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Edition 03: 26 March, 2009



“Poverty is created scarcity”

Wahu Kaara, point 8 of the Global Call to Action Against Poverty, 58th annual NGO Conference, United Nations, New York 7th September 2005.



08.60  How the project seeks to combat corruption.


08.60.01 Introduction.


This project is intended to be corruption-free. The purpose of this section 08.60 of the project is to describe features built into the project structures to combat corruption. Although most people in the project area generally agree on what corruption is, delicate border-line situations of privilege linked to widely accepted traditional tribal practices can arise. Project structures need to be created to handle these situations on a case by case basis. Although the project structures set up during project execution operate independently of both the formal political and administrative structures on the one hand and of the traditional local tribal structures on the other, the all have to be complementary to and work in harmony with them. Permanent conflict would unnecessarily complicate project execution.


The following aspects are taken in turn:


On-going project monitoring.

Project audit provisions.

Support of traditional tribal structures for the project.

Support of formal political and administrative structures for the project.

Social control through project structures and the leading role reserved for women.

Some risks taken into account.

Detecting corruption and encouragement  for and protection of whistle blowers.

Structures for the handling of complaints.


08.60.10 On-going Project Monitoring.


Since the project area covers quite a small surface area and the whole population there participates in the project, measurement and monitoring of the results of the various project activities is relatively simple. The results of most project activities are physical and visible to all. Use made of the various project structures is systematically registered and monitored on a day to day basis as a standard part of their operation. Most operations can therefore be checked in real time.


08.60.20 Project audit and protection of investors’ interests.


Details on auditing structures are set out in section 4.20 Auditing structures. The project documentation includes a diagram of the project’s auditing structures. Two levels of audit are provided for. The first is a permanent detailed on-going independent audit structure carried out on behalf of the NGO responsible for supervising project execution. The audit committee is independent of project execution. Its members may be members of the Board of Directors of the NGO responsible for supervision of project execution, and/or external experts. The second level  is a traditional periodic external audit. Auditors at both levels have full investigative powers and can carry out inspections on site and of all documentation without prior notice.


Project execution passes through a series of logical steps in the creation of the project structures. First the social structures are created, then the financial structures, then the productive structures, and finally the service structures. Exposure of investors at any one point of project execution is limited. Work on next following structures does not take place until the preceding structures are in place and in operation.


The new capital content of project structures tends to increase with progress in project execution. The first (the social and financial) structures to be set up have relatively low formal money capital content. The second (the productive) structures have an intermediate level of capital content. The last (the service) structures, and especially the distributed drinking water structures, have the highest level of capital content. By the time the service structures are to be installed, most of the work on them can be done under the local money system, operational costs and formal money reserves for maintenance and long-term replacement are already being collected, and local production of  items necessary for the service structures is already under way.  For more details see section 07.14 Built-in protection for financing parties.


08.60.30 Support by traditional tribal structures for the project.

The project, including this section 08.60, has been approved by all of the traditional tribal leaders in the project area. Their approvals, together with their  signatures, are included in section 01.11 Declaration of participation of the local population.  Approvals to the project, including this section 08.60, have also been obtained from women’s organisations operating in the project area.  These are also provided in section 01.11.


08.60.40 Support by formal political and administrative structures for the project.

The project, including this section 08.60, has been approved by the formal political and administrative organs in the project area. Their approvals, together with their  signatures, are included in section 01.13 Declarations of political support.  These include those of the local council, who is also a member of the NGO responsible for the supervision of project execution and co-financer of the project. They also include approvals signed by the member of parliament representing the project area,  and of those responsible for health, education, and environmental services in the project area.


08.60.50 Social control through the project structures.


Three-tiered elected social structures are set up at an early phase of project execution. These form the pillars of the various financial and services structures created in later project phases. They are designed to ensure tight social control over all activities at all levels.


The first level is the tank commission level, representing about 40 families.

The second level is the well commission, representing about 250 families.

The third level is the central commission, representing 10.000 families.




Anthropological justification of the social structures.

Schematic drawing of the project area.

Illustration of the project management lines.


The development of social groupings of humans, in particular over the last 11.000 years is used as the basis for the choice of administrative levels for project applications under the Model.


Description of the tank commission level :


About 11.000 years ago, nomadic bands of dozens of hunter-gatherers (mostly defined as “extended families” or “clans”) started producing food and forming village groups. (Diamond J., Guns, germs, and steel, Vintage, London, 1998).  Diamond refers to the village groups as “tribes” comprising several extended families with an upper limit of “a few hundred” where “everyone knows everyone else by name and relationships” (Ibid. p.271). Prof. Robin Dunbar of Liverpool University suggests that the size of the human brain is linked to social practices developed to bind small groups of 150+ members together. (Grooming, gossip, and the evolution of language, Faber and Faber, London, 1996).


Each tank commission serves about 40 families or 200 people.


Description of the well commission level:


The second, or intermediate, administrative level provided for in the Model is the well commission.  It can also be called an area development commission. The well commissions are the equivalent of Jared Diamond’s “chiefdoms” with “several thousand” inhabitants where “for any person [living there] the vast majority of other people…. were neither closely related by  blood or marriage nor known by name.” (op.cit. p.273). They developed some 7500 years ago as a result of higher population densities made possible by the local cultivation of food. Leadership institutions (“chiefdoms”) are believed to have evolved to create ways of resolving conflicts naturally arising amongst inhabitants not directly bound to each other by blood or marriage. Of special interest to integrated development projects in the modern world is that the first systems for the collection and re-distribution of wealth and the first forms of division of labour were established in this phase. “The most distinctive economic features of chiefdoms was their shift from reliance solely on the reciprocal exchanges characteristics of bands and tribes……..[to] an additional new system termed a redistributive economy.” (op.cit. p.275). The well commissions provided for in the Model typically represent about 1500-2000 inhabitants. This population base supports some modern essential services, too. A typical working area for general practitioners in industrialised countries is 1 doctor to 2000 inhabitants. In the Netherlands this was 1 to 2347 on 1st January 2006 (J.Muysken et al, Cijfers uit de registratie van huisartsen – peiling 2006, Netherlands Institute for Health Services Research (NIVEL), Utrecht, 2006.)  Well commission areas can also support a secondary education structure for pupils from the 2-4 primary schools in their area. Project structures at this level include a transactions clearance structure for the local money systems, and a structure for the manufacture of mini-briquettes for high efficiency cooking stoves used in the area.


Description of the central commission level:


The third, or project level administrative structure provided in the Model represents all (50.000) inhabitants living in a given project area. Jared Diamond refers to this level as “states”, with “over 50.000” inhabitants. (op cit. p. 268). Individuals in each project area must be able to associate with and actively participate in the organs running the project structures. The project area must be “comprehensible” to them. The average size of the ancient Greek city state is believed to have been about 40 km across, so that a leader could walk  from the city centre (at the centre of the state) to the farthest point of the state and return home the same day. The total presumed average population was up to 100.000. The average size of a city or “polis” is thought not to have exceeded 20.000, though a few individual centres may have attained a population of 50.000. (C.A.Doxiadis, The ancient Greek City and the City of the Present, Ekistic, vol.18, no. 108, 1964, pp.346-364)


08.60.60 Women play a leading role at all levels:


The 40 families served by a tank commission elect the 3-7 members of the tank commission. Before the first election, women’s health clubs have been set up in each tank commission area. The health clubs serve as a platform for women, so that they can organise themselves and vote en bloc at the tank commission elections. The result is that most, if not all, of the members of each tank commission will be women.


Each tank commission nominates one member to the well-commission serving it. Since a majority, if not all, of the tank commission members will be women, it is expected they will nominate a woman to the well commission, so that most, if not all,  of the members of the well commission will be women.     


Each well commission nominates one member to the central commission, or project parliament.. Since a majority, if not all, of the well commission members will be women, it is expected they will nominate a woman to the central commission,. so that most, if not all,  of the members of the central commission will be women.     


08.60.70 Some factors taken into account. 


The following table makes use, with the kind consent of the copyright owner, of material from attachment 09.53 Need and greed: corruption risks, perceptions and  prevention in humanitarian assistance HPG Policy Brief 32, ODI Overseas Development Institute, London, September 2008.


Some of the high risk areas mentioned are not always applicable to cooperative integrated projects, like this one, where all members of the population participate in all project structures and all project activities. All project structures and services are by definition non-selective. Most project activities take place under close social scrutiny and control.



Activity group

High risk areas

Corruption risk examples




Assistance process





Incorrect information provided to direct assistance to certain households, groups or regions, or to inflate needs.



Names added to beneficiary lists in exchange for payment or sexual favours; bribes demanded; multiple registrations.



Leaders/staff/committees provide false information about which households meet targeting criteria.



Distributors modify ration amounts or composition, or knowingly distribute commodities to "ghost" or to non-beneficiaries.





Food aid

Manipulation or bribery in assessments, registration and targeting; diversion and sale during transport or storage; skimming rations.


High-value items e.g. medicines

Manipulation or bribery in assessments, registration and targeting; diversion and sale during transport or storage; substandard goods; manipulation of statistics.



Intentional use of substandard materials, manipulation of land titles.

Programme support





Collusion, kickbacks, multiple submission of same invoice, conflicts of interest, forging transactions, manipulation of statistics.


Human resources

"Ghost" staff, nepotism.



Falsified or inflated invoices or receipts or transactions, manipulation of exchange rates, abuse of bank accounts, embezzlement, manipulation of statistics.


Fleet management

Unauthorised private use of vehicles, siphoning off fuel, collusion with fuel/service providers, falsified records.



Falsification of warehouse documents, diversion during transport.

Engagement modality




Partnership arrangements

Partners can engage in any of the above corruption areas.


Scaling up local offices for direct delivery

Human resources recruitment and other programme support risks; bribes required for permits or access to public services.


Working through committees

Diversion of assistance to their own networks including family members and friends, acceptance of bribes for inclusion on lists.


Working through local leadership structures / local government

Diversion of assistance to their own networks and political supporters, acceptance of bribes for inclusion on lists; undue influence of local elites.



08.60.80 Detecting corruption and encouragement  for and protection of whistle blowers.


Within some traditional social systems, some community members may not wish to report cases of possible abuse of privilege by their social seniors. As already stated  in section  08.60.10 , abuse of privilege may in some cases even be socially tolerated. In those circumstances, potential whistle-blowers may be reluctant to report abuse, or even afraid of doing so. They need to be convinced their complaints will be taken seriously. It is not enough to declare a policy of zero tolerance with regard to corruption. The people in the project area need to be clearly informed what the project considers to be corruption. Community leaders will be expected to underwrite both the anti-corruption policy itself and the definition given to corruption. Since the project is co-operative in nature, privilege for one person usually means a lowering of priorities and/or benefits for other members of the community.


With a view to the contents of the table in section 08.60.70, and taking into account the elements favouring powerful social control in the project area, people will be asked to watch out in particular for cases of abuse of privilege in general, unjust exclusion from or inclusion in services, cases where community members are asked or forced to pay bribes, cases of extortion, requests for sexual favours in exchange for services, forced sharing of project benefits, and substandard workmanship.      


08.60.90 Structures for the handling of complaints.


As project structures are formed and become operative, responsibility for their on-going management and maintenance is passed over to the permanent Project Management Cooperative. All people in the project area are members of the Cooperative. They elect Tank Commission members, who appoint Well Commission members, who appoint the members to the Central Committee, which appoints a small project Management Team.


Settlement of conflicts arising during on-going management of the project structures  is one of the express tasks of the Central Committee of the Project Management Cooperative.  The Central Committee for each project must decide how it will do this. It is expected the Central Committee will usually choose to set a Claims Review Committee up. The members of the Claims Review Committee comprise Central Committee members only or members entirely independent of the project (therefore external to the project area) or a combination of these. The Claims Review Committee answers exclusively to the Central Committee. It is independent of Project Management, whose members may not be members of the Claims Review Committee.


Settlement of conflicts arising during project execution and before passage of project structures to the Project Management Cooperative, is the task of the Board of Directors of the Project NGO set up to supervise project execution. The Project NGO is the project parliament during execution. It controls the operation of the independent  project coordinator and his team (the project government).  The Board of Directors of each project NGO must decide how it will organise the settlement of conflicts. It may itself to act as the Claims Review Committee. It may decide to include these duties in its instructions to the independent on-going auditing committee. Or it may nominate a Claims Review Committee with members entirely independent of the project and therefore external to the project area. It is independent of the Project Coordinator and his team, whose members may not be members of the Claims Review Committee.



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