Corruption Commission capacity to tackle grand and petty corruption increased. Output number per LF 3 Output Score B Risk: Major Impact weighting (%): 25% Risk revised since last AR? Y in accordance with revised DFID risk categories Impact weighting % revised since last AR? Y/N

5. Smart Guide (version March 2016) 5 • 79 individual , responsible 5 media articles/programmes highlighting grand and petty corruption and/or bribe paying or actions taken to address corruption. C orruption , against a target of 150 . The target would have been exceeded had all articles and programmes been taken into consider ation. Key lessons  Consistent messages and communication that includes all partners is essential for a common understanding and shared objectives and priorities. Clear responsibilities and more regular, formal progress meetings can support this. Capacity building support must be demand - led and all stakeholders engaged. The relationship between the ACC and Coffey has improved considerably over the last six months, but requires further investment .  Consistency in staffing and record keeping by the ACC (and Coffey) is essential for delivery and institutional memory . Key actions  Enhance communication : DFID should hold monthly progress meetings with the ACC and Coffey together to ensure a common understanding for sustainable implementation of the pro gramme.  Sustainability : The strategic plan and supporting capacity building plan should be completed as soon as possible and priority actions agreed with a work plan to take them forward. Interventions that support the sustainability of the PNB platform should be prioritised. Has the log frame been updated since the last review? Yes. The log frame was revised between February and September 2017, largely to reflect the revised programme length and the number of target districts. The key changes are: 1. Outcome indicator 2 has been revised but retains the spirit of the original indicator: this previously track ed small and large successful prosecutions, but was amended to capture completed ACC investigations rather than prosecutorial outcomes, which rest in large part with the jud iciary and other actors. The outcomes of MDA actions (intermediate and final) to respond to PNB reports were also included. 2. Output indicator 2.4: targets were substantially increased due to the higher numbers of re ports than initially expected; t he initially set targets for the life of the programme had been exceeded in the first quarter . 3. The 2018 and end of programme targets were revised based on updated info rmation about the number of districts the programme will target and the decision to move the programme end date from June 2019 to December 2018 . 4. Boxes previously filled with placeholders for completion after the pilot phase were completed and targets set, e.g. output 3.3. 5. Means of collection and assumptions were updated. 5 i.e. containing correct and up to date information

2. Smart Guide (version March 2016) 2  Specific and general MDA actions as a result of reports generated through the PNB already exceeded the February 2018 milestones by November 2017. In order to maximise impact and keep the momentum going, ACC and Coffey formulated an MDA engagement plan in October 2017 focused on MDA Responses and Actions required to re - engage the MDA’s. The plan aims to change the PNB narrative from “exposing and prese nting MDAs in a negative light” (a commonly held view of MDAs), to a more positive narrative whereby MDAs take action to tackle reports of corruption within their services. Actions taken on Last Review: Most recommendations from the last review have been actioned and followed up. The actions taken in response to recommendations from the last AR are covered in Section C. Summary of recommendations for the next year: The review contains a number of specific recommendations around management, focus, ensuring sustainability, and timelines under each output. The key recommendations include :  By May 2018 , DFID, Coffey and the ACC should finalise the comprehensive sustainabi lity plan , focused on ensuring that the ACC has the capability to sustain the investments made to date . In light of this sustainability assessment, a critical examination should be made of whether sufficient sustainability can be built prior to the current prog ramme end date in December 2018, and what would need to receive continued support through other DFID/ donor programmes .  By May 2018 , DFID and Coffey should revise the log frame to reflect the recommendations made within this review and DFID’s revised risk rating categories.  By September 2018 , DFID should finalise the contract amendment with Coffey to reflect the changes in key personnel, the focus and deliverables until the end of the programme, and the revised contract value and end date.  Going forward , DFID should hold monthly progress meetings with Coffey and the ACC togethe r. T o the extent possible all substantive meetings should be joint to ensure consistency in understand ing. A. Introduction and Context DevTracker Link to Business Case: https://devtracker.dfid.gov.uk/projects/GB - 1 - 203881 DevTracker Link to Log frame: https://devtracker.dfid.gov.uk/projects/GB - 1 - 203881 The Support to Anti - Corruption in Sierra Leone programme, commonly known as “Pay No Bribe” (PNB) was initially a £4.7 million programme 2 to reduce corruption in Sierra Leone’s service sectors. PNB is an innovative reporting platform which empowers citizens to anonymously report incidents of bribery an d petty corruption. Citizen s call a free hotline or submit a report via the website or mobile application (app) i n English, Krio, Temne and Mende to make their complaints. PNB is a data - captur e tool that shows trends in bribery in government Ministries, Departments and Agencies ( MDAs ) . The ACC share s data with the MDAs who use the data to address corruption from source through administrative action, system s review s and policy reforms. The ACC communicates the actions taken by MDAs and PNB results through a website, radio and other means . PNB is led jointly by the ACC and the Office of the Chief of Staff in coordination with the relevant MDAs and CSOs . The PNB platform is jointly funded by DFID and the GoSL. The programme is delive red through a contract with Coffey International, and a financial aid component to the ACC . The Millennium 2 Original value. The programme value is being reduced following discussion with partners, along with bringing the closure date 6 months forward to Dec 18. The contract amendment is in process.

3. Smart Guide (version March 2016) 3 Challenge Corporation Unit (MCCU), under State House, is a partner to the programme due to shared goals of reducing corruption in Sierra Leone. PNB is currently operating in five sectors, the SLP, Water, Energy, Education and Health with in the districts of Western Area Rural and Urban, Bombali, Bo, Kenema and Kono . T he judiciary has also been included since early 2018 . The programme ha s been subject to a number of significant delays beyond the 10 month suspension due to Ebola in 2014/5. These have been covered in previous Annual Reviews (AR) , but include delays in implementation in 2016 due to challenges with supplier performance. The 2017 annual review found significant progress and improvements had been made, but further delays occurred in early 2017 due to issues on the supplier team. It was acknowledg ed to the review team that the earlier delays and the further challenges in the first half of 2017 have had a n impact on progress and the partnerships . It was also clear , however, that t here has been a positive change since the new team took up post from J uly . What is the context within which UK support is provided? Sierra Leone ranked 123 out of 167 countries in Transparency International’s (TI’s) 2016 Corruption Perceptions Index (CPI) (a measure of ordinary peoples’ views of corruption in their country) scoring 30/100. There has been little progress in improving CP I scores over the past 5 years, with Sierra Leone scoring 31/100 in 2012 and 2014 and 30/100 in 2013. I n 2015, more than 60% of citizens reported that the level of corruption had increased over the past 12 months . B: PERFORMANCE AND CONCLUSIONS Annual outcome assessment The outcome statement is “ Government and citizens are more aware and capable of addressing smaller and larger scale bribery and corruption in key service delivery sectors in Sierra Leone ” . The table below indicates the progress made in the year under review: Indicators Milestone 2018 Progress 1. Number and percentage of people thinking that the news media are effective in revealing government mistakes and corruption. 53% in ‘hub’ districts (including Kono) Marginally not a chieved : 49% in pilot districts, 39.5% in control districts 2. a) Number of specific MDA actions taken b) Number of general MDA actions taken c) Number of corruption investigations completed 3 by ACC during the year a) 10 (including MEST and Justice) b) 21 (including MEST and Justice) c) 5 Exceeded : a) 21 b) 41 c) 108 3. % of people who are aware of how ordinary people can make a difference in fighting corruption (disaggregated by district, sex and age) 52% (including Kono) 57.5% (Hub excluding Kono) 36% (Control) Overall, t he outcome milestones have largely been met. The target figure for indicator 1 was marginally not achieved, but the percentage of people responding that the news media are effective remains higher in programme districts than in control districts. The 49% response rate is slightly lower than the 50% response rate in 2017, however, but this may reflect a change in the lev el of expectation by citizens. Indicator 2 was exceeded. While outcome indicators 2a) and b) have been exceeded, t he massive overachievement in relation to indicator 2 c) is because t he wording for this indicator was revised in 2017 from “number of successf ul prosecutions” but the milestone was not revised . 3 The wording for this indicator was revised in 2017 from “numb er of successful prosecutions”. The 2017 milestone still reflects the 2016 indicator, which explains the massive overachievement.

12. Smart Guide (version March 2016) 12 Coffey team should increase in - country support to work in partnership with the ACC. This recommendation has not been fully taken forward. Though the existing team has increased its focus on partnering with the ACC, Coffey’s focus for much of the latter part of the year has been on staff recruitment to replenish posts after the challenges in early 2017. A new Te a m Leader joined in July 2017; a CSO Coordinator joined in early September 2017; and the new post of Deputy Team Leader was recruited to in early October 2017. Coffey should consider appropriate resourcing for the remainder of the programme to ensure that it is able to respond to this recommendation going forward. Consider revision of this indicator to captur e work that aims to increase the MDAs capacity to respond to PNB reports, ‘strengthening GoSL response to corruption’. This recommendation was not adopted. The recommendation remains relevant and should be considered again. Recommendations - By June 2018 , Coffey and the ACC should work together to finalise the strategic plan and supporting capacity building plan , and draw out next steps for sustainable programme delivery . - By July 2018 , DFID and Coffey should consider revising this Output to better reflec t the focus and approach to capacity development; and to capture work that aims to increase the MDAs capacity to respond to PNB reports . - By August 2018 , Coffey should report against outputs in the quarterly reports to ensure that this output is given suffi cient focus. Output Title The media is better prepared to engage with citizens, CSOs, ACC and MDAs at national and district levels to pursue news stories on corruption. Output number per LF 4 Output Score A Risk: Moderate Impact weighting (%): 25% Risk revised since last AR? Y in accordance with revised DFID risk categories Impact weighting % revised since last AR? Y/N Key Points 9 E.g . s erialised drama programmes; vox pops from districts; interactive theatre formats; forum theatre rebroadcasts; soap operas. 10 i.e. containing correct and up to date information Indicator(s) Milestones Progress Number and percentage of citizens a) claiming to have listened to/read information on anti - corruption in the previous 3 months; b) claiming to have had a discussion about corruption with family/friends in the last 3 months. a) 65.5% (hub districts and Kono) 75% m, 66% f b) 25% (hub districts + Kono) Exceeded : a) 87.5% (hub districts), 74% (control districts) b) 35.75% (hub districts), 21.5% (control districts) Number of a) divers e radio formats 9 covering corruption/bribery; b) community radio/FM station journalists producing content in rural areas (by distr ict) c) number of responsible 10 media articles/programmes highlighting grand and petty corruption and/or bribe paying or actions taken to address corruption. a) 8 b) 3 local radio journalists per implementation district (total) c) 150 Achieved : a) 7 (Voxpop; radio panel discussions; TV panel discussions; Accountability Forum airings; endorsements; ji n gles and theme songs; radio soap) b) 6 (1 per District and 1 by ACC Headquarters) c) 79 individual articles/programmes (though many reported across multiple papers/networks, which have not been counted)

6. Smart Guide (version March 2016) 6 C: DETAILED OUTPUT SCORING Output Title Reporting mechanism and information on instances of bribery and corruption are available and accessible to the public and MDAs in Sierra Leone. Output number per LF 1 Output Score A Risk: M oderate Impact weighting (%): 25% Risk revised since last AR? Y in accordance with revised DFID risk categories and to reflect concerns around sustainability Impact weighting % revised since last AR? Y/N Key Points The PNB reporting platform has been operational since its launch in September 2016 with citizens able to report payment of bribes or engagement with an honest official through the call centre, website or PNB App. The anonymity of the App continues to be more trusted by citizens, along with citizens increasingly trusting that calls really are free. T here are signs that recent efforts by CSOs to promote self - reporting through the free 515 phone line are starting to e ncourage higher levels of reporting through the call centre and public ownership. The extension of operating hours to 8pm in the evenings and on Saturdays (half day) and recruitment of two new call centre staff who speak the other predominant local languag es (Mende and Temne) from Janu ar y 2018 will hopefully also support greater use of the call centre going forward. The target of 20% of citizens in the target areas stating that it is “ easy ” or “ fairly easy ” to report a bribe was met . An end of project surve y is currently planned to be conducted before the project end in December 2018. 6 Since the accessibility of the Call Centre depends on a range of variables, including some that are outside of programme control (telecommunication networks and poor connectivity), the uptime of the call centre is calculated on whether it has been able to receive and sustain calls. The following definitions has been applied: Uptime : If the call centre has received a call during a clock hour, where the caller has had connection with a call centre a gent for more than 10 seconds, the call centre is considered up in that hour. Downtime: If the call centre during a clock hour has not received a call where the caller has had connection with a call centre agent for more than 10 sec onds, the call centre is considered down in that hour. This represents a 2% improvement from the 2017 AR. Indicator(s) Milestones Progress a) % time PNB has an accessible reporting system (call centre, website and app) receiving information and generating live, accurate public analysis and reports on bribe trends; b) monthly PNB reports prepared by ACC and shared with target MDAs, disaggregated by district and sector. a) 93% b) 25 monthly analysis reports (cumulative, 5 per sector, 1 for justice) Achieved : a) 93% 6 b) 50 mo nthly data analysis reports (but programme not yet extended to include the justice sector) Number of additional pieces of quality information, analysis and research reviewed and made available to the public by the ACC about corruption trends. This should be shared on either the ACC or PNB sites. 8 Achieved : 8: The PNB website includes: 2016 Annual R eview; Updated Communications Strategy; Kenema Learning Event report (August 2017) ; Makeni Learning Event report (December 2017) ; Baseline Survey; End of Pilot Survey; Behaviou ral Analysis of B ribery in S ierra L eone ; Q3 Data Analysis Report % of citizens in PNB target areas who state that it is easy or fairly easy to report a bribe via the website, call centre or app. 40% (hub areas including Kono) 20% rest of c ountry Achieved : 21%

8. Smart Guide (version March 2016) 8 With DFID funding to PNB coming to an end post - 2018 , I T knowledge transfer from the Coffey IT Adviser embedded in the Call Centre and a strategy on how the ACC can ensure maintenance of PNB’s IT platform at the current or improved quality will be a priority over the next months. Recommendations - By March 2018 , the ACC should explore whether it is feasible to further extend call ce ntre operating hours to 9 pm , which the log of out of office calls suggests would enable the m ajority of calls to be captured, and hire additional agents, speaking further local languages . - By May 2018 , Coffey and the ACC should explore DFID’s suggestion of a pilot to locate tablets in local government offices, such as the District Council or ACC regional office. The pilot should test the viability of this option in terms of independent use, maintenance , etc. - By May 2018 , DFID, Coffey and the ACC should finalise a comprehensive sustainability plan. - By June 2018 , Coffey should consider recruiting a medium - term governance expert to provide technical support to the IMCs. - By July 2018 , Coffey should agree with the ACC how to ensure IT skill transfer in the call centre, and to maintain PNB’s IT platforms post DFID support . - By July 2018 , DFID and the ACC should explore ho w strengthen, incentivise and support MDA engagement, through PNB or other programmes. Output Title Citizens are more knowledgeable about legitimate service charges and their rights not to pay bribes. Output number per LF 2 Output Score A Risk: Moderate Impact weighting (%): 25% Risk revised since last AR? Y in accordance with revised DFID risk categories Impact weighting % revised since last AR? N Key Points Indicator(s) Milestones Progress Number of a) ACC outreach officers and b) CSO animators trained in awareness raising for PNB and monitoring of activities. a) 2 additional ACC outreach officers trained in Kono b) 22 CSO animators in Kono Achieved : a) 2 additional ACC outreach officers trained in Kono and 10 ACC officers retrained in the 4 ori ginal districts b) 120 CSO animators trained in 5 districts (including Kono) Number of m/f citizens in pilot programme areas a) reached by information on correct payments for services, and b) trained to access and use PNB . a) 18,000 b) 10,500 hub districts plus Kono Achieved : a) 24,858 b) 11,553 Percentage of (m/f) citizens in programme areas (disaggregated by sex and age) who can describe one or more ways of reporting bribery and corruption issues. 41% in hub districts 21% control districts Exceeded : 58% in hub districts 23.5% in control districts Number of reports/complaints received from citizens highlighting petty corruption through a) free phone line , b) website, c) mobile phone app. a) 3,000 cumulative b) 1,200 cumulative c) 38,000 cumulative Achieved : a) 4980 cumulative b) 1003 cumulative c ) 58563

4. Smart Guide (version March 2016) 4 To deepen sustainability, DFID is designing a new accountability programme which builds on the successes of PNB, and includes interventions to strengthen the capacity and capability of the ACC , amongst other institutions . Overall output score and description The overall output score is A . This reflects good performance across all four outputs, with three being fully met and one partially met . Output Weighting Score Comment 1. Reporting mechanism and information on instances of bribery and corruption are available and accessible to the public and MDAs in Sierra Leone. 25% A Achieved. • The PNB reporting system (call centre, website and app) was operational 93% of the time . • 50 monthly data analysis reports were generated. • 8 additional information pieces published. • 21 % of citizens in PNB target areas state that it is easy or fairly easy to report a bribe via the website, call centre or app. 2. Citizens are more knowledgeable about legitimate service charges and their rights not to pay bribes. 25% A Achieved. • 2 additional ACC outreach officers trained in Kono and 24 ACC outreach officers retrained • 120 CSO animators trained in 5 districts • 24,858 people informed on correct payments fo r services, and 11,553 people trained to use PNB . • 58% of citizens in focus areas can describe one or more ways of reporting bribery and corruption issues. • The free phone line received 4,819, the website 976, and the mobile phone app 47,077 of reports/complaints. 3. Anti - Corruption Commission capacity to tackle grand and petty corruption increased. 25 % B Not achieved . • 15, against a target of 20, of HQ and regional ACC staff trained in methodologies for pursuing and managing higher value corrupt ion cases . • 60%, against a target of 50%, of HQ and regional ACC staff identifying >3 ways in which they feel that their performance has improved after training . • A draft strategic plan developed with the support of a consultant in December 2017 is still under discussion, against an aim that 30% of the plan ’s organisational and capacity development actions would be under implementation or complete d. 4. The media is better prepared to engage with citizens, CSOs, ACC and MDAs at national and district levels to pursue news stories on corruption. 25% A Achieved. • 87.5% of citizens claim to have listened to/read information on anti - corruption in the previous 3 months , aga inst a target of 65%. • 35.75% of citizens (not including Kono) claim to have had a discussion about corruption with family/friends in the last 3 months , against a target of 25 (including Kono) . • 7 , against a target of 8, divers e radio formats 4 covering corruption/bribery developed ; • 6, against a target of 3, community radio/FM station journalists producing content in rural areas (by distr ict) ; 4 E.g . s erialised drama programmes; vox pops from districts; interactive theatre formats; forum theatre rebroadcasts; soap oper as.


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