Presolicitation Notice SSPA Signed RBA 12.23.20.pdf

Presolicitation Notice

USAID Strengthening Systems and Public Accountability

Solicitation Number: 72061720R00008 Release Date: December 23, 2020

The United States Agency for International Development Mission in Uganda (USAID/Uganda), in cooperation with UKAID, intends to issue a Contract to implement the USAID Strengthening Systems and Public Accountability Activity. USAID intends to use full and open competition for this procurement and to release the solicitation in January 2021.

This presolicitation notice provides information regarding the anticipated solicitation through a synopsis and a draft statement of work for the Contract. The purpose of this notice is to allow interested organizations to familiarize themselves with the envisioned activity. USAID does not anticipate changes in the information contained in the draft statement of work. USAID is not requesting comments and is not accepting questions at this time.

Synopsis

Accountability is a core pillar of USAID’s work in strengthening democratic government and is essential to realize the aspirations of USAID/Uganda’s Country Development Cooperation Strategy (CDCS). USAID/Uganda has supported accountability efforts in Uganda for several years; this activity will be the next iteration of the Mission’s evolving approach. The objective of the USAID Strengthening Systems and Public Accountability Activity is to improve the government of Uganda’s responsiveness to citizens, service delivery, and stewardship of resources through strengthened accountability, deepened public participation and oversight, and reduced corruption in Uganda’s public service sectors.

USAID advises Prospective Offerors that this procurement is subject to internal USAID approvals and the availability of funds. This is not an Invitation for Bid (IFB) or a Request for Proposals (RFP) and in no way obligates the US Government to issue an IFB/RFP or award a contract. This notice satisfies the synopsis requirement in FAR 5.2. If a solicitation is issued, all necessary information will be supplied when it is posted at sam.beta.gov.

Presolicitation Notice – USAID/Uganda ‐ Strengthening Systems and Public Accountability

USAID advises interested parties to periodically monitor the above website and solicitation number for updates concerning this procurement.

Sincerely, R. Brian Aaron Supervisory Contracting Officer USAID/Uganda

Presolicitation Notice – USAID/Uganda - Strengthening Systems and Public Accountability

SECTION C – DRAFT STAMENT OF WORK

1. Purpose

The Strengthening Systems and Public Accountability (SSPA) activity aims to improve the government of Uganda’s responsiveness to citizens, service delivery, and stewardship of resources through strengthened accountability, deepened public participation and oversight, and reduced corruption in Uganda’s public service sectors. SSPA will strengthen public sector leadership and accountability for results in targeted sectors, support citizen and civil society engagement on corruption, and support the rewards and sanctions standards under the Ministry of Public Service, norms, and behaviors that enable the abuse of public office for private gain.

2. Scope

USAID and the UK’s Department for International Development (DFID) partner to jointly fund SSPA, with a Total Estimated Cost (TEC) of approximately $40 million over five (5) years. The activity will work with communities and subnational governments across broad geographic coverage, including Northern Uganda, the Albertine region, key municipalities and secondary cities, and districts proposed by the offeror. SSPA will also engage national government institutions extensively.

The SSPA activity seeks to advance three objectives.

Objective 1: On the demand side, the Activity will increase citizen voice, coalition building, and public engagement with the government to reduce corruption and increase accountability. The activity will support sustained civic demand and empowerment for greater transparency, strengthening civil society, the private sector, and the media, and creating a voice that holds the government to a high standard of integrity and performance.

Objective 2: On the supply side, the Activity will strengthen local government and municipality systems and practices for improved public accountability. The activity will promote improved accountability processes, optimize resource utilization, build strong systems of monitoring and reporting, review decentralization policies and improve performance through anti-corruption strategies.

Objective 3: Under this objective, the Activity will improve key systems, practices, standards, and norms of target national anti-corruption and accountability institutions. The activity will target selected national and sub-national institutions to improve service delivery, limit opportunities for corruption, and deepen accountable governance. Where possible, efforts at the national level should link to programming with sub-national actors and institutions.

In addition to the three objectives, SSPA will work on targeted sectors, including the extractive industry, countering wildlife crime-related corruption, accountability in refugee-hosting districts, effective use and accountability of funds in the education sector, and others as opportunities arise. The creative approaches to curb corruption by advancing the three objectives will be explicitly tested and piloted across these cross-cutting target sectors.

3 Background

3.1 Overview

The SSPA activity will advance community-driven accountability and reduce the incidence of corruption in Uganda. SSPA will support open, inclusive, and accountable governance in Uganda at both national and sub-national levels.

Accountability is a core pillar of USAID’s work in strengthening democratic government and effective public administration. Accountability is essential to realize the aspirations of USAID/Uganda’s Country Development Cooperation Strategy (CDCS) and is a key component of the PITA principles (Participation, Inclusion, Transparency, and Accountability) of USAID’s Democracy, Human Rights, and Governance (DRG) Strategy. These elements are self-reinforcing; by deepening inclusive public participation and ensuring transparency, citizens can hold the government accountable for results and appropriate stewardship of financial and natural resources. USAID/Uganda has supported accountability efforts in Uganda for several years; this activity will be the next iteration of the Mission’s evolving approach.

Corruption takes many forms, each with different drivers, norms, and consequences. Since USAID’s 2005 Anti-corruption Strategy, the agency has used Transparency International’s simple definition: “the abuse of entrusted power for private gain.” While the Agency’s approach to corruption has evolved substantially since that strategy, the fundamental idea of what constitutes corruption remains the same.

Corruption distorts public decision-making, discourages private-sector development, and undermines service delivery and the fair application of the law. Just as often, corruption serves as the only means to get public services rendered. Nepotism and cronyism in procurement, bribery, absenteeism, and wage theft all subvert public purpose for private benefit.

Successful strategies to combat corruption are place- and context-specific, dealing directly with social norms and ingrained practices in communities. Approaches must consider incentives for and against corruption, and how various actors can partner in a network to resist it. The literature on anti-corruption is littered with failed or minimally impactful initiatives, and not one best practice exists. USAID anti-corruption efforts must be reflective, acknowledge when an approach isn’t working, and pivot quickly to where there is most traction. Change in this sector is incremental and depends enormously on the political will of individual and institutional actors-- what works in one place may not work in another.

3.2 Ugandan Context

“Corruption has been elevated to the level of an ideology, the culture of the successful in politics, religion, business and public administration.”

Weak governance and accountability are key barriers to inclusive development that includes the most vulnerable. Corruption in Uganda is widespread, posing a major obstacle to the country’s social and economic development and provision of quality public services. In a 2014 report by the Uganda National Governance Baseline Survey (UNGBS), 73% of the people surveyed identified corruption as a serious national problem. Despite the proliferation of anti-corruption and investigatory commissions and promises of “Hakuna Mchezo” ー the slogan for President Museveni’s anti-graft effortsー meaningful improvements in accountability and anti-corruption have been hard to come by. In Transparency International’s estimation, corruption in Uganda has actually gotten worse in recent years. As Uganda slides lower on their index, recent reports claim that “corruption-related challenges in the country are a result of a lack of separation between the public and private spheres, leading to extensive clientelistic practices and patronage, as well as widespread political corruption.” Slow progress on corruption and accountability is not caused by a lack of technical expertise; it is a product of politics, vested personal interests, weak enforcement, and misaligned incentives. As Uganda continues to prioritize large-scale infrastructure and capital investments and prepares for substantial development of its nascent oil and gas sector, the stakes of corruption get higher, and opportunities for it multiply.

Service provision and the business of government is undermined by resource leakages and inconsistent application of the rules. For example, the World Bank IFC’s 2013 “Doing Business in Uganda” report details the propensity for bribery as businesses try to speed up or circumvent complex regulations and registration processes. 10% of survey respondents admitted offering bribes or paying for services that were meant to be free in the health sector, while two-thirds reported major concerns about corruption in the Uganda Police Force. Examples of corruption reports are varied and widespread, including abuse of office, fraud and embezzlement, cost inflation, misappropriation of public funds and assets, paying for goods or services not delivered, absenteeism and salaries to ghost workers, false declarations of imports and exports, bribery and extortion, demands for commissions for work completed, and nepotism.

While several anti-corruption institutions exist in Uganda, most have scant resources given their mandates.

Most Ugandans are not meaningfully engaged with anti-corruption institutions, and the watchdog role of civil society organizations (CSOs) has yielded limited results. While community engagement and participation are critical to fighting corruption and improving accountability, many Ugandans remain politically disengaged on the issue.

When assessing corruption in Uganda, it is constructive to examine three common forms it can take:

• Petty corruption: Individual public officials abuse their offices by demanding bribes and kickbacks-often soliciting private payment to do their public job. Conversely, individuals abet corruption to circumvent bureaucratic bottlenecks, avoid legally applicable costs, or to receive services they should receive for free.

• Grand corruption: The theft or misuse of vast amounts of public resources by state officials, especially members of the political elite.

• State capture and influence peddling: Collusion by private actors with public officials or politicians for their mutual private gain. The political class, public servants, and private parties extort public funds for private gain. This often includes influence peddling, outright theft, seeking commissions on contracts, selective enforcement in the justice sector, and interfering with procurement processes.

The impacts of these practices are hard to overstate. The resultant effects of corruption include undermining political and economic stability, decreased public tax compliance and weakened domestic revenue mobilization, poor value for money in public projects, discouraging foreign direct investment (FDI), poor quality or total collapse of public service provision, demoralization of public servants, institutional decay, and the weakening of the rule of law.

This activity will address the following core problem:

Lack of accountability and endemic corruption in Uganda undermine democracy, development, and service delivery.

3.3 Current and Past USAID/DFID Interventions: Lessons Learned

USAID and DFID reviewed anti-corruption efforts in Uganda and worldwide, and consulted numerous civil society organizations, government officials, and donors. This review revealed that successful programs are politically attuned and context-specific, and consistently test and adapt approaches to changing local system dynamics. USAID and DFID also reviewed lessons from two separate prior efforts

- a DFID-funded anti-corruption activity as well as a USAID-DFID jointly funded accountability program

- and identified that a joint collaboration addressing both issues will be the right approach to effectively address this complex challenge.

USAID/Uganda and DFID have been supporting the Governance, Accountability, Participation and Performance (GAPP) activity to increase public participation, accountability, and effective local governance in Uganda. The GAPP activity revealed key lessons for successful accountability programming in Uganda. First, GAPP demonstrated the importance of a holistic, “systems thinking” approach. GAPP worked through national institutions and local governments simultaneously, working to improve the functioning of Ugandan governance wherever willing partners could be found. This included both technical and political staff. Demand-side interventions that supported civil society and community-based priorities also proved to be a sustainable way to build momentum and citizen voice. GAPP also successfully piloted a “tripartite” accountability model, convening community leaders, private sector and different audiences and institutions together in public hearings for mutual accountability. The model enhanced accountability by subjecting local government operations to public scrutiny. Other successful strategies identified from the GAPP experience include: making state institutions more resilient to political pressure, building the capacity of local government alongside national institutions, enhancing service delivery and government accountability, and supporting the voice of non-state actors.

SUGAR-TAF, funded by DFID, supports national institutions with a mandate to tackle corruption by improving the operation and coordination of core functions across these institutions. The program also supports “institutions under transformation” such as institutions where there is a combination of political will, national importance and leadership aimed at increasing integrity, accountability and tackling corruption effectively. An important lesson from this activity was the significance of making strategic choices throughout the life of the activity that were driven by contextual relevance, learning and adaptation. The activity also highlighted the need to remain realistic about the scale of the challenges faced, their political nature, the need for risk mitigation measures, and the inadequacy of narrow technical, blueprint approaches.

From 2009 to 2011, USAID and the Millennium Challenge Corporation implemented the Anti-Corruption Country Threshold Program (ACP). This intervention demonstrated how the application of administrative authority can drive “institutional will” and play a significant role in overcoming bureaucratic challenges.

The ACP saw the establishment of the Anti-Corruption Court, the Police Anti-Corruption Unit and a case referral and follow up mechanism all established through administrative action instead of through complex legal and policy procedures. A negative outcome of the program was internal transfers and re-deployments of government staff whose capacity was built by the Program, which undermined project success.

Therefore, when focusing only on actors, rather than systems, there is a high risk of losing progress.

3.4 Preliminary Problem Analysis

Design analysis revealed four key enabling factors of corruption and poor accountability.

Norms and Expectations

• Entrenched norms and social expectations of public servants to use their positions for the financial benefit of themselves, families, and communities

• Factional politics, political disenfranchisement, poor and inconsistent public servant pay, and a sense that the allocation of public resources is not fair or equitable undermines respect for the system, causes people to define “fair” for themselves

• Collective action challenges and a sense of resignation to “the way things work”

• Social ties and loyalty within community discourage reporting, causing what some term

“community corruption”

• Shades of grey, ideas of what constitutes “good corruption” and ‘bad corruption”

Corruption Gets Things Done

• Many state institutions already have low capacity

• The poor have few or no other options than public service provision, even if they are forced to pay a bribe

• Lengthy bureaucratic processes and red tape can be circumvented by corruption

• Donors and CSOs frequently step in to fill service delivery gaps

• For the professional class and wealthy, complying with corruption or soliciting special treatment is often easier, more convenient, or less costly

Incentives and Disincentives

• Widespread impunity, weak enforcement, well-connected and wealthy officials unlikely to face administrative or legal consequences

• Officials who are caught are frequently transferred to another job, sometimes even a better one

• Political interference and selective application of the law

• Many public servants are poorly paid, corruption supplements their income

• Lack of incentives to engage the poor and marginalized in participatory governance

Leadership and Institutions

• Regulatory and policy gaps and poor implementation

• Easy to mimic institutional forms without real functionality for accountability actors

• Transparency, financial management, and procurement bodies are under-resourced, sometimes intentionally

• Anti-corruption champions have limited influence, are scattered and disconnected

• Political patronage sustains the status quo

• Dramatic growth of the scale of local and national government, more layers where corruption can occur

• Systemic fracturing undermines cooperation between government institutions

• Lack of fora for public engagement and problem solving

3.5 Alignment to USAID and DFID Strategy

USAID’s 2016-2021 Country Development Cooperation Strategy (CDCS) proposes an integrated approach that brings together a range of interventions to help Uganda fully realize the potential of its people and resources. SSPA will primarily contribute to Development Objective 3: “Key systems more accountable and responsive to Uganda’s development needs” under USAID/Uganda’s CDCS. It may also directly or indirectly contribute to the other development objectives and intermediate results (IRs) through its multi-sectoral engagement. The activity will indirectly contribute to the resilience development objectives under IR 1.1.1, “Behaviors that reduce vulnerability strengthened.” The support to civil society and local communities will strengthen the ability of vulnerable communities to speak out and demand accountability, as well as collaborate with their leaders for improved service delivery. The activity has the potential to contribute to IRs across the CDCS. SSPA also responds directly to the Agency’s renewed focus on sustainability and the “journey to self-reliance.” Public accountability and anti-corruption efforts are crucial to advance Uganda’s ability to chart its own development destiny, with robust citizen participation and appropriate stewardship of public resources.

SSPA is also aligned with the United Kingdom (UK)’s Africa Strategy 2018 that identifies governance as core to building Africa’s prosperity, stability and resilience in the UK’s long-term national interest. The strategy emphasizes the importance of building strong institutions and building trust between those institutions and the people who are governed by them. DFID’s new Governance Position Paper 2018 emphasizes the importance of thinking and working politically, ensuring that all of the UK’s international engagement supports governance - leads on anti-corruption measures, tackles illicit flows, and builds democratic space. Refer to DFID’s Digital Strategy 2018-2020 (See attachment J.18). DFID’s Digital Strategy 2018-2020 (See attachment J.18). SSPA is further aligned to USAID ‘s Digitization Strategy with the objective to strengthen the openness, inclusiveness, and security of country-level digital ecosystems, financial inclusion, and support accountability and transparency in governance.

3.6 Alignment with Government of Uganda Strategies

The activity also aligns with Uganda’s National Development Plan (NDP) II: “Strengthening Uganda’s Competitiveness for Sustainable Wealth Creation, Employment and Inclusive Growth.” NDP II underscores the importance of strengthening mechanisms for quality, effective, and efficient service delivery as its fourth objective, which this activity will directly support. SSPA will also contribute to Uganda’s support of the Sustainable Development Goals (SDG) agenda, particularly goal 16 on peace and governance.

The activity will also advance the objectives of Uganda’s Accountability Sector Strategic Investment Plan, whose aims include: (i) Enhance the prevention, detection, and elimination of corruption by strengthening the enforcement of the existing legal framework; and strengthening the capacity of investigation and prosecution, ombudsman, ethics and integrity functions; (ii) Increase public demand for accountability by strengthening the capacity of the public to demand for accountability; and build CSOs’ capacity to detect and report corruption and anti-money laundering; sensitize CSOs on government projects; and develop and implement information sharing protocols.

In 2011, the Government of Uganda, through the Ministry of Public Service, formulated an eight-point policy paper on the transformation of Uganda’s public service with the aim to increase efficiency within the sector including strengthening supervision, coordination, monitoring and evaluation and inspection functions, improving staff recruitment and selection methods, implementing a stringent performance management system, among a few. While not all of these approaches will form a part of SSPA’s intervention for stronger governance, accountability, and anti-corruption efforts, they are illustrative of the reform efforts already underway in Uganda.

4. Activity Objectives

4.1 Introduction

The goal of the SSPA activity is to improve the government of Uganda’s responsiveness to citizens, service delivery, and stewardship of resources through strengthened accountability.

The objectives contribute to the following broad theory of change: If citizens, civil society, and government institutions more effectively fight corruption and ensure public accountability, then governance, service delivery, and financial and natural resource stewardship will be improved.

In addition to the three objectives, SSPA will work on targeted cross-cutting sectors including the extractive industry, countering wildlife crime-related corruption, accountability in refugee-hosting districts, effective use and accountability of funds in the education sector, and others as opportunities arise.

4.2 Objectives

Objective 1: Increased citizen voice, coalition building, and public engagement with government to reduce corruption and increase accountability

Activities under this objective, SSPA will focus on engaging non-state actors, including citizens, youth groups, religious and cultural institutions, CSOs, CBOs, media, and the private sector. Efforts should work to increase these actors’ impact on national and sub-national government accountability, corruption prevalence, and policymaking. Effective participation from these actors is essential to drive the accountability and anti-corruption agenda for lasting impact. Approaches might include citizen committees, youth groups, collaboration with media houses, or coalition building with CSOs. Robust public engagement must provide a check on inappropriate use of public office, increase and mobilize demand for better governance and service delivery, and hold leadership accountable.

Activities will seek to build on existing momentum for engagement and reform and specify entry points whether national, regional, or local. For example, strengthening the voice of communities might include select interventions with cultural institutions, Local Government Public Accounts Committees (LGPACs), School Management Committees (SMCs), Village Health User Committees (VHTs), Water User Committees, youth groups, Village Savings and Loans Association (VSLA) and farmer groups and extension services, to name a few. Activities should engage youth in both rural and urban areas to hold their leaders accountable. Many community watchdog formations already exist in Uganda, and offer a useful entry point in this area.

Network and coalition building is a fundamental outcome of this activity. Networks and coalitions can serve key functions in effective governance in participation by aggregating and amplifying voice, sharing information, lowering barriers to entry and participation, defining new spaces, norms, and fora for engagement, and brokering access with formal government institutions. USAID anticipates activity to leverage networks and coalition building to deliver on the overall objective and complement work in the other outcomes of the SSPA activity. CSO networks may fight corruption work by linking national and regional efforts on anti-corruption, while others may play a convening role around accountability in budgets and public expenditures. Activities may also explore partnerships with the private sector where meaningful contributions can be made to anti-corruption and accountability initiatives, and might include partnerships with industry groups and professional associations.

Whistleblowing in Uganda is limited, with many Ugandan citizens reluctant to report out of fear, loyalty, apathy, or lack of alternatives. Many Ugandans express skepticism that anything can be done about corruption, greatly reducing their will to engage. Interventions here might target both the enabling environment for whistleblowing and attempt to influence individuals’ willingness to engage and report.

SSPA may include strategies for targeting norms, attitudes, and practices around accountability and anti-corruption, which can be a driver of change or foundational barrier. The three are not the same-- individuals may view corruption as a social ill, yet still perpetuate it. Corruption goes beyond a simple moral calculation. It is frequently a classic “collective action” problem. Test strategies to engage here, test what works with which places and actors, and adapt programming accordingly. This activity should engage both ordinary citizens and non-state actors to help identify, report, and punish corrupt practices.

SSPA can also shape how accountability and corruption topics are reported and understood by working directly with media houses. A free media, vibrant civil society, private sector, and engaged communities are crucial components for improved governance and fighting corruption.

Objective 2: Strengthened local government and municipality systems and practices for improved public accountability

This objective will strengthen public service delivery by strengthening district local governments and municipalities and supporting the decentralization policy framework to increase public engagement, effectiveness, and accountability. Subnational governments, as the sites of service delivery and the institutions closest to communities, are fundamental to public accountability, reducing corruption, and ensuring responsive, high-quality service delivery. Many of these entities implement transparency, accountability, and anti-corruption efforts, yet face resource constraints, coordination challenges, and insufficient political will. Strengthening these institutions and building their capacity will ensure progress on anti-corruption and accountability in Uganda.

Public engagement efforts under Objective 1 should be directly linked to work under SSPA Objective 2.

Frequently, local governments are the primary fora for community and citizen engagement with the state.

As the activity works to strengthen non-state actors’ ability to demand accountable governance, it must also build the will, practices, and capacity of state institutions to deliver and be responsive, especially at the local level.

The SSPA activity will support organizational development efforts for relevant local institutions to build their ability to deliver on, and advocate on behalf of, their mandates. Internal staff performance management, planning, budgeting, financial management, procurement, and monitoring for accountability are all crucial institutional capacities to consider strengthening. Technical assistance to local governments, as well as local offices of national institutions, can be an essential tool to improve the quality and integrity of public administration and resource stewardship.

While part of Objective 1 may lead to the uptake of whistleblowing among the general public, Objectives 2 and 3 approach that same goal for public servants, who face very different incentives, norms, and outcomes of engaging in whistleblowing. Objective 2 activities should target norms, attitudes, and practices around accountability and anti-corruption, which can be a driver of change or foundational barrier.

Individuals with attitudes that corruption is a problem may still perpetuate it through practices, often in conformance with a wider norm. Strategies to engage here, test what works with which places and actors, and adapt programming accordingly. Approaches should be tuned to the types of public officials they are targeting— drivers at the local government level differ greatly from the education sector, infrastructure, or elected office, for example.

Objective 3: Improved key systems, practices, standards, and norms of target national anti-corruption and accountability institutions.

Effective, transparent institutions are at the heart of accountable government. Outcomes under this objective work to strengthen public institutions’ role in effective, transparent service delivery and appropriate use of public authority.

There are numerous potential institutional partners for efforts under Objective 3. Many national entities have mandates that are explicitly or closely tied to accountability and anti-corruption work, including the Inspectorate of Government (IG), the Office of the Auditor General (OAG), the Public Procurement and Disposal Authority (PPDA), Ministry of Local Government (MOLG), judicial institutions, the Directorate of Public Prosecutions (DPP), and Parliamentary Public Accounts Committees (PACs). A number of these have regional and local presence, with substantially varying capacity.

SSPA will support organizational development efforts for relevant institutions to build their ability to deliver on, and advocate on behalf of their mandates. Internal staff performance management, planning, budgeting, financial management, and monitoring for accountability are all crucial institutional capacities to consider strengthening. Effective leadership will be critical to improve accountability and reduce corruption in the public service. In some cases, organizational leaders are already champions of reform, and SSPA may explore ways to partner with and strengthen the reach of these individual champions. In others, leadership development is weak, and an opportunity for improvement. Previous programming implemented by DFID and USAID focused on leadership development and had strong results with entities like Uganda National Roads Authority (UNRA), the Uganda Revenue Authority (URA), the Kampala Capital City Authority (KCCA), and local district governments.

Political will is both a major barrier to reform in this sector but can be a key enabling factor. Large administrative structures and overlapping mandates of accountability and anti-corruption agencies pose a challenge to effective leadership and coordination. This objective will promote transformational leadership values such as equality, trust, collaboration, accountability, integrity and ethical standards.

Individual public servants through their leadership- the pressures they face, the norms and expectations surrounding their work, and the decisions they ultimately make- either sustain or dismantle Uganda’s endemic corruption on a daily basis. Work under this objective seeks to identify champions within the public service who can lead on this issue, and strengthen their ties to broader networks of citizen, CSO, youth, and private sector champions.

When public officials are held accountable through democratic means, service provision is likely to be faster, more inclusive and sustainable and support the stabilization of the political system. Weak enforcement is pervasive in the Ugandan context, and as a result, corruption is neither costly nor risky. In some places and institutions, adequate sanctions exist, but are inconsistently implemented or even weaponized against political opponents. In others, sanctions themselves are weak, with officials facing a mere “slap on the wrist,” if any consequence at all.

Alongside work on norms, institutional capacity, leadership, and political will, under this objective SSPA will work to support a robust, functional system of consequences and rewards to strengthen both the letter and application of the law. In many cases, these may take the form of administrative standards and sanctions within the Ministry of Public Service (MoPS) or various service commissions at the national and district level. The MoPS’s capacity to oversee performance management, compliance, and efficiency and effectiveness for public service delivery all have room for improvement. Patronage—the discretionary allocation of public sector jobs to reward followers and to cement political and personal relationships— continues to be a challenge in a country where a large number of youth are facing unemployment and public service laws are generally not enforced. GoU agencies are generally non-compliant with performance assessment regulations for their employees, and sanctions are rarely enforced, with public servants involved in graft generally left untouched. The GoU has announced intentions for a major restructuring and merger of agencies, which will substantially reshape the dynamics of public management. The government of Uganda has proposed several reforms to the public service, while these reforms have yet to be implemented, they provide a roadmap and framework for potential intervention.

While part of Objective 1 aims to improve the uptake of whistleblowing among the general public, objectives 2 and 3 approach that same goal for public servants, who face very different incentives, norms, and outcomes of engaging in whistleblowing. This objective targets norms, attitudes, and practices around accountability and anti-corruption, which can be a driver of change or foundational barrier. Since corruption-drivers at the different levels of government and sectors, programming for this objective will be catered/customized to the targeted groups/individuals.

State institutions, citizens, CSOs, youth groups, and the private sector cannot work in isolation on accountability and anti-corruption. Activities under this objective include efforts to improve engagement and collaboration between stakeholders. Some state entities, like the Inspectorate of Government, have launched public education and outreach campaigns to strengthen their anti-corruption efforts. These programs are still nascent, however, and could benefit from strategic and operational support. Public trust in state institutions is an important component to reduce the apathy that undermines reporting, and these programs present an opportunity to target that directly. Likewise, agencies are often siloed, with poor collaboration between them, especially in field offices. This Activity will improve linkages between and among public institutions and the public they serve, and will support or enhance existing efforts by GoU actors.

4.3 Cross-Cutting Targeted Sectors

Progress in advancing the three objectives above, cannot be done in isolation of priority sectors. Learning, adaptation, and thinking and working politically is integral to programming in these sectors. The following other cross-cutting targeted sectors also improve on accountability and anti-corruption scale.

4.3.1: Participation, transparency, and accountability in natural resource governance and the extractive sector

Accountability and anti-corruption efforts must go beyond the sound management of financial resources--they include the effective, ethical stewardship of natural resources as well. Uganda faces significant governance and accountability challenges that are brought into sharp relief in the extractives sector. Poised to begin substantial investment into its nascent oil and gas industry in the Albertine region, Uganda is at a major crossroads: involve communities and prioritize transparency and accountability, or start down the well-worn path of the “resource curse.” Transparent, meaningful engagement with communities and the public has been largely absent during initial oil exploration work , and land acquisition deals have largely ignored community benefit, driven forced evictions, and suffered from poor accountability. Given Uganda’s abundance of natural resource wealth and the burgeoning extractive industry sector in the country, SSPA will include a deliberate focus on natural resources governance.

However, there are promising signs of a window of opportunity. With pressure from civil society and the international community, Uganda announced its intention to join the Extractive Industry Transparency Initiative (EITI), with cabinet consent in February of this year. Local civil society engagement on the issue has been robust, with some advocating for transparency and sustainability in the extractives industry in the Albertine, and others for transparent and inclusive natural resource government that benefits women and young people, both traditionally excluded from legal entitlements and political engagement on land. The Government of Uganda (GoU) has shown willingness to improve, and donors like the European Union are directly supporting the GoU during the EITI accession process. Civil society and communities, on the other hand, still lack sufficient support to engage meaningfully in the process.

This activity may support EITI-related initiatives that further the cause of accountability and anti-corruption in the sector. In line with objective 1 and 2, approaches to address corruption in this sector shall take the form of supporting communities, civil society, and local governments to monitor the application of EITI principles, the allocation of revenue generated from the sector, and fair employment practices for local labor. Additionally, SSPA may pursue activities to support the GoU EITI Secretariat in the accession process and meeting the EITI Standard. The EITI sector extends beyond just oil and gas, including mining and logging.

The area of concessions is hotly contested, and given the quantity of resources changing hands, is a key area for accountability and anti-corruption support. Country-level analyses of the oil sector indicate high levels of elite rent-capture at every point along the oil value chain. Approaches should focus to bring greater transparency and public accountability to the concessions process, and reduce corruption, fraud, nepotism, and graft in these transactions. Programming in this area can work to ensure that concessions are accountable, transparent, and in accordance with human rights principles, like ILO 169 guidelines against forced displacement, and consider legal protections, and resource rights of indigenous peoples in this sector.

Community interests are frequently best defended by robust, negotiated Community Benefit Agreements (CBAs) at a project level. Examples from around the world show that when communities are supported to understand transparent extractive project plans, assess their own interests, and to engage companies directly in facilitated negotiation, their development outcomes are much higher. The alternative, typically a cash payment to well-placed community members with the most formal land rights—almost invariably men— replaces assets and livelihoods with cash that rarely lasts, destroys social capital, and excludes women, youth, and vulnerable populations. This activity should also focus on strengthening the processes and products of CBA negotiations in and around extractive industry development. Support to third-party environmental and land use mediators and/or facilitators, coupled with negotiation capacity building for project-affected communities, is a promising practice with a successful track record in other contexts. These consensus-building processes between companies and communities can ensure that rights are respected, and reduce uncertainty for investors. This Activity should elevate community voices in the development of extractive projects, and maximize the value to the communities in a way that sustains them and ensures that they truly benefit.

Given the significance of oil and gas development in Uganda, this should include the Albertine region.

4.3.2: Increased citizen engagement to combat wildlife crime-related corruption

Corruption is a prime enabler for wildlife trafficking in Uganda. The connection between wildlife crime and corruption has more recently gained international attention and recognition as a major factor enabling the proliferation of wildlife crime. Despite the widespread identification of corruption as a driver of wildlife crime, little is actually known about how this corruption occurs. From the few cases being taken forward and anecdotal evidence from perpetrators of wildlife crime, it seems that corruption occurs at every stage of the value chain; from preparation, poaching and selling to concealment, smuggling and fraudulent documentation.

In addition to the value chain, there is significant evidence of corruption linked to the embezzlement of resources intended for wildlife management as well as corruption in the criminal justice system to enable those apprehended for wildlife crimes to escape punishment. Officials from the lowest to the highest levels, across a broad range of ministries, agencies, and parastatals in Uganda, actively engage in or facilitate the illegal wildlife trade and/or undermine efforts to fight it. At the lower levels of government, members of the police, military, and customs frequently participate directly in wildlife trafficking, provide security for civilian traffickers, or accept bribes to look the other way when wildlife contraband passes through their jurisdictions. Higher-ranking officials, including military officers, ministers, judges, and wildlife managers also engage in or facilitate wildlife trafficking, using their influence to help traffickers evade or disrupt law enforcement.

SSPA shall promote transparency, constituency building, and other approaches to combat wildlife crime-related corruption and improve political will for wildlife law enforcement. Understanding who is responsible for paying bribes, who is responsible for paying the costs of shipping illegal wildlife products, and who is receiving the profits is absolutely vital to dismantling the criminal gangs driving illicit wildlife trade and making it more risky and less profitable. In addition, building internal controls to prevent officials from taking bribes with impunity and/or looting resources that are meant to be used to protect wildlife is critical for any prevention strategy to be effective.

The Countering Wildlife Crime (CWC) corruption component of SSPA shall work alongside USAID’s standalone CWC activity to maximize synergy and prevent duplication of effort. USAID’s CWC activity works on GOU interagency collaboration, strengthening law enforcement capacity (investigations, prosecutions and sentencing), improving the use of data in conservation, and building data around wildlife trafficking arrests and crimes. These programming areas will be completed outside the scope of SSPA, but will be aligned to SSPA’s work. The SSPA activity will collaborate closely with the CWC activity, including through joint work planning.

Many activities that tackle the corruption challenges in this sector resemble the public engagement work outlined under Objective 1, but with an explicit focus on wildlife crime-related corruption. This Activity will work to identify barriers and opportunities for increasing the media’s, civil society’s, and the private sector’s capacity to collaborate, advocate, and push for reform. SSPA will work to build a constituency to address wildlife-crime related corruption and engage citizens in understanding, publicizing, and exposing

it. The activity should consider messaging and media campaigns and increase coverage that identify, investigate, and try senior public officials involved in wildlife crime related corruption, including “name and shame” campaigns. These efforts should also support advocacy to enact the 2017 Wildlife Bill into law, and review the revenue-sharing guidelines and other proposed regulations to ensure accountability.

Similarly, efforts in this sector will utilize the institution-strengthening strategies of SSPA Objective 2, applied to the unique challenges of corruption related to wildlife crime. For example, SSPA could promote greater transparency in the sector by supporting an audit of the ivory stockpile. The activity will conduct a comprehensive corruption risk assessment of the sector to inform these interventions, and explore options to support an effective whistleblowing environment. Abuse of public office fuels wildlife crime, with “leaking” stockpiles, lost evidence in cases, and political pressure and interference across the enforcement chain.

4.3.3: Coordination, transparency, and accountability in refugee response

Uganda has over 1.1 million refugees and is the world’s third largest refugee host. The crisis is large, growing, and protracted, threatening regional political and economic stability. From an accountability and anti-corruption standpoint, the sheer quantity of funds presents an opportunity for fraud, waste, and abuse.

Accusations of “double-dipping,'' where donors or government duplicate funds given for the same work performed, are widespread. Meanwhile, services in host communities are greatly impacted by the increased population. Given the protracted nature of the crisis and the long-term effects on population growth and on host districts, a longer-term sustainable approach, outside of emergency assistance, is required.

Accountability, transparency, and public engagement have an important role to play in the management of the response.

The policy environment in Uganda, including the Settlement Transformative Agenda, the ReHoPE strategy, and the Comprehensive Refugee Response Framework all support a long-term development approach to the protracted crisis. The role of local governments features strongly in these policies, around ensuring that benefits to RHDs are also received by host communities and ensuring that humanitarian planning and implementation takes longer-term needs of districts into consideration. As the GoU increasingly looks beyond the immediate humanitarian needs, local governments will have a seat at the table, and a chance to shape the future of the response. As the representatives of their districts, local government officials seek greater transparency and accountability around funding and humanitarian activities in their districts. The shift toward “area-based approaches” and intergovernmental funds transfers create new arenas for monitoring of service delivery, as well as new opportunities for corruption.

In line with Objective 2, partnering with local governments to push for stronger transparency, accountability, and anti-corruption in the response is essential. Regional IG offices have limited capacity and resources to follow the numerous leads they receive related to the response. In line with Objective 3 will strengthen the role and coordination of accountability agencies, generate demand for accountability, and support district local governments to advocate for transparency and sufficient resources. In line with Objective 2 and 3, embedded technical experts might be used to support local district planning, budgeting, and coordination capabilities in refugee-hosting districts.

4.3.4: Efficient and effective use of financial resources in the education sector

Uganda’s National Development Plan II highlights the importance of education as the foundation of sustainable development. It includes an emphasis on early childhood development, increasing student retention, strengthening curricula, and increasing school inspection. Yet GoU resources dedicated to the sector remain insufficient to meet the substantial need of Uganda’s school-aged population. In the 2018- 2019 fiscal year, the Government of Uganda budgeted about UGX 2.73 trillion, approximately 11.6% of the budget.