Promoting Transparency, Integrityand Accountability in the Water and

Sanitation Sector in UgandaMaria Jacobson, Sam Mutono, Erik Nielsen, Donal O’Leary & Rosemary Rop

WIN and WSP, 2010

Water Integrity Network (WIN)

The Water Integrity Network is an action-orientedcoalition of organisations and individuals promotingwater integrity to reduce and prevent corruption in thewater sector. Its membership includes the publicsector, the private sector and civil society, as well asleading knowledge-based organisations and networksin the water sector. WIN is funded by grants from theGovernments of Germany (BMZ), The Netherlands(DGIS), Sweden (Sida) and Switzerland (SDC). The WIN Secretariat is hosted by TransparencyInternational in Berlin, Germany.

www.waterintegritynetwork.net

Water and Sanitation Program (WSP)

WSP is a multi-donor partnership created in 1978 and administered by the World Bank to support poorpeople in obtaining affordable, safe and sustainableaccess to water and sanitation services. WSP providestechnical assistance, facilitates knowledge exchangeand promotes evidence-based advancements in sectordialogue. It has offices in 25 countries across Africa,East Asia and the Pacific, Latin America and theCaribbean, South Asia and in Washington, DC. WSP’sdonors include Australia, Austria, Canada, Denmark,Finland, France, Ireland, Luxembourg, Netherlands,Norway, Sweden, Switzerland, the United Kingdom, the United States, the Bill and Melinda GatesFoundation and the World Bank.

www.wsp.org

Acknowledgements This case study was jointly authored by Maria Jacobson of the Stockholm International Water Institute(SIWI), Sam Mutono and Rosemary Rop of the Water and Sanitation Program (WSP), Erik Nielsen of the Water Integrity NetworkSecretariat (WIN), and Donal O’Leary, representative of Transparency International on WIN’s International Steering Committee.

We are grateful for the peer review input by John Butterworth (IRC), Piers Cross (senior consultant), Gilbert Kimanzi (Ministry ofWater and Environment, Uganda), Jack Moss (Aquafed), Barbara Magezi Ndamira and Elijah Ayieko Osiro, (World Bank-Uganda).

Additional thanks to Jens Christiansen and Tania Dunster from onehemisphere.se for design, Stephanie Debere for editing,Alexandra Malmqvist of WIN for communication coordination and Lucy Mhina of WSP for communication coordination.

© 2010 Water Integrity Network / Water and Sanitation Program. All rights reserved. Printed on 100% recycled paper. Cover image: Refugees cross from DR Congo into Uganda at the border village of Busanza. © Sam Downes/DreamstimeBack cover image: Men on bicycles transporting water, wood, pots and other materials. © Frank van den Bergh/IStock

The findings, interpretations, and conclusions expressed herein are entirely those of the authors and should not be attributed to the Water Integrity Network, theWorld Bank or its affiliated organizations, or to members of the Board of Executive Directors of the World Bank or the governments they represent. Every effort has been made to verify the accuracy of the information contained in this report. All information was believed to be correct as of October 2010.Nevertheless the Water Integrity Network and the World Bank cannot accept responsibility for the consequences of its use for other purposes or in other contexts.

Promoting Transparency, Integrityand Accountability in the Water andSanitation Sector in UgandaMaria Jacobson, Sam Mutono, Erik Nielsen, Donal O’Leary & Rosemary Rop

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SUMMARY 4

1. WHY FOCUS ON TRANSPARENCY, INTEGRITY AND ACCOUNTABILITY IN THE WATER SUPPLY AND SANITATION SECTOR? 5

2. PILOTING WATER INTEGRITY STUDIES IN UGANDA 7

3. SUMMARY OF KEY FINDINGS AND RECOMMENDATIONS 13

4. OUTCOMES AND NEXT STEPS 16

5. IMPLICATIONS FOR SECTOR STAKEHOLDERS AND PRACTICE 19

REFERENCES 22

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Contents

Contents

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Summary

Uganda has placed the fight against corruption high onthe development agenda by establishing a range ofanti-corruption institutions and strategies. The UgandaNational Integrity Survey III, released in 2008 by theInspectorate of Government, recommended that ifUganda was to make real progress in tacklingcorruption nationwide, individual sectors would needto undertake sector-specific studies to identify bestpractice and facilitate scaling-up of anti-corruptionefforts. In that year, the Good Governance Sub-SectorWorking Group, chaired by the Ministry of Water andEnvironment, commissioned a Water Integrity Study toestablish how citizens in both rural and urban areas,

contractors, private operators, local governmentofficials and staff from the main water utilityexperience integrity in the provision of water services.The study would also facilitate development of anupdated action plan to address integrity risks. Thisnote describes the key ingredients to putting in place anationwide good governance action plan in Uganda’swater sector, the challenges to be overcome andlessons learned to date. The implications for practiceare discussed from the perspectives of policy makers,regulators and ombudsmen, development partners,water service providers and civil society actors. Thisprovides guidance for the replication of best practiceby stakeholders in other countries and sectors.

The children of coffee growers help de-huskcoffee with their family after school. © BrianLongmore/Dreamstime

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In developing countries, approximately 80 per cent ofhealth problems can be linked to inadequate water supplyand sanitation, which claim the lives of 1.8 million childrenevery year.

1. Why focus on transparency, integrity and accountability in the

Water Supply and Sanitation Sector?

A standpipe in the Bwindi National Park in Uganda. © Prill Mediendesign & Fotografie/IStock

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Doing Business surveys, sponsored by the World BankGroup, also inter alia pose questions on the extent ofcorrupt practices in doing business.

Global experience demonstrates that corruption in thewater sector can be addressed by a strategy based onpromoting transparency, integrity and accountability(Gonzalez de Asis et al., 2009).

Corruption in the water sector places the lives andlivelihoods of billions of people worldwide at significantrisk. The water sector is facing a severe crisis,exacerbated by corruption (Transparency International(TI), 2008). Approximately 20 per cent of the world’spopulation (1.2 billion people) does not have access toclean water and more than 40 per cent (2.6 billionpeople) is without adequate sanitation, withdevastating consequences for development andpoverty reduction. In developing countries,approximately 80 per cent of health problems can belinked to inadequate water supply and sanitation,which claim the lives of 1.8 million children every year.In Africa, it is estimated that an amount equivalent toabout five per cent of gross domestic product is lostevery year to illness and death caused by uncleanwater and poor sanitation facilities.

While corruption risk in the water sector is manifestedin various ways, it can be broadly classified as ‘petty’or ‘grand’. ‘Petty’ corruption often refers to corrupttransactions between a service provider’s staff and itsconsumers, such as bribes to speed up newconnections to the water network or ‘inaccurately’metered water consumption. TI (2008) reports thatcorruption has the estimated potential to increase theprice for connecting a household to a water networkby as much as 30 per cent. Meanwhile, ´grand´corruption, typically involves bribery in awarding oflarge contracts. Recent studies highlight thatcorruption is widespread in water sector and otherinfrastructure contracts, with bribes often accountingfor 10 per cent or more of the contract value (CoST,2009). ‘Grand’ corruption is frequently accompanied bypoor quality work that can considerably reduce theuseful life of hydraulic infrastructure.

Corruption in the water sector exists within the widerpolitical economy of the nation state. Therefore whenanalysing corruption risks in the sector, it is useful torefer to broader data, such as TI’s CorruptionPerception Index (which ranks approximately 180countries and territories in terms of how corruption isperceived among public officials and politicians).

BOX 1 What are Water Integrity Studies and why are they useful?

Water Integrity Studies can directly help nationalgovernments to develop evidence-basedstrategies to address corruption risks in the watersector. From these, time-bound anti-corruptionaction plans can be created, which can bemonitored using concrete indicators. A WaterIntegrity Study has two interrelated components:

1. A Risk/Opportunity Mapping Study whichidentifies weaknesses in national and regionalinstitutions, and opportunities for corruption,then develops a set of anti-corruptionrecommendations;

2. A National Baseline Survey which covers allthe components, actors, practices andinstitutions that make up the water sector. It isused to verify major corruption risks as well asconfirm the efficacy of the action planidentified under the Risk /OpportunityMapping Study.

Critical to the success of a Water Integrity Studyis oversight by a steering committee consisting ofleading water sector stakeholders andrepresentatives of key accountability organisationsfrom the sector. The steering committee shouldbe charged with overseeing the implementation ofthe anti-corruption action plan, including itsmodification as necessary.

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Uganda is one of the few countries in Africa to placecorruption in the water sector high on the developmentagenda by pursuing an explicit anti-corruption strategy in the provision of water supply and sanitation (WSS) services.

2. Piloting Water Integrity Studies in Uganda

School child holding water canister. © Claudia Dewald/IStock

Although Uganda is endowed with rich waterresources, the delivery of safe water and sanitation toits citizens is hampered in part by poor governancesystems and corruption in rural and urban waterservices (Water and Sanitation Program and the WaterIntegrity Network, August 2009). Sixty-five per cent ofthe population has access to safe water in rural areas,although this includes significant regional disparitiesand dysfunctional water points. Access ranges from aslow as 12 per cent in north-eastern Uganda to morethan 90 per cent in the south-west. In urban areas,access to safe water stands at 67 per cent. This breaksdown to 74 per cent in large towns, which are underthe authority of the National Water and SewerageCorporation (NWSC), and 53 per cent in small towns.(Uganda Water and Environment Sector PerformanceReport, 2010).

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2.1. INTEGRITY ISSUES IN THE WATER SUPPLYAND SANITATION SECTOR

Uganda is one of the few countries in Africa to placecorruption in the water sector high on the developmentagenda by pursuing an explicit anti-corruption strategy inthe provision of water supply and sanitation (WSS)services. In 2006, as part of Uganda’s effort to improveintegrity within the WSS sub-sector, the Ministry of Waterand Environment (MWE) established a multi-stakeholderGood Governance Sub-Sector Working Group (GGSSWG)tasked with recommending specific measures topromote and monitor transparency, accountability andgood governance. This process culminated in thecreation of a Governance Action Plan to improvetransparency and accountability in the sub-sector.However, despite these laudable actions, progress inimplementing many of the measures or engaging withother non-state stakeholders was slow andimplementation of the action plan missed agreed targets.

One of the key recommendations from TI’s 2008 GlobalCorruption Report: Corruption in the Water Sector wasfor the development of specific tools for measuringand diagnosing corruption in the sector. The thirdNational Integrity Survey, conducted in 2008 andcommissioned by the Inspectorate of Government (theGovernment of Uganda’s anti-corruption agency),called for sector-specific studies to be conducted inorder to combat corruption more coherently.

Against the backdrop of both these publications, theMWE’s Water and Sanitation Sub-Sector GoodGovernance Group initiated a Water Integrity Study in2008, to better understand corruption in Uganda’s watersector. Supported by the Water and Sanitation Program(WSP) and the Water Integrity Network (WIN), thisexercise consisted of two complementary studiesdesigned to update the sector’s existing anti-corruptionaction plan: 1) a qualitative Risk/Opportunity MappingStudy of the WSS sub-sector, complemented by 2) aNational Baseline Survey on how water consumers,providers, contractors and other stakeholdersexperience integrity in the provision of water.1

1 Additional detailed information regarding the Water Integrity Study design and findings is on the WINwebsite at: http://www.waterintegritynetwork.net/page/3175

FIGURE 1 Situating Uganda within Africa

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2.2. INSTITUTIONAL OVERVIEW OF UGANDA’SWATER SUPPLY SECTOR

The WSS sector is comprised of a number ofinstitutions as outlined in Figure 2. Several participatedirectly in the development of policy and the provisionof water and sanitation services at national, districtand community levels. These include the cross-sectoral Water Policy Committee (WPC) and, withinMWE, the Directorate of Water ResourcesManagement (DWRM), the Directorate of WaterDevelopment (DWD), and the National Water andSewerage Corporation (NWSC), which is the largestutility. Several other national-level ministries haveimportant roles that complement the mandate ofMWE, which is the line ministry for the water sector.These institutions are overseen by four nationaloversight agencies broadly responsible for promotinggood governance through the elimination ofcorruption. The agencies collectively work to advanceindependent oversight of government operations andfair, transparent public procurement.

Private water suppliers, the majority coordinatedthrough the Association of Private Water Operators(APWO), manage piped water services in small townsand rural growth centres. More than 200 NGOs work inthe sector, of which approximately 150 are coordinatedat the national level through the Uganda Water andSanitation NGO Network.

The sector is funded by the Government (via theMinistry of Finance, Planning and EconomicDevelopment), by revenue generated by water andsewerage service provision, and by developmentpartners through loans, grants, and earmarked andgeneral budget support.

Ladies at a market, Kampala, Uganda. ©Frank van den Bergh/Istock

FIGURE 2 Water Sector Institutional Framework

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NATIONAL OVERSIGHT AGENCIES

» Enforce accountability and integrity » Foster elimination of corruption» Promote good governance» Provide independent oversight

of government operations» Ensure fair and transparent

public procurement

NATIONAL MINISTRIES AND NATIONAL WATER UTILITY

» Policy setting» Regulation» Monitoring» Overall planning and coordination» Quality assurance and guidance» Capacity development» Construction of water facilities in

urban areas and water for production» Commercial, government, household

and industrial customers

DISTRICT LEVEL

» Service delivery» Support to communities» Commercial, government, household

and industrial customers

COMMUNITY AND CIVIL SOCIETY ORGANISATIONS

» Operations and maintenance» Service delivery» Watchdog function» Advocacy

IGG PPDA OAG DEI

MoH MWE

Local Government

Communities

MFPED MoLG

DWO

MoES MAAIF

Private

NGOs/CBOs

MGLSD

DWRM/DWO/NWSC

GGSSWG

KEY: CBO Community-based OrganisationDEI Directorate of Ethics and Integrity DWO Directorate of Water Development DWRM Directorate of Water Resources ManagementGGSSWG Good Governance Sub-Sector Working GroupIGG The Inspectorate of GovernmentMAAIF Ministry of Agriculture, Animal Industry and FisheriesMoES Ministry of Education and Sports

MFPED Ministry of Finance, Planning and Economic DevelopmentMoH Ministry of HealthMGLSD Ministry of Gender, Labour and Social DevelopmentMoLG Ministry of Local GovernmentMoWE Ministry of Water and Environment NWSC National Water and Sewerage Corporation OAG Office of the Auditor GeneralPPDA Public Procurement and Disposal of Assets

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2.3. WATER INTEGRITY STUDYIMPLEMENTATION

Risk/Opportunity Mapping Study

The overall objective of the mapping study was toassess risks and opportunities to promote goodgovernance in the Ugandan WSS sector, based onexisting data, legislation and interviews with keyinformants. In particular, the study sought to identifyweaknesses in the legal and institutional frameworkgoverning the sector which provide opportunities forcorruption to arise.

The study focused on:

» identifying corruption risks at both macroeconomicand sector levels

» identifying institutional and legal bottlenecks in fighting corruption effectively

» analysing accountability relationships and incentive structures

» documenting anti-corruption best practice

» mapping key sector stakeholders for potential anti-corruption partnerships

» making specific recommendations onstrengthening integrity through a revised actionplan to improve transparency and accountability.

To identify the main areas of opportunity forcorruption, the mapping study examined how thesector is regulated, including an assessment ofexternal accountability agencies’ capacity to provideeffective oversight of water institutions. In addition, itreviewed weaknesses in relation to procurement; theextent of political interference in the allocation ofwater projects; the capacity of local governments toimplement water and sanitation projects under thedecentralised system; and the ability of civil societyand international development partners to hold thegovernment to account.

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National Baseline Survey

To validate and substantiate the Risk/OpportunityMapping Study, a quantitative baseline integrity surveywas conducted, focusing on experiences of corruptionamong water service providers and consumers. Thesurvey demonstrated that baselines are useful not onlyfor the data they generate, but also the potential theyhave to promote awareness among policy anddecision-makers of citizen satisfaction withgovernment services. In addition, such studies areimportant for monitoring and evaluation, as baselinesurveys can be used to measure change over time.

The baseline survey involved structured interviewsbased on seven tailored questionnaires, conducted withrespondents from seven target groups:

» urban households

» rural households

» local government officials

» water authorities

» the National Water and Sewerage Corporation

» private water operators

» private contractors

The Uganda Bureau of Statistics was consulted toensure representative samples.

All questionnaires were translated into multiple locallanguages and pre-tested, and the interviewers weretrained in interview techniques by the Inspectorate ofGovernment. The survey was administered andmanaged by a Ugandan consulting company.

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National Action Planning Workshop

In September 2009, following completion of thestudies, a two-day National Water Integrity Workshopwas held in Uganda’s capital, Kampala. More than 100stakeholders validated the findings of the studies andjointly agreed on selected recommendations to updatethe Ugandan Government’s existing anti-corruptionaction plan. Participants included the Minister of Statefor Water, senior MWE leadership, representativesfrom anti-corruption and oversight agencies, localgovernment officials, utility staff, local andinternational civil society and development partners.

Delegates drafted an umbrella statement, supportedby the action plan, to guide enhanced accountability inthe sector over the coming three years. Participationby senior Ugandan government officials ensured thatdiscussions were meaningful, that proposed actionswere endorsed and that follow-up at all levels of thewater services sector would take place. The diversityand position of Ugandan actors participating in theworkshop was a critical factor in building ownership ofthe plan’s development and implementation.

Presentations on global and local anti-corruption bestpractice provided opportunities for participants tolearn and exchange experiences of how to improveintegrity in the water sector. The workshop alsoprovided a platform to build and deepen partnershipsamong the government, civil society and the privatesector, as well as to follow up existing work to promotegood governance in the sector.

Sector Endorsement

During the annual Joint Sector Review held in October2009, the action plan was approved by the Water andSanitation Sector Working Group, the highest decision-making body in the sector charged with providingpolicy and resource allocation guidance. In line withrequirements, sub-sectors are now reporting progresson the plan (known as the Uganda: Water Supply andSanitation Good Governance Action Plan) on aquarterly basis.

BOX 2 Why should a government address water integrity?

There are numerous salient reasons why agovernment addresses corruption in the watersector, including:

» Improved service delivery and accountability tocitizens, especially to poor people.

» Attraction and retention of resources for the sector from the government anddevelopment partners.

» Reduced corruption helps original budgettargets to be met and contributes to theachievement of the UN MillenniumDevelopment Goals.

» Proven leadership, through openly tacklingcorruption at sector level, which encouragesother sectors and countries to follow suit.

» Improved status and reputation in the eyes of the public.

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Services and investments have been targeted towardsaffluent communities, at the expense of poor people.

3. Summary of key findings and recommendations

Housing along open sewer system, Kampala, Uganda. © Frank van den Bergh/IStock

The Risk/Opportunity Mapping Study highlighted:

Risks

» According to TI’s Corruption Perception Index2008, Uganda scored 2.6 out of 10, indicating ahigh propensity for corruption countrywide.

» There is an impressive institutional and legalaccountability framework in place, but a hugegap between this and levels of implementation.

Opportunities

» MWE has demonstrated commitment to combatcorruption by establishing a multi stakeholder,Good Governance Sub Sector Working Group andby putting in place an good governance actionplan. MWE has also undertaken research through,

for example regular value for money studies, aTracking Study for the Water and SanitationSector Cost Variation, and a Fiduciary RiskAssessment for the Water and Sanitation Sector.

» The National Water and Sewerage Corporation(NWSC), as one of the main institutions in theurban water sector, was rated in the Third NationalIntegrity Study as the one of the best institutionsby the Ugandan public in terms of quality services.The NWSC leadership has demonstratedcommitment to fighting corruption and stands asan island of excellence in this respect.

» The media in Uganda operate relatively freelyand there is increasing recognition of the role ofcivil society.

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The study findings (see Box 3A and 3B) demonstratedthat inadequate integrity in the Ugandan water sectorhas resulted in loss of investment; exploitation ofcontractors; compromised professionalism; contractsissued for personal gain rather than on the basis ofcompetence or merit; resources lost through poorquality and incomplete works; and political

interference. As a result, services and investmentshave been targeted towards affluent communities, atthe expense of poor people.

To counter these malpractices, a number of keyrecommendations were proposed for the revised anti-corruption plan (see Box 4).

BOX 3A Primary findings of the Risk/Opportunity Mapping Study

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and recommendations

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BOX 4 Integrity Study main recommendations

» Strengthen political will to ensure integrity in thewater sector at all levels.

» Introduce independent regulation functions toremove conflicts of interest in oversight agencies.

» Strengthen corporate governance of urban water providers.

» Enforce MWE sector guidelines to localgovernment and ensure high-quality rural watersupply facilities.

» Build the capacity of civil society organisations,development partners and the media to monitorand hold the sector to account.

» Build local government capacity in contracthandling and management.

» Support the right to information and adoption of consumer charters and innovative outreach programmes.

» Improve procurement and contract management processes.

» Adopt the use of Integrity Pacts – a signedpromise between the government and biddersthat neither side will offer, demand or acceptbribes during the bidding for and execution of contracts.

» Strengthen and formalise links between thewater sector and integrity institutions, includingthe Public Procurement Development Authority,the Directorate of Ethics and Integrity and theanti-corruption courts. This should be donethrough joint training, and whistleblowing andoutreach initiatives.

BOX 3B Primary findings of the Baseline Study

The Baseline Study confirmed:

» The pervasiveness of ‘grand’ corruption inUganda’s water sector. This finding wasconfirmed by the Surveys of Private Contractors(PCs) and Private Operators (POs):

» According to the PCs interviewed, the average bribe related to contract award was10 per cent.

» According to the POs interviewed, the averagebribe needed to win PO management contractswas also reported as 10 per cent.

» The pervasiveness of ‘petty’ corruption inUganda’s water sector This finding wasconfirmed by the Survey of Urban Householdsserved by the National Water and SewerageCorporation (NWSC) and POs:

» 58 per cent of PO customers and 56 per centof NWSC customers knew of somebody who hadpaid a bribe to get a meter bypassed.

» Bribes to speed up access were morecommon under POs (69 per cent) than NWSC

» For urban consumers, the implementation of theconnections policy for new consumers sometimesinvolves corruption. This finding was confirmed inthe Survey of Urban Households:

» 46 per cent of all respondents had paid extramoney for connections.

» For rural consumers, Water User Committeesare perceived as corrupt and non-functioning.This finding was confirmed by the Survey ofRural Households:

» 90 per cent did not trust that their committeeused the maintenance fee correctly.

» The award of management contracts to privateoperators to run the WSS systems in smalltowns is subject to political interference. Thisfinding was confirmed in the Survey of POs:

» More than 80 per cent of the intervieweesreported that political interference ranged from‘common’ to ‘very common’ in the award ofmanagement contracts.

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A common understanding of how corruption harms thesector and what can be done to reduce it was developed.

4. Outcomes and next steps

Children in Uganda go off to fetch water; this may mean walking for many kilometers. © Duncan Purvey/IStock

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Communication and media strategy An independentmedia is a critical tool in the fight against corruption.However, in order to manage interaction with themedia effectively, a comprehensive communication andmedia strategy is needed. Such a communicationstrategy should make explicit which informationshould be made publicly available, when and to whom,for example, through press releases, pressconferences or the development of media-friendlymaterials in local languages for dissemination by radioand in the print media. In Uganda, the absence of sucha strategy led to sensationalized, negative reporting inthe press, although in fact a lot had been done to takethe sector forward.

Lack of political will Apart from the National Waterand Sewerage Company which has actively pursuedand dismissed personnel involved in petty corruption,one of the challenges that persists is the absence ofsustained, high level political will in the fight againstcorruption. Political will is evident when the country'sleadership verbally denounces corruption, not onlydismissing errant officials, but allows them to faceprosecution. When found guilty, seriousness is shownwhen such officials are barred from holding publicoffice within the sector or elsewhere in future. Raisingthe political will to fight corruption in the sector is oneof top priorities within the GGSSWG action plan.

4.3 Key ingredients for success to date

National ownership and an enabling environment The enabling environment and support for this workbacked up by the national anti corruption strategy andprovided by the MWE, as demonstrated through theexistence of the Good Governance Sub Sector WorkingGroup, created an excellent forum for involving keystakeholders from government, the private sector andcivil society, and for obtaining their buy-in to theprocess right from the beginning. The leadershipwithin the government, as shown by the chairman ofthis group, was also critical to winning support fromthe top leadership of the Ministry. Similararrangements may not yet exist in other countries.Even in favorable contexts such as Uganda, it took alot of time to bring these issues to the table and to talkabout them in the open.

4.1 Main Achievements

Although it is early to draw final conclusions, it is clearthat the overall process of conducting a Water IntegrityStudy in Uganda has contributed to more than just therevised action plan in the sector. So far, three mainoutcomes have been achieved:

» First, the attempt to document the extent of water-related corruption through a baseline survey led toopen acknowledgement by top policy makers ofcorruption as a problem for the sector.

» Second, the inclusive and participatory manner inwhich the studies were undertaken contributed towide ownership of the findings. In addition, a commonunderstanding of how corruption harms the sectorand what can be done to reduce it was developed.

» Finally, the workshop provided a unique forum forfrank public discussion regarding corruptionbetween stakeholders who rarely share the sametable. Since corruption is multi-faceted and involvesmany diverse actors, this cross-sectoral, multi-stakeholder dialogue was an important mechanismfor effecting change.

If sustained, these three achievements will continue to build integrity and reduce the level of tolerance for corruption.

4.2 Key challenges to date

Despite important achievements, key challenges stillneed to be addressed in order to maximise success:

Civil society capacity Civil society in Uganda is weakand has little capacity or confidence to hold thegovernment to account. This is particularly true forwater sector NGOs, most of which are engaged inservice delivery rather than playing a watchdog role.Uganda’s civil society weakness is further exacerbatedby the poor links between water sector andgovernance NGOs. The fact that water sector NGOsobtain a considerable share of their funding from thegovernment further threatens their independence andmay have prevented them from playing a moremeaningful role in the overall process. Therefore oneof the key recommendations of the Water IntegrityStudy was to build the capacity of NGOs to monitorand better hold to account the water sector.

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to be accepted by an array of actors. Within theUgandan process, this demanded dedicated staff withconsiderable time and resources, not only to overseethe survey design and subsequent analysis, but also tocommunicate the process to stakeholders, to ensure itwas participatory and inclusive.

Partnership The entire process benefited frompartnership within the GGSSWG whose memberscomprised the Ministry of Water and Environment(chair), the National Water and Sewerage Corporation,the Inspectorate of Government, various local privatesector and civil society organizations, WIN and WSP.The partnership also benefited from the expertisebrought on board by the Uganda Bureau of Statistics.Each organisation was able to tap into its respectivenetworks and skills in order to support and advance theprocess. WSP experience and established relationshipswith the Government provided a critical entry point forWIN, whose specialised technical expertise on waterintegrity and survey design was key to the overallsuccess of the programme.

Development partner engagement and support Aswith most development projects and programmes,international development partner support is critical.Development partners, whether bilateral ormultilateral, provide important financial and politicalsupport and resources to in-country initiatives.Ongoing dialogue with these agencies is essential, notonly to achieve long-term goals, but to ensure aharmonised sector approach, rooted within nationalgovernment strategy. In Uganda, internationaldevelopment partners fund a considerable portion ofthe national budget and are influential partners inrelation to the country’s development agenda, and thisrole proved to be valuable during the water integrityprocess. Apart from providing financial support andbeing active participants at the workshop, thedevelopment partners also played a critical role byapplauding the government for its efforts and byencouraging it to maintain momentum. TheDevelopment partners and GoU have accepted toinclude the follow of the implementation of the revisedaction plan in the Joint Budget Framework(JBSF)/Joint Assessment Strategy (JAF).

Relevance Undertaking a well-designed WaterIntegrity Study is an important tool for developing anti-corruption strategies in the water sector. However,success depends not only on the content of suchstudies, but also on their process and timing. Theseinclude setting up a multi-stakeholder group tooversee the preparation and implementation of thestudy. If not well-anchored within the government, thestudy can easily be refuted and its impact minimised.

Non-confrontational approach Tackling corruption is achallenging and difficult task that can potentiallyendanger the relationship between governments,development partners and other stakeholders. TheGood Governance Sub Sector Working Group whichcomprises a diverse range of stake holders, led theinitiative which reduced the risk that individuals ororganizations would feel unjustly targeted. In Uganda,this challenge was mitigated by a variety of factors,such as the engagement of diverse stakeholders toown the findings of the Water Integrity Studies, as wellas the non-confrontational approach employed. No‘naming and shaming’ took place and the focus was onidentifying institutional weaknesses rather thanindividual cases of wrongdoing. This is based on abelief that in order to improve integrity and effectchange over time, maintaining the trust of all partiesis critical. In addition, the positive concept ofpromoting integrity in the water sector, rather thanexplicitly combating corruption, was an integralfeature of the strategy in Uganda, in order to engagediverse actors. Anti-corruption actions are sensitive,and without new and improved strategies, combatingcorruption will remain challenging.

Sufficient time and human resources Accuratelymeasuring corruption is complex, and results can berefuted; this is often the case with governanceassessments based primarily on public perceptions orwhen assessments have been undertaken exclusivelyby external actors. In addition, contributions fromexperts may be questioned due to perceivedsubjectivity or bias. Therefore the quality of themethodological process and the manner in whichresults are communicated is crucial if the results are

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Typically action is hindered by a lack of coordination and accountability; apathy or fear of reprisal from the beneficiaries of the status quo, or outsider entrenched interests.

5. Implications for sector stakeholders and practice

Dam on the White Nile, Jinja, Uganda. © Klaas Lingbeek- van Kranen/IStock

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conflicts of interest by separating functions of policyformulation, implementation and regulation. All thesesteps are elaborated in the action plan.

The GGSSWG is a demonstration of policy makers’recognition of their interdependence on the anti-corruption skills of non-sector government agencies,NGOs and development partners. The outputs of theaction plan will be as much an indicator of policymakers’ willingness to be influenced and to change, asit will be of the motivation and effectiveness of non-governmental and cooperating partners in theGGSSWG, and members of the overall water sectorworking group.

5.2. WATER REGULATION

Currently, in contrast to Uganda’s electricity sector,there is no independent regulator for the water sector.The action plan calls for a road map for moving sectorregulation from within the MWE to an independentregulatory agency to oversee services in cities andsmall towns. The independent regulatory unit withinthe ministry would do well to advocate for this roadmap to be in place by the end of the second year, while implementation should be pushed by membersof the GGSSWG.

The GGSSWG action plan prioritises this as animportant step to promoting good governance in thesector. Its essence is separating the roles of policymakers, service providers and regulation. Regulationshould protect consumers from abuse by institutionswith exclusive power; guard the sector from arbitrarygovernment action and promote economic efficiency. Itwould guide sector standards, provide a channel forcitizen complaints and act as an impartial referee:balancing, judging and adjudicating variousstakeholder interests. This demands decision-makingwithout ulterior motives. For this reason, the ministryproviding services cannot regulate itself. Anestablished regulatory agency, with an independentbudget that provides security of tenure for professionalstaff, is needed. Its employees would then be free tomake and enforce unpalatable though necessarydecisions to take the sector forward.

The representatives, stakeholders and partners in thewater and sanitation sector at the 2009 KampalaWater Integrity Workshop acknowledged thatcorruption is real and that it was hurting the sector. Ina joint closing statement they asserted that corruptionhad in many ways hampered sector growth anddamaged the trust of ordinary citizens. They furtheragreed that the battle was too big for any onestakeholder to win alone, and that it would need to betackled jointly by government, service providers, anti-corruption bodies, civil society, contractors, the media,development partners and the general public.

In spite of this commitment, the danger remains, as isoften the case with difficult tasks, that the promiseinherent within the GGSSWG action plan is not fulfilled.Typically action is hindered by a lack of coordinationand accountability; apathy or fear of reprisal from thebeneficiaries of the status quo, or outsider entrenchedinterests. This section discusses the implications ofimplementing the action plan and suggests howstakeholders can ensure that the momentum gainedby the Water Integrity Studies and the newly endorsedaction plan is not lost.

5.1. POLICY MAKERS

There is a traditional proverb that says ‘a fish begins torot from the head’, which implies that leaders areaccountable for corruption that occurs under theirwatch, and if they do not tackle it, directly implicated.For this perception not to apply to water sector policymakers, their leadership and commitment need to beunquestioned. The ministry responsible for wateraffairs should embrace its leadership role and regularlycommunicate progress in implementing the GGSSWGaction plan. By setting up the GGSSWG and launchingan action plan with the public, the ministry took a firststep in promoting accountability around this difficulttopic. It will make further progress by partnering withanti-corruption institutions, giving priority to the largerrisks in procurement and contract managementprocesses, implementing sanctions on corruptindividuals or firms, enforcing sector guidelines in bothrural and urban services, and removing existing

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5.3. DONORS AND INTERNATIONALDEVELOPMENT PARTNERS

Donors are partners with government and, by extension,its citizenry. By supporting the implementation of thegood governance action plan they are protectingcitizens’ interests, especially those without voice andinfluence. Donor partnership in the sector can help intwo ways. Firstly, it can sustain attention to theimplementation of the action plan at policy level withinworking groups and bilateral dialogue. And it canpromote local demand for good governance bysupporting the role played by civil society.

5.4. UTILITIES, LOCAL GOVERNMENT ANDDECENTRALISED IMPLEMENTING UNITS FORRURAL AREAS

The Water Integrity Studies indicated that the priorityfor governance transformation at decentralised levelsis the adoption of modern management practices.These include performance contracts, serviceprovision agreements and licences with incentives andenforceable sanctions. Although these actions involvethe local government, small towns and urban servicebodies, initiation is the mandate of higher tiers ofgovernment. Within local power, however, is theestablishment of forums to enable stakeholderdiscussion around plans, budgets and progress, and ofmechanisms for representation and participation bycitizens and other stakeholders. These ensure thatcitizens’ voices, especially of poorer people, arechannelled and acted on. Finally local level institutionswill need to build public confidence by developing anti-corruption plans to guide staff using standard codes ofconduct, and demonstrate zero tolerance forcorruption by dismissing wayward personnel.

5.5. CITIZENS, INTERNATIONAL AND LOCALCIVIL SOCIETY, AND COMMUNITY-BASEDORGANISATIONS

Rarely have sector anti-corruption and good governancegoals been so clearly articulated and publicised as wasthe case in Uganda. Beyond this, a host of international,regional and national commitments support the casefor the GGSSWG action plan’s implementation.Important policies are beyond national legislation.Examples include the United Nations Conventionagainst Corruption, the African Union Convention onPreventing and Combating Corruption, the Constitution

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Uga

nda

5 Implications for sector

stakeholders and practice

of Uganda, the Uganda Anti Corruption Act, 2009, theUganda Access to Information Act and the UgandaNational Anti Corruption Strategy.

In spite of this, one sobering finding from the UgandaCorruption and Risk Assessment is that an enablingpolicy framework does not lead to action where there isno political will. Civil society must respond to therealisation that its role goes beyond small-scale servicedelivery, in a sector that at district level spends manytimes the average Civil Society Organisation (CSO)annual budget. Instead, CSOs should focus on raising theprofile of political action against corrupt practices in thewater sector. They should invest in understanding andusing evidence to object to practices that reduce returnson investment, allow unfair allocations and neglect poorpeople, and mismanage sector resources. CSOs will alsoneed networks that engage grassroots communities andin general strengthen citizens’ voices to create thepolitical will for change from the ground upwards.

The GGSSWG action plan elaborates five steps toincrease CSO capacity – a demonstration of sectorcommitment to recognising and exploiting the potentialof the CSO role in catalysing good governance. Theaction plan elaborates measures to enhance CSOability to work collectively, improve skills in advocacy,enhance access to and understanding of sectorinformation, and ensure they are taken seriously byimproving CSO’s own internal transparency andaccountability. CSOs must take advantage of theseGGSSWG commitments to ensure that the action planis used to uphold the state-provider-citizen compact.

5.6. CONCLUSION

While this process is ongoing and has faced variouschallenges, it has nonetheless been highly constructivein practice and for learning. A diverse range ofstakeholders, including government, civil society, theprivate sector and development partners, have all playedkey roles and developed an important sense ofownership in the design and implementation of theWater Integrity Study and subsequent action planning.This programme has exemplified an entrepreneurialspirit, involving unique collaboration among all partners,which has promoted an innovative mechanism to tacklecorruption and promote integrity in the water sector.

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CoST, 2009. The Construction Sector Transparency Initiative. London, CoST Secretariat,PricewaterhouseCoopers LLP.

Gonzalez de Asis, Maria, Donal O’Leary, Per Ljung and John Butterworth, 2009. Improving Transparency,Integrity and Accountability in the Water Supply and Sanitation Sector. Washington, DC, The World Bank.

Transparency International, 2008. Global Corruption Report 2008: Corruption in the Water Sector. New York,Cambridge University Press.

Winsor Consult Ltd, August 2009. Baseline Survey on Integrity in the Uganda Water Supply and Sanitation Sector(Executive Summary and Main Report). Water and Sanitation Program and the Water Integrity Network.

Water and Sanitation Program and the Water Integrity Network, August 2009. UGANDA: Risk/OpportunityMapping Study on Integrity and Accountability in the Water Supply and Sanitation Sector (Executive Summary).

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REFERENCES

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Boy in canoe, Bunyonyi lake Uganda. © Dmitryp/Dreamstime

WIN Secretariatc/o Transparency InternationalAlt Moabit 96, 10559 Berlin, Germany Phone: +49 30 3438 20413Fax: +49 30 3470 3912info@waterintegritynetwork.netwww.waterintegritynetwork.net

WSP Water and Sanitation programWater and Sanitation Program - Africa Region

The World Bank Group, Upper Hill RoadP.O. Box 30577, 00100, Nairobi, Kenya

Phone: +254 20 3226300Fax: +254 20 322 6386

www.wsp.org