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NACS NATIONAL ANTI-CORRUPTION STRATEGY 2018-2020

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7. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) vi

1. ANTI CORRUPTION COMM ISSION STRATEGIC PLAN This Anti - Corruption Commission (ACC) Strategic Plan is developed to provide guidance on the Strategic priorities the ACC shall focus and work on during the Strategy period (2018 – 2020) Strategic Plan for the implementation period {2018 – 2020}

76. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 69 Page | 69 SO 6.4: To institute a standing platform for regular ACC - Partners engagement – to support review of work being undertaken in anti - corruption, information exchanges, learning and sharing experiences and mapping out of actions to address challenges 2019/2020 $ 40,000

6. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) v The three year Strategic Plan (2018 - 2020) focuses on quick wins in our enforcement of the law, corruption prevention and awareness raising campaigns as well as other support functions of the Commission to achieve the overall objective of reducing corruption for economic growth and development of Sierra Leone. My appreciation goes to DFID for pr oviding the financial support needed for the drafting of this Strategic Plan. I also wish to express my profound thanks and appreciation to the Consultants, Coffey International and the Management Team and Staff of the ACC for their technical input. A sp ecial thanks to the Deputy Commissioner, for providing the leadership with support from the Director of Public Education and External Outreach as Focal Point, throughout the development of the Strategic Plan. It is my fervent hope that with adequate moral and financial support, this Strategic Plan will make a significant impact in the fight against corruption in Sierra Leone. Signed:.............................. Commissioner

78. 71 Annexe 4 : Snapshot of Functions of the ACC (according to Section 7(1) a - d of the Anti - Corruption Act (2008) The objects for which the Commission is established are: (a) To take all steps as may be necessary for the prevention, eradication or suppression of corruption and corrupt practices; (b) To investigate instances of alleged or suspected corruption referred to it by any person or authority or which has come to its attention, whether by compliant or otherwise; (c) To inve stigate any matter that, in the opinion of the Commission, raises suspicion that any of the following has occurred or is about to occur : i. Conduct constituting corruption or an economic or related offence ii. Conduct liable to allow, encourag e or cause conduct constituting corruption or an economic or related offence; and (d) To prosecute all offences committed under this act.

56. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 49 Page | 49 SO 7:7 Advise HE on the appointment of the NACS Implementation Committee SO 7:8 Support the implementation of the ‘Pay No Bribe’ Program . SO 7:7 NACS Implementation Committee formed SO 7:8 Implementation of the ‘Pay No Bribe’ Program supported .

64. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 57 Page | 57 related to effective Human resources management within the ACC. There are a number of relevant polic ies in place with accompanying systems. There is however the issue of perennial challenges with developing a culture of working strictly on the basis of the policies, systems and guidelines as expected. This is an issue that will require strong management oversight and support. The Human resources office is centrally located at the ACC headquarters in Freetown and the Commission is yet to devolve the Human resources function to the Regional offices where staff is deployed to provide programmatic, adminis trative and finance functions. The Human resources directorate has a number of challenges: The office accommodation like for most of the other Directorates and Units is inadequate to carry staff, equipment and documentation. The official ACC Organogram is still not approved by the Management of the Commission and therefore should be considered to be in draft. The Performance management culture is evolving and yet to be fully developed to meet acceptable Best practice standards. The Human Resources Direct orate will also require trainings in a number of areas such as; managing performance management; electronic documentation; filing and archiving and handling grievance mechanism. There are logistical needs such as; computers and accessories; cabinets and im proved manual storage facility needed for the efficient execution of the Human resources function of the Commission. Information Technology Information Technology Information technology is critical for the effective functioning of an institution as it provides the facilitating support for the processing, storage and retrieval of

63. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 56 Page | 56 The Finance staffing and human resource situ ation is relatively adequate with staff deployed both at the Headquarters and Regional levels with varying forms of qualifications but suitable and relevant to performing finance functions. There are training requirements for increasing proficiency in the following areas: Financial and management reporting, any future new accounting system, management and leadership training. The Finance Directorate is handicapped by having in place an out - dated accounting system/ package (SAGE 50} which undermines the quality of accounting performance. The machines and equipment are also out dated such as computers, server etc. The Finance directorate will require investment to replace the accounting system/ package migrating from {SAGE 50 – 100 or 200} with the requir ed capabilities; an appropriate Server to allow for real time accounting and financial management and to facilitate preparation and production of timely financial statements and reports for internal use as well as sharing with partners. There is also need for the provision of adequate and secured storage facility. Human Resources Human Resources The ACC has a Human Resources Directorate with a Director and Human Resources manager to support the Human resources management function in the Commission. The Human Resources Directorate has a Human Resources policy which is in use but would require review and updating in order to be responsive to emerging issues

66. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 59 Page | 59 There are requirements for a new Server – one with 2012 or 2016 Operating systems; assorted licensed software’s; Microsoft office packages; License for windows product s etc. There is also need for a proper office space to accommodate Server and workstations which as at now are grossly inadequate and lack the required security from unauthorised access. In order to ensure efficiency, the IT unit staff will require a number of trainings so that they can support the ACC staff in rolling out this strategy. The key trainings proposed by the IT Team includes: Web designing; Network security; Ethical hacking; M anagement and supervision of network; Computer hardware and networking; Linox training; windows support upgrading and training in the use of any newly procured Server with integrated features. The majority of the ACC staff would also require trainings in basic computer applications including excel, desktop publishing, micro - soft packages etc. This training should be launched and made ongoing as the lack of capacity for most of the staff places pressure on the IT unit to potentially go beyond support to he lping some staff undertake substantive work. The Management should make a decision to have the IT unit as part of the recruitment panel to ensure that all interviews include a segment on testing of basic IT skills and competencies in order to ameliorate th is challenge going forward in the ACC.

65. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 58 Page | 58 information for use in carrying out activities to fulfil the institutional mandate. The Information technology infrastructure of the ACC is very basic and rudimentary and requi res a lot of management attention for upgrade and suitability to execute expected functions. There are three personnel in the section – {02) Technicians and the Manager who are responsible to cater for the general IT needs of the ACC headquarters in Freeto wn as well as the Regional offices in Bo, Makeni, Kenema and Kono. The It Unit is however coping with the restricted staff size. The IT unit does not have a formal IT policy but do have basic rules and practices guide which has been in use within the ACC for several years. There is definitely a need for the ACC to support the preparation of a comprehensive IT policy to guide the provision of the right type of infrastructure that meets the requirements of the Commission as well as not only to safe guard th e IT assets but also protect the huge volume of critical and strategic information which the ACC generates and stores. There is only one server in place since year 2000 and the version has since been taken off the shelf by Microsoft but it is still in u se by the Commission which makes functionality and repairs a huge challenge for the limited number of IT staff. The Regional offices are not served from this out dated central server and other alternative means are used to support the staff in such locatio ns. The bulk of the functioning computers (mostly desktops) are mostly beyond age of use and also pose challenges through constant demand for repairs and maintenance. The IT section does not have most of the officially registered software’s and the IT staf fs have had to rely on trial versions and personal contacts to access such software’s.

62. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 55 Page | 55 In support of t he proposed role of the Internal audit Unit, is also being proposed that it should be provided the required staffing complement as well as working space ( office) in order to effectively take up and perform the proposed role. The M&E Unit should be mand ated to develop an appropriate and user - friendly reporting template which will be used by the Directorates to collate Strategy implementation information from across the respective units placed under their oversight and supervision as well as by the Office of the Commissioner. There should also be developed an annual Strategy implementation update Report format which will be discussed and agreed upon by senior management. Business Support F unctions Finance Finance The ACC is financed mainly from two sources as follows: (i) National budgetary allocation from the Government of Sierra Leone (GoSL) through the Ministry of Finance and economic development (MoFED) and (ii) Donor support through special Project funding win dows. The Financing from the GoSL has been increasing as compared to other MDAs in the Country with particular reference to remunerations (salaries and wages) as well as programme costs. The national austerity has however undermined the regular transfer of funding by the GoSL while the Donor support is also declining and this has placed pressure on the ACCs funding situation. The funding gap is periodically filled from the 10% retention fees deducted from recovery of funds linked to corruption. The capit al and development financing has not been provided by GoSL since 2015 and this has slowed down major priority projects such as the construction of an appropriate Office building for the Commission’s operations.

58. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 51 Page | 51 The w ork planning for the ACC should commence with the issuance of a Circular from the office of the Commissioner to all Directors indicating timelines for the development of unit plans, compilation at the Directorate level and co nsolidation of the ACC wide work plan. This process could be facilitated by Senior Management Team with support from the Finance Directorate which could be requested to support the preparation of indicative costing of the activities contained in the variou s Directorate and ultimately ACC wide work plan. In order to build and develop a work planning culture within the institution, this Strategic plan is recommending that the work plan be used as the basis of conducting all assessments within the ACC from unit to directorate level. In addition, the Director s should be made to report at regular intervals all progress made against the work plan implementation so that the Commissioner and Senior management are regularly briefed not only about progress but also to be in a position to provide any required support to address challenges in a timely manner. The Strategic P lan provides institutional direction in all areas of its operations geared towards ensuring the mandate (in the case of ACC) as enshrined in the Anti - Corruption Act (ACA) 2008 is implemented. The importance of the Strategic P lan cannot therefore be over em phasised. There is empirical evidence to indicate that in several known instances, institutions spend long periods in planning and developing a Strategic P lan but most often remain weak in its roll out. There are a number of factors responsible for Strateg ic plans being prepared to meet expectations of the g overning entities or as a means of securing resource support but such Plans do not play the pivotal role of guiding operations of some of the institutions. In most institutional and

5. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) iv Foreword - ACC Foreword The Anti - Corruption Commission (ACC) has come a long way in the fight against corruption since its establishment by an Act of Parliament in February, 2000. Significant progress has been made in addressing the systemic issues of corruption in Sierra Leone through prevention and enforcement which has yielded much dividend in the fight against graft. We are proud to state that the level of awareness through public education and outreach on the evils of corruption and t he benefits of a corrupt free society , is greater than ever before. Also , the level of impunity has reduced drastically when compared with the period prior to the establishment of the Commission. This largely owing to the enforcement and punishment of offenders. However, corruption is like a multi - headed hydra that grows its t entacles each time one is removed. Therefore, mechanisms on how to tackle it each time it rears its ugly head, must be developed to minimize the scourge. It is for this reason that a new S trategic Plan to replace the Strategic Plan that expired in 2017 is developed to guide the operations of the Commission in tackling the many challenges posed by corruption in the economy and the general livelihood of our people.

45. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 38 SO 7:8 Support the implementation of the ‘Pay No Bribe’ Program. Envisaged O utcomes It is envisaged that there will be effective, coordinated anti - corruption policies in place by either developing a single anti - corruption strategy or through a set of broader efforts and measures to promote transparency and accountability that will provide a long term vision o n how to address the control of corruption. Furthermore, it is envisaged that to create the right momentum, the strategy will be embedded in the overall government strategy so that there will be a higher degree of ownership and a higher chance of implement ation. Progress M arkers SO 7:1 Last quarter monitoring of the NACS 2014 – 2018 undertaken SO 7:2 The NACS 2019 – 2023 crafted with an implementation action plan SO 7:3 NACS launched and public awareness raising campaigns commenced SO 7:4 Integrity Committe es established in MDAs SO 7:5 Quarterly engagements with MDAs held SO 7:6 Monitoring and evaluation exercises of the NACS conducted SO 7:7 NACS Implementation Committee formed SO 7:8 Implementation of the ‘Pay No Bribe’ Program supported.

61. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 54 Page | 54 The experience of working with partners has had varying degrees of successes and frustrations and this need to be improved if this Strategic plan is to be successfully implemented. In order to improve on partner relations and collaboration, it is being proposed in this Strategy that the ACC conducts a partnership mapping exercise to identify among others its Strategic as well as o perational partners. These partners should be approached for partnership conversations with the objective of reaching firm and concrete agreements on issues to collaborate on and mode(s) of engagement. This discussion should lead to a process of formalisation which could potentially take the form of developing a joint Memorandum of Understanding (MoU) with all the practical details of the envisaged engagement. It will be useful if such MoUs are signed off at the levels of institutional leaderships of all partners that have been identified and participated in the development of the MoU. The MoUs should be made to have life spans that will coincide with the duration of the Strategic plan and there must also be built into them the flexibility to conduct ongoing reviews to address any potential bottlenecks as well as to fully explore any opportunities that may arise during joint operations. Strategy I mplementation U pdates (SIU): The ACC has a mandatory responsibility of preparing annual Reports as well as to report to its partners (especially) those with which it has funding responsibilities. In this regard, this Strategy could provide the required opportunities to c ollect information that could feed into such reporting systems by providing information on priority areas, activities and financial implications. This Strategic plan is therefore proposing that as part of its implementation assurance system, annual strateg y implementation updates s hould be prepared by the Internal audit unit. The input in terms of information for the Strategy implementation updates (SIUs) should be provided by the respective Directorates and the Office of the Commissioner.

29. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 22 The Judiciary despite whatever positive intentions it has is subject of a host of negative public perception in terms of the manner it conducts itself and executes its mandate. This arm of Government is poorly provided for by the Sta te and the logistical and work place environment continues to be cited as a disincentive by the authorities in the Judiciary. The courts are over loaded and there is a feature of having at any given time backlog of cases to address which creates anxiety fo r citizens and other MDAs which require the services of the Judiciary. Economic The fall in prices in the global market at a time when the economy was struggling to recover from the EVD scourge has compounded the nation’s economic woes. The GoSL in response had to declare an economic austerity which is still in force. One of the major setbacks from this situation is the low national revenue earning capacity of the government which in turn has undermined its capacity to effectively and readily service the MDAs resulting to cuts in budgetary allocations for most of the MDAs. A number of economic tax reforms have been initiated by the Government of Sierra Leone geared towards further harnessing the Country’s revenue earning and supporting the national economic revitalisation. The nations GDP is also on the decline but the international fi nancial institutions are predicting positive trends in the future. Social A major condition for promoting sustainable national development in any country is peace and stability. Sierra Leone has and continues to experience uninterrupted peace and security since the end of the Civil war in 2002. This climate of peace and stability has been supporting relative peaceful co - existence of the people from the 16 official ethnic groups in a country of 7 million people. The social indices of Sierra Leone are quite weak in the areas of life expectancy, literacy and educational attainment and in most cases, such as in the UNDP HDR the country is placed at the bottom of countries targeted in the surveys. The recent World hunger report rates Sierra Leone at the bottom t ranslating to mean, Sierra Leoneans are the hungriest. A global study on the status of Youths also places Sierra Leone at the bottom being a Country where youths (young) people are most disadvantaged socially. This situation

37. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 30 Envisaged O utcomes The envisaged outcomes are: Firstly, an informed private sector will slowly and gradually emerge knowing and understanding the scourges of c orruption and what is the role of the ACC in the national anti - corruption fight. Secondly, the members of the public who have been continuously expressing frustration with the ACC for not working on private sector corruption will appreciate the Commission’ s effort while doubts over whether it has mandate to address private sector corruption will be addressed and thirdly, the corruption related incidences in the private sector leading to loss by the state and individuals will be checked and over time control led Progress M arkers The activities and actions could be tracked by the following progress markers: SO 3.1.: The private sector anti - corruption legal and regulatory framework developed, approved and in use to fight corruption in the sector SO 3.2.: A private sector focussed anti - corruption engagement strategy is developed, approved and in use by the ACC to address corruption in the sector SO 3.3.: The No (#) of MoUs negotiated, approved, signed off and being used to facilitate inter agency/ instit utional collaboration and cooperation SO 3.4.: The No (#) of prevention and review reports produced quarterly by the ACC indicating ‘’ compliant’’ as well as ‘’ defaulting private sector entities and actors’’

47. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 40 Page | 40 management practices, delegation, etc.) in order to enhance performance and productivity of the agency SO 1.3: To undertake a comprehensive Human resources management audit so as to determine the quantity and quality of human resources and their competencies for alignment to roles and responsibilities SO 1.4: To ensure that capacity support is secured in the form of tooling to meet the professional needs and requirements of the staff of the ACC in delivering on their terms of references SO 1.3: Human Resources Management audit Report with an accompanying Action plan and management response SO 1.4: Report on staff tooling needs with recom mendations and management’s budgeted action plan SO2. STRATEGIC OBJECTIVE 2:SCALING UP PREVENTION, ETHICS AND INTEGRITY The Assumptions: The assumption in proposing this Strategic objective is that the ACC will ensure that it refines its operations in a manner that will ensure that it effectively engages the MDAs and other avenues of possible corruption in order to ensure that their system s and processes are refined and that all review recommendations will be vigorously monitored and corrective actions taken by the ACC in a timely manner to ensure 100% compliance. It is also assumed that the PNB reporting platform and associated processes w ill be integrated and mainstreamed into ACCs work even prior to termination of the project in 2018 and make it a permanent on - going feature of its ways of working.

57. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 50 Page | 50 A NNEX 2 – Strategy Implementation Arrangements: Acc/Partners Focus areas Recommendations The Internal Audit Directorate of the ACC to support Implementation roll out Work P lanning: This Strategic plan has defined a three years Goal for the ACC and in a complementary manner has also identified a number of Strategic objectives (SOs) which should be fully and effectively delivered so that the ACC could attain the Goal agreed upon during the Strategy timeframe. The Strategic objectives (SOs) have been provided with a number of activities which are proposed and considered as adequate to ensure that the SOs are successfully achieved in the three years period. In order to ensure that the S Os and corresponding activities are delivered, this Strategy is proposing and emphasising on the use of Work plans. This Strategic plan covers a three years life span, therefore in order to ensure effective and close monitoring; the ACC wide Work plan shou ld be developed annually. It is being proposed that the Work plans are facilitated to be developed in December of the preceding year, reviewed and approved before the end of the year so that it is ready for use in guiding and directing the activities of AC C in the ensuing year. Matrix: Strategy implementation arrangements: ACC/ Partners etc.

33. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 26 Overview The ACC has adopted as one of its pillars to guide its interventions in the anti - corruption campaign undertaking prevention work while also upholding high ethical and integrity values. The ACC therefore continue s to emphasise on the need for the Public service entities (with particular emphasis on MDAs) to have and work with good systems and refined processes which if supported could have the potential of regulating Corruption within the MDAs. There is a relative understanding among members of the Public that given the challenges with the Court system and the difficulties of effective prosecution of corruption offences, the ACC should ‘’ stop corruption before it happens’’ and prevention initiatives coupled with a dherence and observance of ethical and integrity standards could ensure success in stopping corruption especially within the MDAs. The ACC and partners are currently rolling out a Project known as “Pay No Bribe” with the well - known acronym of PNB which is designed in a manner to encourage Citizens reporting on corruption and what their reactions were in terms of whether asked to pay, paid or met an honest officer who did not ask for payment. This project tracks corruption hot spots and enables the ACC to en gage sector MDAs to conduct an internal review of structures, systems and processes and to undertake certain critical corrective actions which will be monitored by the ACC. The prevention work is believed to be working although much could be achieved than presently documented. It is in this regard that the ACC is being charged to do more in terms of pushing for systems strengthening and block known and existing avenues for corruption while at the same time monitoring potential new avenues and ensuring that the systems improvements block such avenues. Assumption The assumption in proposing this Strategic objective is that the ACC will ensure that it refines its operations in a manner that will ensure that it effectively engages the MDAs and other avenues of possible corruption. This STRATEGIC OBJECTIVE 2: SCALI NG UP PREVENTION, ETHICS AND INTEGRITY

74. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 67 Page | 67 encourage members of the public to volunteer their time in rendering witness before the courts in support of effective and successful prosecutions SO 5.4: To advocate for the establishment of ‘’fast track’’ special anti - corruption courts with very senior a nd highly trained judges and experience in Criminal and or anti - corruption cases 2019 $ 200,000 STRATEGIC OBJECTIVE 6: STRONG ENFORCEMENT AND EXPANDING THE RECOVERY OF CORRUPT PROCEED SO 6.1: Establish a rapid response Team to undertake speedy investigations into reported incidences of corruption in Sierra Leone 2018/19 $ 100,000 SO 6.2: Introduce and sustain an innovative Review system to address challenges and bottle necks associated with intelligence and investigations management by the ACC 2019/20 $ 70,000 SO 6.3: To recruit and build the capacity of additional intelligence and investigation staff to support the increasing workload of the Directorate of intelligence and investigation 2019/20 $ 100,000

35. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 28 Progress M arkers The activities and actions could be tracked by the following progress markers: SO 2.1: A Prevention management procedures/ guidelines document developed, approved and in use by the relevant Units of the ACC SO 2.2: A Monitoring framework document developed, approved and in use for tracking and review of MDAs performances by the relevant Unit in ACC SO 2 .3: A finalised Study report with details on trends and new techniques used for corruption prevention prepared, approved and in use by the ACC SO 2.4: (04) quarterly Reports on MDAs and other targeted sectors’ performance indicating ‘’ compliant’’ as well as ‘’ defaulting’’ entities placed in the public domain (press releases, public notice etc.) Overview The private sector in Sierra Leone is small and still emerging. It is mostly made up of actors in the production, service and marketing industry of the Country and it has a substantial proportion of the populati on (mostly part of the informal group) and also resident foreign nationals. In recent times, the private sector has also come to involve actors of foreign direct investment especially in mining and agri - business. The ACC since its inception in 2000 and by its establishing legislation did not place much emphasis on fighting Corruption in the Private sector. There is however existing and increasing call for the ACC to also look into corruption perceptions and reported cases in the private sector. The ACC has in recent times also succeeded in successfully prosecuting corruption allegations in the private sector (NGOs) leading to convictions. This is therefore reason for the ACC to dedicate time and resources to undertaking focussed anti - corruption initiatives targeting the private sector and this is being recommended in this strategic objective three. STRATEGIC OBJECTIVE 3: PRIVATE SECTOR AND CORRUPTION

59. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 52 Page | 52 Organisational audits that are periodically conducted, it is often discovered that the Strategic plan lacks an anchor unit which should provide gate keeping by assisting Management to ensure that the Strategic P lan informs programming and general operations as well as monito ring the roll out consistent with the objectives for which the Plan was developed. The I nternal A udit Unit of the ACC is proposed in this Strategic P lan to have the responsibility for supporting the roll out. In performing the Strategic P la n roll out supp ort, the Internal audit unit will be required to prepare appropriate tools for monitoring and reporting on the implementation, leading the processes of reviews, supporting the institutional work planning processes with appropriate tools such as templates a nd monitoring frames. It shall also have the overall responsibility of consolidating all Directorate documentation pertaining to the roll out of the Strategic plan for the attention and necessary administrative and programmatic actions by the Commissioner of the ACC. Building Work P lanning into the C ontracts of Directorate Staff at the ACC: The various Directorates of the ACC should be assigned the responsibility of ensuring that this Strategic plan is fully and successfully implemented. In order to give meaning and effect to such a recommendation as contained in this Strategic plan, it is also being proposed that delivery of the activities linked to the SOs(as relevant) be written into the performance management targets of each Director. The Director s in return should be mandated to write into the performance management target of all Staff under their supervision (as appropriate) and deemed necessary by the Commission. This will ensure commitment and diligence to deliver on the SOs since non - delivery could readily be linked to non - performance and the potential corrective actions that

42. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 35 Overview The Intelligence and Investigation Department is critical to driving the mandate of the Anti Corruption Commission. The Departme nt is responsible for the collection of intelligence as undertaking the investigation of corruption offences as provided for in the Anti Corruption Act 2008. This Department has a number of personnel who are assigned various tasks by the head (Director of Intelligence and investigations). The task of fighting corruption being an onerous one places a lot of expectations on this Department. The Department has been working towards ensuring that high level professional output is achieved. In the last several ye ars there has been remarkable progress in the work being done but there have equally been some challenges especially as it relates to staffing levels, capacity to effectively discharge responsibilities and improving the ways of working. Assumptions This strategy is being prepared on the assumption that an efficient Intelligence and investigation Department at the Anti Corruption Commission will significantly contribute to the agency’s performance in combating corruption in the Country. Actions SO 6.1 : Establish a rapid response Team to undertake speedy investigations into reported incidences of corruption in Sierra Leone SO 6.2: Introduce and sustain an innovative Review system to address challenges and bottle necks associated with intelligence and in vestigations management by the ACC SO 6.3: To recruit and build the capacity of additional intelligence and investigation staff to support the increasing workload of the Directorate of intelligence and investigations SO 6.4: To introduce innovative process es that will facilitate the receipt and processing of Reports in order to expedite the execution of successful investigations STRATEGIC OBJECTIVE 6: STRENGTHENING ENFORCEMENT AND EXPANDING THE RECOVERY OF CORRUPT PROCEED

34. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 27 is to ensure that their systems and processes are refined and that all review recommendations will be vigorously monitored and corrective actions taken by the ACC in a timely manner to ensure 100% compliance. It is also assumed th at the PNB reporting platform and associated processes will be integrated and mainstreamed into ACCs work even prior to termination of the project in 2018 and make it a permanent on - going feature of its ways of working. Actions/ A ctivities The following activities/ actions are being proposed to be facilitated by the ACC in the Strategy period: SO 2.1: To prepare in a consultative manner, a corruption prevention management procedures and guidelines manual for use by the ACC in engaging MDAs and all identified sectors to work with SO 2.2: To develop a Monitoring framework that will be used by the Prevention unit of the ACC in conducting tracking and reviews for compliance SO 2.3: To commission a study on new and emerging trends as well as tech niques of promoting corruption prevention in both the private and public sectors SO 2.4: To establish a mechanism for notifying the Public about compliant and non - compliant MDAs and private sector entities as a way of incentivising those that are making ef forts to control corruption while ‘’ shaming’’ those entities and their leadership that do not take corruption prevention seriously Envisaged O utcomes The envisaged outcomes for rolling out the listed activities related to prevention include:  Greater compl iance with the Asset declaration regime by MDAs  MDAs will meet set targets in addressing recommendations for Systems, policies and guidelines improvements  ACC will have in place the requisite tools to further guide its prevention work leading to consistenc y and improvements in national corruption control arising from improved systems and processes in the MDAs and other identified sectors

70. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 63 Page | 63 ANNEX 3 - Matrix : Indicative Timeframe s for rolling out Strategic Objectives Strategic Objective Activity description Indicative Timeframe (year) Indicative budget per SO education, systems and prosecution as well as its business support functions – HR, Finance and IT. The feedback will enable the Office of the Commissioner and Seni or Management to institute appropriate actions aimed at consolidating gains as well as addressing challenges which may have the advantage of optimising the chances of either fully delivering on the roll out of the Strategic plan or making substantial progr ess that could be commendable given the context and other exogenous factors that may have constrained the Commission and undermined full delivery of the activities and actions in the entire Strategic P lan. Final/ E nd L ine E valuation This is the known final stage in a m onitoring and evaluation support to deliver a programme or set of institutional actions desired to produce results. This Strategic P lan is proposing that the ACC undertake a final/ end line evaluation of how well or not it has implemented it over the agreed three (03) years duration. The objective is to identify concrete results which are assessed by the extent to which targets were at tained as well as gaps and challenges. The learning’s such as enabling factors, blockers and impediments are catalogued and should inform the processes as well as formulation of a successor Strategic plan post 2021.

46. 39 ANNEX ES Annex 1: Strategic Objectives SO1. STRATEGIC OBJECTIVE 1: ORGANISATIONAL DEVELOPMENT AND MANAGEMENT Assumption: The assumption on which this strategic objective is based is twofold. Firstly, the ACC having existed for 17 years have most of its system s and process out dated and cannot be adequate to drive its ambitious mandate of controlling corruption in Sierra Leone and therefore a holistic look at the agency could be justified. Secondly, a possible adjustment to the way the ACC operates is likely to re - energise the agency as well as the employees to deliver more in their respective roles to the advantage of the Commission. Actions/ A ctivities Progress M arker Outcomes SO1.1: To commission a comprehensive Organisational development review of the Anti - C orruption C ommission of Sierra Leone SO 1.2: To conduct an assessment of the operational model of the ACC with a view of determining what needs to be reviewed (work culture, SO 1.1: Organisational Development Report and Implementation plan with timelines SO 1.2: Operational model assessment Report with relevant recommendations and Management response A successful organisational development and management strengthening will reinvigorate the ACC, its management and staff to perform above current threshold as people will be deployed according to skills sets and competencies with the right tools and suppor tive working environment that are supportive of high performance and productivity. Matrix: Strategic objectives

38. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 31 Overview There are several references to indicate that Corruption in Sierra Leone has been on the increase and the cost of corruption to the nation has been very high. The Afro barometer, Wold Bank Governance index and Transparency International Reports have been providing regular data on the Corruption trends in the country. Since the ACC was established it has adopted as a pillar the promotion of public education through public information. There is within the Commissi on a Directorate of public education with a number of critical units supporting community outreach and audio - visual modes of educating the populace on what corruption is and how it undermines national development. The citizens knowledge level of corruption has been growing over the years but there is still some work to be done along the lines of; the dangers of corruption, the need to report corruption and where required to support investigations and prosecutions as well as how to ensure that corruption is abhorred and seen as unethical and destructive to personal and institutional integrity. In line with this thinking, there is still great need for additional public education with possibly a revision of strategy to address the areas of concern identified he re so that the anti - corruption crusade in Sierra Leone is collectively owned by Sierra Leoneans and the country at large. Assumption This Strategic objective’s proposal is predicated on the assumption that despite great achievements in improving the knowl edge of the public about corruption, there are still elements that has either not been well received or have not been assimilated by the public. In order to realise the full benefits accruing from strong knowledge about corruption in all its manifestation, it is also assumed that with additional investment of time and resources by the ACC in public education, it will reach a critical mass of the population. The targeted segment of the population will be made to fully understand and be prepared to actively e ngage the anti - corruption fight in current weak areas such as reporting corrupt actions and partnering with the ACC in investigations and prosecution thereby making the ACCs work more productive and improving on its effectiveness ratings to the public. STRATEGIC OBJECTIVE 4: SCALING UPED UCATION AND PUBLIC INFORMATION

40. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 33 Overview The ACCs legislation (ACA2008) makes expressed provision in Part VI for the ACC to prosecute corruption related offences. The ACC with the enactment of the revised legislation in 2008 has been vested with the powers to indict and prosecute without referenc e to the office of the Attorney - General as was the case under the precursor legislation (ACA, 2000). This feature of the revised and new legislation has received applaud from most segments of Sierra Leonean society and also from other Countries and interna tional agencies as a demonstration of some reasonable degree of commitment to strengthen the anti - corruption fight in Sierra Leone. The ACC has since then proceeded with exercising the prosecutorial mandate but with mixed results of successes and challeng es. The public perception and understandably so from a disconcerted one is that the ACC should do more in terms of ensuring more prosecutions and working towards convictions as a means of deterrence against corruption which to most people is believed to ha ve attained impunity status. There have been repeated calls for the ACC to ‘’set brighter examples’’ through convictions especially in cases of grand corruption which is seen and believed to be on the increase in Sierra Leone and which remains as the most potent threat to the anti - corruption fight of the country. Assumption The assumptions on which this Strategic objective is based are that; public confidence and willingness of citizens to support and cooperate with the ACC will increase with greater focus and emphasis on ensuring that the rate of prosecutions is scaled up. The successful outcomes of the prosecutions will also ‘’redeem’’ the image of the ACC which is often negatively or otherwise perceived of as ‘’barking and not biting’’. There is another assumption which is that the ACCs focus on prosecution and more especially successful ones will change the narrative about whether Sierra Leone should or should not have an anti - corruption agency while from a socio - cultural point of view, it will lead to improved cases of deterrence which will also improve the anti - corruption prevention ratings of the ACC. STRATEGIC OBJECTIVE 5: GREATER EMPHASIS ON PROSECUTION AS DETERRENCE

60. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 53 Page | 53 will be taken by the Commission consistent with its internal policies to promote staff efficiency and effectiveness. The Directorate of Human resources co uld work closely with the Internal Audit Unit and the office of the Commissioner to facilitate the development of targets and embedding them into Staff performance management. Quarterly reviews: A Strategic P lan should be a ‘living document’ and as such should be used t o guide and inform all actions of the institution throughout the approved strategy period. This Strategic P lan could be used for the intended purposes of informing the operat ions of the ACC from 2018 – 2020 . The Strategic objectives and their accompanying activities are identified based on certain assumptions as well as an assessment of the operating national environment as done in the Context A nalysis. As a mechanism for ensuring that the Strategic plan remains fit for purpose, it is being proposed that the ACC conducts quarterly Strategic P lan reviews which will create the opportunity to reflect on implementation progress, challenges and provide the req uired space for a Commission wide decision to be made going forward. The reviews should have an overall objective of ‘feeding forward’, meaning how should challenges identified be addressed and what actions should be taken to build on successes. The quart erly reviews should be built into the annual work plans and could be facilitated by the A nchor Unit with oversight and support from the Office of the Commissioner. MOUs with Partner A gencies: The ACC does not and cannot work in a compartmentalised manner . This is mainly because it requires the support; cooperation and collaboration of a host of external actors (State and non - State) if it is to effectively execute its mandate leading to building a corrupt free Sierra Leone.

11. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 4 and the Rule of Law; Collaboration and partnership Organisational Effectiveness and enhancing professional culture. The ACC delivered substantially on this Strategic plan as it was able to build on the opportunities of the NACS, establish and work more effectively with the Judiciary in prosecuting a number of major corruption cases and strengthen critical Directorates with emphasis on Systems and processes review, Inve stigation and Prosecution Institutional I dentity Vision The Vision of the ACC reads as: Mission The ACC Mission statement reads: 3. Strategic A nalysis and O verview of the I ssues of C orruption as at 2017 There has and still continues to be a general expression by members of the public that corruption is still rife in Sierra Leone. The Afro Barometer ( Transparency International); People and corruption: Africa survey 2015 states that ‘’Street level and grand forms of corruption are reportedly widespread in Sierra Leone. Inefficient government structures, low salaries, excessive bureaucratic regulations a nd red tape offer many opportunities of bribery and corruption ...’’. There are also survey reports from various sources indicating that corruption is increasing in the Country. The national Police, Judiciary and Utility providing agencies have regularly be en identified as being the most corrupt entities in the country. The majority of the Citizens complain of being asked to pay Working in partnership to build a corrupt free society through empowerment, enforcement and compliance with the rule of law A corrupt free Sierra Leone which will ensure that the Socio - economic needs of the Citizens are met

71. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 64 Page | 64 STRATEGIC OBJECTIVE 1: ORGANISATIONAL DEVELOPMENT AND MANAGEMENT SO 1.1: To commission a comprehensive Organisational development review of the Anti - corruption Commission of Sierra Leone 2018/2019 $ 30,000 SO 2.2: To conduct an assessment of the operational model of the ACC with a view of determining what needs to be reviewed (work culture, management practices, delega tion, etc.) in order to enhance performance and productivity of the agency 2018/2019 $ 25,000 SO 3.3: To undertake a comprehensive Human resources management audit so as to determine the quantity and quality of human resources and their competencies for alignment to roles and responsibilities 2018/2019 $ 20,000 SO 4.4: To ensure that capacity support is secured in the form of tooling to meet the professional needs and requirements of the staff of the ACC in delivering on their terms of references 2018/19/20 $ 100,000 STRATEGIC OBJECTIVE 2: SCALING UP PREVENTION, ETHICS AND INTEGRITY SO 2.1: To prepare in a consultative manner, a corruption prevention management procedures and guidelines manual for use by the ACC in engaging MDAs and all identified sectors to work with 2018/2019 $ 45,000

39. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 32 A ctions/ A ctivities The following actions/ activities are being recommended by this Strategy to strengthen the work in public education: SO 4.1.: To conduct regular KAP surveys on Corruption in order to continuously gauge citizens knowledge and understanding of Corruption issues in Sierra Leone and respond through targeted programmes SO 4.2.: To review and upgrade programme structures, contents and packaging of public information products for targeted audiences SO 4.3.: To establish an Editorial Team, prepare and disseminate bulletins and newsletters SO 4.4.: To introduce and effectively integrate innovative techniques (including use of Apps and Social media) of undertaking information, education and communication on anti - corruption issues in Sierra Leone Envisaged O utcomes The envisaged outcomes are that a re - energised and strengthened public education campaign could help to increase the knowledge base of citizens and place them in a position to increasingly support the ACC in the execution of its mandate consistent with provisions of the ACA (2008). Progress M arkers SO 4.1.: (03) annual KAPs conducted, reports produced, recommendations adopted and fully rolled out by Public education unit and other Units (as appropriate and relevant) within AC C SO 4.2.: A new public education programme structure developed, adopted and rolled out by ACC to drive all public education activities SO 4.3.: A new editorial team constituted, (12) Newsletters and (02) Bulletins produced annually SO 4.4.: At least (0 4) innovative techniques and platforms identified, adapted, approved and rolled out to support information, education and communication

54. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 47 Page | 47 innovative Review system to address challenges and bottle necks associated with intelligence and investigations management by the ACC SO 6.3: To recruit and build the capacity of additional intelligence and investigation staff to support the increasing workload of the Directorate of intelligence and investigatio ns SO 6.4: To introduce innovative processes that will facilitate the receipt and processing of Reports in order to expedite the execution of successful investigations established with requisite features to support review of Reports in timely manner in aid of necessary decision making regarding line of action(s) post investigations by t he ACC SO 6.3: At least 12 trained and qualified intelligence and investigation personnel recruited and in post by the ACC SO 6.4: AT (20) corruption reports received are processed per year in aid of combating corruption in Sierra Leone corru ption cases. The successful prosecution of cases investigated by the ACC will demonstrate the capability of the agency to deliver on its mandate while realising twin benefits of improved public confidence as well as producing value for money as a result of technical and financial support being provided to the agency. STRATEGIC OBJECTIVE 7: NACS SECRETARIAT SUPPORT ENHANCED MULTI STAKEHOLDER ENGAGEMENTS Assumption The assumption here is that: - 3. There shall be, in compliance with Article 5 of the UNCAC, “effective, coordinated anti - corruption policies that will not only be implemented by the public sector, but that the ACC will take the lead in developing and

75. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 68 Page | 68 SO 6.4: To introduce innovative processes that will facilitate the receipt and processing of Reports in order to expedite the execution of successful investigations 2018/19 $ 40,000 STRA TEGIC OBJECTIVE 7 : NACS SECRETARIAT SUPPORT ENHANCED MULTI STAKEHOLDER ENGAGEMENTS SO 6.1: To undertake a comprehensive mapping of potential Stakeholders (GoSL and Non - state actors – NSAs) working on issues of Transparency and accountability as well as working directly on anti - corruption related issues 2018/2019 $ 30,000 SO 6.2: To negotiate and enter into Standard partnership agreements which will be formalised in various Memorandum of Understandings (MoUs) which clearly states among others the expectations from each party and how to work in a joined up manner 2019 $ 10,000 SO 6. 3: To develop mutual operational plans with the partners and the ACC to consolidate such plans which will provide information on the activities and areas being covered by the various partners, set realistic targets and clarity on what each set of partners (MDAs/CSOs/Development partners) should do geared towards to supporting the anti - corruption fight in the c ountry as well as indicating areas of joint programming 2019/2020 $ 20,000

36. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 29 Assumption This strategic objective (working on corruption in the private sector) has been proposed in this Strategic plan based on a number of assumptions. In th e first place, corruption in the c ountry has pervaded almost all segments of the society so limiting the corruption fight to mainly the public sector will lead to partial success only as cases of corruption in the private sector are left to continue mainly due to lack of adequate focus on it by the Country’s anti - graft agency. The second and perhaps most important assumption is that the private sector as a result of high volume of financial resources and asset that circulates is very susceptible to corrupti on and therefore there is every necessity for the ACC to go into it using its three - pronged approaches; prevention, education and where these fail to yield fruit investigation and prosecution. Third and finally it is assumed that the dual sector targeting (private and public sectors) by the ACC will subsequently lead to minimisation and ultimate reduction in the cases of real and perceived corruption in this Country. Actions/A ctivities The following actions/ activities are being recommended by this Strateg y to support the ACCs work in combating corruption in the private sector: SO 3.1: To prepare the requisite legal and regulatory instruments that will support the ACC in engaging corruption related issues in the private sector in Sierra Leone SO 3.2: To design strategies for continued engagement with both the formal and non - formal categories of actors in the private sector SO3.3 : To negotiate and enter into a number of Memoranda of Understanding with private sector umbrella agencies ( in and out) of Go vernment including but not limited to; Sierra Leone Chamber of Commerce, industry and Agriculture; Banking associations; Mining association and Unions on how to collaborate in the anti - corruption fight SO 3.4 : To extend the prevention and control of corrup tion work to cover all known, registered and operating private sector entities in Sierra Leone.

43. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 36 Outcome(s) The implementation of the actions and activities pertaining to this strategic objective will contribute to increasing the number of successful investigations as well as gathering evidence that meets the threshold for effective prosecution of reported corruption cases. The successful prosecution of cases investigated by the ACC will demonstrate the capability of the agency to deliver on its mandate while realising twin benefits of improved public confidence as well as producing value for money as a result of technical and financial support being provided to the agency. Progress M arkers SO 6.1: At least (10) recognised corruption cases successfully investigated with credible evidence to support successful prosecution per year SO 6.2: An innovative system established with requisite features to support review of Reports in timely manner in aid of necessary decision making regarding line of action(s) post investigations by the ACC SO 6.3: At least 12 trained and qualified intelligence and investigation personnel recruited and in post by the ACC SO 6.4: AT (20) corruption reports received are processed per year in aid of combating C orruption in Sierra Leone Overview National anti - corruption strategies are a relatively new phenomenon in Sierra Leone. Article 5 of the United Nations Convention against Corruption (UNCAC) makes it mandatory for member countries to have in place “effective, coordinated anti - corruption policies.” In Sierra Leone, we have largely STRATEGIC OBJECTIVE 7 : COORDINATING THE IMPLEMENTATION OF THE NATIONAL ANTI - CORRUPTION STRATEGY AND SUPPORTING THE IMPLEMENTATION OF PNB

72. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 65 Page | 65 SO 2.2: To develop a Monitoring framework that will be used by the Prevention unit of the ACC in conducting tracking and reviews for compliance 2018/2019 $ 20,000 SO 2.3: To commission a study on new and emerging trends as well as techniques of promoting corruption prevention in both the private and public sector 2019/2020 $ 15,000 STRATEGIC OBJECTIVE 3: PRIVATE SECTOR AND CORRUPTION SO 3.1: To prepare the requisite legal and regulatory instruments that will support the ACC in engaging corruption related issues in the private sector in Sierra Leone 2019/2020 $ 25,000 SO 3.2: To design strategies for continued engagement with both the formal and non - formal categories of actors in the private sector 2020 $ 45,000 SO 3.3 : To negotiate and enter into a number of Memoranda of Understanding with private sector umbrella agencies ( in and out) of Government including but not limited to; Sierra Leone Chamber of Commerce, industry and Agriculture; Banking asso ciations; mining association and Unions on how to collaborate in the anti - corruption fight 2020 $ 5,000 SO 3.4: To extend the prevention and control of 2020 $ 35,000

30. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 23 creates anxiety and calls to qu estion what could be the causes of such poor national performance. The incidences of corruption are also reported to be high in the Country as can be gleaned from various regular sources such as Transparency International Report; Afro barometer studies, WB Governance indices etc. The cost of corruption is assessed as being high for the Country with loss of Government funds and depriving the Country of much needed resources to support socio - economic development and lift the Citizens out of poverty. There are a number of national responses such as that of establishing and maintaining a national Anti - Corruption Commission, the national audit processes, working to improve p ublic financial management, the preparation and adoption of a National anti - corruption str ategy (NACS) etc. The social sector is still characterised by evidence of poverty, marked levels of illiteracy although there are programmes ( health and sanitation, water and roads improvement) being supported by the Government of Sierra Leone and its par tners to address the causes. There is some progress although there is still much to do. Technological Sierra Leone is also taking strides to become part of the t echnological age and towards that end a number of reforms and institutional arrangements are on - going. The Information technology base is being strengthened with the establishment of a National Commission on Tele communications. This entity is providing regulatory ove rsight of the sector. There are t elecommunication service providers of various pro ducts including voice and internet. There is work on going to install fibre optics to improve on capability and functioning of the sector. In other development sectors of the c ountry, efforts are being undertaken to leverage the advantages of technology to improve working situations as well as the overall wellbeing and human development in the c ountry

73. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 66 Page | 66 corruption work to cover all known, registered and operating private sector entities in Sierra Leone. STRATEGIC OBJECTIVE 4: SCALING UP EDUCATION AND PUBLIC INFORMATION SO 4.1.: To conduct regular KAP surveys on Corruption in order to continuously gauge citizens knowledge and understanding of Corruption issues in Sierra Leone and respond t hrough targeted programmes 2018/2019/2020 $ 125,000 SO 4.2.: To review and upgrade programme structures, contents and packaging of public information products for targeted audiences 2018/2019/2020 $ 25,000 SO 4.4.: To introduce and effectively integrate innovative techniques (including use of Apps and Social media) of undertaking information, education and communication on anti - corruption issues in Sierra Leone 2019/2020 $ 45,000 STRATEGIC OBJECTIVE 5: GREATER EMPHASIS ON PROSECUTION AS A DETERRENCE SO 5.1: To recruit experienced Criminal lawyers to prosecute 2018/19 $ 60,000 SO 5.2: To set up (establish) a Case management environment 2019/2020 $ 115,000 SO 5.3: To develop a witness protection policy that will 2019/2020 $ 55,000

69. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 62 Page | 62 using this Strategic plan as the Steer of all agreed actions. The listed sub actions below are being recommended as me asures in support of re - positioning and laying the basis for the establishment of a strong and effective M& E system within the ACC for the Strategy period and beyond into the short to medium term operations of the institution. This strategy has as one of its cornerstones encouraging the building of an integrated system and ways of working. This therefore requires the various Directorates to have relatively fair knowledge of the inner workings of each of them. In this regard, in the i mplementation of this Strategic plan, it is recommended that the Monitoring and Compliance Unit should plan and conduct quarterly appraisal of M&E work across Directorates as well as facilitating learning Sessions highlighting attributes of the Strategic p lan implementation that are working well (and possibly on track); not working quite well (but making relative progress) and those are not working at all (and having nothing to report as progress). The rationale will be to discuss and learn from each other what innovations and or systems have been adopted and in use responsible for success while also knowing about and learning about peculiar challenges of other Directorates all with a view of identifying success factors and working towards addressing challen ges so that the Strategic P lan is implemented in full as envisaged during its development. Mid Term R eview - MTR There is always need to undertake stock taking half way into the roll out of a premier document such as an institutional Strategic plan and in this regard, mid - term review (MTR) is considered as a necessary condition to be fulfilled for successful roll out . This strategic plan recommends that the ACC through the support and facilitation of the Monitoring and Compliance U nit should plan and conduct a mid - term review on or around June of 2019. The importance of the Mid - term review will be the opportunity it will create for the ACC to take comprehensive stock of both the substantive programme work –

50. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 43 Page | 43 SO 3.3 : To negotiate and enter into a number of Memoranda of Understanding with private sector umbrella agencies ( in an d out) of Government including but not limited to; Sierra Leone Chamber of Commerce, industry and Agriculture; Banking associations; Mining association and Unions on how to collaborate in the anti - corruption fight; SO 3.4: To extend the prevention and con trol of corruption work to cover all known, registered and operating private sector entities in Sierra Leone. SO 3.3.: The No (#) of MoUs negotiated, approved, signed off and being used to facilitate inter agency / institution collaboration and cooperation; SO 3.4.: The No (#) of prevention and review reports produced quarterly by the ACC indicating ‘’ compliant’’ as well as ‘’ defaulting private sector entities and actors’’ whether it has mandate to address private sector corruption will be addressed and thirdly, the corruption related incidences in the private sector le ading to loss by the state and individuals will be checked and controlled over time STRATEGIC OBJECTIVE 4:SCALING UPEDUCATION AND PUBLIC INFORMATION The Assumptions: This Strategic objective’s proposal is predicated on the assumption that despite great achievements in improving the knowledge of the public about corruption, there are still elements that has either not been well received or have not been assimilated by the p ublic. In order to realise the full benefits accruing from strong knowledge about corruption in all its manifestation, it is also assumed that with additional investment of time and resources by the ACC on public education, it will reach a critical mass of the population that will fully understand and be prepared to actively engage the anti - corruption fight in areas that are currently weak such as reporting corrupt actions and partnering with the ACC in investigations and corruption thereby making the ACCs work more productive and improving on its

41. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 34 Actions/ A ctivities The following actions/ activities are being recommended by this Strategy in order to scale up prosecutions by the ACC: SO 5.1: To recruit experienced c riminal l awyers to prosecute SO 5.2: To set up (establish) a Case M anagement E nvironment SO 5.3: To develop a witness protection policy that will encourage members of the public to volunteer their time in rendering witness before the courts in support of effective and successful prosecutions SO 5.4: To advocate for the establishment of ‘’fast track’’ special anti - corruption courts with very senior and highly trained judges with experience in c riminal and or anti - corruption cases Envisaged outcomes The successful prosecution of anti - corruption cases over time will rebuild trust in the ACC and will also indicate the seriousness and commitment of the Government of Sierra Leone to reduce and ultimately slow down the increasing rate of corruption in the Country. The dividends that will be accrued from fines and or confiscations will serve as additional national revenue that the GoSL could use to address pressing socio - economic and development issues that will improve well - being a nd assist in improving on the HDIs of the Country. The statutory retention resources accruing to the ACC could be used to support its operations in a constrained national budgetary environment. Progress M arkers SO 5.1: At least (03) experienced lawyers en gaged and retained in the ACCs prosecution Team for a minimum of three years SO 5.2: A tracker system for prosecution cases developed, approved and in use by the ACC Prosecution Team SO 5.3: A witness protection policy developed, approved and in use by the ACC and the c ourt(s) SO 5.4: A position/ justification Brief prepared for attention of the Chief Justice, court established and equipped, judges assigned and attending to cases in an expeditious manner

68. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 61 Page | 61 the three years of this Strategic plan’s duration. There will therefore be a lot of focus and emphasis on the Monitoring and evaluation attributes of this Strategic plan and this is elaborated in this section. In order to effectively manage the associated processes of M & E, this Strategic plan considers it very vital that the Monitoring and compliance unit of ACC should be reinvigorated and be appropriately staffed and empowered to develop and make available all the required tools and systems in order to support the Staff to carry out their respective assigned responsibilities Continuous R eview of the P rogress M arkers This Strategy is developed using a methodology that has ensured that each of the agreed activities have corresponding markers. It is important to note that experience has shown in a number of instances that the progress markers agreed upon at the design stage may sometimes require adjustment and further refinement. This strategy is therefore recommending that the Focal points in the ACC Directorates shou ld work with the internal audit unit and the 3 man team to undertake continuous review of the progress markers for the various activities under the respective Strategic objectives throughout the Strategy period. Monthly M & E monitoring reports The rationale for establishing and operationalising an M&E system is to ensure that quality information is generated to guide in the implementation of programmes as well as to provide evidence based feedback in support of timely and objective decision maki ng by managers often in consultation with their Team members. Quarterly A ppraisal and Learning Sessions (ACC wide) The roles and responsibilities of the various Directorates of the ACC are interrelated and inter - linked which makes it pertinent that a cu lture of seamless working should be developed and maintained. There is need for continuous improvements in the Business processes and ways of working with a view of building and maintaining a form of synergetic relationship between the Directorates.

32. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 25 Actions/ activities The following activities/ actions are being proposed to be facilitated by the ACC in the Strategy period: SO 1.1: To commission a comprehensive O rganisational D evelopment R eview of the Anti - corruption C ommission of Sierra Leone SO 1 .2: To conduct an assessment of the operational model of the ACC with a view of determining what needs to be reviewed (work culture, managemen t practices, delegation, etc.) in order to enhance performance and productivity of the agency SO 1 .3: To undertake a comprehensive Human resources man agement audit so as to determine the quantity and quality of human resources and their competencies for alignment to roles and responsibilities SO 1 .4: To ensure that capacity support is secured in the form of tooling to meet the professional needs and req uirements of the staff of the ACC in delivering on their terms of references Envisaged O utcomes A successful organisation development and management strengthening will reinvigorate the ACC, its management and staff to perform above current threshold as people will be deployed according to skills sets and competencies with the right tools and supporti ng work environment that are supportive of high performance and productivity. Progress M arkers SO 1.1: Organisational Development Repo rt and Implementation plan with timelines SO 1 .2: Operational model assessment Report with relevant recommendations and Management response SO 1 .3: Human Resources Management audit Report with an accompanying Action plan and management response SO 1 .4: Rep ort on staff tooling needs with recommendations and management’s budgeted action plan

31. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 24 Definition of Strategic Goal of the ACC (2018 – 2021) The strategic g oal for the ACC for this Strategy period is: To work in effective partnership with other critical stakeholders to ensure significant reduction in corruption at all levels in both the public and private sectors of Sierra Leone 7. Strategic O bjectives This three years strategic plan shall be guided by the following strategic objectives: Overview The ACC was established in 2000 and has since been functioning as the official GoSL agency respon sible for fighting graft in the c ountry. The agency has witnessed changes in leadership and with each of these changes; there have been adjustments to the work culture based on the personality and leadership style of the Commissioner. Th e A gency (ACC) should be seen as a candidate for institutional review with the objec tive of ensuring that it is critically looked at to determine whether in its current form and mode of operations it is agile and fit for purpose. The ACC is executing its task but there are varied degrees and levels of appreciation of its corruption fighting efforts and this narrative needs to change and be more positive. Assumption The assumption on which this strategic object ive is based is twofold. Firstly, the ACC having existed for 17years have most of its systems and processes out dated and cannot be adequate to drive its ambitious mandate of controlling corruption in Sierra Leone and therefore a holistic look at the agenc y could be justified. Secondly, a possible adjustment to the way the ACC operates is likely to re - energise the agency as well as the employees to deliver more in their respective roles to the advantage of the Commission. STRATEGIC OBJECTIVE 1: ORGANISATIONAL DEVELOPMENT AND MANAGEMENT STRENGTHENING

49. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 42 Page | 42 control corruption while ‘’ shaming’’ those entities and their leadership that do not take corruption prevention seriously releases, public notice etc.) STRATEGIC OBJECTIVE 3:PRIVATE SECTOR AND CORRUPTION The Assumptions: This strategic objective (working on corruption in the private sector) has been proposed based on a number of assumptions. In the first place, corruption in the Country has pervaded almost all segments of the society so limiting the corruption fight to ma inly the public sector will lead to partial success only as cases of corruption in the private sector are left to continue mainly due to lack of adequate focus on it by the Country’s anti - graft agency. The second and perhaps most important assumption is th at the private sector as a result of high volume of financial resources and asset that circulates is very susceptible to corruption and therefore there is every necessity for the ACC to go into it using its three - pronged approaches; prevention, education a nd where these fail to yield fruit investigation and prosecution. Third and finally it is assumed that the dual sector targeting (private and public sectors) by the ACC will subsequently lead to minimisation and ultimate reduction in the cases of real and perceived corruption in Sierra Leone. Actions/activities Progress marker Outcomes SO 3.1: To prepare the requisite legal and regulatory instruments that will support the ACC in engaging corruption related issues in the private sector in Sierra Leone; SO 3.2: To design strategies for continued engagement with both the formal and non - formal categories of actors in the private sector; SO 3.1.: The private sector anti - corruption legal and regulatory framework developed, approved and in use to fight corruption in the sector; SO 3.2.: A private sector focussed anti - corruption engagement strategy is developed, approved and in use by the ACC to address corruption in the sector; Firstly, an informed private se ctor will slowly and gradually emerge knowing and understanding the scourges of corruption and what is the role of the ACC in the national anti - corruption fight. Secondly, the members of the public who have been continuously expressing frustration with the ACC for not working on private sector corruption will appreciate the Commissions effort while doubts over

4. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) iii MoU Memorandum of Understanding NACE National Advocacy Coalition on Extractives NACS National Anti - Corruption Strategy NEC National Electoral Commission NGO Non - Governmental Organisation NPPA National Public Procurement Authority PNB Pay No Bribe PSC Public Service Commission SMT Senior Management Team SO Strategic Objective SWOT Strength , Weakness , Opportunities and Threats TI Transparency International TRC Truth and Reconciliation Commission UN United Nations US United States UNDP United Nations Development Programme WB World Bank

51. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 44 Page | 44 effectiveness ratings to the public. Actions/ A ctivities Progress M arker Outcomes SO 4.1.: To conduct regular KAP surveys on Corruption in order to continuously gauge citizens knowledge and understanding of Corruption issues in Sierra Leone and respond through targeted programmes; SO 4.2.: To review and upgrade programme structures, contents and packaging of public information products for targeted audiences; SO 4.3.: To establish an Editorial Team, prepar e and disseminate monthly bulletins and six monthly newsletters; SO 4.4.: To introduce and effectively integrate innovative techniques (including use of Apps and Social media) of undertaking information, education and communication on anti - corruption issu es in Sierra Leone SO 4.1.: (03) annual KAPs conducted, reports produced, recommendations adopted and fully rolled out by Public education unit and other Units (as appropriate and relevant) within ACC; SO 4.2.: A new public education programme structure developed, adopted and rolled out by ACC to drive all public education activities SO 4.3.: Anew editorial team constituted, (12) Newsletters and (02) Bulletins produced annually; SO 4.4.: At least (04) innovative techniques and platforms identified, adapted, approved and rolled out to support information, education and communication The envisaged outcomes are that a re - energised and strengthened public education campaign could he lp to increase the knowledge base of citizens and place them in a position to increasingly support the ACC in the execution of its mandate consistent with provisions of the ACA (2008).

28. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 21 partners for mostly specific projects accounts for a little below 10% of total budget of the ACC. The Ministry of Finance and Economic Development through its Budget bureau makes funds available to ACC (normal times) through quarterly allocations and when there are liquidity issues the timing for disbursement could be affected not only for the ACC but all MDAs in the c ountry. The ACCs financial management is based on its internal financial management system { SAG E 50} and this is under the oversight and management of the Director of Finance and the Finance Team at the Headquarters level in Freetown. There are also Personnel at the Regional offices who serve Finance functions under the supervision of the Director o f Finance. In support of funds management, there is a Finance manual which defines the modalities for accessing, utilisation, liquidation and reporting for all funds disbursed for operationalizing the ACCs mandate. The ACC ’ s procurement processes are guide d by the provisions contained in the National Public Pr ocurement Authority’s Act (NPPA ) which among other things makes it mandatory for every Procuring entity like the ACC to have an internal Procurement Committee which should supervise all procurements re garding Goods, Services and Works. There is an internal audit department within ACC which provides the standard and requisite oversight and advisory function while at the same time undertaking tracking and management of funds with periodic Internal Audit Report to the Head of agency. The ACC is also subjected to the Annual National audit processes conducted by the designated agency – the Audit Service Sierra Leone (ASSL). 6. National C ontext A nalysis This Strategic Plan is developed against a national context that exhibits the under mentioned features: Political Sierra Leone has a new administration which was ushered in after the March 31 st Presidential elections. The new administration will determine the course and direction of State Governance including its commitment and support for strong anti - corrup tion crus ade in the c ountry. Political will and leader ship has been assessed as critical for any successful anti - corruption programme. The governing party in its manifesto had articulated a robust strategy to fight corruption which is among the top (4) priorities of the new President.

53. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 46 Page | 46 successful prosecutions SO 5.4: To advocate for the establishment of ‘’fast track’’ special anti - corruption courts with very senior and highly trained judges experienced in Criminal and or anti - corruption cases SO 5. 4: A position/ justification Brief prepared for attention of the Chief Justice, court established and equipped, judges assigned and attending to cases in an expeditious manner assist in improving on the HDIs of the c ountry. The re tention resources will accrue to the ACC in support of any budgetary short fall SO 6: STRENGTHENING ENFORCEMENT AND EXPANDING THE RECOVERY OF CORRUPT PROCEED The Assumptions : This strategy is being prepared on the assumption that an efficient Intelligence and inves tigation Department at the Anti - Corruption Commission will significantly contribute to the agency’s performance in combating corruption in the c ountry. Actions/ A cti vities Progress M arker Outcomes SO 6.1: Establish a rapid response Team to undertake speedy investigations into reported incidences of corruption in Sierra Leone SO 6.2: Introduce and sustain an SO 6.1: At least (10) recognised corruption cases successfully investigated with credi ble evidence to support successful prosecution per year SO 6.2: An innovative system The implementation of the actions and activities pertaining to this strategic objective will contribute to increasing the number of successful investigations as well as gathering evidence that meets the threshold for effective prosecution of reported

19. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 12 well as its negative implications for socio - eco nomic growth and national development. This has and continues to sustain some degree of public interest in the work of the ACC. Devolution The ACC has undertaken some form of devolution as a strategy of ensuring that it has national presence. There are Regional offices across Sierra Leone in Bo, Kenema, Kono and Makeni. The devolution process has addressed a major concern of the past which has to do with the centralisation of the ACCs work in Freetown as the Country’s administrative and political capital . (ii): Weaknesses: Inadequate staffing The ACCs scope and work load has been continuously increasing since its establishment in 2000. There is however the weakness of the Commission’s inability to recruit and maintain the full complement of Staff. As at the time of undertaking the development of this Strategy, the ACC was under staffed in most of the critical Directorates which is placing pressure on the existing Staff. Office Accommodation The ACC continues to operate with inadequate office accommodation in a privately rented facility. The facility is also privately owned and is believed to absorb a substantial proportion of the Commission’s budgetary provision with implications for expenditure in many other critical areas of the agency’s work. Implementation of R ecommendations Limited implementation of Systems R eview recommendations The ACC has over the years developed a number of systems and however majority of these systems and procedures are yet to be fully utilised in a manner that will bring the agency the anticipated benefits which will ensure that it delivers on its mandate W eak P ublic R elations ACC is credited to have a good Public Education System, but the agency is yet to develop and roll out an effective and

22. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 15 SWOT issues The major SWOT issues are; There is a progressive Legislation (ACA08), but there is an absence of the much - needed Whistle blower policy to complement provisions in the legislation in ensuring that the Anti - Corruption fight is more robust with active Citizen’s engagement from investigations to Prosecution in cases where such prosecutions are found unavoidable The inadequate st affing levels in the commission relative to the scope of its mandate and need for their services would require some very urgent high - level attention in order to redress the imbalance. The weak commitment of several MDAs to the effective roll out of the NAC S undermines the efforts of the ACC in realising an i ntegrated approach for optimal results ACC should further devolve to the district level rather than on a regional basis as this will encourage citizens to report corruption when there is minimum cost of accessing the ACC from their communities. The limited w ork space (office) is restraining and cannot rationally allow expansion in terms of recruiting new staff and bringing in new machines and equipment which are required to scale up the operational effectiveness of the ACC The p ublic perception of the work of the ACC is still an issue to address as majority of the c itizen’s assess the performance beyond the reality. The need for a Public relations strategy cannot be over emphasised. The needs of the ACC and the funding situation are deemed to be at variance. There is less Donor input with increasing reliance on Government of Sierra Leone whose budgetary allocation is not adequate to roll out all ACCs activities (including its capital expenditure for buildings, veh icles, machines and equipment). The engagements by the ACC in various International Platforms would need to be further enhanced so that the agency could benefit from Opportunities that avail themselves to be active members

25. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 18 The quality of complementary support from the Judiciary could be linked to the success of the ACC whenever it decides to use the route of p rosecution as the issues aro und prioritising assigning courts and judges are critical to speedy trials. The delays in court cases and the frequency of unsuccessful outcomes poses the risk of ACC suffering from negative citizen’s perception of its role and effectiveness, and support c ould decline to apathy. The absence of a known and acceptable a nti - c orruption champion could also undermine a nti - c orruption initiatives. The reality in Sierra Leone is that majority of the c itizens consider p ublic officials who hold resources in trust on t heir behalf suspect. There is need to have p ublic figures (especially) in the p olitical class who will move beyond the suspicions of pronouncements to actual evidence of unbridled support for the independence and support of the ACC to execute their mandate in timely, dispassionate and independent manner. This leadership by example will help to offset the impunity culture and could possibly encourage Citizen - activism to support the ACC in not only reporting Corruption and Corrupt activities, but even aiding investigations and supporting prosecutions. The continued non - existence of Champions will continue to underpin the negative perceptions of neglect of grand corruption and placing emphasis in petty Corruption. The CSOs are very essential in any effective a n ti - c orruption f ight and reasons range from good understanding of the issues, capacity to conduct advocacy, the regular citizen engagements and contributions to shaping public opinion. The current project based, often short - term projects implemented by CSO s do not have the potential of forging any enduring partnership with such CSOs to work in a sustained manner on a nti - c orruption issues in Sierra Leone. This should be addressed if the a nti - c orruption fight in Sierra Leone is to gain the usual CSO traction to educate and mobilise citizens to support the fight against c orruption. The average citizen in Sierra Leone today have some level of knowledge of what c orruption could mean but the degree to which they do engage with the ACC and related agencies to fight corruption would require critical analysis in order to form any expert idea that cannot be readily challenged for lack of convincing evidence. The feeling of weak morale by some of the Staff in the ACC is also a major source of risk. The human resource of an agency is critical in the planning and delivery of its mandate. It is important that this issue be considered as it

12. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 5 bribes before accessing basic services across the country especially in education and health delivery. There is also the tendency to identify the damaging consequences of political corruption which is considered prevalent through clientelism. The bribery rate by a Transparency International assessment in Sierra Leone (2015) was placed at (41%). There have also been major national co ncerns over corruption highlighted year in and year out by the annual report of the Audit Service Sierra Leone (ASSL) as well as allegations of corruption arising from the management of the Ebola Funds, Pilgrimage to Mecca scholarship funds. These remain a s pendi ng issues under the ACCs investigations. There have sinc e been indictments and prosecution of some influential publi c personalities by the ACC . The ACC ha s reported over the period since 2008 to have recovered monies that could have been lost to corruption. A US Department of State report quoted thus: ‘’ The ACC managed to recover approximately USD 2Million for government’’ (US State Department; 2010). As a result of such interventions of prosecutions and recovery of resources, a Transparency International Report indicated that: ‘’ 64% of respondents assess the government’s actions in the fight against corruption as effective’’ (Transparency International, Global corruption Barometer, 2009 ) Sierra Leone has been experiencing fluctuations in its Global assessment of the status of corruption in the Country as indicated by Transparency International, World Bank Governance indicators and data from the US Millennium Chal lenge Corporation - MCC (i nformation could be gleaned from the annex to this Strategic plan). The Government of Sierra Leone has taken a number of strategic and programmatic actions over the years aimed at demonstrating commitment to fight corruption in the country. The preparatio n of a National Anti - Corruption Strategy (NACS) which serves as the national road map for MDAs in supporting Anti - corruption measures has been introduced and over two generations of NACS has been prepared and rolled out. The Performance Contract system has been introduced as a mechanism to improve Public service performa nce and delivery while minimising delays and bureaucr atic hurdles which facilitate corruption. As the main anti - graft agency - The Anti - Corruption Commission has also adopted a number of stra tegies over the last decade geared towards improving on its performance in fighting corruption in the Country. The main

13. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 6 strategies are: the strengthening of its outreach mechanism , introduction of telephone hotlines and continuing to building citizen’s aw areness. Partnership The ACC and DfID are collaborating on a project known as “Pay No Bribe” (PNB) . This project has a strategy of encouraging the reporting of corruption and corrupt practices from identified sec tors – Police, infrastructure ( energy), education, health that are considered as having the greatest potential for corruption. The use of a special App and Call centre as well as working with CSOs to animate communities, PNB has increased reporting and ACC has been engaging the listed s ectors to undertake institutional reforms to address cited avenues of corruption. The a nti - corruption fight in Sierra Leone is often maintained by the ACC officials as one requiring collaboration and partnership with other actors. In this regard therefore , the ACC has been leveraging on the opportunities that are available to work with a number of State and non - State strategic actors . There are a retinue of partners and Stakeholders that the ACC collaborates with in executing its Anti - corruption mandate in Sierra Leone. The leading partners both in and out of Government includes but are not limited to the following; (ASSL, NPPA, PAC, DBOC, Ombudsman) – CSOs (BAN, SLEITI, NACE) and the Media (Print and electronic). The ACC has over the years adopted a stra tegy of negotiating and entering into partnership arrangements with its identified Partners and in a number of cases (as with the Audit Service, Sierra Leone) entered into formal Memorandum of Understanding (MoU) to promote cooperation and collaboration . The CSOs support Community engagements, public education and advocacy for increased Political commitment to support the activities of the ACC in the execution of its mandate. There is also a lot of work being done in the area of promoting general Transpare ncy and Accountability which when successful will build on the ACCs work in advocating for improved Systems and processes within institutions geared towards reducing the occurrences of corrupt actions . The ACC also works with a number of in country and foreign International Development partners such as the World Bank , European Union, the Millen nium Challenge Cooperation, UK/ AID and a host of International NGOs.

20. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 13 efficient Public Relations Strategy to address the myriad of negative public perception related to its existence and operations. There is repeated Public reference to ‘’catching small fishes and leaving out the big fishes; barking but not biting; chewing but not swallowing’’ etc. These seeming negative perceptions still lingers and has the potential to undermine the anti - corruption crusade under the leadersh ip and coordination of the ACC. Inadequate specific legislation on Whistle blower and witness protection The ACC despite popular clarion call by Anti - corruption professionals and citizens is yet to develop and facilitate through the national government machinery a National whistle blower policy. The policy is believed to have provided boost to the anti - corrup tion work of similar agencies in West Africa. The inability of the ACC to ensure that the relevant and pertinent rules, regulations and systems are effectively integrated into the organisation’s Business processes would continue to pose challenges (iii): Opportunities: There is high level of citizen’s awareness about Corruption and its ills for society and in particular Sierra Leone. The citizenry is therefore receptive and quite supportive of the efforts of the ACC to contain corruption in Sierra Leone. External S upport There is commitment of support from Development partners and actors to provide financial and technical assistance for the effective functioning of the agency. The GoSL has and continues to provide much needed budgetary support to the ACC. New S trategic F ramework The ACC will have a strategy developed to guide its opera tions in 2018. The NACS which is the c ountry’s National Anti - C orruption Strategy that is coordinated by the ACC will also be

10. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 3 manual to guide managers and their Supervisees in ensuring prudent People management. Finance D epartment The Finance Directorate is responsible for all budgeting and financial management functions of the Anti - Corruption Commission . It also ensures that all assets of the ACC are managed in a manner that is consistent with the policies and guidelines of the ACC. The ACC has a financial management system in place to promote accountability and sound financial management which is a function on which a lot of premium is placed given that the ACC is the Country’s premier anti - graft agency. Functions The core functions of the ACC are clearly spelt out in Section 7 S ub S ection (1) a – d, with subsidiary functions also detailed out in Section 7 S ub S ection (2) a - q of the ACA 08. The broad focus of the ACCs functions is ‘’to take all steps as may be necessary for the prevention, eradication or suppression of corruption and corrupt practices... to investigate instances of alleged or suspected corruption ... to prosecute all offences committed under (the ) ACA 2008.” The details of these functions are part of the annexes to this Strategic plan. Strategic Planning In the ACC, the positive culture of functioning on the basis of a Strategic P lan has evolved over time. A Strategic plan was developed for the pe riod covering (2008 – 2010). The Strategic areas of emphasis were on: c apacity enhancement of ACC to lead the roll out of the NACS; support to the expansion and improvement in Service delivery by MDAs and enhancing public awareness on corruption. The ACC w ithin this period achieved a number of successes in terms of facilitating the development of the NACS as well as establishing Integrity committees in MDAs in support of addressing issues which have the tendency of breeding corruption. In the (2011 – 2013) period, the ACC developed another Strategic P lan which built on the successes of the previous Plan while addressing some of the challenges encountered during the implementation of the Plan . The (2011 – 2013) Strategic Plan had as strategic objectives the following: Compliance

67. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 60 Page | 60 Implementation mechanism The 3 man team will consist of the D eputy C ommissioner and two other persons. R eports on progress on the implementation will be submitted on a quarterly basis. the terms of reference for the 3 man team include: If the ACC were to adopt a practice of ensuring internal – institution wide monitoring and evaluation additional staffing (03) to complement the existing staff in the internal A udit Unit . Strengthening M & E of the ACC This Strategic plan has been prepared with an overall objective of facilitating the planning and execution of various activities of the ACC geared towards enhancing the effective execution of its mandate as contained in the ACA (2000) and amended in 2008. The need to ensure that the activities and related institutional and organisational development actions that are contained in this Strategic plan a re fully implemented is paramount to the work of the ACC in Baseline on status of ACCs work for agreed Strategic objectives As a precursor to the much detailed anticipated Monitoring and evaluation work which will complement this Strategic plan, it is being recommended that a solid foundation be created for measuring progress based on appro ved and acceptable methodology and evidence. In this regard, this Strategic plan will require the ACC to support the respective Directorates to make provisions in their work plans for the conduct of Baseline assessments to determine the status of the ACCs work in the identified and prioritised areas highlighted in the Strategic objectives. This is expected to be light touch assessment taking cognisance of what has been achieved , and gaps that need to be filled. The rationale for such a baseline assessment is to place the respective Directorates in a position to objectively (with evidence) report on progress that will be attributed to the adopted and implemented activities in this Strategic P lan. Monitoring Tools T he Monitoring and evaluation process being so cardinal to good programme and management practices also require adequate planning and the development of systems. This Strategic plan seeks to strengthen the M & E component which means that the basic tools to support a system should be in place. Unit M & E F ocal P oints

18. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 11 ACC could effectively and eff iciently execute its institutional mandate in Sierra Leone. (i): Strengths: AC Act Advisory B oard NACS The Anti - Corruption Commission (ACC) has a progressive enabling legislation (Anti - corruption commission act 2008) which is a remarkable improvement on the pioneering legislation of 2000. The 2008 legislation bestows the powers and authority in the ACC to i ndict and enter into prosecution of persons and entities considered to be in violation of the Anti - corruption legislation and other relevant legislations of Sierra Leone. The ACC benefits from the knowledge and experience of an Advisory Board consisting of persons and institutional nominees of diverse and varied backgrounds. The provision in the ACA ( 08) regarding the existence of the Advisory Board as part of the ACCs gove rnance structures supports inclusiveness and promotes participation in the national anti - graft crusade . The ACC has facilitated the development of the National Anti - Corruption Strategy (NACS) in fulfilment of its international obligations. The NACS has b een rolled out to several MDAs with accompanying Integrity Management Committees (IMCs) to support implementation of the activities contained in the NACS. The ACC supports the NACS management and implementation from its NACS Directorate. Funding The ACC is not prohibited by law or any national legislation from raising funding through project proposals to support its operations. In this light, the resource gap between GoSLs subventions and the actual financial and logistical needs of the Commission could be addressed through ACCs external resource mobilisation strategies. The absence of legal encumbrances to mobilise funding also serves as a latent strength as it reduces the ACCs degree of reliance on the Central government (GoSL) by raising and sp ending. Public A wareness There is a strong Public Education and Outreach P rogramme which has over the years enhanced the reach of sensitisation and awareness raising on the negative effects of Corruption as

3. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) ii List of Acronyms ACA Anti - C orruption Act (2008) ACC Anti - Corruption Commission AUCAC African Union Convention Against Corruption ASSL Audit Service Sierra Leone BAN Budget Advocacy Network CEO Chief Executive Officer CRF Consolidated Revenue Fund CSO Civil Society Organisation DBOC District Budget Oversight Committee DFID Department for International Development DPs Development Partners EVD Ebola Virus Disease GDP Gross Domestic Product GoSL Government of Sierra Leone HDR Human Development Report HR Human Resources HRMO Human Resources Management Office IT Information Technology KAP Knowledge, Attitude and Perception MCC Millennium Challenge Corporation MDAs Ministries, Departments and Agencies M&E Monitoring and Evaluation MoFED Ministry of Finance and Economic Development

48. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 41 Page | 41 Actions/activities Progress marker Outcomes SO 2.1: To prepare in a consultative manner, a corruption prevention management procedures and guideline manual for use by the ACC in engaging MDAs and all identified sectors to work with; SO 2.2: To develop a Monitoring framework which will be used by the Prevention unit of the ACC in conducting t racking and reviews for compliance? SO 2.3: To commission a study on new and emerging trends as well as techniques of promoting corruption prevention in both the private and public sector; SO 2.4: To establish a mechanism for notifying the Public about c ompliant and non - compliant MDAs and private sector entities as a way of incentivising those that are making efforts to SO 2.1: A Prevention management procedures/ guidelines document developed, approved and in use by the relevant Units of the ACC; SO 2.2: A Monitoring framework document developed, approved and in use for tracking and review of MDAs performances’ by the relevant U nits in ACC; SO 2.3: A finalised Study report with details on trends and new techniques used for corruption prevention prepared, approved and in use by the ACC; SO 2.4: ( 4) quarterly Reports on MDAs and other targeted sectors’ performance indicating ‘’ c ompliant’’ as well as ‘’ defaulting’’ entities placed in the public domain (press The envisaged outcome of rolling out the listed activities related to prevention includes:  Greater compliance with the Asset declaration regime by MDAs  MDAs will meet set targets in addressing recommendations for systems, policies and guidelines improvements  ACC will have in place the requisite tools to further guide its prevention work leading to consistency and improvements in national corruption control arising from improved systems and processes in the MDAs and other identified sectors

52. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 45 Page | 45 STRATEGIC OBJECTIVE 5:GREATER EMPHASIS ONPROSECUTION AS DETERRENCE Th e Assumption: The assumptions on which this Strategic objective is based are that; public confidence and willingness of citizens to support and corporate with the ACC will increase with greater focus and emphasis on ensuring that the rate of prosecutions i s scaled up. The successful outcomes of the prosecutions will also ‘’ redeem’’ the image of the ACC which is often negatively or otherwise perceived of as ‘’ barking and not biting’’. There is another assumption which is that the ACCs focus on prosecution and more especially successful ones will change the narrative about whether Sierra Leone should or should not have an anti - corruption agency while from a socio - cultural point of view, it will lead to improved cases of deterrence which will also improve th e anti - corruption prevention ratings of the ACC. Actions/ A ctivities Progress M arker Outcomes SO 5.1: To recruit experienced c riminal lawyers to prosecute SO 5.2: To set up (establish) a c ase management environment SO 5.3: To develop a witness protection policy (taking on board support mechanism – transportation, feeding etc.) that will encourage members of the public to volunteer their time in rendering witness before the courts in support of effective and SO 5.1: At least (03) experienced lawyers engaged and retained in the ACCs pro secution Team for a minimum of three years; SO 5.2: A tracker system for prosecution cases developed, approved and in use by the ACC Prosecution Team; SO 5.3: A witness protection policy developed, approved and in use by the ACC and the c ourt(s); The successful prosecution of anti - corruption cases over time will rebuild trust in the ACC and will also indicate the seriousness and commitment of the Government of Sierra Leone to reduce and ultimately slow down the increasing rate of corruption in the c ountry. The dividends that wi ll be accrued from fines and or confiscation will serve as additional national revenue that the GoSL could use to address pressing socio - economic and development issues that will improve well - being and

27. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 20 Management The day to day management of the commission is attributed to the commissioner as provided for in the AC Act section 5 and as also highlighted in existing policies regulation and operational guidelines. Human Resource M anagement The Human Resources management is guided by Policies, regulations and guidelines. In addition, there is a handbook which highlights the expectations of the Commission. The recruitment Policy makes provision for internal and external recruitment and this has occasioned the upward mobility of Staff through internal r ecruitments. External recruitments are subjected to standard practices of open advertisement, long and short listing and interviews mostly made of panels that are internally constituted. The policy requires that all staff should be subjected to probation and confirmation processes with varied types of appointments being on offer. The Human Resources policy has provisions for regular p erformance management of sta ff by their Line managers and Supervisors to be routinely conducted and this is part of the agency processes that are facilitated by the Human Resources Directorate. There are systems in place to address grievances as well as discipline for staff of variou s cadres. Budgeting and F inancial M anagement The ACC is established and supported by the Government. The budget process for the ACC is linked to the national budget circle which commences with the issuance of the budget call circular by the Financial Secretary of the Ministry of Finance and Economic Development (MoFED). The call is immediately followed by the activation of ACCs internal budget preparation processes involving appropriate Heads of Directorates and Departments working alongside the Direct orate of F inance to develop the agency’s budget estimates which is presented at the National budget hearings organised by MoFED. The ACC ’ s submission is subsequently integrated into the National budget. The ACCs budget takes cognisance of all administrati ve expenses (salaries, allowances, gratuities and pensions ) of the Commissioner, Deputy Commissioner, and staff of the Commission all of which is charged to the Consolidated Revenue Fund (CRF). The Government of Sierra Leone takes up to 90+% of the budget while external contributions from d evelopment

44. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 37 understood this as a re quirement for developing a single anti - corruption strategy although in reality anti - corruption policies may take different forms depending on specific country contexts. Understandably therefore, the Anti - Corruption Act 2008, under Section 5 (1) (c), provid es that the Commissioner, as head of the Commission is responsible for “the coordination of the implementation of the national anti - corruption strategy.” The various entities in the public sector implement the strategy. Assumption The assumption here is th at: - 1. There shall be, in compliance with Article 5 of the UNCAC, “effective, coordinated anti - corruption policies that will not only be implemented by the public sector, but that the ACC will take the lead in developing and coordinating the national anti - corruption strategy. 2. There will be a mid - term review of the strategy to address emerging issues Action/Activities : The following actions / activities are recommended to be undertaken by the ACC in the development, coordination, implementation, monitoring and evaluation of the national anti - corruption strategy: SO 7: I To monitor the last quarter implementation of the NACS 2014 – 2018 SO 7: 2 Craft the next five - year (2019 – 2023) national anti - corruption strategy with an implementation action p lan SO 7:3 Launch and undertake public awareness raising activities on the new national anti - corruption strategy. SO 7:4 Establish integrity management committees (IMCs) in all MDAs SO 7:5 Hold quarterly engagements with MDAs through their IMCs SO 7:6 Un dertake yearly monitoring and evaluation exercises to gauge implementation. SO 7:7 Advise HE on the appointment of the NACS Implementation Committee

55. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 48 Page | 48 coordinating the national anti - corruption strategy. 4. There will be a mid - term review of the strate gy to address emerging issues Actions/ A ctivities Progress M arker Outcomes SO 7:I To monitor the last quarter implementation of the NACS 2014 – 2018 SO 7: 2 Craft the next five - year (2019 – 2023) national anti - corruption strategy with an implementation action plan SO 7:3 Launch and undertake public awareness raising activities the new national anti - corruption strategy. SO 7:4 Establish integrity management committees (IMCs) in all MDAs SO 7:5 Hold quarterly engagements with MDAs through th eir IMCs SO 7:6 Undertake periodic yearly monitoring and evaluation exercises to gauge implementation. SO 7:1 Last quarter monitoring of the NACS 2014 – 2018 undertaken SO 7:2 The NACS 2019 – 2023 crafted with an implementation action plan SO 7:3 NACS launched and public awareness raising campaigns commenced SO 7:4 Integrity Committees established in MDAs SO 7:5 Quarterly engagements with MDAs held SO 7:6 Monitoring and evaluation exercises of the NACS conducted It is envisaged that there will be effective, coordinated anti - corruption policies in place by either developing a single anti - corruption strategy or through a set of broader efforts and measures to promote transparency and accountability that will provide a long term vision on how to addre ss the control of corruption. Furthermore, it is envisaged that, to create the right momentum, the strategy will be embedded in the overall government strategy so that there will be a higher degree of ownership and a higher chance of implementation.

16. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 9 The Private sector Compliance with anti - corruption measures, implementing review recommendations and reporting on weak systems and regulations Low – This is a sector that is often corruption p rone Low – They can only adopt indirect means in support of a nti - c orruption measures International agencies(with corruption eradication) mandates and focus Technical assistance, exposure/ learning exchanges, advocacy and institutional strengthening High – They have potentials of strengthening the Anti - Corruption A genda of the c ountry High – They could advocate and lobby for strong actions to be taken against the State in support of enforcing compliance with a nti - corruption measures in the c ountry Key Stakeholder I ssues There are varied interests, impact and influences exhibited by the diverse actors working either directly or remotely on issues related to fighting c orruption in Sierra Leone. This situation requires the investment of time, resources and energy on ensuring that networking and coordination is ensured on a regular and sustained basis if the benefits of working in a joined - up manner is to be fully harness ed for an effective a nti - c orruption fight in the c ountry The multiple Stakeholders as would be expected have different and divergent core mandates but at close scrutiny tend to gravitate towards enhancing Transparency, probity and accountability. There is however at present a tendency for most of the strategic actors to give more credence to protecting their ‘’ mandate corridors ’’, with less effort towards alignment of operations. The ACC and ASSL have however made great strides by entering into formal MoU w hich identifies areas that the two agencies could work in

17. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 10 despite retaining the differences that exist based on their legislations and mandates. The national legal and regulatory e nvironment is perceived as not quite robust to support effectiveness. The AC C has a strong legislation (ACA08) but it is yet to have all of the required policies and prominent among these is the whistle bl ower and witness protection one. The ASSL is still challenged by procedures requiring it to present its Annual audit Reports t o Parliament and not the ACC irrespective of whether there are glaring evidences that some Corruption related issues have been identified . This state of affairs makes it challenging for the Stakeholders to proactively identify and engage Corruption issues . There is restricted and limited financing to support the operations of the various Stakeholders (especially the inadequate funding from the Government of Sierra Leone ) that will allow them expand their roles to readily complement the a nti - c orruption m andate of the ACC. The ACC itself experiences such limitations in financing to enable it address critical areas that will facilitate its delivery of efforts geared towards ensuring that its mandate is fully covered by its operations. The Stakeholders do e ncounter capacity limitations to effectively discharge their respective mandates and such limitations are in the areas of skills and competencies, the availability of the appropriate working environment and the provision of tools such as office machines , e quipments and vehicles. 4. S trength W eaknesses O pportunities T hreats of ACC The ACC has been in existence for (17) years. The changes which have occurred in the country during this period may have had direct and indirect implications for the functioning and effectiveness of the ACC. I n determining the Strategic direction of the agency in the next three (03) years there is need for a thorough assessment t o be undertaken so that the factors that constrain or fa cilitate its operations are i dentified. The quadrant below is a summary of the SWOT – Strength, Weaknesses, Opportunities and Threats which the ACC envisages now and which may have implications for the roll out of this Strategic Plan. This SWOT will serve the purposes of ensuring that the senior management is guided to address the Threats and Weaknesses while taking concre te measures to ensure that the Strengths and Opportunities are optimised and fully leveraged in order that

26. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 19 may over span of time have implications for the recruitment and retention of quality personnel. Potential Strategic D irection gleaned from the Risk A nalysis (Linked to the Goal) The r isk analysis and emergent issues that have been discussed would require some strategic re - orientation of the ACC as an institution pertaining to its modus operandi. In this regard, the following Strategic d irection is being proposed for the attention of the ACCs Senior Management: a) To assess and determine what the required Policy are, legal, regulatory and international requirements that the ACC would need to undertake and deliver its mandate in a timely mann er to a high quality and meeting other s takeholders and c itizen’s expectations. b) A dopt a policy regarding the recruitment and managem ent of Middle and senior staff with the possibility of a fixed Term contracts subject to renewal c) Capital expenditure requirements and needs should be undertaken as a matter of urgency to cover the completion of the AC C s permanent office building, p rocurement of vehicles, IT and equipment. d) Address the existing special skills and competency challenges in In vestigations, Prosecutions and pertinent directorates. e) The ACC to invest meaningful time, effort and resources to harness more Strategic and long - term partnerships with key stakeholders. f) D evise workable strategies to address Public perception and enga gement, project ACC successes, and challenges 6. Administrative A nalysis of ACC Policy and D ecision M aking The Policy and decision - making processes within the ACC rests with the Commissioner and the Senior Management Team. There are a range of internal policies; Human resources management; financial management; Information Technology investigations and prosecut ions.

21. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 14 reformulated in 2018 and the ACC could have emerging issues requir ing other partner agency support captured and addressed in a coll aborative manner. International C ooperation The ACC shall continue to benefit from engaging with sub regional, continental and global processes and systems through the windows provided by UNCAC, AUCAC and UN anti - Drug agency. (iv): Threats: Negative P ublic P erception The perception over hang that ACC is ‘backing and not biting; ‘’ACCs nets focuses on small fishes and less on the big fishes’’. This has the tendency of undermining Citizen’s interest and engagement with the processes and system s which the ACC uses in its corruption crusade and fight. Inadequate F unding The ACC is inadequately funded to fully execute its functions that flow from its mandate. Limited Judicial S upport The Judiciary has often been seen as failing to provide the right level and quality of support to the fight against corruption . Civil S ervice Conditions of Service The Sierra Leone Civil service in its current form and operations makes its members work w ith limited resources and poor Term s and conditions of service which pose s a threat to corruption. F alling ethical standards is often considered as one of the factors responsible for the rise in corruption in the country. Studies such as t he Afro barometer; World Bank Governance indicators; and Transparency int ernational reports present the c ountry as one with high incidences of corruption. There is weak Partner collaboration . The ideal situation is for the GoSL and CSOs to complement each other (based on mandate and programmes) in order to effectively address the problems of corruption in Sierra Leone.

8. 1 1. Background Sierra Leone acceded to the United Nations Convention against Corruption (UNCAC) on 9 th December 2003 an d ratified the convention on 9 th September 2004. UNCAC required review and strengthening of national anti - corruption laws to meet the robust dictat es of the international drive of reducing graft in a member country. Therefore, Sierra Leone amended its 2000 Anti - Corruption Act (ACA) with a stronger anti - corruption law in 2008. The law gave prosecutorial powers to the Commission deviating from the practice of relying on the office of the Atto rney General and Minister of justice for investigation and prosecution. 2. Profile of the Anti - Corruption Commission (ACC) in Sierra Leone History The ACC was established in 2000 and its origins are linked to the realisation that Corruption was one of the antecedents to the Civil war which ravaged the Country for over a decade (1991 – 2002). The establishment was also supported by recommendations contained in a national study undertaken in 2000 which provided data on public knowledge as well as perception of the magnitude of corruption in the society and its implications for s ustaining the post war Peace and stability . T he first Commissioner and Directors were nominated by the President of the Republic of Sierra Leone from among Public servants who wer e entrusted with the responsibility of setting up and operat ing th e core departments of ; Investigations , Research and Development, Prevention and Community Relati ons . The Commission was to later expand and other specialised Directorates, departments and Units set up among which were; Prosecutions, Systems and Processes and Public education. The ACC since 2008 has not only been accorded increased professional autonomy but has been functioning based on the legislation complemented by its own internal rules , guidelines and regulations. This according to Staff has improved on the ACCs overall performance enabling it to respond to its mandate of leading the fight against Corruption in Sierra Leone. Mandate The mandate of the ACC as stipulated in ACA 2000 is ‘for the prevention, investigation, prosecution and punishment of corruption and corrupt practices and to provide for other related matters’’ with further recognition to ‘’ provide for the continuance’’ of this mandate in the ACA 2008. Structure and Admini stration The A gency is configured to have as its Technic al and I nstitutional H ead a Sierra Leonean with considerable legal experience to s erve as the

24. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 17 service corruption and other predicate offences. service that is consistent with living standards L ow budgetary allocation to the ACC to support anti - corruption initiatives ACCs inability to oper ate at optimal level GoSL to rationalise its taxation and revenue regime to enhance increased revenue generation and collection Others Limited adherence to the implementation of the strategic plan The ACC will work in an unstructured and potentially ad - hoc manner Implementation of the Strategic plan to be built into performance contract of all directorates. Inadequate Business support systems ( HR, IT, M&E) The Strategic plan will not be effectively rolled out An Organisational Development review to be undertaken. Low ACC Staff morale The productivity level will fall and the ACC will be challenged in rolling out this Strategic plan and delivering effectively on its mandate A Human Resource review to be conducted. Key S trategic I ssues L inked to the Risk A nalysis The strategic issues pertaining to the risks likely to confront the a nti - c orruption campaign in Sierra Leone are discussed below: The s low pace of Public Sector R eform will invariably undermine the quality of cooperation and collaboration from MDAs in supporting the implementation of the NACs and or embracing the recommendations from the ACC led Systems and processes reviews. This could be due to a number of factor s such as; the existence of weak policies and in some cases the non - existence of such policies, the out - dated work and b usiness processes in the p ublic sector led agencies and above all the work and professional ethics that may be lacking in personnel who would undermine , instead of support a nti - c orruption fight mainly for personal benefit.

15. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 8 observance of anti - corruption laws and regulations, sensitisation and awareness raising, research and advo cacy accompanying and promoting Anti - Corruption agenda initiate actions to promote Political Will, funding, Capacity support through advocacy and lobbying as well as working together with the ACC The Media Public education, investigation, and advocacy High – To influence public understanding and perception of the ills of Corruption as well as benefits of fighting it High – They get the attention of the Public and other critical actors to support anti - c orruption ini tiatives Stakeholders Role(s)/Interest Impact Influence The Development partners Technical and financial assistance, supporting reforms High – They can support as well as complement the efforts of ACC High - They are listened to by Senior State functiona ries and could also influence public opinion on Corruption Faith based institutions Sensitisation and awareness raising, demanding accountability and promoting ethics in private and public life High – They are positive channels of outreach Low - they can only apply moral principles and appeal to reasoning of members

9. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 2 Commissioner . The Commissioner is supported by a principal Assistant in the office of a Deputy Commissioner. The current and existing Directorates are :  Investigations  Prosecutions ,  Systems and Processes,  Education and Outreach ,  National Anti - Corruption Strategy (NA CS) secretariat. There are also support functions Directorates :  Finance,  Human Resources  Internal A udit . The ACC has also adopted a P olicy of De concentration which has been implemented through the setting up of Regional offices in Bo, Kenema, Makeni and a sub regional office in Kono under the oversight of Regional managers . Senior Management T eam The management and decision making of the ACC is a t the Senior Management level . The Senior Management Team ( SMT ) is self - regulatory and guided by internal procedures, systems and processes. The SMT convenes management meetings to deliberate and take decisions on administrative and technical issues . Outcomes are cascaded downwards through the various Directors, managers and Officers in the ACC. Human Resource Department The Human R esource D epartment is charged with the responsibility of leading the recruitment and placement of all ACC personnel apart from the Commissioner and Deputy Commissioner whose appointments are at the level of the Presidency and subject to Parliamentary approval. There is an existin g Human resource policy with accompanying Personnel management

14. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 7 The areas of cooperation and partnership ra nge from funding to capacity building and lobbying with Government for the requisite support that an Anti - Corruption Agency would require for effectiveness. National stakeholder analysis In their functioning the various actors exhibit features such as ef ficiency and in extreme cases under performance. The ACC is a public service agency and as such must operate within the bureaucratic confines as well as work within and across diverse sectors in the quest of implementing its mandate. The various actors hav e both core (their institution specific roles) and complementary roles to ensure that other sectors with which they collaborate do provide the requ i site support to undertake their primary responsibilities. The matrix below presents a summary of the wide - ranging numbers of actors who are critical to the corruption crusade while highlighting the roles they currently perform in support of not only control of corruption but also its ultimate eradication. Stakeholders Role(s)/Interest Impact Influence Central Government: - - Office of the President - NPPA - ASSL - House of Parliament - Judiciary Oversight through monitoring and supporting the implementation of recommendations to address weaknesses in policies, legal and regulatory environment and enforcement High – where there is the will to support or complement the work of the ACC Very high but not readily applied Local Government: - - Local councils - Provincial administration Implementing recommendations and making suggestions to address identified gaps in policies, systems and regulations High – if they cooperate with the ACC to observe and respect systems and processes Low - they do not have mandate o r force enough to support Anti - Corruption crusade outside their jurisdictions Civil society / Non - State actors Monitoring compliance regarding High - in support, High – They could

23. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 16 5. Risk Analysis Per ceived Risk Possible impact Proposed mitigation action Political Slow pace of Public - Sector Reform for enhancing anti - corruption The commission will continue to experience challenges when there are institutional or policy impediments The Public - Sector Reform should be prioritised and completed P erceived inadequate support from the Judiciary The ACC will continue to encounter challenges in timely prosecution of corruption cases The establishment of special anti - corruption courts with assi gned Judges W eak levels of inter - MDA cooperation and collaboration There is the likelihood for corruption and related activities to persist in such MDAs especially where review recommendations are not implemented Ministerial leadership with oversight from Office of the President ACC to enforce compliance sanctions consistent with provisions in its enabling legislation (ACA2008) Social Decline in public interest in the Corruption crusade and the work of the ACC There will be low levels of appreciation of the ACCs work and the challenging environment it operates in ACC to address the issues of negative citizens perception as well as take steps to improve on its public relations and branding The absence of a high level champion of the anti - corruption crusade who enjoys Public trust and confidence This undermines belief in political will and the GoSL and country’s commitment to fight corruption in Sierra Leone The Political will and commitment has to be made manifest and demonstrated by GoSL W eak CSO partnership and complimentary support to anti - corruption issues Fragile advocacy on behalf of the commission To ensure a mechanism for sustained engagement with CSOs. Economic Poor public - sector Terms and conditions of This is a recipe for the perpetuation of GoSL to introduce a realistic condition of

2. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) i Table of Content Contents T abl e of Content ................................ ................................ ................................ ................................ .. i List of Acronyms ................................ ................................ ................................ .............................. ii - iii Forward ................................ ................................ ................................ ................................ ........... i v - v 1. Background ................................ ................................ ................................ ................................ .. 1 2. Profile of the Anti - Corruption Commission (ACC) in Sierra Leone ................................ .............. 1 3. Strategic Analysis and Overview of the Issues of C orruption as at 2017 - ................................ ... 4 National Stakeholder A nalysis ................................ ................................ ................................ ...... 7 4. Strength Weaknesses Opportunities Threats of ACC ................................ ................................ 10 Implementation of R ecommendations ................................ ................................ ..................... 12 SWOT I ssues ................................ ................................ ................................ ............................... 15 5. Risk Analysis ................................ ................................ ................................ ............................... 16 6. Administr ative A nalysis of ACC ................................ ................................ ................................ .. 19 7. National Context A nalysis ................................ ................................ ................................ .......... 21 8. Strategic O bjectives ................................ ................................ ................................ ................... 24 ANNEXES ................................ ................................ ................................ ................................ ............... 39 Annex 1: Strategic O bjectives ................................ ................................ ................................ ........... 39 ANNEX 2 – Strategy Implementation Arrangements: A CC /Partners ................................ ................ 5 0 ANNEX 3 - Matrix: Indicative Timeframes for R olling O ut Strategic Objectives ............................... 63 Annexe 4: Snapshot of Functions of the ACC (according to Section 7(1) a - d of the Anti - Corruption Act (2008) ................................ ................................ ................................ ............... 71

77. Anti - Corruption Commission, Sierra Leone Strategic Plan (2018 – 2020) 70 Page | 70 ANNEX 4 : Sierra Leone’s Assessment on Corruption by International Agencies Agency Rank by Year Score by Year 07 08 09 10 11 12 13 14 15 16 17 0 7 08 09 10 11 12 13 14 15 16 17 Trans - parenc y Inter - national 150 158 146 134 134 123 119 119 119 123 130 2. 1 1.9 2.2 2.4 2.5 31 30 31 29 30 30 World Bank Govern - ance Indica - tor 38. 94 43. 75 40. 28 42. 18 40. 85 37. 09 36. 62 38. 42 37. 93 42. 36 38. 94 Millen - nium Chal - lenge Corpora tion - 0.4 5 (15 %) - 0.2 4 (28 %) - 0.2 9 (27 %) - 0.2 1 (40 %) 0.0 2 (53 %) 0.1 0 (53 %) - 0.0 3 (47 %) - 0.0 4 (45 %) - 0.0 9 (37 %) 0.0 3 (53 %)

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